Submitted by M J Savill
WEAKNESSES IN THE APPROVAL PROCEDURES FOR
GENETICALLY MODIFIED FOODS
I have recently used the Internet to study the
approvals procedures for novel foods, and the BSE enquiry. I am
a qualified chemist, environmental scientistand also have
a degree in business and many years carrying out management science
in industry. There appears to me to be very legitimate reason
for public concern that the procedures for assessing food safety
are inadequate, and need further strengthening to prevent another
BSE disaster. The weaknesses I have identified are detailed below.
1. A lack of use of management science techniques.
The techniques of decision analysis under uncertainty, cost/benefit
analysis and risk analysis (a much misused term), should be used
to illuminate the true balance of benefits, costa and risks associated
with producing and consuming foods. This would require a new professional
input to the procedures.
2. A lack of experimentation. If sufficient
good experiments had been carried out on animal feeds, we would
not have had 35 deaths from CJD/BSE and possibly thousands to
come. The Advisory Committee on Novel Foods and Processes (ACNFP)
has published a paper on the MAFF Internet site describing procedures
for toxicological testing of novel foods. This paper makes it
clear that most GM foods have not, and will not, be given any
long term animal feeding tests, because of the difficulty carrying
out such experiments and interpreting the results. In addition
there are no long term tests carried out on human volunteer test
groups. This policy seems foolhardy in the extremewhen
a foods DNA is modified (for example in the case of Monsanto Soya
with genes from a virus, a bacterium and a plant) the new organism
(never before seen on this plant) makes a new mix of chemicals
and proteins. This mix cannot be predicted or reliably analysed,
therefore the only way to determine its safety reliably is through
scientifically designed experimentation. The principle of "equivalence"
outlined in the paper is scientifically very suspectit
pays to beware of scientists arguing the case for not doing experiments
because they are too difficult! If it really is impossible to
carry out meaningful animal testing, then clearly human testing
must be carried out before allowing the whole population to consume
these foods for life.
3. Allergies. The whole question of allergy
to novel foods has not been adequately explored. In another paper
on the MAFF site, the advisory committee argues that merely notifying
consultant allergy specialists, and allergy support groups, of
the approval of foods containing lupin genes is sufficient safeguard.
This is clearly not the case since sufferers from lupin allergy
are very unlikely to inform their consultant (if they have one),
or allergy support groups. Even if some sufferers to a particular
allergy are alerted in this fashion, they may not in practice
be able to avoid exposure. Soya, be example is extremely widespread
in processed and restaurant food. The presence of genetic material
from a wide variety of sources, including bacteria, fungi and
viruses clearly raises the possibility of severe allergic reactions
in consumersthis must be properly tackled as a safety issuewhich
can, I believe, only be reliably and definitively studied if human
consumption trials are included in the scientific procedures.
4. Scientific consultation. Politicians
should have alarm bells ringing when there is scientific disagreement
on issues of health and food safetyas clearly demonstrated
by the Professor Lacey/BSE saga. There is usually only significant
disagreement in real science when there is a lack of understanding
in the area concerned, which in turn implies that policy makers
should be extremely cautious. I know some improvements have been
made in this area, but I think advisory committees should be required
to consult widely, and tackle the issues raised during consultation
in a transparent fashion.
I hope the Select Committee sees fit to investigate
the approval procedures for novel foods in detail (including GM
foods not defined as "novel" in the legislation).