Segregation and Identity Preservation
(IP)
6. Early in this inquiry, we were taken to task by
several witnesses for our use of the term 'segregation'. Companies
with experience of the US market and the system for bringing crops
from the field to the consumer all stressed that "using the
terminology 'identity preservation' [IP] seems more useful".[6]
PG Economics explained that "both segregation and IP essentially
refer to any system of crop or raw material management that segregates
or preserves the identity of the source or nature of the materials.
At a general level segregation is synonymous with 'keeping crops,
products etc apart' whilst IP is more widely considered to apply
where there is a positive desire to preserve the identity or source
of a crop or product".[7]
This distinction was supported by the American Soybean Association[8]
and Cargill plc[9]
who both underlined the central importance of the end-user in
an IP system. The Vice-President, Public Affairs, of Cargill plc
also pointed out that "identity preservation does imply traceability,
which segregation does not".[10]
The key difference is that identity preservation, traditionally
applied to high-value crops, ensures that a particular crop is
monitored throughout the food chain to ensure its 'genetic integrity'[11]
and thus guarantee the quality which commands a premium, whilst
segregation, albeit "a fundamental component" of IP,[12]
merely separates one batch or crop from another.
7. Ms Rawling of Cargill plc assured us that "people
can get too hung up on words"[13]
but it is clear that there is a very important distinction to
be made here in talking about the supply chain. In this case,
segregation matters if the end-user - the consumer - wishes to
be certain of the nature of a particular product. Marks and Spencer
plc explained that "Consumers are demanding new levels of
traceability to give assurances of food safety to which food retailers
and manufacturers are responding", and that "there is
an increasing tendency to require independent auditing and verification
of effective segregation to provide transparency in support of
claims".[14]
At the moment, it is likely to be non-GM crops which are identity-preserved
as this will be the only way of separating them from the system
which delivers commodity crops to the market. In future, it may
be that some GM crops will require this degree of preservation,
where their added characteristics enhance their value to the consumer.[15]
Where crops on farms are concerned, however, segregation may have
a different purpose. The NFU argued that, in addition to the consumer-
and price-led reasons for keeping certain crops apart, "a
crop could be grown that would be hazardous if the products of
it were eaten by humans or livestock".[16]
Here, segregation is necessary to prevent cross-contamination.
This is the sense in which the term is generally used in the context
of the field trials and of future commercial plantings in this
country and although we are mindful of the implication that GM
crops are thereby treated as harmful, we find the term useful
and employ it in this narrow sense in our Report.
GM-free and non-GM
8. The purpose of segregation is to allow the identification
of foodstuffs as either derived from GM crops or not. There is
some confusion as to the terminology which should be applied to
the latter category. Several witnesses pointed to the "widespread
reference to 'GM-free' by the press, influence groups, consumers
and even some retailers"[17]
and argued that the use of 'GM-free' was "misleading".[18]
There are several reasons why this is the case. First, we heard
consistent accounts from witnesses that it was impossible to achieve
100% GM-free or "absolute purity".[19]
This assessment arises from the acknowledgement that the seeds
from which crops are grown are not 100% pure,[20]
with the accepted level for certified seed being around 99.7%,
depending on the crop.[21]
This gives scope for a tiny percentage of GM material in even
the most stringently monitored crops, a situation made more probable
by the percentage of GM crops now in the open agricultural chain.[22]
Secondly, there is the question of measuring the GM content of
a food.[23]
The analysis is only as reliable as the test and at the moment
it would appear that results cannot be 100% accurate.[24]
Thirdly, we were reminded that "the whole emphasis of policy
development in Brussels has been to provide a workable distinction
between GM (labelled) and conventional (unlabelled) supplies,
with products labelled GM-free providing a potential third category".[25]
Where reference is made to regulatory activity, it is therefore
incorrect to oppose 'GM' with 'GM-free', rather than 'non-GM'.
9. When we put the great potential for confusion
on this issue to Baroness Hayman, she agreed that consumers do
not understand the difference between GM-free and non-GM.[26]
She argued, rightly in our view, that "you have to have a
definition that is testable and a definition that is universally
accepted".[27]
Her first point leads to acknowledgement that GM-free cannot be
guaranteed and therefore thresholds for tolerance of accidental
'contamination' must be established. However, her second point,
whilst correct in terms of agreements within the food chain, is
likely to be harder to achieve where consumers are concerned.
The Soil Association argued that "most consumers believe
it is their right to remain GM free".[28]
We recognise that consumers who wish to avoid GM foods believe
the alternative is GM-free and would find it hard to accept the
scientific explanations why this claim is so difficult to verify
and so should not be made. Nevertheless, we accept the distinction
which has to be made between 'non-GM' and 'GM-free'. There is
not yet a satisfactory definition of GM-free but once it has been
agreed, we expect it to be enforced.
2 Sixth Report from the Agriculture Committee, Session
1998-99, Genetically Modified Organisms, (HC 427), para
3. Back
3 Press
notice No. 23, Session 1998-99, 30 July 1999. Back
4 Ev.
p. 175. Back
5 Ibid. Back
6 Ev.
p. 26. Back
7 Ev.
p. 127. Back
8 Ev.
p. 152. Back
9 Ev.
p. 26. Back
10 Q
146. Back
11 Q
79. Back
12 Q
84. Back
13 Q
146. Back
14 Ev.
p. 57. Back
15 Ev.
pp. 125, 137. Back
16 Ev.
p. 24. Back
17 Ev.
p. 3. Back
18 Q
333. Back
19 Qq
332-3; see also Q 86; Q 162. Back
20 Q
159. Back
21 Q
223. Certified seed is high genetic purity seed produced by seed
companies to statutory requirements and sold to farmers. Back
22 Q
332. Back
23 Ev.
p. 118. Back
24 Ev.
pp. 5-6. Back
25 Ev.
p. 8. Back
26 Q
501. Back
27 Q
504. Back
28 Q
378. Back