Examination of witnesses (Questions 539
WEDNESDAY 14 OCTOBER 1998
and DR GERALDINE
539. Good morning, welcome to our Committee.
May I thank you very much indeed for having come to give evidence
to this Committee in the enquiry it is conducting into genetic
modification in agriculture. You have also very kindly sent us
some interesting evidence. Perhaps I could start by asking you
to say whom you represent within the food supply chain and perhaps
at the same time you could state, for the interest of the Members
of the Committee, to what companies you are linked as individuals,
if indeed you are linked to companies.
(Mr Ferguson) Certainly, my Lord Chairman. If
I could introduce myself. I am Iain Ferguson and I chair the Food
Policy and Resources Committee of the FDF which is a committee
that, as its name suggests, looks at the policies regulation as
it affects our industry. It is a committee composed of 15 chief
executives of the major food companies. I also represent Birds
Eye Walls, I am the Chairman of Birds Eye Walls, which is a division
(Dr Schofield) Geraldine Schofield, I chair the
Novel Foods and Biotechnology Sub-Committee of the Food and Drink
Federation. I am actually a research scientist and by background
a microbiologist. I am Head of Regulatory Affairs, Foods at Unilever
Research, based in the United Kingdom.
(Mr Craddock) I am Neville Craddock, I chair the
Food and Drink Federation's Scientific and Regulatory Affairs
Committee which is the principal technical, scientific and regulatory
committee and comprises the chairmen of the FDF's specialist sub-committees,
of which Dr Schofield is one. My permanent employment is with
Nestle UK where I am the Group Regulatory and Environmental Affairs
Manager responsible for the legal compliance of Nestle's United
Kingdom Business and external representation of the company in
respect of environmental and regulatory developments.
Chairman: Thank you
540. Mr Ferguson, do the genetically modified
products currently on the market benefit you as manufacturers?
What modifications would be of most value to you? Are you indicating
these ideas to your suppliers? When do you expect such modifications
to be on the market, either in the United States or the EC?
(Mr Ferguson) Thank you for the question. Just
as I answer it, would it be helpful to describe who the FDF are
or are you confident of your knowledge of the FDF?
541. I think it would be useful for Members
of the Committee, Chairman, to hear who they are for those of
us who are not familiar with them, of course.
(Mr Ferguson) If I can very briefly then just
say that the FDF represents the United Kingdom food and drink
manufacturing industry. It represents the companies of 45 different
sectoral trade associations. It brings together those trade associations.
We account in the United Kingdom food manufacturing industry for
22 per cent of the purchases made by United Kingdom consumers
and we are responsible for using 70 per cent of the output of
United Kingdom agriculture. We employ in our businesses directly
around 500,000 people and the gross annual output of the industry
is about £50 billion, so it is a substantial business. We
do represent the food chain through from suppliers of ingredients,
and they can be very small companies, to the big manufacturing
companies, so we cover the whole chain. In terms of your direct
questions, the products of genetic modification which are on the
market today are essentially those where the benefits are derived
by those earlier in the supply chain, by the growers and by the
farmers principally. They are essentially modifications which
help in the growing of the crops. As manufacturers there has only
really been one product which is genetically modified rennet called
Chymosin which is used in cheese manufacture which has had a direct
influence on the way that we produce foods today. In fact, that
genetically modified rennet is used in over 90 per cent of cheese
production today in this country. Perhaps I could pass over to
my colleagues to answer the other questions.
(Dr Schofield) My Lord Chairman, as Mr Ferguson
said, most of the ones we are seeing have had agro-economic benefits.
There have been some innovations in processing, mainly enzymic.
What we are looking at in the food industry are particular areas
of functionality, combining lots of the sciences, including nutritional
science, as well as genetic modification and other techniques:
plant physiology and biochemistry. We are actually looking at
things like modifications of oilseed rape by cutting out a processing
step and other oils which have health benefits, particularly modifications
of starches. There is quite a long list. For example, Isoflavonones
in soya beans. Soya beans are an extremely good source of protein
and although we know they are nutritionally beneficial there are
some anti-nutritional compounds in there. If we could reduce those
we could actually benefit from soya beans in a different way.
We have to process at the moment in order to obtain some of those
benefits. The food industry, particularly the manufacturing industry,
is looking at products which are going to have considerable consumer
542. Any indications to manufacturers?
(Mr Ferguson) Perhaps I could comment on that.
One of the things which needs to be understood is that we are
dealing with a global supply chain. The production of the majority
of the crops that we are talking about at the moment in genetic
modification, things like soya and maize, are international crops
which are grown on many different continents and they are internationally
traded as commodities. As United Kingdom manufacturers we are
sourcing raw materials from a very wide range of sources, therefore
the number of companies which are involved in the supply chain
is large. In terms of indications of the general types of improvements
which would be ultimately of consumer benefit, those are clearly
fed back through suppliers and, of course, the main suppliers,
the main biotechnology companies too, employ people who have a
knowledge of the food industry and of nutrition, so there is an
interchange of information. We have compiled a small aide memoir
of facts and figures on transgenic crops as they are today to
underline the fact that this is an international sourcing issue,
the crops are grown internationally in many different countries
now. We have also laid out some of the expectations about what
the next crops are likely to be as they come forward into production
which we hope might be of some help to you.
Chairman: Thank you.
We will study those, that is very helpful.
543. Can I ask you about food safety? Do
you have any concerns at the moment about the safety of GM foods?
Do you think allergenicity is a potential problem? Do you think
that the safety of GM foods is better or worse regulated than
(Mr Ferguson) I would like to ask Mr Craddock
to answer that question.
(Mr Craddock) I think we would start from the
premise that for the food industry safety is effectively non-negotiable;
it is a given, not only in our own operation in providing products
for the consumers who are clearly fully entitled to expect such,
but we also as producers, processors, expect the same with our
raw materials. We base this as part of our fundamental credo with
a twin pillar of full, meaningful and relevant information. Through
that, we then allow the consumers to make a full and informed
choice as to the products they are purchasing. In terms of the
specific question, I am not aware of any reason why we should
consider the ingredients and the derivatives from the GM foods
themselves to be inherently any less safe than any of the other
developments which we have seen over many, many years. We clearly
have to rely, and indeed we do rely, on the scientific rigour
of the various approval processes around the world. My colleague
mentioned the international trading nature of our business. GMgenetic
modificationis global and so indeed is the assessment of
these products. We are confident that the mechanisms are in place
to pick up any suggested reasons for lack of safety or any lesser
degree of safety being mooted but I think, to date, certainly
these have been picked up by the scientists and the peer review
of the work that is in hand.
544. So from your point of view you are
satisfied with the working of the existing regulatory system in
the United Kingdom?
(Mr Craddock) I would hedge my answer a little,
my Lord, and say as it is operating at the present it appears
satisfactory, but that is not to say there might not be improvements.
I think one of the areas that we would very much like to see improved
is in terms of bringing together the regulatory process and indeed
the regulations themselves into a seamless whole. I know the suggestion
has been made in other places for an overarching regulatory body,
an overseeing body, which would pull together the various advisory
committee structures, and I believe that is a suggestion that
is worthy of some further consideration. We are not talking only
of the safety of genetic modification; there are the ethical and
the environmental aspects, and I believe we should be looking
in totality rather than just in isolation.
(Mr Ferguson) I think perhaps we should make the
point too that it is important that that is looked on at least
in a European context. This is an international business, the
sourcing is international, and it is impossible to compartmentalise
this into a country by country approach. It has to be looked at
over a broad spectrum. Then, of course, there has to be a mechanism
for national interests, such as our own, to be fed into the European
debate and then ultimately into a wider debate. Is your Committee
aware of the Royal Society's Report on genetically modified plants?
There is some very good argument in there which we in the food
industry have contributed to and, in fact, Mr Craddock sat on
Chairman: Yes, the
Royal Society's statement has been made available to us and has
545. I am glad that you have referred to
the Royal Society's statement, which we have. Could you comment
on what you think is the adequacy of the regulatory system in
the United States which is where most of the soya comes from?
Do you think that it needs to be tightened up very much? Do you
believe, as the Royal Society does, that there is need for a tightening
up in the United Kingdom? Would you comment on the system as you
see it in the United States?
(Dr Schofield) Obviously it is difficult to go
into too much detail about the United States' system. If you look
at the two systemsUK/European versus the United Statesthere
are certain advantages in terms of the United Kingdom system in
that you actually get specific approvals and specific approvals
on field trials. At the moment in the United States there are
a lot of field trials which are just going on by notification,
without prior approval. From a regulatory and from a risk assessment
point of view we are having those field trials pre-approved by
an advisory committee. All they have to do in the United States
is a thirty day notification. In terms of actual commercialisation,
all of the data is actually published and open in the FDA registers
and people can comment. Maybe one of the successes in consumer
acceptance and perception in the United States has been the openness
of the approvals that were given to some of these field trials
which were actually openly published and the debate could be seen
in the public arena. I think it is probably not for me to judge
the Food and Drug Administration in the States as to whether their
safety is there. I am sure that they would not release anything
on which there is a safety question. It (soya) has been in the
market now for two to three years and, as far as we know, nobody
has recorded any health effects. In terms of the physical environment,
it is so much different in the United States in agriculture and
in Europe that I think it would be going a little too far to try
and compare any environmental risks and benefits of those two
546. What is your view of the call which
some are issuing for a moratorium on the commercial release of
genetically modified crops?
(Mr Ferguson) I am very happy to comment on that.
We believe that a moratorium would be unworkable. As we have already
discussed we are dealing with an international sourcing base here
and a moratorium on the cultivation of genetically modified crops
in the United Kingdom would have little effect on genetically
modified ingredients becoming part of food production in the United
Kingdom. We can see a number of very negative aspects to a moratorium.
It would make it very difficult to undertake field trials. If
there is no research it is very difficult to build up bodies of
evidence, which seems fairly self-evident. I think it could give
us trading difficulties. We would potentially have some difficulties
under the WTO arrangements. It would also inevitably drive up
the costs of raw materials in the United Kingdom if we were doing
something which was very different from the rest of the world
commodity system. We are unclear too as to quite how it would
apply, for instance, to imported finished food products and imported
raw materials. It is very unclear to us just exactly what could
be achieved by a moratorium so we would certainly not support
Lord Wade of Chorlton
547. What do you believe can be done to
improve the whole question of public acceptance of this technology?
What is the FDF doing in order to assist in this? Would you agree,
in fact, that your Foodfuture programme has possibly not gained
the public awareness that you had hoped?
(Mr Ferguson) We welcome the opportunity to
comment on this. First of all, we believe that this is a long-term
issue. We are talking about a long-term need to make information
unbiased, transparent information available to people. We do not
believe that this is a quick fix campaign. The Foodfuture initiative
is very much based on a long-term process of making available
a series of publications, making available a website on the Internet
which, interestingly, since it was launched about a year ago has
had over a million visits. There is activity there. It is also
about making available material for journalists to incorporate
in their articles giving an unbiased source of information and
running a whole series of exhibitions and roadshows. We have tabled
a summary of the activities of the Foodfuture activities for
your Lordships to look at afterwards. The feedback of the evaluation
from people who have attended the Foodfuture various activities
has been that two-thirds of those who have been there have responded
to the questionnaires very positively saying that this is the
sort of information they want and being able to discuss these
issues with people who are knowledgeable in a way where unbiased
and informed debate can take place is very helpful and very useful.
We clearly believe that more of this has to happen. One of our
worries is that there is a lot of material in the public domain
now which goes back two or three years and this is a very rapidly
evolving area of science, it is a very rapidly evolving area of
business, and the saliency and relevance of some of the material
which is in the public domain comes into question now two or three
years after it was published. We continuously pick up issues where
people are getting hold of information which was published two
or three years, not realising that arguments have evolved and
new evidence is available. One of the essential issues is to keep
the debate moving forward. We see the Foodfuture campaign
as being something that tries to be part of helping to do that.
The IGD, which is the Institute of Grocery Distribution, which
in a sense is the overarching body for our industry which brings
together the retail sector and the manufacturing sector, has also
been active in this area with publications and making available
leaflets and booklets through the retail stores.
548. Following that point up, are you content
that the amount of provision of information to the public is adequate
at present? Are you content that the debate is being conducted
in a constructive manner? Might the provision of a unified information
source be an improvement? Perhaps you might expand a bit more
on how you see your role in this debate.
(Mr Ferguson) Yes, I will comment and then I am
sure my colleagues would also like to comment. We fundamentally
believe in making available information to help consumers make
up their own minds, to make a choice. That requires a number of
things. It requires clear, unbiased information and it also requires
clear, unbiased labelling of products which has to take place
in the context of clear, concise and universally applied legislation.
All three things have to be in place before consumers can make
an educated choice. We are very much involved in all three of
those areas in the food industry.
(Mr Craddock) We have probably moved forward on
to the issue of labelling and I would like to reiterate the point
that labelling is not necessarily the only way of conveying the
information relating to the use of this new technology and derivatives
from it in food. Sometimes I think the debate does get a little
bit channelled down the middle, that it is labelling, labelling,
labelling. There are many, many other ways today, and increasingly
there will be more with modern technology coming on line in stores,
etc., to convey the relevant information about a particular product
other than just in hard print on the individual packaging. That
is an area to be considered for the future.
(Dr Schofield) The industry has also supported
academic initiatives, such as the National Centre for Biotechnology
based at Reading who do an excellent job of travelling around
schools and providing information packs and so on. They were originally
set up by the Department of Trade and Industry. There are lots
of other people who help to support their work which is independent
and I think they do an extremely good job in the education field.
Probably more of that type of information would be very useful.
549<fb. Is there anything to be said
for a single information source, a sort of national GMO helpline,
which people could use to get information on the subject? Is that
of interest or not?
(Mr Ferguson) Clearly there is an interest in
the public receiving unbiased information. You can see that by
the number of visits to the website of the FDF. The British Nutrition
Foundation, which is a charitable organisation supported by industry
and by the academic world, also runs a website which has had a
similar number of visits. It deals with nutritional issues but
it also deals there with issues of genetic modification. There
is a large demand for this type of information. Some of the earlier
Government publications, particularly the so-called MAFF Foodsense
booklet entitled "Genetic Modification and Food", for
instance, are now in a sense four or five years old which are
guilty of being out of date and dealing with the debate as it
was four or five years ago, talking about the forthcoming introduction
of this technology rather than talking about the technology as
it is in the marketplace. Any source of information of this type
has to be kept up to date. I think on balance if it were available,
if there were a central point of information, it could only be
a positive attribute at the moment.
550. There has been a good deal of publicity
following the action of Iceberg in saying they would not use genetically
modified crops in their own-brand products. Do you think that
there is a future for segregating genetically modified foods or
do you think that the whole thing should be market driven, as
it clearly is in the case of Iceberg.
(Mr Ferguson) Thank you for your question, Lord
Jopling. I think it is Iceland.
(Mr Ferguson) I think Iceberg is the thing that
sank the Titanic.
(Mr Craddock) Or a type of lettuce.
552. I do not go shopping very often.
(Mr Ferguson) At least not in Iceland by the sound
of it. The issue is quite complex. I would agree with you totally
that segregation ultimately can only happen for two reasons. It
can either be a requirement of law or it can be market driven;
there are no other mechanisms which can achieve segregation. There
are a number of very practical issues here and I would ask Neville
Craddock, who is an expert in this area, to comment.
(Mr Craddock) I am not sure about the "expert"
but I will certainly comment on that. I think you have given part
of your own answer, my Lord. Yes, it would have to be market driven.
The only way you would get statutory, mandatory segregation would
be if there were perceived to be some degree of safety concern
and then you go round in full circle: if there is a safety concern
then the crop ultimately will not be released. Commercially, at
the moment the principal driving force is the United States. They
have made it abundantly clear up to Government level that they
do not see segregation as a legal issue. We, therefore, are looking
to ask whether we are talking of segregation of the GM crop or
segregation of conventional, traditional strains and we are coming
back now to looking at the latter. To be effective, whichever
route you follow, the segregation has to be right through the
food manufacturing chain, right through the supply chain. It is
of little purpose to segregate just the crops and bring them in
for further processing, you need to segregate totally the derivatives
of these crops. Soya is processed into countless numbers of derivatives,
as indeed is maize. These derivatives are our own ingredients
and we have to attempt to keep those completely segregated throughout
our manufacturing and trading chains. Some of these derivatives
themselves are traded as commodities and traded internationally.
I think you are beginning to see the very wide network of chains
that would all have to be kept separate and ultimately one could
envisage that, if segregation were to become the norm, you are
talking of parallel processing streams right the way through from
crop to finished product on the retail shelf; i.e, there would
be two systems for producing Kitkats, or whatever products you
would care to think of. Again, we have mentioned the complexity
of the international level. It is one thing to think of doing
it as a national thing, even worse if you go on to the international
trading and manufacturing and import/export of finished goods.
I think also one point which would focus very much back into the
United Kingdom, in terms of segregation, is the commercial reality
of today. We, as a company, and I know other colleagues in this
room, manufacture in the United Kingdom for supply to what we
might call third countries, and I do not mean developing countries.
We are in competition for that business here, to get the business
in the United Kingdom, against our own and competitors' factories
elsewhere in the world; segregation will undoubtedly add cost.
If we are producing goods in the United Kingdom for a market in
which the GM debate is of no real concern, any additional cost
which we put on to our manufacturing base in the United Kingdom
will be reflected in the export prices, and quite honestly at
the present time, with the high pound and other debates, with
which I am sure you are extremely familiar, we cannot take that
cost on to export goods. At the end of the day if we impose unilaterally
within the United Kingdom an additional cost, it will certainly
cost jobs because we will lose business on our export lines.
553. Could I go back for a moment to what
you were saying about the moratorium? You made your view very
clear about a possible moratorium in this country. Does what you
say apply equally to the possibility of a moratorium throughout
the European Union?
(Mr Ferguson) Substantially, yes. A moratorium
in one part of the supply chain only will not do anything other
than potentially reduce the supply of genetically modified material;
it will not remove it or eliminate it. One has to question what
are the practical benefits of such a moratorium. From the food
industry perspective we see no validity to this, we see no real
benefits. If one then talks about public confidence, I think putting
in place something which would be unlikely to be workable, and
the fact that genetically modified cropsthe majority of
soya is grown in North America for the market herestill
having soya coming into the European Community, into the United
Kingdom from the United States, whilst there was a moratorium
on growing it in the United Kingdom or Europe seems nonsensical.
554. Thank you very much. Now about traceability.
Mr Craddock, I think, has already covered a good deal of this
in his previous answer but I wonder whether you would be in favour
of traceability for genetically modified crops and, if so, what
this might cost and what the benefit would be? Can you tell us
whether any other products are traceable all the way from the
farm to the retail shelf?
(Mr Craddock) I would like, if I may, just to
add a comment in relation to segregation because I think in reality
the segregation and traceability
debates are very, very closely linked. Whatever is done to segregate
the crops at the present time is not going to be 100 per cent
segregation. I think, Lord Jopling, you mentioned a particular
retailer saying that they are using no GM ingredients. When you
look into the issue of segregated crops it is physically, and
indeed commercially, impossible to obtain 100.0 per cent separation,
there will always be the adventitious presence of non-target crops
in the streams. Segregation will not be the total answer, it cannot
be. What we do need is absolute clarity in the current regulatory
framework as to what is meant by a product which is below a threshold
as far as the legal considerations are concerned in respect of
labelling. As far as traceability is concerned, if I can move
on to that, certainly there are schemes in place to enable traceable
supplies but, as I have indicated, these are not pure non-GM material,
they do cost and they are complex; there is a lot of bureaucracy
related to them. I think that as far as the United Kingdom schemes
are concerned, one with which we are familiar involves soya derivatives
for the baking industry and maybe the next evidence this morning
will build on this. The current US crop of soya is many tens of
millions of tonnes. The United Kingdom requirement out of that
is possibly at most seven million tonnes; I will be corrected
if I am wrong. The segregated stream is measured in tens of thousands
of tonnes. It is very smallif you will pardon the punthe
tip of the iceberg. It can be done but at a price and where there
is a demand.
(Mr Ferguson) There is an example, I think, that
it is useful to quote from seed production. In commercial seed
production today the highest standards of purity are required
in basic seed. That is where the generation of farmed C1, C2 seed
starts. The cost of producing basic seed is roughly four times
the cost of producing a commercial crop. That gives an indication
of the cost of pure traceability and trying to guarantee a very
high standard of agricultural practice so that co-mingling and
any cross-contamination is kept to a minimum. It is a very, very
555. I am sorry, I do not think, with respect,
that answers the question that Lord Moran put to you because I
think controls on breeding seed stock raise separate issues. Could
you hazard a guess as to what the extra cost of soya would be
if it could be traced as to whether it was non-genetically modified,
bearing in mind that there will always be a bottom limit of tolerance
of contamination, to use that word, with genetically modified
product? Would you hazard a guess for us because I think it is
very important in our enquiry as to just how much extra per tonne
it would cost to have traceability?
(Mr Craddock) I do not think it is possible to
put an absolute figure on this, my Lord, because at the moment
the figures that are being quoted for adventitious presence, adventitious
residues of a genetically modified crop, range from between two,
three, four, even I have heard as high as five per cent mentioned.
Clearly if the limit is at two per cent then it is possible to
work through and say what is required in the way of dedicated
transport, dedicated systems, dedicated mills, silos, etc. An
exercise was done about two years ago which suggested that possibly
a premium of 40 per cent would be required. Without knowing what
the acceptable level of adventitious presence is, it is a little
like saying how long is a piece of string? We are talking here
a little about a dilemma; the existing figures are based on quality
criteria relating to yellow maize in white maize, etc., but with
the GM debate, we are talking of rather more ethical concerns;
we are talking of something other than just pure quality of the
product. Clearly if the segregation level were 0.2 per cent, even
half a per cent, this would magnify quite dramatically the cost
of achieving that level of segregation.
(Dr Schofield) The other question is that at each
stage from farm through to processing you may have an added percentage
each time. If you are talking about segregating the crop in the
States and containerising it rather than shipping it you will
have an on-cost there. If you are using that raw material for
animal feed then that end cost remains there. If you are then
taking a by-product of maize, for example, which at a much smaller
level is producing added value ingredients then at each stage
in that production where you have to keep segregation, you have
to keep the process plant clean, you will add a cost at each of
those stages. If you are looking at particularly value added maize
products, starch products, the on-cost will be so much more than
if you are just looking at the raw kernels themselves because
at each stage you will have a cost.
556. Could we move on to labelling. Could
you say what your views on labelling are and what you recommend
to your manufacturers? As I understand it from reading your paper
you only consider labelling should be required if there is a practical
difference in the end product. Could you confirm whether that
is the case or not and explain what the implications of that would
be in the present circumstances?
(Mr Ferguson) Yes, my Lord Chairman. Clearly at
the moment labelling is an issue particularly made more difficult
because there are not clear regulations and legislation in place.
At the moment, as from 1 September, effectively our view is if
there is soya in the product it should be labelled because there
is no threshold provision. Therefore, if a product contains soya
it may well contain genetically modified soya for all the reasons
that we have gone through earlier. Our advice and the advice of
the FDF and its membership is if in doubt, label. That has been
our advice consistently now for the last five or six months. We
do desperately need a threshold level to be agreed because the
threshold level, of course, is what will drive the labelling decision
and it is also what will allow consumer choice to take place.
If there is no threshold everything eventually ought to be labelled
and that gives no consumer choice. If a threshold level is set
at a sensible level, and people have talked about percentages,
0.2 per cent, 0.5 per cent, two per centI think there is
a debate to be had about what the right percentage isonce
it is set of course it then allows a clear labelling decision
to be made and then gives the consumer a clear choice. In labelling
we see the need to be very clear. There are three different things
in a sense that can be labelled. A label can apply if there is
genetic material there above a certain threshold. No label would
appear if there was genetic material below the threshold. Certain
people, and the retailer that Lord Jopling mentioned, wish to
claim GM free. In our view that should be 100 per cent GM free
and must be capable of being audited to be 100 per cent GM free.
It is only by being absolutely clear about this that we can hope
to build consumer confidence, which returns to a point we talked
(Mr Craddock) May I just add something further.
The debate is very much on labelling but, of course, increasingly
we are seeing foods consumed ever more out of home; there is also
a perception, I will put it no stronger than that, of superiority
of the many products which are purchased over delicatessen counters,
etc., so-called loose sales, and which are currently exempt from
the vast majority of statutory labelling requirements. Clearly
if we are majoring on labelling here for the ethical and emotive
issue of genetic modification then labelling means something wider
than just the food label on a pre-packed product. We have to find
a means of addressing this and Her Majesty's Government is currently
doing this in a round of consultation. We have to find a way for
catering and loose sales being brought into the same framework.
557. Do you see the labelling situation
changing radically in the future? If the move is, as Dr Schofield
was explaining earlier, towards products which are going to be
modified in ways which are attractive to the consumer, it will
be necessary to point out the purpose for which they have been
modified and labelling will have a different information aspect
to it. The choice that you are describing, Mr Craddock, is simply
for the consumer as between whether they consume a food that is
genetically modified or one that is not, irrespective of the purpose
of genetic modification. Is that correct?
(Mr Ferguson) Yes, that is correct, but clearly
we have already seen in the marketplace genetically modified tomato
paste, for instance, a single ingredient and, therefore, in a
sense, quite an easy example to label with claim of benefits for
the consumer, and clearly as we go forward there may be other
products of that type. Of course, most food products and most
prepared food products contain quite a wide range of raw materials.
As time goes on, a number of those will inevitably be genetically
modified, for different reasons. Some will be like soya and maize,
genetically modified because they confer an advantage on the growing
and perhaps the processing part of the chain. Others may offer
particular benefits to consumers which Dr Schofield laid out earlier.
So there will inevitably be, as there is today, a whole series
of different reasons why different raw materials are in a finished
(Dr Schofield) But, my Lord Chairman, those products
which do have substantial changes would have to go through the
Novel Foods Regulation, which makes the labelling provisions.
So in the same way as with soya and maize now, they would have
to be labelled. Obviously then the question would come of the
marketing planning but they would have to be labelled legally
in the same way as herbicide tolerant soya or maize would be,
actually on the fact that it was genetically modified.
Lord Wade of Chorlton
558. The difficulties on labelling bring
us rather neatly to my question on testing. Is the absence of
a GM testing policy confusing? You mentioned thresholds, Mr Ferguson.
What sort of thresholds would you like to see?
(Mr Ferguson) I think it is not so much the testing
policy that we require, it is a validated method of analysis,
and we are in an area here which is quite rapidly evolving. Tests
are being developed today which allow for the testing of individual
raw materials much more rapidly than the testing of a finished
product, and I think in anything that we talk about we have to
take account of the fact that testing methods will become more
sensitive. It will also take a considerable amount of time to
build up a body of statistical evidence, as we do with safety
and as we do with a number of other areas in the food industry.
We tend to work on a thing called HACCP (hazard analysis and critical
control points). We manage quality through the process. We do
not just test the finished products, we test as we go through
the production process and over time one can build up a statistical
picture of the performance of a manufacturing unit at each of
its critical points. That takes a considerable amount of time.
That will ultimately be the approach that will be used in this
area, too. At the moment clearly many companies are having tests
done. They are quite expensivearound £100 per sampleand
there are relatively limited lab resources who can handle this,
so it is quite an interesting time. You might want to add something
(Mr Craddock) Not really, just on the question
of the numbers, and the methodology and sensitivity your question
posed, what sort of threshold. At the moment I think the most
adept laboratories would claim that they can detect to a limit
of about 0.2 per cent. Below that it becomes a bit of, "It
looks as if it is there but we cannot be sure," and if we
are looking at quantification then I believe the current figure
is somewhere around 1 per cent. In other words, if it is less
than that you just have an open argument as to how much is there.
So it is not quite the same as using the most sophisticated testing
that exists for pesticide residues or heavy metals. We are not
talking about being able to go down to parts per million or parts
per billion at this stage. It is a sophisticated method but the
results are still relatively crude, if you understand the apparent
(Dr Schofield) Could I add, I think the other
thing we have to remember is that testing is not an end in itself,
it is a means. We should not look at testing as actually the end
point. If, in terms of policy, we actually had the policies in
terms of the segregation and the labelling and the whole of those
things sorted, then we are using testing in a totally different
way, as an audit trail and not as an end in itself. In this particular
instance, because the levels of detection, as we know, are getting
now, in raw materials, to 1 in 10,000, to 1 in 100,000 and it
could even go beyond that, what we should be looking at is going
back up this traceability/audit trail/HACCP-type route, and using
testing as we do now, to verify those audit trails, is not an
end in itself.
559. Have your members come under any pressure
from wholesalers, supermarkets or others for or against genetically
(Mr Ferguson) This is different from the normal
commercial pressure, is it? Clearly the whole food chain exists
to satisfy consumer needs. If there is a perceived consumer need
for a product which does not contain genetically modified material,
people will seek to fulfil that need, and there are companies
who have been making products which have been reformulated to
take, for instance, soya out at the moment so that they can claim
that they do not contain genetically modified material, but it
is part of a normal commercial relationship.
1 The FDF have understood traceability to mean the
identity preservation system described to the Committee by Iceland
and United Biscuits, as opposed to mandatory traceability for
monitoring purposes. Back