APPENDIX 10
Memorandum submitted by the National Farmers'
Union of England and Wales (R 14)
1. INTRODUCTION
The National Farmers' Union (NFU), in association
with the British Society of Plant Breeders (BSPB) and the United
Kingdom Agricultural Supply Trade Association (UKASTA), released
two complementary codes of practice in April 1997 (see revised
versions, Appendix 1 and 2 [not printed]). Both codes laid out
guidelines that were intended to ensure traceability for individual
UK consignments of genetically modified (GM) crop varieties. This
was to be done via a seed package identifier plus accompanying
information, appropriate on-farm record keeping, segregation,
and post-harvest documentation that should accompany each crop
consignment. These procedures were designed to ultimately allow
foods that contain material derived from GM crops to be labelled
to ensure consumer choice. These codes were produced well in advance
of the commercial growing of GM crops in the UK, which at the
time of preparing this submission is still not occurring.
In response to a consultation process on GM
herbicide tolerant crops that was initiated by MAFF in the summer
of 1997, the group that had produced the two codes of practice
re-convened. On this occasion five groups were able to agree on
a submission to MAFF. These were the NFU, BSPB, UKASTA, the British
Agrochemical Association (BAA), and the British Sugar Beet Seed
Producers Association (BSBSPA). As a result of the degree of cooperation
that had proved possible, it was decided that the informal group
should be constituted into a more formal body. As a consequence
the Supply Chain Initiative on Modified Agricultural Crops (SCIMAC)
was formally launched in July 1998, with the five member groups
being those who had submitted the joint statement to MAFF. This
new body has proved to be an effective one and it has produced
a set of guidelines for growing newly developed herbicide tolerant
crops (Appendix 3 [not printed]).
2. THE SCIMAC
HERBICIDE TOLERANT
CROPS GUIDELINES
The SCIMAC guidelines, code of practice, and
associated documents, were developed to ensure that farmers and
growers grew GM crops in a responsible manner. These documents
were endorsed by government in May this year. They are now being
used as a means of controlling the growing of herbicide tolerant
GM crops in the government-sponsored field-scale trials. The processes
outlined in the guidelines were derived from well established
practices that have been used for many years to grow crop varieties
for certified seed production. A comparison of the SCIMAC guidelines
with the appended MAFF guidance notes for growers of seed crops
in England and Wales show that there are many similarities in
the procedures outlined in the two documents (Appendix 4 [not
printed]). For example, the requirement for isolation distances,
the provision of appropriate information, etc, are common to both.
Also the need to physically separate the produced seed (ie segregation)
to provide a clearly identified product (identity preservation)
is a clear requirement.
3. OTHER CROPS
THAT REQUIRE
SEGREGATION/IDENTITY
PRESERVATION
Another type of crop that has to be separated
from other varieties is one that produces a specialised oil. In
the UK this presently means a high erucic acid variety of oilseed
rape (HEAR). For this crop, and to protect certified Brassica
seed crops in the area, a zoning system has been set up in North
Essex to try to ensure that contamination is unlikely to occur
(see Appendix 5 [not printed] for details of the scheme).
4. SEGREGATION/IDENTITY
PRESERVATION
The two examples that have been given show that
UK farmers already have experience of segregation and identity
preservation. There are several reasons why segregation and identity
preservation may be required. These are as follows:
— Consumers demand choice and the only
way that they can be given it is by a process of segregation/identity
preservation. For example, consumers may be unwilling to eat foods
that contain genetically modified (GM) ingredients, and so GM
food will need to be labelled. Other consumers may have ethical
reasons why they do not wish to eat certain products (eg animal
products if one is a vegetarian, various religious taboos).
— A crop may be grown because of its
increased value (eg one for certified seed purposes, a crop producing
a specialised oil, a GM crops with specialised qualities). To
maintain this increased value separation of the produce is required.
— A crop could be grown that would
be hazardous if the products of it were eaten by humans or livestock
(eg a crop designed to produce industrial chemicals, pharmaceutical
products, etc). Such crops would generally have to be grown in
confinement. However, again the harvested crop will need to be
separated from other non-modified varieties.
5. REQUIREMENTS
FOR SEGREGATION/IDENTITY
PRESERVATION
There are a range of requirements that need
to be put in place for the establishment and maintenance of segregation/identity
preservation. However, it should be noted that not all farmers
and growers are presently suitably equipped to carry out these
processes. It should also be noted that a failure to maintain
appropriate standards at any stage could lead to a breakdown of
segregation/identity preservation. Note that the degree of effort
required to produce segregation/identity preservation will depend
on the degree of purity that is defined in the contract between
farmer/grower, and the company to which he/she supplies the harvested
product. This may be further complicated by any legal requirements
that may be in place at the time. The requirements are as follows:
— The purity of the initial seed is
essential. The development of new crop varieties has to take place
under very controlled conditions. For example it is common practice
to maintain a cordon sanitaire around the crop being developed
to reduce the likelihood of cross-pollination with adjacent crops.
This distance is generally recognised as being sufficient to attain
a seed purity level of at least 99 per cent. As with plant breeding,
the crop to be used for seed multiplication has to be separated
from adjacent crops to attain a high level of purity.
— When available to the farmer the
seed variety has to be clearly identified by a seed package identifier.
This identifier needs to be supported by more extensive information.
This would include information on the nature of any genetic modification,
and advice on good farm management practice for that particular
seed variety. An information helpline, or another means of accessing
additional agronomic advice should be provided by the seed supplier.
— It is important that each crop be
clearly identified by variety at all stages of production, from
initial seed stock, through planting, to harvesting and storage.
Detailed accurate records of plantings and other information need
to be kept.
— Uncontaminated planting equipment
needs to be used. Pre-treatment of the field to be planted is
necessary if a different variety was grown in it over the previous
growing season. Agronomic advice on this should be available.
— To minimise the likelihood of cross-pollination,
agreed separation distances between the GM crop and adjacent ones
must be put in place. These distances are outlined in the SCIMAC
guidelines for several herbicide tolerant crops (see Appendix
3 [not printed]).
— It is important that the harvesting
process does not cause contamination of the favoured crop. For
example, the harvesting machinery must be thoroughly cleaned before
use. The farm machinery used to transport the harvested crop also
needs to be cleaned. Care must also be taken to make sure that
GM seeds are not split on transport to avoid the possibility of
the contamination of non-GM crops. The on-farm storage bins must
be cleaned before the harvested crop is put into them.
— The equipment and processes used
need to be independently audited to ensure that the requirements
are carried out.
— To maintain identity preservation
throughout the food chain similar care to that taken on the farm
will need to be taken at all levels of the chain.
6. COSTS OF
SEGREGATION/IDENTITY
PRESERVATION
It should be noted that because of the procedures
required for the attainment of segregation/identity preservation,
there will inevitably be extra costs involved. For example, the
extra land area required because of the separation distances needed
to grow GM crops will have to be factored into the eventual costs
of the harvested product. In the same way, the extra care required
for growing GM crops will add labour costs to the endeavour. Consequently,
this process is only practical if there is a significant agronomic
and/or cost advantage over and above the growing of traditional
varieties of the crop in question. The two examples given earlier
in this document are ones where this has been the case. The economics
of identity preservation of GM crops have been studied in a detailed
report (Buckwell et al, 1999) and a similar conclusion
has been drawn.
7. CONCLUSIONS
The use of segregation to produce and identity
preserved agricultural or horticultural product is already commonplace
for the production of certified seed. Similar processes can be
used for GM crops. However, it should be noted that there is a
cost involved in such a process.
8 October 1999
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