APPENDIX 17
Memorandum submitted by the Local Authorities
Coordinating Body on Food and Trading Standards (LACOTS) (R 26)
I refer to your letter dated 3 November 1999
addressed to Nick Cull, seeking LACOTS views on the issue of the
segregation of genetically modified foods. Our comments are set
out below.
GENERAL
To enable consumers to exercise pre-purchase
choice in relation to genetically modified foods it is important
that they can rely on the accuracy of labelling information. It
is essential that foods labelled as "GM Free" or similar
terms are genuinely GM free. It is equally important that foods
which bear no positive declaration but which most consumers would
expect to be "GM Free" also do not contain GM ingredients.
This reflects the general view of one of our parent bodies, the
Local Government Association.
Adequate and effective segregation at all stages
in the cultivation, harvesting, storage, packaging, processing,
distribution and retail chain is obviously vitally important in
ensuring that cross contamination, substitution or adulteration
does not take place thus rendering labelling information wholly
or partly false or misleading.
POINT OF
PRODUCTION
The process of segregation must begin at farm
level with appropriate systems to prevent cross contamination.
If both conventional and GM crops are being grown on the same
farm harvesting and storage processes should prevent contamination.
Harvesting equipment including trailers should be adequately cleaned
between operations involving conventional and GM crops.
Dedicated storage areas should be used so that
conventional and GM crops can be clearly identified and segregated.
Instructions to staff and record keeping requirements for the
movement of harvested crops would be appropriate to ensure that
segregated crops are not accidentally mixed or confused.
Dedicated bulk transporters should be used or
if the same transport is used for both types of commodities it
should be adequately cleaned between consignments.
PROCESSING
At both mills and food production plants practices
and processes which ensure that adequate and effective segregation
of both types of commodities must be in place. Bulk storage or
holding facilities should either be dedicated or if they are used
for both types of commodities should be adequately cleaned between
these different usages. Instructions to staff and record keeping
requirements would be appropriate to ensure that ingredients used
in food processing were not accidentally mixed or confused.
If both conventional and GM ingredients are
being processed using the same production line it is important
that key elements such as conveyor belts, hoppers, mixers, fillers
etc are adequately cleaned between each type of operation.
Procedures should also be in place to ensure
that the appropriate packaging and labelling is applied to the
appropriate products. This is particularly important where two
versions of an identical product (one containing conventional
ingredients and the other containing GM ingredients) are being
produced.
RETAIL
Multiple retailers commissioning "own label"
products from other suppliers should ensure that all the elements
referred to above to ensure the authenticity of products are adopted
by their suppliers. This is particularly important where numerous
suppliers produce the same "own label" product or where
suppliers change frequently based, in particular, on purchase
price considerations.
IDENTIFICATION
Finished products are required to bear a lot
mark to identify a production batch. This information could serve
a useful purpose in ensuring proper segregation and could perhaps
be further refined and extended. Batch marking of commodities
and bulk ingredients prior to packing could also be usefully considered
as part of record keeping arrangements.
CONTAMINATION/TOLERANCES
It is impossible given pollen drift to totally
guarantee the authenticity of all conventionally grown crops if
they are in close proximity to GM varieties. To reflect this the
European Commission will be introducing a 1 per cent tolerance
for accidental inclusion of GM material in conventionally produced
products. LACOTS would wish to see this figure adopted only in
extreme circumstances and not universally applied as this may
undermine strict segregation procedures.
TRACEABILITY
It is important that all the segregation control
identification measures highlighted above are linked so that the
origin of commodities can be verified as well as the final product
labelling. There should be effective traceability throughout the
production and distribution chain.
IMPORTED COMMODITIES/FOODS
Whilst UK food control officers (trading standard
officers and environmental health officers) can exercise control
at all stages in the production and distribution chain for commodities
and foods cultivated and produced in the UK, control is more difficult
in relation to imported commodities and foods.
Much more reliance will need to be placed on
the control systems in place in the country of origin. UK companies
importing such materials will need to be able to demonstrate that
they have taken all reasonable precautions and exercised all due
diligence to ensure that consumers interests are protected.
UK companies can seek assurances from their
suppliers about the authenticity of the products which they are
being supplied with and may wish, as part of this process, to
require guarantees about adequate segregation. In addition to
analytical checks on products carried out by the UK food control
officers, UK companies may wish to consider some form of independent
testing.
26 November 1999
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