APPENDIX 25
Supplementary memorandum submitted by
Marks & Spencer plc (R 38)
Enclosed is the additional information which
the Committee asked us to make available:
1. THRESHOLD
TOLERANCES
Notes on threshold tolerances for the unintentional
presence of GM material describe how the production of maize faces
different kinds of risk at the agricultural level in comparison
to soya.
2. NON GM ANIMAL
FEED
Copies of the labelling / ticketing (not printed)
used to identify meat products derived from animals fed on a non-GM
diet. This is a comparatively small scale trial and we have avoided
high profile promotion—apart from gaining valuable practical
experience, the purpose is to understand better our customers'
reaction to the offer in relation to the impact on selling price.
3. COMMUNICATION
WITH CUSTOMERS
We informed our customers at each phase in the
work to remove GM ingredients from our food products mainly by
means of large tickets displayed in the food section of our stores.
Later this information was communicated by means of advertisements
in magazines, radio broadcasts and our Food & Wine magazine.
The back cover of the magazine contains a glossary
of terms in which we have defined terms such as "genetic
modification" and "non GM". We have consistently
avoided the term "GM free".
7 January 2000
THRESHOLD TOLERANCES FOR THE UNINTENTIONAL
PRESENCE OF GM MATERIAL
1. INTRODUCTION
1.1 Marks & Spencer gave oral evidence
to the House of Commons Agriculture Committee on Tuesday 14 December
1999 and was invited to submit further information concerning
threshold tolerances for the unintentional presence of GM material
in crops such as maize.
1.2 In our original submission, we commented
that, from the perspective of the UK food industry, numerical
tolerances are not essential (para 4.4-4.5 page 7). In particular,
the absence of numerical standards can allow enforcement to keep
in step more easily with technological progress using the "due
diligence" defence to provide the basis for effective enforcement.
Nevertheless, the latest moves to include a numerical standard
have the effect of legitimising the "identity preserved"
approach to the supply of non-GM ingredients and are most welcome.
1.3 This legislation requires demonstrable
efforts to have been made to ensure segregation of non-GM crops
and only then are tolerances permitted for unavoidable contamination
in the supply chain. A single figure for a legal threshold tolerance
covering all GM crops has the attraction of simplicity but in
practice this may not be appropriate. Tolerances must take account
of the differing risks from GM contamination that each crop faces
and need to be established on the basis of what can be achieved
in practice by a well-managed "identity preserved" supply
chain.
2. CURRENT EXPERIENCE
2.1 Soya
2.1.1 At a field level, the main experience
to date of managing the segregation of non-GM supplies is based
on soya. Since this crop is largely self-pollinating, the risk
of GM contamination from crops grown in nearby fields is comparatively
small. The main thrust of agricultural controls to achieve segregation
is to ensure seed stock of high purity supported by disciplines
during harvest and subsequent handling.
2.2 Maize
2.2.1 Maize is usually wind-pollinated and
vulnerable to cross-fertilisation by plants which may be physically
separated by some distance. These risks received attention in
1999 when UK organic farmers expressed their concerns at the proximity
to their own production of GM maize field trials. At present,
it is not known how great the separation from GM crops should
be to maintain a level of contamination below a threshold tolerance
of 1 per cent nor the full range of other factors on which such
a threshold would depend.
2.2.2 There is some parallel experience
not connected with genetic modification which throws light on
these questions in the production of speciality starches from
specific varieties of maize which need to be protected from unintentional
cross-fertilisation. This is discussed in more detail below but
in summary, a tolerance level of up to 5 per cent contamination
due to cross-fertilisation has been adopted by the North American
Industry.
2.2.3 It should be possible to reduce the
tolerance but this requires new measures of control which as yet
have not been fully explored. By analogy, control of unintentional
cross-fertilisaton between any maize variety and GM types would
require a similar approach.
3. MAIZE
3.1 Maize is widely grown in many parts of the
world for food, animal feed and industrial products. Apart from
protein and oil, the principal constituent of the traditional
or Regular Maize is starch (chemical name amylose). Other types
of maize include sweetcorn characterised by its high sugar content.
3.2 Waxy Maize varieties are grown specifically
for their high content of a particular type of starch known as
amylopectin which is valued for its distinct properties as a thickening
agent. Amylopectin is often further processed into a range of
modified starches in order to tailor these properties to meet
precise food processing needs.
3.3 The kernels on the maize cob are individually
fertilised, usually by wind pollination. Waxy maize will also
cross-pollinate quite readily with the regular varieties but then
produces amylose instead of amylopectin starch. It is possible
to find individual kernels on the same cob fertilised either by
regular or waxy maize pollen. In order to retain the functionality
of these speciality food ingredients, it is important to minimise
this cross-pollination and to maintain the segregation of waxy
maize varieties at every stage in growing and processing.
3.4 Waxy maize is normally grown under contract
which will stipulate measures to minimise the risk of unintentional
cross-fertilisation including:
— field perimeter controls to counter
pollen drift;
— controls on crops grown in same field
during the previous 3-5 years;
— control or knowledge of plantings
in adjacent fields;
— taking account of the prevailing
wind direction;
— sowing at time intervals to avoid
pollination windows coinciding with near-by plantings of regular
maize; and
— documentation and controls.
3.5 The impact of cross-pollination between
waxy and regular maize is demonstrated in photograph 1 [not printed]
showing the results of a simple test that can be applied at field
level. Approximately one quarter of the cob is treated with iodine
which stains the individual kernels.
3.6 The kernels coloured black contain amylose
starch and have been cross-fertilised with a regular maize variety.
The majority of kernels in the photograph contain amylopectin
starch and show a red/brown coloration in the absence of amylose.
These kernels were fertilised with pollen from another waxy maize
plant. Approximately 10 per cent of the kernels have been cross-fertilised
with regular maize and place this sample outside the limits of
acceptance of the starch processing industry[11]
3.7 The iodine test is used to estimate
the extent to which a field of wax maize has been penetrated by
pollen from regular maize. This allows controls to be introduced
during harvesting to avoid areas of the field which are likely
to contain excessive levels of amylose-containing plants. An isolation
zone of 5 to 7 rows is usually created around the perimeter of
the field which may be planted with an entirely different crop.
3.8 The starch industry standard tolerates
a level of 5 per cent of regular maize in waxy maize kernels for
processing. This represents a balance between the impact on the
functional properties of the amylopectin starch and the cost to
achieve segregation in the field. No doubt it is possible to achieve
a lower level of cross contamination but at present there is insufficient
experience to set the control requirements or to quantify the
impact on cost.
4. NON GM MAIZE
4.1 Most food ingredients obtained from
maize are produced from European grown raw materials—a region
which is effectively non-GM and at the moment issues of segregation
are comparatively straight-forward.
4.2 Some speciality starches from waxy maize
of particular importance to Marks & Spencer are produced uniquely
in the USA. At present there are no genetically modified varieties
of waxy maize but regular maize varieties are grown in the same
region and this brings the risk of GM contamination through cross
fertilisation.
4.3 Working together with the supply chain,
we have been able to ensure a reliable supply to meet our current
needs of non-GM speciality starches from North America based on
the industry's previous experience of segregating waxy and regular
maize. Additional controls were introduced such as increasing
the extent of the isolation zone at the field perimeter with levels
of regular maize pollination being closely monitored using the
iodine test.
4.4 We are confident that this comparatively
small production volume is within the 1 per cent tolerance level
for GM contamination. However, we do not have sufficient experience
to anticipate how controls would operate to produce non-GM regular
maize varieties grown against a background of significant plantings
of the GM types as already takes place in North America and may
eventually happen in Europe.
4 January 2000
11 To avoid confusion it should be noted that the iodine
test does not detect the presence of GM maize. Back
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