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.
28. Many witnesses called for strategic approach
above and beyond the necessarily reductive and reactive line taken
by the existing advisory committees.
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."
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."
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.
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
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.
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.
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.
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:
- 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
- liaison with any body set up to look at the
health effects of GMOs over the longer term;
- 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.
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.