APPENDIX 21
Supplementary memorandum submitted by
Dr Philip Dale, John Innes Centre (R 34)
Following further consideration of the subject,
I would like to make the following points:
1. GM crops must pass through a rigorous
scientific risk assessment before they are accepted for commercial
production. Once approved, they are considered to be as safe as
conventionally bred varieties for use in agriculture and for food.
2. It follows from this 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. In the future, pollination
between certain non-food GM crops (eg for industrial processing
or biodiesel) and food crops, may need to be minimised by growing
under special conditions for reasons of safety. This is already
the case for certain conventionally bred industrial crops (eg
high erucic acid crop varieties of oilseed rape for lubricant
production).
3. The debate about GM and non-GM crop segregation
is principally about finding a mechanism to provide maximum choice.
This is choice for consumers to buy GM or non-GM foods, for farmers
to grow GM and non-GM crops and for society to benefit from future
advances in biotechnology.
4. There are various ways in which GM and
non-GM crops can become mixed, including volunteer seeds growing
in crops, pollination between crops and seed mixing at sowing,
harvesting, handling and storage.
5. For any field grown crops, it is virtually
impossible completely to prevent some mixing between GM and non-GM
crops.
6. The issue of segregation is essentially
a matter of finding a compromise between the level of mixing acceptable
to the consumer and the level achievable in agricultural practice
at an acceptable cost.
7. In order to determine what seed purity
is practical in agriculture, it is relevant to draw on the statutory
procedures laid down for the production of high quality Breeders
or Certified seeds used for sowing by farmers. There have been
many decades of experience of crop isolation distances to minimise
pollination, and of seed handling procedures to maximise the genetic
purity of seed samples. The levels of purity achieved for Certified
Seeds in cereal crops (wheat, barley and oats) is 99.7 per cent.
The genetic purity achieved for higher quality Breeders Seed is
99.9 per cent.
8. The level of tolerance of GM plant material
in a non-GM sample that is practical is within the range 0.1-2.0
per cent. The presence of GM plant material at 0.1 per cent (one
GM seed in 1000 non-GM seeds) is near the limits of routine analytical
detection. If GM material is below the limits of analytical detection,
mixing cannot be verified. The lower the tolerance level that
is accepted the higher the cost of crop and food production.
9. 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. 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.
17 December 1999
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