Examination of witnesses (Questions 720
WEDNESDAY 4 NOVEMBER 1998
720. So that should not be labelled?
A. No, because
there is no DNA or no protein present, but where there is DNA
or protein present above a thresholdand this is subject
to a great deal of scientific argumentit should be labelled.
It is not just a question of setting the threshold, it is a question
of ensuring that you have got the right analytical techniques
and the right regulatory processes to police that threshold. It
is one thing saying, "Yes, we have got all these wonderful
analytical techniques where we can go down to a picomole level
of protein, for instance, or we can go down to 0.001% DNA, that
is fine", but if each test costs £80 and it takes three
days in the laboratory it is no use as a regulatory tool for a
poor trading standards officer or whoever who is trying to enforce
the regulation. So until we have got agreement on the levels and
then rapid, cheap, reliable testing where we know the degree of
certainty of the result as well (because analytical testing is
very difficult when you are not testing a pure product and you
are not testing a pure product when you are testing a processed
food) then there are a lot of issues. The generic point is that
I think the thing should be labelled according to regulation whenever
there is DNA or protein present. What about catering establishments?
You can say the menu should be labelled. What about when you phone
up and order a pizza? Should it be delivered with a label, by
which time you have already ordered it? And what about the higher
class catering establishments where the chef, who is probably
a bit of a prima donna, might say, "There is not much gluten
in this flour, I will shove an extra pinch of this in or put a
few more bits of that in", how on earth could you accurately
and sensibly label that? In my mind there are some very major
issues, but certainly work is going on in terms of the thresholds.
721. The purpose of a threshold is to allow
for the adventitious presence. That is the principle of it.
A. You have got
to think of segregation at every stage in the food chain. Obviously
many of these commodity crops are not only grown for food use
and as you progressively go through more and more purification
and more and more dilution of the GM crop the cost of segregation
would be absolutely impossible. So you have got to allow for that
722. But the case of additives is different.
An additive should be labelled in your view?
and flavourings at the moment are not subject to the labelling
regulation which came into force on the 1st September. I understand
there are discussions going on in Europe because there are some
concerns. Lecithin for instance, which is a soya derivative, it
could well be from GM soya depending on the quantity, whether
it was classed as an additive or not currently would not necessarily
need to be labelled. I have to say that the retail trade, people
like the Food and Drink Federation, the Institute of Grocery Distribution,
have been labelling on a voluntary basis prior to the 1st September
mandatory implementation of 1139 and are very very keen to clarify
the labelling issues. I think there is a consumer issue. Many
women, men as well to a certain extent, go to the supermarket
and they look at the box and all they are really interested in,
unless they have got a particular medical problem or interest,
is the energy value, will it make them fat or not and then when
they look at the energy value, in spite of the current SI units
being kilojoules, they do not understand that, they just want
kilocalories. That is the extent of the understanding even of
something that is important to them. So we have got a very difficult
balancing act because we want to label but without them understanding
what the label isyou could almost envisage everything
coming in a box with a long pull out with all the details of the
labelling which is clearly ludicrous. So there are some major
issues still around there.
723. But in your view should additives and
flavourings be labelled?
yes. Unless we can say to the consumer that where there is a GM
product, whether there is protein or whether it is DNA above this
particular thresholdwhen that is agreedthen it will
be labelled, then I do not think we are on the road to consumer
confidence. When you say that there are rules about labelling
but additives are not part of it or flavourings are not part of
it then it does not really do anything to encourage consumer confidence
in my opinion.
Lord Willoughby de Broke
724. Do you believe we need traceability
as part of the monitoring arrangements for GM foods and how practical
is the idea of traceability in GM foods?
A. It is not.
There has been a lot of talk about traceability on the back of
the BSE crisis and traceability to cattle. As I understand it,
that has caused enough problems, although that is now being implemented.
How do you trace a soya bean is a simple question. It is very
very difficult. I think the approach to monitoring certainly that
we are considering in ACNFP is not based on traceability but it
is much more based on looking at the databases that we have and
building on the existing capability of retailers to trace food
products. They do have inherent traceability, they need to, in
terms of a whole range of safety areas, for product recall for
instance. It never ceases to amaze me when there is a problem
how quickly the supermarkets can identify a particular batch or
a particular production line or a particular supplier and actually
recall them. So there is traceability in that sense. I think it
is much more important in terms of the GM component, which is
obviously where your question is focused, to go for monitoring
and I have already referred to that. I have referred to the joint
meetings and indeed the monitoring subgroup, representatives from
the retailing groups and we have been enormously encouraged by
their support and their willingness to help us and their willingness
to provide data because there is a great deal of information out
there. I have referred several times to the need for databases
or the need for more research, but it is also quite important
that we do not reinvent the wheel. I heard someone say recently
at the open meeting of the Food Advisory Committee, this is not
in formal session but just in the corridor, we do not need any
more people doing surveys on the street corner in Reading or wherever
it might be, but what we want is people to start looking at the
data that is already there. One major source of data obviously
lies in the loyalty card schemes that many many retailers now
have and we have been talking to the retailers. Obviously there
are issues about confidentiality of data, but retailers are more
than confident about sharing that data on trends and things and
enabling us to use that data towards monitoring. So I think the
message from ACNFP is monitoring rather than traceability but
not forgetting the traceability that is available anyway through
the retailers own systems.
725. The post-market monitoring that you
have referred to and which you are going to make recommendations
on, are your recommendations going to include recommendations
regarding who should be responsible for monitoring and what monitoring
should consist of?
A. There are
two generic issues. There is one about developing a system for
monitoring and we have got to be confident that we have got a
realistic and a meaningful system and at the same time that it
is workable and then we have got to considerand I suppose
this is where it goes outside the remit of the Committee, this
is for discussion by Members (of Parliament) and Ministershow
that is actually going to be undertaken. Obviously there are always
throughout all these systemsmaybe we can use an existing
system in a slightly different wayfinancial and practical
knock-on effects and we cannot divorce the financial cost. So
we have got to make realistic recommendations because if we do
not there will be questions like who bears the cost and is it
right that it should be the taxpayer or the consumer and the sorts
of questions that have been aired many times in terms of the Food
Standards Agency for instance.
726. Do you see the monitoring as being
conducted by the companies in the private sector or by a government
A. No. Again
it is a question of consumer acceptance and I think the monitoring
has got to be seen to be independent. I think the data obviously
will come from the companies in the private sector, but how it
is used I think is quite important and it has got to be used independently.
There has been a great deal of talk about an over-arching committee,
because it is not just the remit of any one of the advisory committees
to which you have referred, we are all concerned with different
aspects of monitoring. It should be either the over-arching committee
or the agency, if and when the agency comes in.
727. So it could be something for the agency?
A. I think that
would be the most likely location for the monitoring system because
we have heard in the plans for the agency that it has made provisions
728. That brings us to the end of the questions
that we wanted to ask you. Can I thank you, on behalf of the Committee,
for the evidence you have given us. It has really been extraordinarily
helpful, interesting and clear and you have been with us for almost
two hours. We really are immensely grateful to you. Thank you
A. Thank you.