Memorandum submitted by The Soil Association
(R25)
1. BACKGROUND
The Soil Association promotes organic farming
as the most sustainable of food production that is also well defined,
in commercial use and supplies food of the highest health and
animal welfare standards. Organic farming is an approach which
avoids the use of synthetic chemicals and outside inputs and instead
harnesses natural processes to promote the natural health of plants
and animals (eg via rotations, fertility building crops, and natural
methods of pest control). The best of old and new knowledge is
used according to these principles. This approach avoids many
of the immediate and long-term problems of conventional agriculture.
The organic movements in Europe are agreed that
GM techniques should not be part of agriculture: they are not
necessary, the release of GMOs into the environment carries too
many risks for all farmers and consumers, and their use is against
the principles of organic production systems.
2. CURRENT REGULATORY
SITUATION
The Soil Association has various concerns with
the current regulatory situation in respect of issues relating
to the segregation of GM foods:
— There is a current presumption by
the Government and influential parts of the industry that genetic
engineering is necessary and can be safe and beneficial. Neither
has been subject to adequate independent assessment or a public
consultation.
— Decisions to accept the importation
of GM foods have been taken without the availability of adequate
data relating to testing for environmental impact and food safety,
and without adequate infrastructure (such as segregation and labelling)
for those who wish to source GM free supplies and to enable consumers
to have a genuine GM free choice of foods.
— The likelihood of genetic contamination
of GM free crops from GM crops is very high, outside the control
of the farmer, and the implications, including economically, are
very significant. But, this is not reflected in the current controls
on the separation of such crops in the UK, which are voluntary
and use distances shown by independent research to be insufficient.
— The above are despite the fact that
Government has said it would respect the right (and request) of
consumers to have the choice of GM free foods, that it would base
its decisions on sound science and that it would ensure a sound
regulatory framework.
3. OBJECTIVES
FOR THE
SEGREGATION OF
GM FOODS
There is no doubt that consumers want a genuine
choice of GM free foods. This choice depends on access to identifiably
GM free foods which depends on segregation and labelling, and
also on adequate supplies of GM free foods. As long as
GM crops are allowed to be grown and GM foods traded, there will
be a need for a system for segregating GM foods from non GM foods
that is trusted, practically robust and does not significantly
hinder the supply of GM free foods (eg through unreasonable costs
incurred for the producers of GM free foods).
The organic movement is committed to the prohibition
on GMOs in organic systems and to ensuring the integrity of organic
foods is maintained in this regard. It is important to the sector
that consumers know and can trust that organic foods are produced
free of GMOs. This is supported by what most consumers believe
the GM status of organic foods is and should be (ie GM free).
To policy makers who are trying to encourage
organic food and farming for all the many other benefits it brings
to individuals and society (environmentally, to health, to health
costs, to securing stronger farming and rural economies etc),
it is important that this commitment from both the movement and
the consumers of organic food is appreciated and upheld. The GM
status of organic foods and therefore the continued growth of
the sector must not be jeopardised by Government policy in this
area but supported.
Segregation at the retail end clearly depends
on segregation at each point in the supply chain including crops
on the farm and agricultural supplies such as feed and seed. The
Soil Association has researched the issues for the segregation
of agricultural crops on farm in depth and this makes up most
of this submission.
4. ORGANIC PRODUCTION
STANDARDS
The EU rules for organic production were revised
this year to "prohibit" GMOs in organic production.
Although the initial avoidance of GM crops and livestock is relatively
simple, there is no guidance on how to avoid unintentional cross
contamination. The Soil Association was the first body to undertake
a detailed analysis (see next section) of how to implement this
new requirement in practice and consider to what extent contamination
from external sources can be avoided.
Based on the findings of our research, in June
this year we produced new Soil Association standards that deal
with GM issues (Annex I). These have also been approved in principle
as the new UK standards for organic production, with only a couple
of minor modifications. Many of the rules in the new standards
deal with excluding the use of GMOs in organic systems, including
a requirement to ensure that biological inputs (manures, feed
etc) do not contain GMOs or their derivatives. There is also a
section dealing with cross contamination from external sources
that would be outside the control of the farmer, ie transfer of
pollen by wind or bees from GMO production sites (2.4.18-2.4.22).
To avoid such contamination, this section requires
that a six mile "notification zone" is established around
all organic holdings so if GM production is planned in that area
a decision on the risk of contamination can be made. We intend
to use a common risk assessment procedure to implement this. A
table (Annex II) shows how we would to take into account the type
of crops being grown and the wind direction. We are awaiting more
information from the National Pollen Research Institute before
completing this.
Currently, if a risk of contamination is established
and the farmer is unable to take steps to avoid it (for example,
a neighbour has planted or insists on planting GM crops) the Soil
Association would have to decertify the farm.
5. CROP SEPARATION
AND THE
RISKS OF
CROSS CONTAMINATION
There are two main factors for the cross-contamination
of non GM crops: first, the rate of cross pollination from GM
pollen, as this would result in a percentage of the harvest and
then increasing proportions of the ensuing crops being GM; secondly,
the amount of pollen of other species landing on the crop and
contaminating an otherwise GM free harvest.
(i) The Transfer of Pollen by Wind
Referring to the separation distances required
in the UK for GM trials, the government had stated that "at
a standard distance of 200 metres between the organic sweetcorn
and the GM [forage] maize the likely cross-pollination frequency
would result in no greater sweetcorn kernel in every 40,000 being
a GM hybrid". The Soil Association commissioned research
from the National Pollen Research Institute (NPRI) on this matter.
The Report ("The Dispersal of Maize Pollen") showed
that actually, in conditions of moderate wind speeds, the cross
pollination rate would be one kernel in 93 (1.08 per cent). Assuming
that a corn on the cob has something like 1,000 kernels, this
would mean that someone eating non GM corn grown at this distance
would on average actually eat 10 GM kernels. We clearly felt that
this was unacceptable for organic food.
Furthermore, this would equally mean that over
one per cent of any farm saved seed and therefore of the following
years supposedly GM free crop would then be GM and without any
separation distances between the GM and GM free plants. Thus,
increasing proportions of the crop each year thereafter would
be GM once contamination occurred. Even where the crop is changed
to another type, there would be the problems of GM "volunteers"
appearing in following years (growth of the previous crop as weeds
in the new crop). Thus, there are severe implications of inadequate
separation controls.
Following our findings, the government undertook
its own research (by the John Innes Centre). This agreed with
the NRPI conclusions that the risks had been underestimated.
According to mathematics, we understand that
increasing the distance by a factor would reduce by the square
of that factor the degree of cross-pollination. Thus, for example,
at 10 kilometres, an increase of x50 over 200m, the degree of
contamination in these conditions for maize would drop to a 2,500th
of 1.08 per cent (0.0004 per cent) ie it seems that the risk of
wind pollination can be avoided by consideration of the risks
within such distances.
For contamination by non-related species, there
is still a risk but the degree of risk would be many orders of
magnitude less than that posed by pollen from related species.
The pollen would be unable to fertilise the plants and produce
a GM crop, so it is just the pollen that landed on the crop that
would be GM, as opposed to whole seeds/kernels. Furthermore we
understand that pollen degrades within a couple of days (maize
pollen, for example, remains viable under normal conditions for
approximately 24 hours).
(ii) The Transfer of Pollen by Bees
Similarly, our research has considered bees.
The relative importance of wind and bees for spreading pollen
will vary according to the plant species. Bees regularly visit
maize flowers and transport maize pollen. For sugar beet, research
in Germany showed that 10 per cent of pollination was caused by
insects.
Bees will regularly travel three miles to find
sources of nectar and pollen if good sources are not available
closer (though they are thought to be able to travel up to 10
miles). On the basis of this information we concluded that there
should not be an organic and GM site in the same three mile radius
around a bee hive, ie, a six mile separation distance for related
species would generally be necessary which fortunately fits well
the findings for avoiding wind cross contamination.
The rates of pollination, weight of pollen grains
and amounts transferred will vary between species, but this research
indicates that the distances that would be required to avoid the
risks are not impractical. Thus adequate minimum separation
distances from GM crops must be used at a UK and preferably
EU and international level. This would be greatly assisted by
an EU or international register of GM production sites.
The NRPI pollen report can be found on the Soil
Association website (www.SoilAssociation.org, under "hotlinks").
We are currently gathering more information from the NPRI.
6. DIFFICULTIES
At the moment, the organic sector is having
to shoulder on its own the complete problem of cross contamination
for the organic sector through its control of the standards to
which organic producers operate and its control over which producers
are certified. This is already not without difficulty and must
be having a negative effect on the sector's attractiveness to
conventional farmers considering converting and thus the ability
of the sector to grow. For example, it is difficult for farmers
to know in advance or be able to influence the siting of trial
sites.
This will become a much greater problem should
the Government proceed to greatly increase the number of trial
sites as it recently announced, or should commercial planting
ever be allowed.
7. PROPOSALS
Ideally, the Government would decide not to
proceed with its trials programme. But in the absence of such
a decision, what is needed from the Government is positive
co-operation with the organic sector through its licensing
procedures. Most basically, we need the Government to inform the
organic certifying bodies of the location of intended trial sites
sufficiently in advance. But preferably, decisions on trial sites
would be made dependent on the absence of risks to any
organic farms.
We have drawn up proposals to integrate these
considerations in the current licensing procedures for GM trials,
based on the idea of the notification zone used in our standards.
These are set out below, and we ask for the Select Committee's
support for these.
PROPOSED CHANGES
TO THE
PROCEDURES FOR
LICENSING GM TRIALS
1. Application for trial approval (site
specific) received by DETR or its licensing agent.
2. UKROFS/organic certifying organisations
informed of location of proposed trial site.
3. Research undertaken to identify any certified
and in-conversion organic farmland lying within a six mile radius
of the proposed trial plot (= "notification zone").
4. Assessment of potential risk of genetic
pollution undertaken using agreed protocols, for all holdings
within the six mile "notification zone"—see Annex
3.
5. Decision reached about holdings (if any)
where pollution risk is established.
6. Information passed back to DETR or licensing
agent.
7. Licensing decision on trial granted or
withheld according to absence or existence of risks established
under 4 and 5.
Notes
A decision will have to be taken on the appropriate
organic sector body to undertake the research outlined in 3.
The protocols would need prior approval by DETR
and its licensing agents.
Costs associated with procedures 3-5 should
be borne by the Government.
(In a scenario of commercial plantings, the
procedure might need adaptation, such as a legal requirement for
the companies concerned to adopt equivalent procedures and to
bear the costs.)
25 November 1999
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