Examination of Witnesses (Questions 80
WEDNESDAY 3 JUNE 1998
J POOLE, DR
DAVID A EVANS
and DR SIMON
W J BRIGHT
80. Should labelling go further than stating
that a product is genetically modified, and state the purpose
of the modification, as may be the case in Canada?
(Dr Poole) I think we need to come back to what
a label means. The label gives information. It must be verifiable
and true; otherwise there is no point in having a label. I think
the way you are trying to take it forward is actually giving a
need. I think it is part of the communication exercise of why
you are selling the product. If you looked at our tomato puree
it actually says there are environmental benefits. I think it
is actually best left to the producer, the company, to explain
why they have done it. I do not think that should be a mandatory
81. My reasoning behind this is that the
consumer might beware a label saying it is genetically modified.
The next question is, "In what way is it genetically modified?
Is this something I wish to purchase or should I be frightened
off?" or whatever the case may be, and I just wondered whether
that was something that could go on the labels, "genetically
modified to" and then tell you what the reason
(Dr Poole) I think that is a very good argument
and there is a lot of logic in that, but the final decision should
come down in the end to the producer. I do not think that it is
a role of regulation to help us sell products. We have to sell
products. I would question whether or not the label is a major
turn-off for people. I am sorry: we keep on talking about tomatoes
but it is the only product we have got which we have experience
with in Europe. We are outselling the other product. Over the
two years now that that has been on the market it has sold side
by side with the other product and if you look at the cans it
is very clearly labelled, "Produced from genetically modified
tomatoes". I do not think it scares people. I think it is
treated as giving people information and that must be right.
82. You see it more then as advertising
rather than as information?
(Dr Poole) No, giving information is not advertising.
This is giving information which I think we should do. We have
not spent one penny on advertising, none of the companies has,
on this product.
83. If labelling is to be required, should
it be required only to the extent that the labelling can be verified
by testing? What thresholds should be set?
(Dr Poole) I think that is a very important question.
The label is so important. It has to be verified. You have got
to be able to measure it in some way. Otherwise there is no point
in having the label there. We, the regulators or the inspecting
services will not be able to determine what it means unless you
can actually measure it. I think that that is a very important
area. Thresholds are also important here. We get back to the debate
about understanding percentages, I suspect, and the mathematics.
All through agriculture we are used to thresholds. When we sell
hybrid seed, the accepted purity level of hybrid seed is, from
memory, about 95 per cent for most hybrid seeds. If you take the
organic label, it says that 95 per cent of the products must be
organic. Those are their standards. Those are normal threshold
standards which are used throughout the food industry and they
have to be brought into our normal, legal regulatory system.
84. What lessons in allaying public concern
have you derived from your experience of marketing the genetically
modified tomato paste in the United Kingdom, and I ask this question
particularly when I think public concern has been heightened by
recent publicity, for instance with regard to maize modified to
control corn borers and its effect on lacewings in laboratory
experiments, and also the publicity which there has been about
the effect on ladybirds with regard to genetically modified potatoes.
All these things increase public concern but perhaps you could
tell us what lessons you have learned in allaying that concern?
(Dr Poole) Let us take it down step by step. The
most important requirement is that you have to have a product
which is a good product that people want to buy. The second important
requirement is to get that regulatory approval and, as we said
in the written paper, one of the reasons we had to bring this
product to the United Kingdom was that we had had a long history
of novel food guidelines operating within this country which had
been copied around the world, so you had that safety requirement.
Thirdly, I think it is providing information, which is part of
the label, it is showing respect for your customer, which I hope
we did. Ours was the first United Kingdom product so we were setting
the standards if you like. It was very important to us to actually
respect the consumer, listen to the consumer, and provide that
information. I think those were the major requirements. The other
point which we find it very hard to deal with is this sort of
soundbite way of looking at risk assessment which is going on.
An orgy of "all GM foods are dangerous". As we say in
our paper, there is no such thing as a generic or universal genetically
modified crop. Every species, every variety, is different. Tomatoes
are very different from maize. The traits that we put into our
tomatoes are very different from the traits we put into maize
or soya, so each one has to be done by a case-by-case system and
analysed that way, and that is a very hard fact to communicate
to society. We have got to be much better at communicating the
diversity of agriculture and food.
85. Surely you are more likely to get unexpected
effects, and I can think of one of provoking allergy reactions
for instance, following genetic modification rather than plant
breeding. Surely that is right. Do you not see danger for instance
in genetically modified foods provoking allergic reactions?
(Dr Evans) Yes. Allergy towards proteins, and
these plants are producing proteins by and large, is a well studied
subject and there are tests available in toxicology laboratories
which detect these, so it is tested in that sense. The proteins
are tested and indeed approved, so there is a regulatory framework
which ensures this. If I may return to a partly related question
when you talked about beneficials, the effect on beneficials of
any crop protection treatment, whether it be chemical or genetically
based, is subject to regulatory approval. It is a major part of
the regulatory package. Those hundreds of environmental scientists
that we employ are largely in place to deal with the environmental
effects of our products and we know full well that success in
the market place and success in regulation will be very largely
based on the safety that we bring forward with our products, and
that is why we use biotechnology, to come forward with exclusive
products in terms of safety to beneficials, growers and the public.
The package on safety typically will account for up to 50 per
cent of the spend on a crop protection product in bringing it
from invention to market.
86. What about the danger of transplanted
genes interacting with or combining with other genes to produce
a toxic reaction? Is that a real danger? It certainly is suggested
as such by some.
(Dr Bright) I think that is a good example where
again you have to turn it into a positive question that you are
asking rather than saying, "Can you show that nothing has
happened anywhere?" which is trying to prove a negative.
It seems to me that for each gene you have then to say, "What
are the anticipated effects?" and, "Do you see those?",
and in going through the laboratory, glasshouse, small-scale field
trials, you then have to say, "Is this behaving in the same
way as it would going through a normal breeding programme?"
You will have the same scrutiny there for unexpected effects in
the environment, and then, if it is a food, when you are tasting
it you will be asking questions about, "Does it taste like
a tomato?", if it started out as a potato, "Does it
still taste like a potato?" "Are there any other off-
flavours?" and so on. Your testing process has to be there
to ask questions about, "Is this still the same base? Has
it still got the same hundred thousand genes that make it a tomato?"
plus your one or two extra genes in there. You are always asking
that against the standards, comparing it against the standards,
it seems to me, rather than saying, "Is there a new interaction
in general?", which is a very open-ended question to which
you cannot get a satisfactory answer.
Lord Willoughby de Broke
87. Is the furthering of antibiotic resistance
through genetically modified foods a genuine cause for concern?
How can the least-safe practices be identified and phased out?
(Dr Poole) Again there are only a very few antibiotics
which are being used in plant breeding. We have used kanomycin
resistance as a marker in some of our plants. We believe that
that is a safe product, and I think that has been accepted virtually
all round the world now by regulators and independent scientists.
However, we have to accept the fact that people are genuinely
concerned about antibiotic resistance. We are therefore moving
very fast away from this sort of marker, but agriculture is a
slow process and it will take some time before that happens.
88. What about the question on insect resistance?
I notice in members' papers that areas are to be set aside called
"refugia" areas where the crop has not been treated
so that insects can survive on these crops. Am I right in thinking
that sprays are never 100 per cent anyway and they only reduce
insect populations? Is there a likelihood that these refugia areas
could lead to insect resistance being built up?
(Dr Evans) The purpose of refugia in a crop which
is expressing an insecticidal agent protein is to ensure that
beneficials have a breeding ground on that crop, so it is in fact
performed for the exact reason of ensuring that we do not get
resistance to that particular insecticide expressed with the crop.
In terms of the development of resistance to insecticide, we know
that continuous pressure on the insect of the agent can cause
resistance. That is true of chemicals and genes and that is a
well studied phenomenon. The refugia is set there to avoid that
problem. Levels of safety are built into that and in some countries
of the world the percentage of refugia is quite large. As you
probably know, in Australia it is a large refugia. Essentially
we are doing an experiment there but it is an experiment which
has got a huge safety margin. The purpose of doing that is to
ensure that the effect is one to which resistance does not develop
and so that effect can be used into the future.
Lord Willoughby de Broke
89. What is the danger of genetically modified
genes escaping to weed relatives and producing a superweed that
presents a control problem? Can the risk be defined or quantified?
(Dr Evans) The concept of a superweed is very
interesting and quite difficult to grasp. We have all seen The
Day of the Triffids and I guess that can cause some alarm, but
frankly I do not believe it is a problem in that farmers are used
to dealing with escapes and volunteers, weeds they do not want
in their crop, by using herbicides. Provided that there are enough
selective herbicides on the market which kill weeds or take care
of these volunteers (which is the phrase we use), that will not
be a problem. Presently I can say that there are literally very
many more than 10 different types of action of herbicides, so
a herbicide will be available for control. In terms of the modelling
of this, it has been modelled and indeed it will happen and we
know the extent to which it will happen, but the control will
not be the problem.
(Dr Bright) Can I just add to that, that the rate
of outcrossing if you like between crops, weeds and feral species
is different for different crops. You have to do it on a case
by case basis. Genes are very unlikely to travel out from a tomato
for instance because it is largely self-pollinating. Other crops
have different breeding systems and the birds and bees do what
they are going to do anyway in that crop. You also have to look
at it case by case by what the gene is. If a gene is conferring
resistance to a particular herbicide application, then that is
going to have a different effect on selective advantage of weed
that receives that or a plant that is left behind in the following
year. If it is a different trait, if it is a trait for changing
starch content, it is very unlikely to have any effect on selective
advantage. It is certainly jolly difficult to become a superweed.
90. None the less the fact that there could
be this outcrossing from pollination could lead potentially to
a need for a farmer to have more chemicals in his armoury rather
(Dr Bright) We think it is a zero sum. Again,
there is a strong incentive to control that and to make sure that
you have thought about that, and that is part of the regulatory
assessment that goes into the release in the first place. We think
it is actually quite neutral. There is always a requirement by
farmers for better means of control and weeds are always evolving
resistance to natural gene based resistances or chemical based
resistances. It is a new example of an old problem if you like
which has been going on for quite a while.
91. Would you like to comment on Greenpeace's
call to ban the planting of rapeseed because of the outcrossing
dangers associated with it?
(Dr Poole) We are not actually involved in that
area, so it is difficult for us as a company to give that comment.
92. I detect that quite a body of opinion
is to the effect that they would prefer their crops not to be
sprayed rather than to be sprayed with something to survive a
poison. Would you say that herbicide-tolerant crops would encourage
more damaging use of herbicides in the long term?
(Dr Evans) I think the statement that chemicals
are seen as poisons actually has to be examined. The current research
in the chemical part of crop protection is dedicated towards producing
superlative chemicals which are extremely safe. That is what the
regulations require and that is what the companies are producing.
It is possible to invent a herbicide, and I can think of two which
are particularly used at the moment, which act on biochemical
systems which do not hurt human beings, and these molecules have
remarkably low toxicology. One of these in particular is the basis
of herbicide resistance to crop technology at the moment. It does
not follow that chemicals, either because of their widespread
use or even because of their inherent activity, are more toxic
to other species. There is no general rule in this case by case.
The point I am making is that the chemicals used in that context
are extremely safe, so I do not think the chemical/poison theme
stands up. Our strategy as a company is to provide the farmer
and grower, and indeed the stakeholder, with the optimal combination
of safe chemicals and safe genetic technology. We see it as an
integrated future in that context.
(Dr Bright) I have been involved in herbicide
resistance research in terms of saying, "What can you do?",
I guess for the last 15 years, and it has actually come down in
the end to saying that with all this wonderful technology actually
the regulation is around the herbicide. If it is a good herbicide
and you can build in selectivity or change selectivity through
genetics, then that is fine. If it is a bad herbicide this does
not make it any better. It is really all about how we regulate
the chemicals and those are very highly regulated and the hurdles
are getting higher. In that sense it does not follow that you
can alter selectivity either through finding a new chemical which
has that selectivity or by building it in through selective breeding
or through biotechnology. It is essentially about changing selectivity
and that is one of the only examples. My personal preference is
for spraying weeds to kill them rather than having to dig them
up one by one but other people might have a different choice and
as long as the choice is there it seems to me that is fine.
Baroness Young of Old Scone
93. Could I ask whether your marketing strategy
is moving in the direction that some other companies have of very
closely linking a genetically modified strain with a particular
own brand herbicide and marketing the two as a package?
(Dr Evans) Certainly bundles on a crop are attractive
packages to farmers and growers. It is impossible actually to
tie up a whole market; there is not that amount of trust. There
is always choice, and even in the cases of the bundles the farmers
and growers have an extremely wide variety of choice in all those
crops. There is one marketing strategy to provide the farmer with
convenient bundles of both gene and chemical effects on particular
94. Can I declare an interest? My wife has
a small hill-farm in Wales. As you know, the draft revision of
directive 90/220 proposes that genetically modified crops should
be monitored for environmental impact after commercial approval
has been given. Do you think that is right and do you think it
is feasible and desirable that there should be such monitoring?
(Dr Poole) This worries me because it is again
that soundbite answer to science. This is the solution to somebody's
concerns: monitor. Several times in our messages when we give
them we have to come back to the science basis. The most important
thing as scientists you have drummed in to you time and time again
is to define the question. Monitoring is fine if the regulators
can actually define a question. What are we meant to be monitoring?
The hill farm in Wales: is it feasible to monitor it? Otherwise
you will be spending an awful lot of money achieving nothing.
There can be nothing wrong with monitoringit is like motherhoodbut
you must define the question and the rationale of doing it first.
For example, with certain products in America they have said they
would like a review after a number of years because of this insect
resistance question. That is normal practice and there is nothing
difficult in doing that and our legislation does that anyway at
95. So do you think the draft revision of
the directive goes too far?
(Dr Poole) I think it is rather badly drafted
at the moment. It is sloppy drafting.
Baroness Young of Old Scone
96. Could I perhaps help Dr Poole with a
question? If you were asked not only as part of the regulatory
process in terms of the information you were going to provide
at various testing points but also as part of the post-release
monitoring process to monitor not only the impact on beneficials
but also the impact on other plants and particularly the broad
land use pattern that is resulting in the vicinity from changed
decisions by farmers about how they manage their land, would that
be reasonable or unreasonable to ask you as part of that process?
(Dr Poole) Again, this is not the area to go down
without a scientific based question, but I think it is legitimate
to ask us are we changing the beneficial insects, do we see a
use pattern change in that? That is a very fair question and we
would be look at that question anyway.
(Dr Bright) Only if you had an insect resistance
(Dr Poole) I am assuming that.
(Dr Bright) If you had a crop where you had changed
the quality for industrial use and it seems to me you would have
to ask the question about beneficials if that was one of the things
that you expected to change.
(Dr Poole) Let us come back. It is defining the
question for the crop. You then asked about land use and other
take-up of the technology. I am not sure that is our responsibility.
I am not quite sure how we would measure it. You are looking,
as perhaps English Nature (Or is it the Government's) concern
at how technology is being used. We would report how our products
are used but determining the sociological aspects I think would
worry me even more. That is the sort of question we would look
at. You would have to define before you started the questions
you examined and the answer you wanted, which is just as important.
(Dr Evans) One of the commonly used phrases is
that association does not mean causation, so it has to be a question
that is framed scientifically properly because expending our effort
chasing the wrong question which is not properly defined is a
waste of resources and can find totally inappropriate solutions.
You have to be able to come down to define a sensible scientific
question which can be scientifically answered.
97. In the long run could you tell us how
viable you think is the segregation of commodity crops? Could
you also tell us whether you think there is a role for governments
in requiring segregation or is it a matter best left to the market?
(Dr Poole) If you look through our research portfolio,
a lot of it is into quality traits. The only way we can get value
back to pay for research is segregation of those products. That
is the only way that can happen. If we come to segregation of
commodity crops, I believe if there is a real market pull, segregation
will happen along the whole of the food chain. The agri-food chain
is a very complex food chain but there has to be evidence of the
real market pull for it to happen. At the moment I am not quite
sure on the commodity crops but in the future we see segregation
coming in as part of the normal agri-food chain.
98. What about the Government role?
(Dr Poole) I think in the end it has to come down
to the market deciding that segregation is needed. The government
role is to decide whether or not they wish to have these crops
in their particular country.
(Dr Bright) Once they are approved then they should
not have that problem; they should say, "These are now normal
products" and that seems to me to be the key thing that the
regulation system has to provide, to say, "Yes, these are
equivalent" and if they are not equivalent then you are required
that they need to be kept separate or whatever. If you are really
saying they are a commodity, wheat is wheat or whatever, that
probably should be the end of it. You should not be discriminating.
99. Could I ask you a final question on
which you have not had notice? Does your company take out insurance
policies to protect itself against the possible consequences of
unforeseeable consequences of genetic modification?
(Dr Evans) I cannot answer that question. I do
not know the answer.
(Dr Poole) My belief is that as a company we carry
our own insurance for those areas and the answer on liability
which Dr Evans gave much earlier is part of that answer, but I
will check with the lawyers.
(Dr Evans) We certainly have insurance policies
against failures in crop and so on, so we have insurance, but
what I cannot answer is if it is specific in relation to your
Chairman] Thank you.
The Committee is grateful to you for having come to give evidence.
We have had a fairly brisk canter over quite a long haul. It may
be that we have broken into a gallop at some stages. If you feel
that you have not had time to answer any of these questions fully,
we would welcome any amplification in written form which you wanted
to send in. We are extremely grateful to you for coming and giving
us your point of view on this subject. Thank you very much indeed.