Select Committee on European Communities Minutes of Evidence

Examination of witnesses (Questions 539 - 559)




  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 of Unilever.
  (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 very much.

Lord Gallacher

  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 benefits.

  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.

Lord Rathcavan

  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 other foods?
  (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. GM—genetic modification—is 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 that committee.

Chairman:  Yes, the Royal Society's statement has been made available to us and has been circulated.

Lord Jopling

  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 systems—UK/European versus the United States—there 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 systems.


  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 it.

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.

Lord Grantchester

  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.

Lord Jopling

  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.

  551.  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.

Lord Moran

  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 crops—the majority of soya is grown in North America for the market here—still 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[1] 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 small—if you will pardon the pun—the 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 expensive process.

Lord Jopling

  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 cent—I think there is a debate to be had about what the right percentage is—once 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 about earlier.
  (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 product.
  (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 expensive—around £100 per sample—and there are relatively limited lab resources who can handle this, so it is quite an interesting time. You might want to add something to that.
  (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 contradiction.
  (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.

Lord Gallacher

  559.  Have your members come under any pressure from wholesalers, supermarkets or others for or against genetically modified foodstuffs?
  (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

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