Memorandum by Greenpeace Ltd
1. Greenpeace is an international campaigning
organisation with 2.5 million supporters world-wide and 194,000
paying supporters in the UK. Greenpeace has been campaigning on
environmental issues for over 25 years.
2. How we, as a society, handle the issue of
genetically modified organisms (GMOs) is the best illustration
of a broader question about the relationship between science,
policy and the handling of risk in modern society. Food problems
like BSE, pesticide residues and food poisoning all require that
available science is interpreted to form policy in a way that
carries conviction with the public. But what happens when the
science is uncertain? In complex arenas like health and environment
uncertainty is a giventhere will always be uncertainty
because it is almost inconceivable that research can provide all
the knowledge required for certainty about the risks involved.
3. Governments have struggled with this basic
truth. Official assurances of safety have unravelled as new knowledge
about environmental or health impacts has overwhelmingly shown
that problems are present, with the consequent loss of public
confidence and faith in the systems and institutions that were
meant to protect the public good. This occurred most famously
with BSE, but a similar pattern played itself out with pesticide
use, the effects of low levels of nuclear radiation and, longer
ago, with the health impacts of smoking. One can see the same
dynamic playing currently with Gulf War Syndrome and the side
effects of vaccinations.
4. Genetic Engineering (GE) introduces new risks
that do not come from traditional breeding methods and there are
many opportunities for unpredictability to appear (see Appendix
1 by Dr Michael Antoniou, Senior Lecturer in Molecular Pathology,
5. This is not to say that traditional breeding
methods are risk free, but GE provides new and unknown risks about
which we have little experience.
6. This evidence sets out to show that the risks
from genetic engineering in food and agriculture are real, and
that there are major political and commercial risks being taken
as a consequence.
7. Although the Select Committee is not seeking
to duplicate the work of the Nuffield Committee on the ethics
of genetic modification, it should be noted that many of the issues
that affect food production are focused beyond that of a narrow
"scientific" analysis of food content but on traceability,
provenance and the process of production. A key part of retailer
and food producer requirements is now that of traceability all
the way back down the food chain to farm or even field of origin.
For example, crop assurance schemes run by supermarkets and independent
companies have been introduced, and some supermarkets are now
buying beef from farmers rather than from livestock auctions.
Examples of "process-led" choice available in the shops
are organic production, dolphin-friendly tuna, free-range eggs,
fair-trade products and an aversion to food irradiation. It is
a mistake to dismiss these values as "unscientific",
indeed any scientific analysis or presentation of results will
have imbedded in it value-laden assumptions.
8. Genetic engineering has produced results
that canand havebeen unpredictable. Examples are
documented at Appendix 2 (Too Good to Go Wrong, Greenpeace 1997)
(Not printed) and include microbes proving to be unexpectedly
resilient, the transfer of allergy by genetic engineering, unexpected
pathways of escape for genetically modified bacteria and problems
for genetically engineered crops when moving into real world situations.
Further examples have come to light since that report was written.
9. Roundup Ready cotton produced by Monsanto
and Delta Pine and Land seed company has experienced problems
with the cotton bolls shrivelling up and dropping off in an effect
looking similar to that in tests involving large quantities of
herbicide. The problems are only associated with the Roundup Ready
cotton although the mechanism is not clear.
Sixty Mississippi farmers have considered taking legal action
and Monsanto has settled out of court with most of them. Some
are holding out for more than the $100,000 offered.
Reportedly, state officials say that complaints have been received
from farmers in as many as seven other states.
Monsanto have explained the failure as being a result of exceptional
cold weather and wrong use of varieties.
As Robert McCarty, Mississippi Agriculture and Commerce Department
chief regulator put it to farmers "I sure couldn't recommend
they plant one of these varieties and take that kind of risk unless
someone could assure them they wouldn't have the same kind of
problems we had in 1997.
10. Three hundred kilos of pulp coming from
a field trial of genetically engineered sugar beet (which had
not received clearance for marketing) were mixed with conventional
varieties and went for processing to a sugar company CSM. The
pulp was traced but only after it had ben incorporated into a
much larger block of 12.3 million kilos of sugar.
11. Other reports have indicated that a number
of GE crops, such as Bt cotton in Arkansas, are not producing
the financial returns expected because of low yields. A Monsanto
competitor has also claimed that farmers planting Roundup Ready
soybeans have experienced losses of $43 per acre.
12. Already science has shown that some risks
are close at hand in terms of out-crossing of GE crops (see, for
example, Appendix 3, excerpt from "Genetically engineered
oil seed rape (AgrEvo/PGS) A Critical assessment and Background
Information"), that small genetic changes are capable of
producing significant changes in the invasive capability of plants,
and that argumentation to inform "ecological safety"
is often naive.
Some of the proposed genetic modifications could have impacts
on insects, presumably not considered in the approval process
judging by the insistence by the European Commission on the authorisation
of Novartis Bt maize.
13. Question marks need to be raised over the
authorisation of the Novartis maize and other Bt crops by the
recent work of Hillbeck et al.
Bt-maize is produced to deal with insect attack from, amongst
other things, the European corn borer. Lacewing larvae (lacewings
are generally considered to be beneficial predator insects) were
fed on the corn borer larvae fed on the Bt maize and they survived
less well than the controls. This is very alarming as Bt crops
have already been authorised for growing and have been planted
14. Potatoes engineered to resist aphid attack
by the incorporation of a gene from a snowdrop (to produce a lectin
which interferes with insect digestion) were found to have affected
ladybirds. The engineered potato plants did indeed affect aphids
but female ladybirds fed on aphids which had eaten from the engineered
plants survived only half as long as those fed on controls. The
females also laid fewer viable eggs.
15. Both novel foods and deliberate release
need to take into account the need for justification of the risks
involved. This involves answering "big picture" questions
that have not been answered, either by the EU or the UK, either
at a regulatory or a policy level. Examples of such questions
Is genetically modified food necessary?
Is genetically modified food wanted?
Is genetically modified food the
right direction for long-term food policy?
What is the justification to allow
companies which wish to commercialise GM foods to expose the public
to GM food risks, when the public themselves do not presently
stand to benefit?
Will herbicide-tolerant crops encourage
more damaging use of herbicides in the long-term?
Are GM crops a disincentive to investment
in further research and development of (genuine) environmentally
friendly agricultural practices, and is this acceptable?
What will be the cumulative effects
on natural ecosystems from introduction of many different herbicide-tolerant
or pest resistant crops on a widespread scale?
Will widespread introduction of pesticide-resistant
crops have a long-term impact on biodiversity (e.g., on soil organisms,
on microflora, microfauna, on flora, on birds, on other fauna)?
16. Of course many of these questions are obvious
to members of the public when exposed to possible development
in GE but that is all the more reason the regulatory process should
not leave them out. The enquiry cannot just set these issues aside
as "ethical" issues to be dealt with elsewhere.
17. There are substantial commercial risks being
run because of the fragile nature of public support as revealed
by surveys, and particularly by focus groups which can reveal
the real reasons for people's uneasiness.
18. The introduction of GMO food is coming at
a time when sensitivity to food integrity and safety is high.
It is also occurring at a time when the ability of political institutions
to handle risks is at crisis point, and when people are much more
likely to take definite action as a result of what they see as
failures of the bodies around them. All this puts farmers and
food companies in the front line in relation to any potential
"backlash" when something goes wrong with a GMO product.
19. There has been much opinion polling done
on GMO food including by Greenpeace. These polls generally show
around 60 per cent or more of Europeans taking a negative view
of GMO food, and about 20 per cent supportive. Of more significance
is what underlies the general antipathy towards GM food.
20. It is clear from the Eurobarometer survey
that the distaste for GM food is not a matter of lack of knowledge,
because the survey shows that, overall, if they know more about
the issue people are not more inclined to view GE favourably.
Thus the often repeated mantra that "Public Understanding"
will enhance people's views towards a liking of the technology
is misplaced. The Eurobarometer authors linked this to moral or
value-based unease about some GE applications. Thus there is a
mismatch between the regulatory framework with its intense focus
on risk management, and a powerful value-based distaste for GE.
21. Further, in complex arenas like environmental
or health impacts the Eurobarometer survey showed that trust acts
as a functional substitute for knowledge. Levels of trust in political
institutions are low. Reassurance from political actors in the
event of some problem or crisis with GMO food will be ineffective.
22. The focus group research by University of
sponsored by Unilever was not pan-European but limited to the
UK. However some of the findings are closely reflected in the
Eurobarometer research outlined above. The Lancaster work provided
additional knowledge on the public feelings, which show a high
degree of fatalism that GMO food will arrive, despite deep and
largely latent unease about the prospect.
23. Further, people would buy genetically engineered
food even though they were not happy about it, showing the limitations
of marketing data if it is the only means used to gather knowledge
about public reactions. As consumers, people recognised that they
may well purchase GM food, but would in general prefer that society
were not embarking on this course, or if it were, only with a
good deal more justification. This apparent contradiction has
been interpreted by some to mean that people's expressed opinions
in polls are not the same as their "real" views, but
this would be a misguided interpretation. Labelling of GM food,
although necessary (essential even) it is an inadequate response
on its own.
24. Public attitudes to GMOs are complex and
not easily understood. More broadly we see that UK consumers are
becoming more ready to take action on the basis of inadequate
service or ethical and moral concerns. Research by GGT
in 1996 showed that 64 per cent of people said they were more
likely to take action against a company than five years ago. Fifty-nine
per cent believed disobeying the law could be justified in protest
against something that is unjust, 14 per cent would boycott a
company, three per cent would damage property as a form of protest
action. How can this be reconciled with the conclusion of the
Lancaster research showing apparent fatalism about GM foods? There
was no fatalism about the protests over live animal exports (in
the UK), road building, Brent Spar and nuclear testing by the
French in the Pacific. So what is the Lancaster research telling
25. The answer may lie in a quote from an article
written in 1995 about consumer protest: "What has driven
the ordinary citizen to stop buying Shell petrol and French goods
is latent anger about the power of international companies and
foreign governments to do these things with such scant regard
for public feeling. Nuclear testing is the lightning rod of much
more than environmental concern. It is the focus of a much deeper
frustration with institutions over which they have no control".
26. The fatalism only converts to militant action
when a "lightning rod" is provided to push people into
a different mode of action. Greenpeace's own research into attitudes
to environmental protest indicates that people distinguish between
local-scale action where there is a sense of agency to individual
action, and international issues like climate change where, generally,
there is not. The global scale problems provoke an apathetic and
fatalistic approach, the local scale issues (local pollution and
planning issues, or shoddy service from company) a more active
Such fatalism is understandable given that often people are put
in a position of having no choice about what they want to happenwe
are all in the position of having to trust regulatory processes
whether we like them or not.
27. But when a "lightning rod" is
provided that turns a global issue into one that can be influenced
by individual (albeit collective) action, then the agency gap
28. The same situation could apply to GM food,
but what is lacking for widespread action to start is a triggersomething
to identify the "lightning rod". The export of live
animals through Brightlingsea had been going on for years before
the protest started; once local people became aware that their
action could influence things, the activities snowballed into
something that local police could not control. What is awaited
for the societal tensions in the GM food issue to find expression
is a trigger, most likely for something to "go wrong",
which, as outlined above, is almost inevitable.
29. What, then will be the "lightning rod"
for the public frustration? The most likely answer is that it
will be the brands implicated and companies selling the products
which are tarnished either by association or directly in a food
health issue. Further, those farmers who are engaged in the growing
of GE crops or for whom their crops will inevitably become contaminated
by the crops of others will be seen as legitimate targets for
public anger. With BSE it was the farmers, not the food or even
animal feed companies who suffered most. Who knows where the axe
will fall with a GM crisis.
2 On learning of this allegation, the Pioneer Overseas
Corporation supplied the Committee with the following: "In
response to your call for evidence, we understand Greenpeace stated
to the committee on 3rd June that Pioneer is recommending 50%
refuge populations for genetically modified crops with genes from
Bacillus thuringiensis (Bt) to confer insect resistance.
This is not true, and it has never been true. We are developing
Bt-maize varieties with insect resistance. We are committed to
maintaining the efficacy of Bt-maize and have developed a comprehensive
insect resistance management programme to ensure that Bt-maize
is cultivated in a sustainable manner. The programme addresses
the need for refuge populations where appropriate and it recommends
either 5% untreated or 20% treated maize refuges. There has been
no change to this original position." This means that Pioneer
recommend that, should a farmer wish to maintain the insect population
and slow down the development of Bt resistant insects, he can
either grow 5 per cent non-GM seed and use no pesticide at all
(As the GM maize is resistant to pests it does not need to be
sprayed with a pesticide.) or grow 20 per cent non-GM seed and
use a pesticide. Back
A paper by the Committee's Specialist Adviser (not printed). Back
Kleiner, K, 1997. Monsanto's cotton gets the Mississippi blues.
New Scientist, 1 November 1997, p. 4. Back
GenEthics News, 1998. Transgenic crop problems continue, Issue
22 February/March 1998, p. 12. Back
Myerson, A, 1997. Breeding Seeds of Discontent; cotton Growers
say strain cuts yields, New York Times, 19 November 1997. Back
Colin Merritt, Technical manager, Monsanto. pers. comm. Back
Myerson, A, 1997, op cit. Back
Agarisch Dagblad (Agricultural Daily), Transgene Beet Pulp on
market, 2 December 1997. Back
Pesticide Action Network North America Updates Service, Disappointing
Biotech Crops, April 24 1998. Back
Williamson, M, 1993. Invaders, weeds and the risk from genetically
modified organisms, Experientia, Vol. 49(3), 1993. p. 219. The
case study on Impatiens showing how small morphological differences
can make a large impact on ecological fitness begins on p. 222. Back
Kareiva, P and Parker, I, 1994. Environmental risks of genetically
engineered organisms and key regulatory issues, An independent
report prepared for Greenpeace International. Back
Hilbeck, A, Baumgartner, M, Fried, P M and Bigler, F, 1998. Effects
of transgenic Bacillus thuringiensis corn-fed prey on mortality
and development time of immature Chrysoperla carnea (Neuroptera:
Chrysopidae), Environmental Entomology, April 1998, p. 480. Back
Gledhill, M. and McGrath P., 1997. Call for a spin doctor, New
Scientist, 1 November 1997, p. 4. Back
Biotechnology and the European Public Concerted Action Group,
Nature, vol. 387, 26 June 1997, p. 845. Back
Grove-White et al, Uncertain World, Food and public attitudes
in Britain, University of Lancaster, March 1997. Back
GGT Research services, Uncomplaining Brits are turning into a
nation of vigilante consumers, 28 June 1996. Back