APPENDIX 13
Memorandum submitted by the Board of United
Kingdom Register of Organic Food Standards (R 17)
BACKGROUND TO
UKROFS' INTEREST
1. The United Kingdom Register of Organic
Food Standards is the body established in 1987 by Agriculture
Ministers as the UK Authority for organically produced foods.
Since the establishment of EC Standards for Organic food and farming
(principally Council Regulation (EEC) No 2092/91 and Council Regulation
(EC) No 1804/1999) it has become the inspection authority for
control of standards for the production of organic food in the
UK.
2. UKROFS has approved six private sector
bodies (Organic Farmers and Growers Ltd, Scottish Organic Producers
Association, Organic Food Federation, Soil Association Certification
Ltd, Bio-Dynamic Agricultural Association and Irish Organic Farmers
and Growers Association) for all aspects of organic production.
In addition it has approved Food Certification (Scotland) Ltd
for organic salmon production. UKROFS itself is also able to register
producers directly, although only 10 producers are registered
under this scheme.
3. The UKROFS Board—see Annex—is
appointed by Agriculture Ministers. There is a small secretariat
supplied by the Ministry of Agriculture, Fisheries and Food.
UKROFS' POSITION
ON USE
OF GM MATERIAL
IN ORGANIC
FARMING
4. As early as 1995 the Board of UKROFS
stated its view that GMOs or their derivatives have no place in
organic production systems. In giving this opinion the Board said
that it was mindful of the potential benefits of gene technology,
but considered that most consumers and producers would, currently,
be opposed to the application of the technology to organically
produced foods.
The UKROFS Standards for organic food production
were amended in 1997 specifically to exclude GM products, or derivatives,
whether as whole organisms, ingredients, processing aids or ingredients
for animal feeds. UKROFS took this decision in advance of EC legislation,
although Regulation 1804/1999 published on 24 August 1999 has
instituted similar EC-wide provisions with immediate effect.
5. The initial provisions in the UKROFS
standards were concerned with the use of GM products or their
derivatives. However, with the introduction of field scale trials
of GM crops and the likely commercialisation of such crops, attention
is now especially focused on the need, which the Board of UKROFS
and the organic industry perceive, to ensure that GM materials
are fully segregated from organic foods at all stages of production.
6. The difficulties of ensuring absolute
segregation of crops were highlighted in the Report produced for
MAFF by the John Innes Centre "Organic Farming and Gene Transfer
From Genetically Modified Crops" (May 1999). The report confirmed
that once released, GM crops, like all crops, cannot be contained
completely and that the complete isolation of organic crops cannot
be guaranteed under present circumstances. The report suggested
that it was necessary for "acceptable levels" of contamination
of organic crops to be decided and measures identified to achieve
them. EC Regulation 1804/1999 also recognises this possibility
and makes provision for the setting of de minimis thresholds
for the presence of GM material in organic products, although
this provision has not yet been used.
7. The Board of UKROFS remain concerned
that many consumers and producers of organic foods have a strong
desire to avoid GM material entirely and for them a minimum acceptable
level would be a betrayal of the organic ideal. The Board believes
that 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, a comparison
which is sometimes made by those outside the organic movement.
8. In farm or horticultural production of
organic crops, the Board identify two particular dangers: the
"pollution" of crops through incorporation in plants
of genetically modified genes by sexual transmission and "contamination"
through the external presence of pollen etc. In addition the Board
identify other routes by which organic farming might be affected,
such as through agricultural inputs (seed, feed etc) or through
modification of soil flora or gut microflora in animals.
9. In the preparation of organic foods,
processors are required by law to ensure that any non organic
materials used (eg processing aids or minor agricultural ingredients
not available organically) are GMO free. This exclusion extends
also to derivatives of GMOs described in Regulation 1804/1999
as "any substance which is either produced from or produced
by GMOs, but does not contain them". It is thus important
that there is clear labelling of all food ingredients derived
from GMOs whether or not they contain the genetic material of
the original organism.
10. The Government has placed much emphasis
on the ability of the industry which produces GM seed to police
the introduction of commercial planting and to ensure adequate
separation between GM crops and other plants, including organic
crops. The Board of UKROFS does not accept that this is an adequate
approach or that the protocol drawn up by SCIMAC (Supply Chain
Initiative on Modified Agricultural Crops) is sufficient to protect
organic production.
11. On 16 July 1999 the Chairman of the
UKROFS Board, Professor Roy Ward wrote to the Minister of Agriculture
Fisheries and Food to ask that Ministers should confirm their
previously stated commitment to protect the right of consumers
to eat organic food. In addition the Board requested discussions
to agree procedures for the approval of field trials of GM crops
and assessment and monitoring of the impact on organic farms of
the field trial programme.
12. The Board called for further research
and assessment of the impact of release of GMOs into the environment
and for a moratorium to be imposed on the commercial planting
of GM crops. The Board emphasised that it was suggesting this
not as a campaigning point, but because it felt that it was impossible
to introduce adequate controls without further information.
13. Whilst MAFF has undertaken to consider
further research and development work on the lines requested by
the Board and to consider the adequacy of arrangements for protecting
organic crops from GM planting, the Minister has replied that
a moratorium would be unnecessary, since there are sufficient
safeguards in place and that there would be legal and other difficulties
in preventing the planting of GM crops which had successfully
negotiated the approval process. The Minister has said that "GM
crops can be introduced in a cautious and carefully controlled
way, ensuring that justified concerns are fully addressed".
RECOMMENDATIONS TO
THE AGRICULTURE
COMMITTEE
14. Despite the Minister's assurances, the
Board of UKROFS believes that justified concerns are not being
met at present. The Board recommends that, pending the outcome
of further research the Committee should:
— reiterate the call for moratorium
on the commercial planting of genetically modified crops;
— call for organic farmers to be compensated
for any loss of organic status resulting from a trial as a condition
of the approval;
— urge the establishment of better
arrangements (already discussed with MAFF) for the assessment
of the likely impact on all organic farms within an agreed radius
of trials of GM crops;
— urge the commencement of further
research (also already discussed with MAFF) on the impact of the
introduction of GMOs on organic farming;
— insist on clear labelling so that
any food or ingredient derived from a GMO is identified whether
or not it contains GM material.
8 October 1999
Annex
UKROFS BOARD MEMBERS—JUNE
1999
Professor Roy Ward. Emeritus Professor of Geography,
University of Hull and former Deputy Vice Chancellor. (Chairman).
Mr John Barnard. Consultant and former senior
Trading Standards Officer, in Norfolk.
Mrs Dorothy Craig, MBE JP. Chairman, Food and
Agriculture Working Party of Consumers in Europe Group.
Jan Deane. Organic Horticulturist and Official
of International Federation of Organic Agricultural Movements.
Mr Robert Duxbury. Product Manager—Organics,
Primary Agriculture Dept., Sainsbury Supermarket Ltd.
Mr Nigel Elgar. Organic Farmer in Powys.
Mr Douglas Gray. Regional Veterinary Manager,
Scottish Agricultural College.
Mr John Hoey. (from December 1999) Organic agricultural
adviser and former organic farmer in Northern Ireland.
Mr Andrew Jedwell. Managing Director, Meridian
Foods Ltd, Corwen, Denbighshire.
Ms Diane McCrea. Consultant in food and consumer
affairs, Commissioner of the Meat and Livestock Commission. Negotiator
for Consumers International at Codex Alimentarius.
Professor John McInerney. Glanely Professor
of Agriculture Policy and Director of the Agricultural Economics
Unit, University of Exeter.
Mrs Charlotte Russell. Organic Farmer in Cornwall.
Mr Charlie Wannop. Organic Farmer, Kirkcudbright.
Mr Lawrence Woodward. Director, Elm Park Research
Centre, Hamstead Marshall, Near Newbury.
Mr Simon Wright. Consultant Food Technologist.
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