Select Committee on Environmental Audit Fifth Report


  GENETICALLY MODIFIED ORGANISMS AND THE ENVIRONMENT:   COORDINATION OF GOVERNMENT POLICY

Government's approach to genetic modification

10. The Government's approach to biotechnology and genetic modification was described by Dr John Cunningham, Minister for the Cabinet Office as "the need to strike a careful balance" between capturing the potential benefits whilst always protecting human health and the environment.[15] This was set out by the Minister in announcing the review of the framework for biotechnology oversight as follows:

    "The Government believes that the protection of human health must be the first priority in regulating biotechnology. The impact on the environment and on biodiversity must also be throughly assessed, and the ethical issues raised by biotechnology fully taken into account. At the same time, the Government believes that this technology has the potential to offer enormous opportunities for improving the competitiveness of the economy and the quality of life in terms of health, agriculture, food and environmental protection, and that regulation should facilitate technological development by not imposing unjustified burdens on the biotechnology industry..."[16]

Dr Cunningham is Chairman of the Cabinet Committee established to " to ensure that as the technology develops Government policies are properly thought through and coordinated".[17] The Committee's membership spans the wide range of departments with a policy interest: Environment, Transport and the Regions; Agriculture, Fisheries and Food; Trade and Industry; Health; the Home and Foreign Offices; and the Treasury. In addition to this ministerial group an official-level network, the Inter-departmental Group on Genetic Modification Technology, "provides a forum within Government for debate of GM policy across Government".

11. The Government sees the UK as having a substantial stake in the economic success of the biotechnology industry, not least because of a large contribution to the science behind the technology.[18] Dr Cunningham told us that the UK was a world leader in the industry, second only to the United States, with about 250 companies employing 14,000 people. The world market was forecast to reach £70 billion by 2000 of which the UK's share might be about £10 billion. Biotechnology had significant implications for up to a quarter of the UK's industrial output - including the pharmaceutical chemical, diagnostics and agri-food industries which together provided employment for about 6% of the UK workforce and accounted for 7% of GDP.[19] The UK's current annual spend on biotechnology research and development is £600 million. Dr Cunningham described the UK's interests in the sector as "formidable".[20]

12. In a recent speech to the industry, which emphasised the importance of public confidence in the technology, the Secretary of State for Trade and Industry, Rt Hon Stephen Byers, MP, described the sector as "in hard economic terms ... an industry of the future - a knowledge driven industry - with great potential to create wealth and jobs. Exactly the sort of industry the Government wishes to promote."[21] The Department for Trade and Industry (DTI) is the sponsoring department for the industry and in its submission to us stressed the primary duty of Government to protect people and the environment but also that "this must be done in ways that do not deny people the healthcare, environmental, economic and other benefits that flow from technological advances."[22]

13. Food safety is primarily the responsibility of MAFF which is the competent authority under the relevant EC legislation[23] for approval of new products, including GM food, advised by the Advisory Committee on Novel Foods and Processes (ACNFP). Mr Rooker stressed that the Food Standards Agency, reporting to health ministers, will take on these responsibilities once established and that, in the interim, food safety decisions are taken jointly between himself and the Minister for Public Health.[24] MAFF of course has responsibility for UK agricultural policy, within the constraints of the Common Agricultural Policy (CAP). Overall this task includes efforts to make agriculture more sustainable and to encourage lower-input and organic modes of production. MAFF has published a set of indicators for sustainable agriculture for consultation. A modus vivendi between GM producers and, particularly organic farmers, will need to be established and may require Government facilitation. A specific responsibility of the Ministry is in relation to the regulation of pesticides, advised by the Advisory Committee on Pesticides (ACP). This is of major significance in the GM debate given that most current GM crops are related to herbicides, to which they are tolerant, or to pesticides, which plant-produced toxins may replace. Government policy is that pesticides which are to be used on GM crops have to go through the approval process again in relation to this new use.

14. The environmental implications of GMO release are the responsibility of DETR. The department is the competent authority for consent to all GMO releases, experimental and commercial, to the UK environment from single plants in pots outside to field- and farm-scale trials. The regulatory system is governed by statute and EC legislation[25] with the latter currently undergoing revision as mentioned above. DETR is advised by the Advisory Committee on Release to the Environment (ACRE) made up predominantly of scientific experts whose task is to assess individual applications to release GMOs. DETR, advised by ACRE, is also responsible for the UK's position on applications made to other EU Member States for consent to market GMOs. Applications under this system must "demonstrate that the release will avoid adverse effects to the environment".[26]

15. The implications of GMOs for the environment are the subject of heated debate and a range of views. At one extreme are Greenpeace, Friends of the Earth and others arguing for a freeze on all releases (and on marketing of GM food) while more research is undertaken on environmental, and other, impacts and the `big picture' questions (for example 'do we want GMOs?') are asked and answered.[27] At the other extreme are those who point to the example of already substantial cultivation of GM crops in the United States and who argue that delays within the EU system are the result of political inertia and give a misleading impression that substantive evidence of risk is being considered. A theme common on both sides of the debate is a lack of evidence. For example, Novartis UK Limited states: "There has been much speculation about potential environmental damage from GMOs but no group has been able to give any evidence for this potential damage".[28] Equally, evidence from English Nature states "it is important to note that 'environmental benefits' have been claimed for GMO use, but have never been demonstrated in terms of benefits for wildlife".[29]

Handling potential risks

16. The current generation of GM crops, pose potential risks to the environment in two ways. There is the risk of direct impacts in the spread of novel genes to wild species introducing hybrids with problematic characteristics such as multiple-resistance to herbicides (giving rise to the so-called 'superweed' scenario) or insect resistance. This can be exacerbated by the incidence of 'volunteer' plants where seed remains in the soil to grow in subsequent years (whatever that field is being used for).[30] A further possible impact is unwanted effects on non-target species of toxins produced by modified pesticide resistant plants. However, the focus of concern in our evidence has been on the indirect risks that altered farming practices, enabled by GM crops, will further encourage the intensification of agriculture that has already contributed significantly to declines in biodiversity.[31]

17. In the UK where 75 per cent. of available land is farmed, agriculture and wildlife must therefore co-exist in a way that is not the case in the United States, for instance, where land for agricultural production (about 30 per cent.) and land for nature conservation are separated. As the Lords report commented, in contrast to the aims of UK regulation of GMOs, the stated aim of the main US regulatory agency is the protection of American agriculture rather than the environment.[32] Direct comparisons therefore are invalid. The UK Biodiversity Action Plan and the EU Biodiversity Strategy commits the Government to conserving and enhancing biodiversity by encouraging wildlife-friendly land management and the integration of biodiversity into other sectors including agriculture. Our evidence was clear that the intensification of agricultural practice was putting UK biodiversity in jeopardy. Baroness Young told us that: "The experience over the last 30 years of intensification under the Common Agricultural Policy (CAP) is that these common species have very much declined ­ some by as much as 70 per cent. and, indeed, in some species by as much as 80/90 per cent."[33] Baroness Young described the position as "backs to the wall time for farmland biodiversity".[34] Mr Meacher agreed. He told us that: "There is no question that we have got to reverse this decline ... brought about primarily, let us be clear, by the intensification of agriculture which has occurred in this and other European countries since the war. That is overwhelmingly the main cause."[35] Mr Rooker agreed with the need to address declining biodiversity "if it were possible" within CAP obligations.[36]

18. The problem is one of agricultural policy as a whole. The question raised by GMOs, in common with other agricultural innovations, is over the nature of their contribution to the problem. Evidence from the ACRE, the industry grouping Supply Chain Initiative on Modified Foods (SCIMAC), DETR and MAFF all points to a lack of baseline data and a poor understanding of the ecological and environmental impacts of current agricultural practices.[37] SCIMAC argued that without such baseline data and an understanding of the impacts of current agricultural practice there was no effective way to provide a comparative evaluation of the effects of GM crops in the future.[38] Mr Meacher told the Agriculture Committee that there was an 'astonishing' lack of systematic international data on the environmental impact of existing GM crops given their cultivation, in the US, for over a decade.[39]

19. Sir Robert May, the Chief Scientific Adviser, described the current thrust of GM technology as accelerating the realisation of "the ages-old dream" of growing crops that nothing eats but us.[40] English Nature stressed that it was not against GM technology per se recognising with other witnesses that it could have the potential to mitigate the environmental problems of intensive agriculture. But, it noted that most of the arguments about these benefits are about the volume of biocides used rather than their impact and that "the current trend in GM crops is to develop traits that will allow even more intensive use of biocides" leading to weed-free and insect-free fields.[41] Other concerns were voiced by English Nature and the new Countryside Agency, amongst others, over the potential for GM technology to produce crops and grasses with resistance to lower temperatures or salt thus putting pressure on land (such as moorland, heath, rough grazing and estuaries) that currently provided refuges for wildlife. The Countryside Agency, English Nature and the Royal Society of Chartered Surveyors also pointed out the economic benefits derived from the amenity values of a diverse landscape and wildlife populations.[42]

20. The possibility of GMOs encouraging adverse effects through changing agricultural practice was presented by witnesses as far more significant than direct effects. Unfortunately ACRE's statutory task, undertaken well by virtually all accounts[43], has been to focus on the latter category. Dr Julian Kinderlerer from the Sheffield Institute of Biotechnological Law and Ethics, former member of ACRE and adviser to the Lords Sub-Committee D, wrote that ACRE's "case by case analysis ... is not sufficient to ensure total safety ... has not allowed consideration of the likely changes in farming practice due to the new technology, nor has it considered the impact of these changes on the wider environment."[44]

21. In response to these types of concern the remit of the Advisory Committee on Releases to the Environment (ACRE) has been extended to include the consideration of wider and indirect environmental effects (in line with proposed provisions of the Directive). Witnesses welcomed the extended remit of the advisory committee but questioned whether it was a sufficient answer to the problem.[45] The Royal Commission for Environmental Pollution (RCEP) has recently concluded that "No satisfactory way has been devised of measuring risk to the natural environment, even in principle, let alone defining what scale of risk should be regarded as tolerable."[46] This appears to pose a huge methodological challenge to ACRE, a committee already groaning under the weight of work.[47] A second initiative is the UK farm scale trials planned with the stated aim of assessing the impact of herbicide tolerant GM crops on biodiversity in comparison with those of equivalent non-GM crops (and we return to these below). We look forward to the conclusions of the Government's review of the biotechnology framework which we expect to have addressed this issue.

Handling potential benefits

22. Mr Rooker told the Science and Technology Committee that the Government's role was to regulate and not to stop or push particular technologies or products.[48] All Ministers confirmed that self-evidently the Government was not in the driving seat as far as developing the technology went.[49] In explanation to us Mr Rooker said "so far as ... taking the science forward, that is a matter for the companies concerned. The Government is in the role ... of guardian of the public interest."[50] We would contrast this attitude to GMOs with the Government's willingness to 'push and stop' other technologies and products in line with its policy objectives. For example the Non-Fossil Fuel Levy has been working to push innovative forms of energy, nuclear to begin with, renewables such as wind and solar more recently. Equally, the Government is operating a temporary strict consents policy to stop development of particular energy-generating technologies to allow sufficient time for the framework of the energy market to be reformed. Mr Rooker responded: "we are not going to tell people what to eat. That is the issue. The only advice the Government gives people on their diet is to eat more fresh fruit and vegetables and have a balanced diet. Our job as regulators is to ensure that the food that is out there is safe ... pushing a particular product or a particular process of food manufacture, that is not the Government's function." [51] This neutral stance does not chime with the emphasis of Sir Robert May that "the main reason why we have to remain a player in this is to try to make sure that these new technologies are indeed harnessed in ... a more environmentally friendly, less relying on fossil fuel subsidies and more sustainable way to produce the agriculture of the future."[52]

23. The weight of evidence for the potential benefits of the bulk of GM crop varieties coming forward is, as one would expect from their provenance, on their potential for increased yield and like features. Mr Rooker told the Agriculture Committee that the benefits of current GM developments, slow-ripening tomatoes aside, are all producer-benefits concentrating on yield rather than nutrition or taste (and consequently was a public relations disaster).[53] Sir Robert May told us that while he believed that it was plainly in the industry's interest to avoid a health or environmental disaster at all costs, "I do not believe that the commercial motivations of Monsanto or anyone else are the guarantee that they will be developing the things which are most useful for the world as distinct from most profitable for them."[54]

24. Significant potential environmental benefits have been asserted. The Government's memorandum states, albeit cautiously, that genetically modified crops have the potential to reduce herbicide use; reduce tractor use (with implications for soil erosion, nutrient leaching and carbon emissions); and there is the potential for creating further resistance to pests and diseases as well as improving the yield from plants of renewable resources currently derived from fossil sources.[55] Other benefits have been suggested to us such as the potential to improve the nitrogen fixing of crops (reducing the need for artificial fertilisers) and in evidence both Mr Meacher and Sir Robert May referred to a range of other possible developments from drought-resistance to the inclusion of vaccines.[56] We were disappointed however, to see from a DETR report on the environmental impact of agriculture that "little if anything has been done to investigate the environmental and agronomic benefits of biotechnology." The report goes on to say that "It is also worth noting that in the case of environmental benefits associated with other technological improvements in agriculture, Government funded research provides an impartial assessment in advance of commercialisation ... In the case of GM crops, investment in this valuable research is conspicuously absent."[57]

The consideration of risks and benefits together

25. This question of benefits as against risks, environmental or otherwise, is not one that has to be addressed in the current regulatory regime and this may explain the absence of research on the matter. The memorandum from Government states: "The current directive does not permit possible benefits to be taken into account. Releases of GMOs are judged solely on the basis of an assessment of the risks to human health and the environment which must demonstrate that the release will avoid adverse effects to the environment." The statement goes on to say that "There have been calls for, and the European Parliament has proposed, the incorporation of an assessment of the benefits in the revised Directive and the Government is considering whether to support the inclusion of such a provision."[58] The European Parliament's amendment introduces a requirement for a study of the likely "socio-economic" costs and benefits of a proposed release. We would appreciate clarity as to whether this includes likely environmental benefits.

26. We recognise that the integrity of a system aimed at assessing the risk of harm to human health or the environment from a release, and providing advice thereon, would be damaged by the incorporation of trade-offs between small risks and large benefits. There would almost certainly be justifiable outrage in a case where a small health risk was set aside in favour of a substantial and more certain economic benefit. However, an assessment of 'negative risk' (a benefit) could be contemplated, not as a trade-off mechanism, but as a further hurdle, in terms of a specific requirement for applications to include in their submissions an assessment of the direct and indirect environmental benefits, where they exist. This may encourage the industry to consider these issues in more depth.

The case for a new approach

27. In terms of its role to regulate to protect the environment the Government's memorandum stated that the requirements of the Deliberate Release Directive and the work being done to develop a common EU approach to risk assessment meant that a strategy for assessing and managing the environmental implications of GMO release was in place. In oral evidence, however, Mr Meacher suggested that the review of the biotechnology framework was to identify a strategic approach to wider issues.[59]

28. Many witnesses called for strategic approach above and beyond the necessarily reductive and reactive line taken by the existing advisory committees.[60] ACRE itself, in the discussion paper on its new wider remit, concluded "the present legislation does not take a strategic approach to regulating GMOs and reacts to developments by assessing applications...as they are submitted on a 'first come, first served' basis. Government needs to consider whether more could be done with the industry, farmers and conservation groups to identify the scope for certain types of GMOs to play a positive role in developing sustainable farming systems which enhance farmland wildlife."[61] This would appear to support the Chief Scientific Adviser's advice for some of the 'pushing' if not the 'stopping' that Ministers felt was outside the Government's regulatory role. As Baroness Young told us: "somebody somewhere needs to be looking at how we get the potential benefits assessed and developed, if indeed there are potential benefits of GM crops, because at the moment we get lots of assertion about the benefits but nobody is doing terribly much to bring those to the marketplace."[62] Mr Meacher told us that the Government was concerned to "nudge" GM development in this direction but what the Government cannot do is prescribe exactly what shall or shall not be pursued.[63]

29. As an example of influence of the direction of GMO development, the Government's memorandum cited guidance issued by DETR regarding risks which might be of concern in relation to large scale commercial release. The example quoted was the use of antibiotic resistant marker genes used as research tools. Government guidance is that these genes should be excised at an early stage of plant development. Sir Robert May told us that the contribution of this source to evolving human antibiotic resistance is "a drop in the bucket" compared with the over-consumption of antibiotics directly by humans and indirectly through use on animals.[64] We concur with Sir Robert and with the Lords report that, given the development of alternatives and the potential for excision before release, there is no need to risk adding to the problem of human resistance and the practice of releasing GMOs with antibiotic resistant genes should be abolished.

30. We conclude that there is a need for a new strategic approach to complement the work on risks to human health and the environment and the case-by-case focus of the existing system in responding to applications. This should be built on the precautionary approach and seek to balance the industry's commercial agenda with a focus on the possibilities of applications of GM technology that will contribute to the mitigation of the environmental impacts of agriculture. Government must develop new mechanisms and ways for working alongside, and influencing, the industry's research effort to this end. Ministers recognised concerns about the effects of the reforms of the 1980s under which research institutions now operate almost invariably with a mix of public and commercial funding.[65] If necessary Government should re-consider the role of publicly-funded research in this area. Ideally this approach should be placed within a strategy to promote a more sustainable UK agriculture for which MAFF has published a set of indicators.

31. This new approach suggests that new mechanisms are needed. A number of witnesses pointed to the Cabinet Committee as signalling an improvement in the coordination of government policy and strategic approach.[66] We believe that Cabinet Committees are useful for government but are not designed for openness and the demonstration of how decision are taken. This is not a criticism. Ministers remain accountable for decisions taken in whatever forum. We welcome the establishment of the Committee given that the coordination and cohesion of the different department's interests in this complex policy area is vital. We especially welcome evidence that the Committee, fully attended by Ministers, is taking a hands-on approach to this "fraught" topic on a regular basis.[67]

32. The Royal Society, English Nature, the Royal Society for the Protection of Birds, the RCEP and the Lords Sub-Committee D, amongst others have all called for new advisory structures to over-arch, or to parallel, the existing system. We conclude that there is a need for an over-arching advisory committee for Ministers to consider the development of GMOs from a perspective above and beyond the examination of applications by the existing regulatory system. This should be a committee of experts and lay members and include the chairmen of the individual advisory committees. Its main tasks should include the provision of published advice to Ministers on:

Strategy

  • setting the general direction for the role of GMOs in agriculture, defining which impacts will and will not be acceptable and identifying potential for biotechnology to contribute to sustainable agricultural practices;

  • the oversight of new developments in biotechnology that may be expected to have wider environmental, social, ethical or economic consequences;

  • the identification of the best environmental option to address biodiversity decline through a comparison of GM and non-GM crop management in the context of realising a more sustainable agriculture;

  • liaison with any body set up to look at the health effects of GMOs over the longer term;

Review

  • the coordination and review of the advice of the existing committees including an audit function with respect to how that advice is used by Government;

  • review and assessment of the implementation of the precautionary principle in the advice received, and decisions taken, by Government;

  • taking an overview of broader issues relating to biotechnology across their various remits, in particular issues that the individual committees may not be dealing with such as risk/benefit analysis, generic ethical issues, and the environmental implications of international trade negotiations;

Articulation of public values

  • incorporation of people's values in the way policy questions are framed as well as in the eventual decisions on GMOs (the values of citizens rather than compromises brokered between interest groups); and

  • provision of authoritative advice at short notice in response to public alarm over particular issues.

In appointing such a committee the Government must have regard to the demands of credibility - expertise in a wide range of fields; independence from vested interests; and openness and transparency (to which we return below).

33. The Government specifically raised the question of an environmental stakeholder forum in its review of the biotechnology framework. We regard this as serving the distinct purpose of seeking to build consensus around the issues between explicitly interested parties and must include representatives of all the industries and businesses involved, consumer representatives, environmental groups and representatives of wider civil society. In this context we note the submission of the Environment Council on 'managed stakeholder dialogue' and commend the principles therein.[68] We conclude that a stakeholder forum could serve an important purpose but, if it is to be established, it should be a distinct entity, but linked to, the committee recommended above.



15  Q165 Back

16  HC Deb, 17 December 1998, wa  Back

17  Q165 Back

18  Q298 Back

19  Q236 Back

20  Ibid Back

21  Speech to Biotechnology Industry Association, 21 January 1999 Back

22  Appendix 18 (DTI) Back

23  EC Novel Foods and Novel Food Ingredients Regulations, May 1997 Back

24  Q381 Back

25  EC Directive 90/220/EEC on the deliberate release into the environment of genetically modified organisms implemented in the UK by the Genetically Modified Organisms (Deliberate Release) Regulations 1992 (as amended in 1995 and 1997) together with Part IV of the Environmental Protection Act 1990.  Back

26  Ev p62 Back

27  Appendix 5 Back

28  Appendix 11 (Novartis UK Limited) Back

29  Ev p3 Back

30  Evidence from the Royal Society of Chartered Surveyors, Appendix 12, sets out the concerns of land managers in respect of the future status of land previously used for growing GM crops. Back

31  Ev p1 and ff. Back

32  HL 11-I, 1998-99, paragraph 47. In the US as a general principle the transfer of genes to the environment at large is only of significant concern if there is a likelihood that they will cross back into the managed agricultural environment. Back

33  Q4 Back

34  Q75 Back

35  Q280 Back

36  Q282 Back

37  Appendix 15 (SCIMAC); Environmental Effects of Agriculure, DETR, July 1998; The commercial use of genetically modified crops in the UK: the potential wider impact on farmland wildlife, ACRE, February 1999. Back

38  Appendix 15 (SCIMAC) Back

39  Evidence taken before the Agriculture Committee, 5 May 1999, HC427-i. Back

40  Genetically Modified Foods: facts, worries, policies and public confidence, UK Chief Scientific Adviser, Office of Science and Technology, February 1999. Back

41  Ev p4 Back

42  Ev p3 and appendices 1 (Countryside Agency) and 12 (Royal Institute of Chartered Surveyors).  Back

43  But see Appendix 4 (Friends of the Earth). Back

44  Appendix 14 Back

45  See for example Appendices 4 and 14. Back

46  Setting Environmental Standards, RCEP, Cm 4053, p56. Back

47  Evidence before by the Science and Technology Committee, from Professor John Beringer, Chairman, ACRE, HC286-iv. Back

48  HC286-vii Back

49  Q291 Back

50  Ibid Back

51  Q307 Back

52  Q138 Back

53  HC427-i Back

54  Q139 Back

55  Ev p63 Back

56  QQ137 and 398 Back

57  Environmental Effects of Agriculture, DETR, July 1998, p156 Back

58  Ev p62-63 Back

59  QQ293-7 Back

60  See for example appendices 4, 5, 6, 10 and 14. Back

61  The commercial use of genetically modified crops in the UK: the potential wider impact on farmland wildlife, ACRE, February 1999. Back

62  Q30 Back

63  Q309 Back

64  Genetically Modified Foods: facts, worries, policies and public confidence, UK Chief Scientific Adviser, Office of Science and Technology, February 1999.  Back

65  Q315 Back

66  See for example appendices 9 and 11.  Back

67  Q277 Back

68  Appendix 3 Back


 
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