MEMORANDUM SUBMITTED BY THE SUPPLY CHAIN
INITIATIVE ON MODIFIED AGRICULTURAL CROPS (SCIMAC) (R21)
SCIMAC was established in June 1998 to support
the open, responsible and effective introduction of GM crops in
the UK.
SCIMAC represents the UK farms supply chain,
from initial seed stock to harvested crop.
SCIMAC represents the UK farms supply chain,
from initial seed stock to harvested crop.
SCIMAC supports the provision of full and open
consumer information in relation to GM crops and foods, and has
established a robust UK framework for identity preservation of
GM crops up to and including sale of the harvested crop ex-farm.
The SCIMAC system was formally endorsed by Government
in May 1999. It has been welcomed by food processors and manufacturers
as a means of satisfying consumer demands for information about
the use of GMOs in food products.
However, consistent threshold levels within
the food industry to define "GM" and "GM-free"
products must be established as a matter of urgency to ensure
labelling claims and consumer information are meaningful and can
be verified.
1. The Supply Chain Initiative on Modified
Agricultural Crops (SCIMAC) is a formal UK grouping of industry
organisations representing farmers, plant breeders, the seed trade
and biotechnology companies (see Appendix 1 [not printed]). SCIMAC
welcomes the opportunity to submit evidence to the House of Commons
Agriculture Committee inquiry into segregation of GM foods, and
would be pleased to give oral evidence to the Committee if required.
2. SCIMAC membership comprises the National
Farmers Union, British Society of Plant Breeders, British Agrochemicals
Association, UK Agricultural Supply Trade Association and the
British Sugar Beet Seed Producers Association. As such, SCIMAC
represents the entire primary supply chain from initial seed stock
to harvested crop.
3. SCIMAC member organisations share a common
belief that GM crop technology offers benefits for consumers,
the food chain and the environment. They support proper, science-based
regulation of the technology, transparency of information and
responsible stewardship by industry.
4. To this end, SCIMAC has developed an
independently audited stewardship programme for the carefully
managed introduction of GM crops onto UK farms. The core aims
of this initiative, described below, are to provide identity preservation
for GM crops, so allowing consumer choice, and to ensure responsible
adoption of the technology within UK agriculture through best
practice guidelines.
5. In developing this programme, SCIMAC
has not sought to reinvent the wheel, but to build on existing,
proven systems of identity preservation and crop segregation already
in operation within UK agriculture.
6. The SCIMAC stewardship programme, subject
to annual review, has been established well in advance of the
first commercial plantings of GM crop sin the UK, and currently
provides the basis for managing the GM crops involved in the ongoing
programme of Farm-Scale Biodiversity Evaluations.
7. The SCIMAC Code of Practice on the
Introduction of Genetically Modified Crops (Appendix 2 [not
printed]) is centred around the need for openness and provision
of information at each stage in the farm supply chain. It establishes
the premise that meaningful information further along the food
chain—and ultimately to consumers—cannot be provided
without details of the provenance of a GM product or ingredient
from the initial seed stock onwards.
8. The SCIMAC Code of Practice establishes
a consistent, industry-wide framework for identity preservation
up to and including despatch of the harvested crop from the farm.
It specifies that details of GM crops and the nature of the modification
should be communicated by successive information transfer at each
stage in the primary supply chain, for example via seed labels,
product literature, variety guides and post-harvest declaration.
It also establishes the important principle that where harvested
produce of GM and non-GM varieties are mixed, they should be treated
as a GM crop.
9. The Code of Practice provides a framework
to establish principles of good agricultural practice in relation
to GM crops, highlighting the specific management implications
of new traits—such as herbicide tolerance in the first instance.
10. The SCIMAC Guidelines for Growing
Newly Developed Herbicide Tolerant Crops (Appendix 3 [not
printed]) have been drawn up to promote responsible environmental
practice, to maintain the integrity of GM and non-GM crops, and
to optimise the effectiveness of the new technology within a farm-scale
rotation.
11. Specific practical measures to safeguard
the integrity and identity of harvested GM (and non-GM) crops
include:
— Seed storage and planting guidelines—covering
basic requirements to store GM seed separately and to clean down
seed drills before and after planting;
— Crop separation distances—designed
to safeguard the integrity of both GM and non-GM crops, including
registered organic and certified seed crops. The distances specified
in the SCIMAC guidelines draw on experience gained in more than
30 years of growing officially certified seed crops to stringent
levels of varietal purity and identity;
— Harvesting and post-harvest management—specify
requirements to clean down harvesting machinery before and after
use, to minimise seed loss at harvest and to prevent seed spillage
into unplanned areas of the farm;
— On-farm monitoring and record-keeping—are
fundamental to the effectiveness of this system and require farmers
growing GM crops to maintain full details of crop management,
storage and field monitoring throughout the rotation.
12. Application of the SCIMAC stewardship
programme (Appendix 4 [not printed]) will mirror the proven and
robust legal framework for the production of certified seed. This
provides the elements required to ensure compliance, namely:
— Specification of on-farm management
protocols within a contractual agreement
— Provision for routine crop inspection
by the contract-giver
— Provision for third party audit
— Provision for handling non-compliance
or default with the terms of the agreement
13. Formal Government backing for the SCIMAC
stewardship programme was announced in the House of Commons by
the Rt. Hon. Jack Cunningham, Minister for the Cabinet Office,
on 21 May 1999 (Cabinet Office Press Notice CAB 109/99 refers).
14. Furthermore, the SCIMAC initiative has
been welcomed by customers in the food industry.The Food and Drink
Federation—representing UK food processors and manufacturers—issued
the following statement in June 1999:
"FDF welcomes the SCIMAC initiative which
will greatly facilitate the managed introduction of GM crops to
UK agriculture and the provision of associated information along
the food chain to food manufacturers and their customers."
15. SCIMAC fully supports the application
of transparent, science-based regulatory controls on GM technology
in agriculture and food production. No GM crops can be approved
unless they have been rigorously assessed for food, feed and environmental
safety.
16. Once approved on safety grounds, the
requirement for customers to exercise choice in relation to GM
foods should and will be addressed by the market place, not by
statute. Labelling provisions relating to "GM" or "GM-free"
must urgently be clarified, however, to ensure information presented
to consumers is meaningful and consistent.
14th October 1999
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