Select Committee on Agriculture Third Report


THE SEGREGATION OF GENETICALLY MODIFIED FOODS

II. SEGREGATION IN THE FOOD CHAIN

On the farm

10. GM and non-GM crops may become mixed on farms in several ways. Dr Philip Dale of the John Innes Research Centre listed four potential sources of mixing: the degree of impurity of the certified seed used to establish the crop; mixing with GM volunteer plants already present in the soil; mixing with seeds present in sowing, harvesting and storage equipment; and cross-pollination with adjacent GM crops.[29] The risk can be minimised by good agricultural practices which ensure that the crops are handled separately. Identity preservation systems are already in place in the US to deal with conventional crops on farms, paying farmers a premium to maintain the purity of waxy maize, for example.[30] In the UK, procedures for growing GM crops are set out in the SCIMAC Code of Practice on the Introduction of Genetically Modified Crops.[31] The Code is designed to provide "a consistent, industry-wide framework for identity preservation up to and including despatch of the harvested crop from the farm",[32] drawing on "management practices within the certified seed production sector which in more than 30 years of operation in UK agriculture has consistently delivered levels of varietal purity and identity in excess of 99.5 per cent".[33] The SCIMAC guidelines are currently in use in managing the field trials of GM crops but in time they will apply also to commercial plantings. The Government is firmly in favour of the initiative, endorsing the use of the Code and exploring with the European Commission how it could be incorporated into EU legislation.[34] The credibility of the guidelines in ensuring segregation of GM crops on farms is therefore a matter of some importance. Supporters included Novartis, who told us that from an international perspective, "SCIMAC is being viewed as one of the more established and credible organisations".[35] Some witnesses, however, raised doubts which touch upon the key issues involved in segregation on the farm: separation distances, practicalities, notification, relations with the organic sector and transparency. We will examine each of these in turn.

Separation distances

11. The most contentious issue is that of the distances needed between crops to reduce the risk of cross-pollination. The separation distances operated by SCIMAC are set out in the table below.

SCIMAC separation distances

Crop type
Certified seed crops
(same species)
Registered organic crops
(same species)
Non-GM crops
(same species)
Oilseed rape
200 m
200 m
50 m
Sugar beet
600 m
600 m
6 m
Fodder beet
600 m
600 m
6 m
Forage maize
200 m
200 m
200 m (sweetcorn)
50 m (forage maize)

Source: SCIMAC, Guidelines for growing newly developed herbicide tolerant crops, May 1999.

These distances have been subject to much criticism from environmentalists as inadequate to prevent pollination either by air-borne methods or particularly by insects.[36] Research commissioned by the Soil Association from the National Pollen Research Institute suggested that the risk of the former had been underestimated, while other studies have shown that "bees will regularly travel three miles to find sources of nectar and pollen if good sources are not available closer".[37] The Soil Association concluded from this data that "a six mile separation distance for related species would generally be necessary".[38]

12. We took evidence from two expert scientists on this issue. Professor Alan Gray of the Institute of Terrestrial Ecology stressed that "the ability to segregate the crop by physical separation varies considerably from crop to crop".[39] Between crop species, the decisive factors include the method of pollination and the existence of wild relatives. Even within any particular crop species, "there is known to be enormous variation in the levels of gene flow" which makes it difficult to predict.[40] Moreover, "there is a clear difference between the pollen travelling and it making an effective cross-pollination".[41] Dr Dale added that "many of the cereals will self-pollinate preferentially, so you get very little cross-pollination".[42] Both witnesses agreed that any guidelines should be based on past experience with certified seed production, using the established procedures as a 'baseline'.[43] Professor Gray, acting Chairman of ACRE which decides all applications to release genetically modified materials on a case by case basis,[44] advised that, owing to the variation in gene flow shown by so many studies, his committee based separation distances on what "on average actually happens".[45]

13. The scientists also advised us that to ensure total genetic purity would require segregation far in excess of what is practical, that is "regional separation of GM and non-GM crops".[46] The question therefore turns on the issue of tolerances, and we were reassured by all the evidence we received on the ability of the seed industry to guarantee such high levels of purity. Nevertheless, we note the conclusions of an overview of research into pollination produced by the National Pollen Research Unit in Worcester during the course of our inquiry which suggests that the SCIMAC advice on separation distances may need adapting. For example, on oil seed rape, "pollen dispersal has been recorded at up to 4km by insects (some 20 fold higher than the recommended isolation distances), and to 3km by the air flow".[47] When we put this conclusion to Baroness Hayman, she reminded us that "while pollen can travel several kilometres, the issue is the likelihood of cross-pollination and that reduces very much over distance".[48] However, she also agreed that "we need to look at whether we need to develop those separation distances".[49] This is being taken forward in conjunction with representatives of the organic sector and of SCIMAC, whose guidelines state that "separation distances are based on current regulation, established practice ... and best scientific knowledge and may be subject to review".[50] We believe that separation distances for GM crops must be based on the best available scientific research matched to best agricultural management techniques. We are pleased that the Minister accepts that the Government may not "necessarily have got it 100 per cent right now"[51] and we recommend that the Government ensure that the separation distances set out in the SCIMAC guidelines be reviewed if there is clear evidence of cross-pollination taking place within the existing guidelines and any necessary revisions implemented in the next round of field trials. If such a review becomes necessary, we would expect all interested parties to be represented on it.

Practicalities

14. The SCIMAC guidelines include "specific practical measures to safeguard the integrity and identity of harvested GM (and non-GM) crops", covering procedures such as storage of seeds, cleaning down seed drills and harvesting machinery, and mechanisms to minimise seed loss at harvest and to prevent spillage into unplanned areas of the farm.[52] The Royal Institution of Chartered Surveyors (RICS) highlighted the difficulties of observing these guidelines, particularly where contractors were used, advising the Committee that "the practicality ... of cleaning seed drills and combines in field situations is highly questionable as is the 'policing' of this if the growing of GM crops become widespread".[53] The RICS believed the only solution would be "a requirement that GM crops can only be sown and harvested and handled using designated machinery".[54] The NFU, a member of SCIMAC, listed all the requirements necessary to ensure full segregation, including cleaning of equipment, and stressed that "not all farmers and growers are presently suitably equipped to carry out these processes".[55] The procedures required by the guidelines would also involve extra costs for the land used in separation distances and labour charges due to the additional care demanded.[56] This is undoubtedly true, although clearly not all farmers will be required to carry out these procedures as we are unlikely to reach a stage where all farmers grow GM and non-GM crops side by side. Where equipment is shared between farmers, it may be easier rather than more difficult to dedicate machinery to either variety of crops.

15. There is good reason for the stringency of the guidelines agreed by SCIMAC and we are not convinced that they are impractical. Once again, we are reassured by the use of similar processes in the production of certified seed. Much will depend upon the monitoring and policing of the guidelines as they are implemented by the farmers themselves. UKASTA, another member of SCIMAC, assured us that "adherence to the guidelines, checked by an external and independent audit of compliance, is mandatory".[57] Failure to comply triggers off a penalty system and ultimately loss of access to GM technology.[58] In addition, of course, one objective of the guidelines is to ensure traceability which makes it very much in the farmer's best interests to ensure that correct procedures are followed. We therefore conclude that the SCIMAC guidelines are a practical approach to crop-handling procedures on a particular farm.

Notification and registration

16. Under the SCIMAC guidelines, farmers are required to notify neighbouring farms of their intention to plant specific crops and to reach agreement on planting strategies.[59] Any failure to reach agreement is notified to SCIMAC which then consults with the appropriate representative body, after which continuing disputes have to be "resolved through normal legal channels".[60] For several witnesses, this did not go far enough. Two points in particular were raised. First, the inability of an anti-GM farmer to stop his neighbour growing GM crops near his land. The RICS was concerned that "the lack of any power to veto the growing of GM crops, by neighbouring farmers is likely to cause immense friction in the countryside".[61] We had direct evidence of this in the response generated by one witness who asserted that he had discussed his wish to grow GM crops with six nearby farmers, of whom "four are totally in support ... two are agnostic".[62] Correspondence from the two farmers in question made it very clear that they were not agnostic but firmly against the planting of GM crops at this stage.[63] Secondly, in accordance with its policy on separation distances, the Soil Association believed that the notification zone should be much wider than neighbouring farms, stretching to a six-mile radius of the field,[64] and that the Government should be obliged "to inform the organic certifying bodies of the location of intended trial sites sufficiently in advance".[65]

17. Closely linked to the issue of compulsory notification within a set area around a GM crop is the proposal that the details of all land used for growing GM material should be kept in a public register so that future purchasers would be aware of the land's status. The RICS suggested that this information could be collected through IACS which "has the advantage of being a comprehensive map based system and will reach the majority of those farmers who would be likely to grow GM crops".[66] The register would then be made available to the public, perhaps through the regional service centres. This would be particularly useful for those wishing to purchase land in the vicinity of a GM site. At the moment, the SCIMAC rules prescribe record-keeping on farms with those records maintained for a period of seven years,[67] but there is no requirement to offer access to those records to the public, nor is there a separate permanent register of land use.

18. In addressing these questions, Baroness Hayman emphasized the difference between the field trials and future plantings of crops which have passed regulatory approval procedures.[68] She told us that "I believe it is important that we maintain the transparency of the regulatory system as it is at the moment, which means that we do have to be very clear about where crops are grown on an experimental basis".[69] However, "if a crop has gone through all its regulatory processes, I am not certain what the justification would be for singling out a GM crop rather than any other crop for compulsory notification".[70] She explained that "we have to be careful about assuming that GM crops are completely qualitatively different from anything else and that different rules have to apply in all aspects of the way in which they are handled post introduction, after very careful scrutiny and regulation".[71] Under SCIMAC guidelines, the availability of the records kept by individual farmers to prospective purchasers "would be a matter of negotiation".[72]

19. It is ironic that the Government's openness on the issue of GM crops has enabled protesters to trash several of the field trials. On the other hand, neighbouring farmers and purchasers of land have a clear interest in what is and has been planted in a particular field. We note that the Soil Association "did not say that there should be no GM trial crops within six miles of organic holdings" but that "within six miles we should assess each case according to the risks".[73] This implies that not even the organic movement is asking for an outright veto on what a farmer can plant on his own land. On balance, we believe that notification should be compulsory, that the notification zone should at least match the separation distances and that SCIMAC must work harder to ensure that the views of neighbouring farmers and other directly interested parties are taken into account in the planting of GM crops. If the guidelines are put on a statutory footing, the requirement for notification will also become statutory which should give it more force. On the question of a public register, we understand Baroness Hayman's argument that it would be invidious to single out GM crops as uniquely polluting. Obviously, it would be far easier to begin such a register now at the very commencement of the planting of GM crops than to attempt such a task retrospectively, should scientific research prove the need for one in the future. However, we believe that we should not give the impression that there is something inherently dangerous about GM crops which warrants rules different from any other circumstance. On balance, we believe that there is a real problem in requiring a register for one category of crops only. Either a product is safe or it is not safe. If it is safe, it should take its place on an equal footing with other crops.

Relations with the organic sector

20. GM crops pose particular difficulties for the organic sector which operates under EU rules which explicitly 'prohibit' GMOs in organic production.[74] Accidental cross-contamination could have severe implications for a farmer trying to produce organic goods, with the threat of decertification by the organic certifying bodies and consequent loss of income. The Board of the United Kingdom Register of Organic Food Standards (UKROFS) has previously raised its strong concerns about the planting of GM crops in the UK with the Government. Despite reassurances to the contrary, the Board has rejected the idea that "the protocol drawn up by SCIMAC is sufficient to protect organic production".[75] It believes "the presence of GMOs (irreversible incorporation of genetic material into the food chain) is of an entirely different order to accidental environmental contamination by pesticides".[76] However, Dr Dale emphasised that "currently organic farmers (1-2 per cent of UK agriculture) and non-organic farmers accommodate each other by accepting a degree of spray and fertiliser drift, pest and disease transfer, cross-pollination and crop mixing during harvest and handling".[77] His point was that "the adoption of extreme crop isolation procedures such as a 6-mile distance between organic and GM crops will seriously limit the freedom and choice of neighbouring farmers to follow a diversity of farming systems".[78] Therefore, to grant protection to the organic sector would be to deprive the many farmers and consequently consumers who wish to benefit from GM crops.

21. The dispute between the organic and the pro-GM lobbies crystallises the debate over freedom of choice. The Government, which has shown every sign of wishing to encourage both types of farmers, is caught in the middle, although Baroness Hayman was robust in her assertion that "the organic movement has to recognise and find a way of living with adventitious contamination from conventional crops".[79] She went on to explain that the movement also had to accept that "they do not have a veto over other agricultural methods, whether GM or non-GM, just because they are not the methods that they choose to adopt".[80] In fact, MAFF has faciliated a meeting to bring the two sides together in order "to consider how the [SCIMAC] guidelines might be developed to address the issue of detectable GM material being found in organic crops".[81] This includes a review of the need for further research and a fresh look at the separation distances.[82] These measures do not meet all the demands of UKROFS,[83] but they do show a willingness on the part of MAFF to discuss the legitimate concerns of a growing agricultural sector.

22. There have been occasions upon which the organic movement has been guilty of exaggeration on this issue. For instance, the Soil Association wrote of the "negative effect" of GM concerns on the sector's attractiveness to conventional farmers considering conversion.[84] This is patently not the case. Nor has the research commissioned by some in the movement always been presented in a responsible way. Nevertheless, we have been consistent in our support for organic farming and we recognise that their views are sincerely held. The analogy with pesticides is misleading insofar as pesticides were already established within UK agriculture before the rise of the organic sector, whereas GM crops represent a new factor which can be addressed before it has a substantial negative impact. We welcome the ongoing discussions between SCIMAC and representatives of organic farming as the right approach to this issue. It would be as wrong for an organic farmer to prevent his neighbour growing GM crops as for a farmer planting GM maize to put his neighbour's organic crop, and therefore livelihood, in jeopardy. A modus vivendi must be found and written into the guidelines to ensure that the special circumstances of organic farmers are recognised. The two types of farming are equally legal and neither should be subject to discrimination.

Transparency

23. One difficulty with the guidelines drawn up by SCIMAC is their ownership by the industry. While their foundation on certified seed production attests to their effectiveness, there is a crucial difference in that the need in that industry is to guarantee the purity of seeds for the customer. In the case of GM crops, the need is to persuade those who wish to avoid contact with the segregated material that the procedures are watertight. It is the distinction we made earlier between identity preservation conducted for the benefit of the end-user and segregation which isolates a particular substance for the sake of other products. Clearly, there is a greater need in the second instance for the utmost transparency to reassure sceptics and opponents that the risk of GM material mixing with non-GM is minimal. The credibility of the arrangements may be challenged where the guidelines are drawn up, policed and enforced by pro-GM groups with an active interest in GM crops.

24. Such doubts of the integrity of the guidelines may be unfair but they have to be addressed if the SCIMAC rules are to form the basis of segregation on farms. We recognise that SCIMAC has consulted widely on its code of practice,[85] but this is not sufficient to allay concerns and convey a sense of ownership and trust to organisations naturally wary of GM technology and its effects on food or the environment. We believe that the Government's policy of putting the SCIMAC guidelines on a statutory basis could be very helpful in this regard. SCIMAC itself was doubtful about the move, arguing that "a voluntary initiative is the best footing on which to address this particular issue".[86] Its Secretary believed that once a GM crop had passed its regulatory stages, it was "not an issue of health or safety which should be addressed through regulation but is an issue of observing the commercial interest, the economic interest, of both GM farmers and non-GM farmers".[87] We believe that the self-regulatory arrangements need to be clearly endorsed by Government so that they have equivalent status to statutorily based guidelines. However, we also consider that such statutory guidelines should only be imposed if they are part of a uniform arrangement across the EU.

Conclusion on segregation on farms

25. Attitudes towards segregation of GM crops on farms depend upon the perception of risk. Dr Dale told us that "from a scientific perspective, pollination between GM crops and non-GM crops is considered to present no greater risk than pollination between different conventionally bred crops" and he accepted that "for any field grown crops, it is virtually impossible completely to prevent some mixing between GM and non-GM crops".[88] For some people, that risk is intolerable. Whereas SCIMAC reassured us that "the potential contamination is very, very low",[89] the Soil Association believed that "the likelihood of genetic contamination of GM-free crops from GM crops is very high, outside the control of the farmer, and the implications, including economically, are very significant".[90] Taken to its logical conclusion, this results in the view expressed by Friends of the Earth that "we are not at all convinced that we can operate GM farms in the United Kingdom alongside conventional farming".[91] These views are irreconcilable but that does not absolve any of the parties from the responsibility of trying to find a system which will satisfy all reasonable objections. We believe that the SCIMAC guidelines offer a firm basis on which to build in order to segregate GM and non-GM crops in the UK countryside. We have identified areas where improvements are needed but we conclude that an acceptable level of segregation can be achieved without incurring excessive costs. We note that in the US, where GM planting is widespread, premiums are now being offered for non-GM crops, and that the trend may be shifting away from farmers preferring GM seeds. In the UK, the extra protection is provided around GM crops, while conventional crops are still seen as the norm so the growing of GM crops under SCIMAC guidelines should not affect the cost of non-GM produce to the consumer.

26. A key issue which remains to be solved is the question of liability. Organic farmers in particular are concerned that farmers should be eligible for legal compensation if they lose their organic status because of pollution.[92] There is also the matter of GM material finding its way into conventional food, leaving farmers open to fines and compensation claims from manufacturers and retailers where GM tolerance levels are inadvertently breached.[93] Efforts to minimize mixing should mean that the risk of this occurring is extremely low but it is an issue which must be addressed. Baroness Hayman advised us that "it may involve legislation at an EU level rather than a United Kingdom level".[94] We recommend that the Government resolve the issue of legal liability on an EU-wide basis as a matter of urgency and aim to have the necessary measures in place before any commercial plantings of GM crops are permitted.

The field trials

27. There has been much publicity surrounding the on-going field trials with GM crops. The purpose of the trials is to answer many of the questions which have been raised about the release of GMOs into the environment. The Minister for the Environment described "the primary objective of the farm-scale evaluations" as being "to study how the management of GM herbicide tolerant maize and oil-seed rape might affect wildlife and biodiversity compared to the management of their non-GM equivalents".[95] The trials are funded by the Government, with the crops grown in accordance with SCIMAC guidelines and the research conducted by a consortium led by the Institute of Terrestrial Ecology, overseen by a steering committee of scientific experts drawn from English Nature, environmental NGOs and academics.[96] They have been opposed by the Soil Association, whose Director spoke for many other organisations and individuals when he told us that "it is our stated policy that we believe that there is no case for open air trial plots because it is a form of treating the countryside like an open-air laboratory and the Government have no means of controlling genetic pollution".[97] Mr Holden objected to "the current parameters of the research" as "largely misdirected ... if you look carefully through the current research objectives of the trial plots, you will find that they are very badly designed and unlikely to lead to any useful outcomes".[98]

28. Professor Alan Gray from the Institute of Terrestrial Ecology defended the trials and his research methods, pointing out that the farms had been chosen to be "representative of commercial practice" and that the sample size was "that considered sufficient to reveal statistically significant differences with an appropriate power".[99] The research is unique: Professor Gray told us that he knew "of no other project anything like as comprehensive as this".[100] On behalf of MAFF, Baroness Hayman described the field trials as "essential to a proper assessment of the implications of the properties of particular GM crops".[101] She explained that "I can envisage a situation where it is perfectly possible to say that a food is safe to market whereas we might not wish it to be grown in this country because of our particular environmental consequences".[102] This is a highly emotive issue and we acknowledge concerns about the field trials but we recognise that the only way in which the necessary research can be conducted is through work in the countryside on a mathematically determined scale. It is impossible to replicate the conditions experienced by outdoor plantings in a laboratory without seriously compromising the results; and we know from inquiries into other issues that it is vital that sufficient trials are completed to ensure the statistical power of the experiment is met. We recommend that the Government maintain the programme of GM crop field trials as planned, and that all steps are taken to ensure that experiments are not scaled down below the size calculated to produce reliable and scientifically sound results and that they are protected from interference.

From the farm to the processor

29. The presence of GM material in products processed or sold in the UK is the result of the dependence of the UK food industry on imported soya and maize from the United States. The UK annually imports 1 million tonnes of soyabeans and 1.3 million tonnes of soyabeanmeal[103] which are used in a wide variety of products, ingredients[104] and animal feed. However, this is only a fraction of the total US soya harvest of 75 million tonnes.[105] The size of the US operation has resulted in the development of means of handling crops which have no equivalent in the UK. The supply chain is designed to create economies of scale by bringing together crops from all farms and treating them as a single commodity, with vast storage silos (up to 100,000 tonnes in capacity[106]) and bulk transport systems. Throughout the chain, GM and non-GM crops are commonly intermingled as until very recently there had been no consumer pressure in the US to separate out the 50% of soya crop which comes from GM seeds and no regulatory requirement to do so.[107] Therefore, although most UK food companies "never specified the use of GM ingredients",[108] inevitably their supplies from the US contained GM material.

30. The response of companies dealing in the transport and processing of these commodity crops to the demand for non-GM supplies has been to point to procedures for identity preservation, designed, for example, for soya destined for the Japanese tofu market. Cargill plc and DuPont (UK) Ltd both supplied us with detailed descriptions of how such IP systems work and their implications for the segregation of GM crops.[109] It is a complicated process. Cargill plc had "identified, in the case of the major commodity crops produced in countries such as the United States, that there are something like eight stages in the supply chain where the product goes through a period where it could be co-mingled accidentally with another commodity".[110] Nevertheless, it is possible to supply crops within a set tolerance for GM content. The main difficulties are that, in US terms, the market for non-GM product is a specialised one, which significantly raises the cost of IP measures, and also the timing. Cargill plc told us that "when the GM technology arrived, we, as a company, expected that within five or seven years we would have the opportunity to segregate special traits, which would bring a consumer benefit".[111] Instead, the backlash against GM technology has meant that the industry is trying to make rapid adjustments to its commodity supply chains to isolate non-GM crops to meet customer requirements.

31. It is possible that we have reached a turning point in that there is some evidence that US attitudes are changing towards the supply of non-GM crops. As the Consumers' Association observed, "Initially we were told that [segregation of crops] was impossible to achieve and therefore unrealistic".[112] Now, with so many European food and retail companies removing GM materials from their products, the market has found a way to meet the customer demands. The Food and Drink Federation reported "an evident increase in ability or preparedness of growers to supply conventional materials",[113] and Marks and Spencer plc replaced all GM ingredients with alternatives or non-GM equivalents in a comparatively short period of time.[114] Non-GM supplies will increase still further if, as appears to be the case, more American farmers turn back to conventional crops. Future GM technology should focus on offering consumer benefits, rather than agricultural ones, and so the emphasis is likely to be on separating out those crops to ensure that the full value is realised. Hence, even within the US commodity system, it is possible that it will be GM crops which require segregation, while conventional crops remain non-GM and make up the bulk of the harvest.

32. For the moment, there is confusion within the industry as to which way the trend will go. From regarding GM as the norm - a great advantage for the farmer and a matter of indifference to the consumer - companies involved in transporting crops are having to rethink their policy. Cargill plc recognised that "the market is in a period of transition from not understanding whether it has a requirement to segregate, to identity preserve, to have non-GM supplies, and fully going to the position of having a non-GM system".[115] As UKASTA pointed out, "non segregation of these products is a result purely and simply of the long established storage and transport structure within the agricultural industries of both North and South America".[116] It was not a refusal to meet consumer demands, nor a point of principle. If it becomes economically attractive to reverse the emphasis of GM crops, that is the way companies will direct their operations. As Friends of the Earth predicted, "we could end up with a GM commodity trade and a non-GM commodity trade and both working alongside each other."[117] It is apparent that already the UK demand for non-GM ingredients can be met when dealing with US imports. When the question arises of UK home-grown supplies, we can expect that the forewarning of the need for clear identification of GM and non-GM crops will ensure that the supply chain will put in place the processes needed to guarantee the status of crops from the farm to the plate.

Animal feed

33. Soya is an important component in animal feed, particularly of pigs and poultry but also of beef,[118] and public attention is now beginning to focus on the entry into the food chain of GM material through this channel. The provision of non-GM animal feed presents similar problems to those outlined above but on a larger scale because of the greater percentage of soya in the diet of farm animals. Cargill plc advised that "the animal feed industry is not at such an advanced stage in wrestling with this issue and finding a solution [as the food industry], in that some of the ingredients in animal feed are not as easily replaced".[119] UKASTA, which represents animal feed manufacturers, believed the industry could cope with the demand for small quantities of either GM or non-GM animal feed: "what would present problems ... would be a widescale move towards a marketplace which was looking for finished products produced in quantity of both GM and non GM streams".[120] That scenario would demand "a significant change in the structure of feed mills".[121]

34. Marks and Spencer plc has introduced a trial range of meat products guaranteed to come from animals fed on non-GM materials.[122] This decision has been welcomed by consumer groups and by industry representatives such as UKASTA.[123] Novartis told us that it "supports any decision to create a channel for the production of meat and dairy products that are produced without the use of GM crops in animal feed, provided that the supply chain can adequately meet these demands and allow independent verification of this status".[124] Speaking for the Government, Baroness Hayman saw the question of animal feeds as "an issue of consumer information".[125] She argued that "we have to have some common sense about how far back you go, what you label and in what detail you label",[126] but stressed that it was a matter which the UK Government was pursuing within the EU. We accept that, as with GM crops in fields, there are no proven food safety implications in eating products derived from animals fed on GM soya. Nevertheless, we recommend that the Government press the European Commission for an early consideration of a workable and transparent labelling regime for meat and dairy products derived from animals fed on GM materials and for labelling of the feed itself.

Costs

35. The extra care involved in segregation and identity preservation is likely to involve additional expenditure, which traditionally has been reflected in the price paid by the consumer. We have had widely varying estimates as to the on-cost for segregation of GM crops within the commodity trade. Novartis spoke of higher costs and "a significant price increase" because of the need for "dedicated silos, dedicated ships and very well cleaned-out trucks".[127] Northern Foods put the cost of dedicating a UK soya mill to non-GM beans at £11 per tonne of beans, most of which additional expenditure would be carried by the end-product lecithin which would work out at £2,200 per tonne of lecithin.[128] On the other hand, DuPont (UK) Ltd calculated that "some legitimate extra costs are incurred due to some loss of flexibility in the supply chain" but these "need not necessarily be excessive".[129] Premiums could be as low as 10-15%, equal to "less than two pence on the price of a whole chicken or less than 1,000th of 1 per cent on the cost of ice cream using lecithin".[130] In general, it was agreed that the costs would be higher in the animal feed industry where there is much greater use of GM product. Cargill plc put the premium here at "something of the order of $25 to $30 on a product whose value is $200".[131]

36. There are several factors which could reduce these on-costs to the consumer. First, there is the degree of tolerance of GM content permitted. The more stringent the requirement, the more expensive the process.[132] Secondly, there is the quantity of the product going through the supply chain in this fashion. Cargill plc pointed out that "if we have a common definition of what is required by the UK industry then we no longer need to talk of premiums and discounts".[133] In other words, if an entire stream is non-GM, there are no additional costs. Thirdly, there is the amount of GM ingredient used in consumer products. Marks and Spencer's experience had shown that "the costs involved with segregation are often irrelevant due to the low rate of inclusion in the final food product".[134] This explains the difference between ice-cream and animal feed in terms of percentage mark-up. Fourth and finally, there is the question of whether any extra cost is passed on to the consumer at all. It is generally assumed by all, including the Minister, that the consumer will bear the costs of segregation.[135] However, this has not been the case so far. The Consumers' Association noted that segregation had been achieved in the food industry "without increasing the price of foods to consumers".[136] It is interesting in this context that Marks and Spencer has chosen to charge a premium for meat from animals raised on non-GM feed.[137] It is at least possible that if non-GM feed comes to be seen as the norm by purchasers of meat, it will prove difficult to maintain higher retail prices in this area as well. We were grateful for an analysis of the cost implications of segregation prepared by PG Economics which concluded that in the medium term additional costs in both animal feed and other non-GM ingredients may be passed down the supply chain, although the authors accepted that it was "difficult to estimate what level or to what extent this may occur".[138] From all the evidence we have received, we conclude that segregation of GM and non-GM crops is possible without incurring excessive costs to the consumer.

Guidelines for the whole chain

37. Any system of identity preservation can only be as reliable as the provision of information along the chain. The SCIMAC guidelines were designed only to address the segregation of GM crops on the farm. Once the crop has passed the farmgate, there is no equivalent bible of regulations to govern its treatment from that point onwards. Several witnesses raised the need for just such a protocol. UKASTA told us it was actively considering how to extend the SCIMAC principles through the marketing and transport of crops, arguing for a 'seamless' operation: "SCIMAC principles start this trend and we feel these must continue through processing and retailing elements if the requirements of consumer information and choice are to be achieved".[139] Further down the food chain, the Food and Drink Federation saw it as "a current priority amongst both manufacturers and retailers to agree a best practice standard for the supply of I-P soya and maize",[140] whilst Marks and Spencer plc urged the need "to establish common standards for effective segregation", especially on tolerances.[141]

38. There are different approaches which could be adopted to this issue. One would be to have "a seamless protocol from 'plough to plate'", as called for by the RICS,[142] presumably overseen by a greatly enlarged SCIMAC-type body to represent all the links in the chain. Another would be a baton-type approach, where each sector passed on information to the next stage but retained its own responsibility for procedures independent of the others. SCIMAC strongly favoured the latter approach, telling us that "we have always regarded it very much as a relay race".[143] It had "continuous dialogue, a continuous exchange of information, with organisations such as the Food and Drink Federation, on the progress of the development of these guidelines and the kind of information that would be presented to them as secondary buyers".[144] However, SCIMAC believed "the bottom line is not to reinvent the wheel but to build on existing systems that work",[145] and it was against extending its own scope beyond the farmgate.

39. Baroness Hayman believed that there was no need for regulation in this area since "a lot of the identity preservation issues throughout the food chain will actually be led by market forces rather than regulatory forces".[146] She doubted that "it would be our responsibility to say the actual process in which someone who makes a claim ensures that it is appropriate".[147] We agree that it is not for the Government to set out statutory requirements in this detail. Nevertheless, we believe that consumer faith in the transparency and effectiveness of the process would be enhanced by a clear chain of command in the baton-passing method so that it could be seen to be both comprehensive and effective and by the drawing up of a Code of Practice available for public scrutiny. We recommend that the Government encourage and facilitate the establishment of an industry forum to examine the options and adopt whichever can be implemented effectively and comprehensively on an international basis.

Conclusion

40. We are persuaded that the industry's past experience in producing certified seed and identity preserved crops will help it deliver products of an acceptable GM or non-GM status. There will be further developments in this rapidly changing area in the near future but we believe that the market is responding to the demands of consumers and of farmers to choose whether or not to buy GM materials. The industry has a responsibility to back up its claims by following clearly-formulated procedures which guarantee full traceability and proof of status. However, this is not beyond the reach of existing systems and we would deplore any attempt to charge premiums to consumers for conventional crops. We recognise that some concerns remain, particularly as regards organic foods where standards are much higher and therefore more difficult to meet. While we have accepted the definition of non-GM elsewhere, we acknowledge that the organic sector is working to 100% GM-free insofar as this definition is attainable.


29  Ev. p. 37. Back

30  Ev. p. 28. Back

31  SCIMAC is "a formal UK grouping of industry organisations representing farmers, plant breeders, the seed trade and biotechnology companies"(Ev. p. 1). Its membership consists of the National Farmers' Union, the British Society of Plant Breeders, British Agrochemicals Association, United Kingdom Agricultural Supply Trade Association and British Sugar Beet Seed Producers Association. Back

32  Ev. p. 1. Back

33  Ev. p. 166. Back

34  Ev. p. 94. Back

35  Q 92. Back

36  e.g. Friends of the Earth, Q 297. Back

37  Ev. p. 70. Back

38  Ev. p. 70. Back

39  Ev. p.38. Back

40  IbidBack

41  Q 218. Back

42  Q 211. Back

43  Qq 236, 237. Back

44  Q 193. Back

45  Q 221; witness's emphasis. Back

46  Ev. p. 37; see also Ev. p. 38. Back

47  Pollen dispersal in the crops Maize, Oil seed rape, Potatoes, Sugar beet and Wheat, National Pollen Research Unit, University College, Worcester, January 2000, p. 2. Back

48  Q 530. Back

49  IbidBack

50  SCIMAC, Guidelines for growing newly developed herbicide tolerant crops, May 1999, p. 6. Back

51  Q 531. Back

52  Ev. p. 2. Back

53  Ev. p. 140. Back

54  IbidBack

55  Ev. p. 138. Back

56  Ev. p. 139. Back

57  Ev. p. 135. Back

58  IbidBack

59  SCIMAC Guidelines, p . 6. Back

60  IbidBack

61  Ev. p. 26. Back

62  Q 36. Back

63  Unprinted evidence. Back

64  Ev. p. 71. Back

65  Ev. p. 71. Back

66  Ev. p. 141. Back

67  Q 61. Back

68  Q 534. Back

69  IbidBack

70  IbidBack

71  Q 538. Back

72  Ev. p. 113. Back

73  Q 380. Back

74  Ev. p. 69. Back

75  Ev. p. 147. Back

76  IbidBack

77  Ev. p. 165. Back

78  IbidBack

79  Q 545. Back

80  Q 547. Back

81  Q 530. Back

82  IbidBack

83  Ev. p. 148. Back

84  Ev. p. 71. Back

85  Ev. pp. 165, 166-7. Back

86  Q 42. Back

87  IbidBack

88  Ev. p. 165. Back

89  Q 50. Back

90  Ev. p. 69. Back

91  Q 297. Back

92  e.g. Q 364. Back

93  Ev. p. 162. Back

94  Q 548. Back

95  Ev. p. 164. Back

96  IbidBack

97  Q 382. Back

98  Q 384. Back

99  Ev. p. 169. Back

100  IbidBack

101  Q 514. Back

102  Q 511. Back

103  Ev. p .29. Back

104  See Ev. p. 61. Back

105  Ev. p. 29. Back

106  Ev. p. 115. Back

107  Ev. p. 151.  Back

108  Ev. p. 115. Back

109  Ev. pp. 28-29; 118-120. Back

110  Q 150. Back

111  Q 154. Back

112  Ev. p. 123. Back

113  Ev. p. 134. Back

114  Ev. p. 56. Back

115  Q 151. Back

116  Ev. 136. Back

117  Q 301. Back

118  Ev. p. 115. Back

119  Q 141. Back

120  Ev. p. 136. Back

121  IbidBack

122  Ev. p. 56; Q 346. Back

123  Ev. pp. 124, 136. Back

124  Ev. p. 14. Back

125  Q 589. Back

126  Q 591. Back

127  Q 96. Back

128  Ev. p. 115. Back

129  Ev. p. 120. Back

130  IbidBack

131  Q 163. Back

132  Ev. p .28. Back

133  Q 165. Back

134  Ev. p. 60. Back

135  Q 498. Back

136  Ev. p. 123. Back

137  Q 325. Back

138  Ev. p. 134. Back

139  Ev. p. 137. Back

140  Ev. p. 134. Back

141  Ev. p. 56. Back

142  Ev. p. 140. Back

143  Q 66. Back

144  Q 65. Back

145  Q 69. Back

146  Q 496. Back

147  Q 552. Back


 
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