GENETICALLY MODIFIED ORGANISMS AND
COORDINATION OF GOVERNMENT POLICY
Public concerns and values
34. Clearly there is concern amongst the public about
GM food and genetic modification in general. There are also wider
issues of the confidence of the public in the advice that is offered
to Government and, perhaps more significantly, the way that advice
is then used. This is linked to recent experiences and the way
that episodes relating to BSE, e coli, listeria and salmonella
were dealt with. There is the potential for a deep and harmful
divide between Government's concept of 'sound science' and public
opinion. The findings of the review of attitudes to bioscience
are eagerly awaited and Dr Cunningham heralded some "uncomfortable
reading for Ministers".
He also told us that, in terms of public understanding the debate
was not assisted by the recent "barrage of media hysteria".
We look to Government to address the underlying factors which
give such stories credibility with the public. Sir Robert May
told us that internationally where citizens demonstrate a greater
degree of understanding of science (not just 'factoids') they
tended also to worry more about it. The UK usually scored second
or third in Europe in such exercises.
35. The Government's written evidence to us on the
existing mechanisms for incorporating public values and concerns
alongside the results of scientific assessment within the decision-making
process on GMOs is worth quoting in full:
"The Regulations require that all applications
to release GMOs are advertised in a local newspaper within 10
days of the application being submitted to the DETR. Information
about proposed releases and applications to market GMOs is placed
on public registers held at regional offices of the Environment
Agency and on the DETR website in sufficient time to allow public
comment. The advice from ACRE to the Secretary of State about
whether, and under which conditions, a consent should be issued
is also placed on the website and the public registers before
a final decision is taken. ACRE's scientific advice and all comments
received from the public are taken into account in making that
36. We think this is plainly inadequate. The recent
report of the Royal Commission on Environmental Pollution (RCEP),
Setting Environmental Standards,
recommended that DETR should consider how new methods for articulating
public values should be incorporated into the procedures for considering
environmental issues and setting environmental standards, including
the framing of questions to be addressed in analysis and communicating
the results in a comprehensible form. We recommend that the
advice of the Royal Commission on Environmental Pollution on the
incorporation of public values and concerns be applied to GMO
policy. We also agree with Baroness Young's personal view that,
if public confidence in the Government's monitoring of genetic
modification is to be rebuilt, it is a task for concerted effort
by Government over 5 to 10 years. We certainly believe that an
improved information strategy is required if the Government is
to address what Ministers described as "hysteria" in
the press. Underpinning this, a clear strategy is needed for
what the UK wants out of biotechnology to provide people with
an idea of what the benefits are and why, therefore, the efforts
and taxpayers' resources put into the regulation are worth it.
37. The principal concerns expressed in evidence
about the advisory system were perceptions that the advisory committees
were not sufficiently independent of the industry; that they were
not adequately open nor transparent; and that they did not have
sufficiently broad memberships. There appears to be a tension
between two of the demands of credibility for an advisory system:
for expertise and independence. In the biotechnology sector expertise
is often linked with the industry. This is sometimes direct employment
but more often it is through less direct funding links caused
by the Rothschild reforms of the 1980s which encouraged research
institutions to go out and secure funding from industry creating
closer links between the science base, public research and commercial
interests. We have not received convincing evidence of undue influence
being effected through these indirect channels. ACRE traditionally
has had two members directly employed by the industry.
Mr Meacher told us that, without reflection on the work or integrity
of the members concerned, this practice would not continue because
of the need for ACRE's independence to be above a peradventure
of a doubt. He said that industry representation would be catered
for elsewhere in the system, heralding clearly the establishment
of an environmental stakeholders forum.
38. The regulatory system for GMOs is technical rather
than ethical. The UK Environmental Law Association (UKELA) contrasted
the approach to GMOs with the regulation of human genetic manipulation
which they describe as having been introduced on the basis of
widespread public agreement about what was ethically acceptable.
There is no equivalent consensus on GM crops - and no mechanism
to seek to build one.
While this should primarily be a task for a body over-arching
the regulatory system, we believe that there must also be lay
personnel on each of the advisory bodies. Mr Meacher told us that
the creation of a strategic forum would obviate the need for lay
representation from environmental groups within ACRE.
Technical expertise is vital of course and must be the mainstay
of the advisory bodies however, we believe there must be a leavening
of the scientists' approach to what is significant by persons
with other frames of reference and non-scientific expertise. We
applaud Mr Rooker's commitment to this integrated approach.
We believe that there should be consistent protocols for the
inclusion of lay members on all the advisory committees on GMOs.
39. Openness and transparency are also key elements
in any attempt to improve the confidence of the public in this
process. While the agenda and minutes of meetings of the ACNFP
and ACRE may not often be the subject of debate in the pub, their
accessibility, as well as ACNFP's open meetings are to be welcomed
as contributions to the potential for informed debate. This also
should be consistent across the regulatory and advisory bodies.
Here MAFF does not score so highly as many witnesses commentated
on the lesser openness of the Advisory Committee on Pesticides.
We recommend consistent arrangements for openness and transparency
of proceedings across all the advisory bodies - and we single
out the practice of the Advisory Committee on Pesticides as in
need of reform.
40. We received a further proposal to this end by
UKELA for the Government to provide detailed guidance on the criteria
which the regulatory bodies should apply in its decision-making.
This would appear to be being addressed at a European level in
terms of the debate over the guidance on risk assessment to be
annexed to any revised Deliberate Release Directive. We note the
trenchant criticisms made about these annexes by witnesses to
the Lords inquiry.
We believe that while it is important for there to be guidance
on the questions that are asked it is even more important for
there to be guidance on the interpretation of the answers. We
recommend that the Government pursue agreement in Europe on detailed
guidance on risk assessment in terms of both the procedures to
be followed and the evaluation of the results. We further support
the proposal of the Royal Commission on Environmental Pollution
that there be comprehensive explanations attached to every official
decision on GMOs.
69 Q213 Back
70 QQ165 Back
71 Q158 Back
Cit., Cm 4053, p112 Back
legacy of its health and safety provenance. Back
and 377 Back
77 Q377 Back
78 Q379 Back
for example Appendix 6. Back
11-I, paragraph 93 Back