Examination of witnesses (Questions 220
- 239)
TUESDAY 7 DECEMBER 1999
DR PHILIP
DALE and PROFESSOR
ALAN GRAY
220. Although it is, as I understand it from
their evidence, the oilseed rape in particular and maize should
have a six-mile limit.
(Dr Dale) The point is that there is no—
(Professor Gray)—cross pollination, as far as
I am aware, with organic maize.
(Dr Dale) There is hardly any organic oilseed rape.
There is hardly any organic sugar beet. There are certain crops—
221. That is not the point, is it? The fact
that there may not be much there, does not surely mean that they
are not right in saying that they are the recognised distances
which they are stipulating at the moment, which we are looking
at. 1 per cent of agriculture is organic, and it might go up to
a few more per cent in the coming years, but if we are trying
to encourage organic, then surely this is a very, very important
step we are taking at this stage and we have to make sure we get
it right? Either somebody is right and somebody is wrong or there
is confusion.
(Professor Gray) This would be a considerably more
stringent view of the degree of cross-pollination which might
be allowed than is currently allowed for certified seed. When
it came to placing crops on the market and one was faced with
the problem of what distances one would like to advocate in those
situations, because there is so much variation, because of all
the scientific studies which have been done—whether they
are from single fields or large groups of fields—these show
that there is this variation year on year, and what we fell back
on, (I think sensibly), was what was found to be on average actually
happens. What actually happens, if you grow crops at certain distances,
is that you can predict the amount of impurity that you would
get in the seed of one or the other grown perhaps over specific
distances. These have, over the years, become part of the regulatory
system for producing seed of a known purity. So in oilseed rape,
if you want to produce seed of basic and pre-basic standard, so-called
(these are all laid down in the Oilseed and Fibre Regulations,
which farmers have to use if they are growing for seed), you have
to keep them at 400 metres apart and at that distance your seed
is slightly different because here you are dealing with things
coming into your crop and not going out.
222. May I stop you here. Oilseed rape should
be kept 400 metres apart?
(Professor Gray) If you are growing a crop of oilseed
rape to produce seed to sell on the market, guaranteed as a certain
purity, (that is, of basic or pre-basic standard), one of the
rules you have to follow is that there must be a distance of at
least 400 metres between that and the next oilseed rape.
223. This is where the confusion comes in; it
leads to my next question. You referred in your submission to
Levin & Kerster, which found that the average isolation distance
for self-fertilising species to be 300 metres. Now SCIMAC last
week told us that a 200-metre margin is adequate for seed production.
(Professor Gray) Of a different quality. That is seed
of certified seed level, which is not 99.9 per cent but 99.7 per
cent. These are not figures pulled out of the air. They are based
on seed testing stations around the world, whether it is in Boston[1]
where they do these things, or whether it is the OECD. They have
tested the seed and they tell us it works. When you look and see
what is being submitted as being of that standard of purity they
do not get batch failures. It works on average most of the time.
224. You are saying the baseline should be 99.7?
(Professor Gray) I am not saying anything about what
the baseline should be. I am just telling you what are the scientific
targets.
225. The reason why I said that— I am
sorry if I have got it wrong. It is Dr Dale who says 99.7 per
cent purity. I presume you disagree with that? Professor Gray
has just said that he does not think there should be a baseline.
(Professor Gray) No. I said I am not telling you what
the baseline should be.
Chairman
226. That is a commercial issue really.
(Professor Gray) Yes, the issue to do with organic.
Mr Marsden
227. Perhaps you could say what you think it
should be.
(Dr Dale) Isolation distances and procedures depends
on the crop. It depends on the outbreeding, the inbreeding, the
nature of the pollination. All of the criteria are different for
the different crops. In cereals it is 2 metres to achieve whatever
level is chosen.[2]
I think the reason why I suggested this really, as a basis for
discussion, is that there has been a lot of experience of achieving
those kinds of levels. It may be that on a large agricultural
scale it is very difficult and uneconomic to achieve. Maybe one
can achieve higher levels of purity. But let us talk about what
level is appropriate. I think the difficulty with that is that
there is, as Alan Gray has said, no scientific basis for accepting
or rejecting 0.1 per cent and so on. The GM crops have gone through
a regulatory process and have been shown to be acceptable. Many
of these crops have been grown in North America on millions of
hectares. So there is all of that experience.
228. That comes back to my original point about
consumer choice. People out there are very upset and clearly very
anxious: first of all, if they are consumers themselves, about
is it non-GM or is it organic? and, secondly, for organic farmers
out there who are extremely concerned. I have them in my own constituency
who say to me, "We do not want them within six miles. We
agree with the Soil Association." All I am saying is that
it may be very clear in your minds, but I am just a very humble,
ordinary, lay person trying to get to grips with this. What I
am saying is that I am seeing different figures quoted, and I
am obviously trying to get to the bottom of that.
(Dr Dale) Let us talk about the principle of "GM
free". It is virtually impossible to guarantee absolute "GM
freeness" because in some cases seeds are brought in from
abroad, from North American maize. It is quite likely that some
of those, with a very, very low frequency, may have some GM in
them. As has been said, bees could potentially travel a long distance.
We know in oilseed rape that honey bees will transport pollen
for kilometres. If we are talking about absolutes we really cannot
say.
229. Forgive me, but I am not saying that. I
have acknowledged the point you have made. The same point that
Professor Gray has made. What you are both saying though is that
it is appropriate, based on science. What I am saying back to
you is that the Soil Association are saying that it is not appropriate,
based on their science. They obviously quote—this is not
just off the wall—they are quoting the National Pollen Research
Institute, the NPRI, in their evidence.
(Dr Dale) Well—
230. From that reaction I take it, for the record,
that you disagree with the findings of the organisation?
(Dr Dale) No. It is essentially about this principle
of GM free state or not. If you accept the principle that there
may be some pollination of organic crops, then you have accepted
that we are really talking about tolerances. If we are talking
about tolerances, then the debate is: what is a reasonable tolerance?
If we look from the science, there is no reason (from my point
of view anyway) whether it should be 1 per cent or .1 per cent.
If we are talking about the ideology, that is outside of science.
Therefore, I believe that what we are really talking about are
practicalities: what kinds of levels are practical? How can we
nurture organic agriculture? How can we accommodate the other
99 per cent of agriculture? How do we work it together? If you
have a six-mile radius, or whatever it is, then essentially you
have to police a six-mile region around an organic farm. That
would be very, very difficult to achieve in practice.
231. I am glad you have raised this because
you have both acknowledged in your written submissions: you say,
Professor Gray, that "... full segregation on anything but
a regional scale of separation ... can minimise cross-pollination
in the species." Dr Dale, you have acknowledged that effective
isolation is only possible by " ... regional separation of
GM and non-GM crops."
(Professor Gray) That depends on the crop. To qualify
it again, with oilseed rape that would be true. There is not quite
a parallel but there is practical experience in segregating oilseed
rape which has been grown for industrial oils and food consumption.
There is a scheme (I have forgotten its name) which MAFF operates,
in order to ensure that these crops for those two purposes are
grown at sufficient distance, so that the final product gives
less than a 2 per cent contamination, in this case, of the oil
with the high glucosinolates, the erucic acid, the chemical which
you want to keep out of the food that might have come from the
oil. That is what farmers do in that case. That is done with MAFF
approval and you could set up such a scheme. If you wanted to
do the sort of thing you are going to do say that no hybrid was
produced which had a GM mother or father you would have to do
it on a regional scale for oilseed rape.
232. What do you mean by a region? How big is
it?
(Professor Gray) North Lincolnshire.
233. Literally that big?
(Professor Gray) Literally that big.
(Dr Dale) It is not only about pollination. It is
machinery. It is about these volunteers that we are talking about.
234. Professor Gray, you noted that ACRE has
agreed appropriate isolation distances on a case-by-case basis
for small-scale research and development releases of GM crops.
How should isolation distances for commercial planting be determined?
Obviously you have differing views that have been submitted to
us on this one.
(Professor Gray) As I say, I do not think the issue
about the organic versus the scientific reasons is straightforward.
You can apply science to it but in the end a decision has to be
based, as Philip Dale was saying, on questions of choice, and
belief about whether the gene is safe or not. Explicit in the
consent to place on the market, by all the regulatory committees
around Europe who have looked at it—indeed, in those countries
where it is grown on a large scale—is the scientific view
that, for example, herbicide tolerant genes are not sui generis
unsafe. However, it is not unsafe if you have these. Of their
own right they are not unsafe.
235. Sui generis?
(Professor Gray) I do apologise. It is in my note.
They are not of their own right unsafe. A plant containing that
gene, if you eat the seed from it or a product derived from it,
it has a low risk or effectively zero risk. What we do in trying
to assess the risk is to look at the hazard. What could happen
if that gene got somewhere you did not want it? That is so much
part of the regulatory process. If it was a gene one was worried
about; if it had allergenic properties; if you thought it was
a gene that could cause those sorts of problems; if it was a gene
that could produce a toxic protein; if it was a gene that, for
some reason, you had some anxiety about it being out in the environment;
you would not put it into oilseed rape. You would not do that.
You would have to grow it under containment. So in the risk assessment—and,
indeed, for the consent to place on the market—explicitly
is the view that this gene is, in environmental terms and human
health terms, safe. Now what has happened, in effect, is that
we have gone on to look at other aspects of growing these things
in farm-scale trials, so there has been a de facto hiatus
here between saying things are safe, and saying: what is its impact
on the environment? This is a very new process that we are going
through. From the point of separating the individual crops that
are grown either organically or not, it would very much depend
on the crop; and you do have a good chance of isolating, for example,
organic sweetcorn from GM corn.
Mr Curry
236. Picking up from Paul, you can see why we
are confused. Your own paper is very helpful. First of all, you
say you have got to have a regional scale for full segregation.
You then quote a French paper which says that at 65 metres you
get 0.01 degree of purity, which at 99.9 per cent is, you say,
right at the top end. Then we have the Tayside experiment, which
says that over time there will be transfers. Are the scientists
able to come up with a Code Napoleon of all of this, so
that we all know what we are talking about for what product? Everybody
talks about different distances but when we get into it, it depends
whether it is this product or that product or for this purpose
or that purpose. We just end up with an incredibly confusing spectrum
of conflicting scientific advice. At the end of the day we all
wonder whether the numbers are pulled out of the air in any case.
(Dr Dale) If I can answer that. The point we are trying
to make is that there is an enormous experience of growing high
genetic purity seeds, certified seeds that are sold to farmers.
There are statutory requirements to follow certain isolation distances,
the handling of the seeds and so on, to maintain high purity.
I am not saying that this should be the be-all and end-all of
this, but this is a useful experience upon which we can draw.
There are all kinds of levels of purity which those procedures
can provide. That is a useful baseline for debating what is essentially
our ideological view about what is acceptable, what levels of
tolerance should be accepted.
237. So you could, in fact, produce a Code
Napoleon so we all knew where we stood pretty well, which
would represent best science at the time, which is all we could
ever do.
(Professor Gray) What we are saying is that this is
pretty well there anyway in terms of the practical experience
of producing seed. It is a very good guide to help us know what
happens on average.
238. You could say—and you will see the
relevance of this question—that there is an argument as
to whether GM is merely the continuation of science by other means,
if you see what I mean. This is just simply doing it in a different
way from what has always be done. What is all the fuss about?
This is against others who say, "Hang on, this is something
really new. This is seriously new and we have to re-think from
scratch." Where does your argument lie?
(Dr Dale) If you follow the development of plant breeding
from the beginning of the century, essentially it started in the
1920s. Then it was just straight pollination, essentially Mendel's
procedures. There was the development of mutation breeding where
you take a bag of seeds, hit them with a chemical mutagen, and
there was wide hybridisation when quite distantly related plant
species were hybridised, where various techniques were used to
achieve that. There has been a progression. This is part of that
progression. Now each one has novel features. We could, 30 years
ago, have been debating that mutagenesis was completely unpredictable,
with no idea of what kinds of products it would provide. We have
developed selection and evaluation procedures. This is a step
forward and it is an important one in that we can introduce genes
from very different kinds of organisms, but we ask the same sort
of questions of those as we do of conventionally bred ones. We
are concerned about toxins and allergens, they are all there in
conventional breedings.
239. The fact that you can change a gene from
a fish into a vegetable, that in your view is not something that
is different?
(Dr Dale) It is different in the sense that we need
to ask some different questions. It defines the questions that
we ask in that risk assessment.
(Professor Gray) This is what most people recognise
it as being—and I agree with everything that Philip has
said—and this is in many ways an extension of the process
of plant breeding if we are applying it to crops. In some ways
it is much more precise than shuffling lots of genes, but I think
what everybody recognises, and the reason why this technology
is regulated around the world, is that it does open the possibility
of introducing genes from organisms which would normally not cross-pollinate
or hybridise with the organism concerned. That is why it is regulated
and that is why it has to be looked at carefully. You can take
genes from bacteria and put them into plants, you can take genes
from plants that are not compatible and put them into plants and,
as you say, if you really wanted to, you could take genes from
fish and put them into strawberries. That is why there is concern.
That is why scientists have said, "Hang on a minute. Let's
think about this. It has to be regulated."
Mr Curry: Thank you, that is helpful. Is it
also your view that in a sense we are chasing a red herring here?
In talking about how you get complete segregation so you can get
the assurance of a product that is absolutely clean, is that not
a red herring? Bernie Grant told the House a few weeks ago that
we all had black blood in us. In that sense should we be focusing
on an acceptable level of tolerances—
Chairman: You are getting into Mr Todd's questions.
Mr Todd: They have already been well-tilled!
Mr Curry: Let me ask it and Mr Todd can have
mine, if you like! It is important that we do not go chasing after
the wrong thing. We had the traders here saying that 99 per cent
was pretty reasonable. We have had 99.7 and 99.9 floating across
the firmament.
Chairman: Before you answer Mr Curry, can I
bring Mr Todd in.
Mr Curry: Let me finish my question. The question
is what is the sensible place to direct our concerns in this area
and what is the right question to be seeking to answer? Have we
been asking ourselves the wrong question?
Chairman: The right question is the answer to
Mr Todd's question.
1 Note by Witness: ie, the National Institute
of Agricultural Botany. Back
2 Note by Witness: ie, certified seed genetic purity standard. Back
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