Examination of Witnesses (Questions 357
- 379)
TUESDAY 14 DECEMBER 1999
MR PATRICK
HOLDEN
Chairman
357. Mr Holden, welcome. You are an old hand
at this so we will go straight into the questions. Thank you for
coming and for your very useful and detailed evidence, which the
Committee appreciated, and which formed the basis of questioning
already in a previous session. One thing that has come across
in our oral evidence sessions is the degree of tolerance in organic
standards for things like pesticide drift and animal feedstuffs.
Perhaps you could run us through some of the principal thresholds
that you set when you define what organic food actually is.
(Mr Holden) The definition of organic
food is built around a set of principles which result in standards
which define a system of production some of the characteristics
of which are the non-use of certain inputs. The system of production
was never defined by the non-use of the inputs per se.
Rather it was defined by a description of the management of the
system which resulted in the production of high-quality food.
Having said that, there are a number of areas obviously where
the non-use of inputs has been, in part, responsible for the development
of markets. In particular, historically, this is true of the non-used
pesticides. The Soil Association standards were developed well
after pesticides were in common use in conventional agriculture.
Indeed it is well-known that pesticide residues find their way
all over the world including into the fat of penguins in the Antarctic,
etcetera, and therefore it was certainly not possible for us to
describe any product as being "pesticide residue free"
for that reason. However, what our standards and our certification
procedures are committed to is arriving at as close as possible
to a pesticide free status as it is practical to get in an imperfect
world which we inherited from when pesticides came into common
use. The difference in the approach that we have taken in relation
to GM from pesticide residues is that, firstly, our perception
is—and I could come back to that if you ask me further questions
about how we arrived at that perception—that the public
is for GM free foods and the public expectation is for GM free
foods, certainly in relation to organic production. I think the
public wish would be to have the option of GM free foods in the
non-organic sector as well. When we developed our standards in
relation to genetic engineering—and again I could come back
to that process if you wanted me to—we considered that it
was not too late to set standards which were built around the
expectation of GM free, and whilst we do not guarantee that organic
products are GM free, what we do guarantee is that our standards
and inspection systems will go as far as we can to delivering
GM free status within the constraints of the actions of government
and the introduction of GM crops, either imported or grown in
commercial trials or, God forbid, grown commercially in this country.
And we are mindful of the fact that a number of Ministers have
said very publicly that they recognise the right of consumers
to be able to purchase GM free foods if that is their wish.
358. So the bottom line on pesticides is that
there is an imperfect world and you cannot undo that, but on the
GM issue there is a greater possibility of making the world, or
at least the United Kingdom, perfect and that is why the standards
are different?
(Mr Holden) I would put it slightly differently to
that. It seems to us that consumers have a right to expect to
be able to purchase products that they perceive to be free of
contamination by something they do not want and we think it is
incumbent upon the Government to uphold that consumer right of
choice. If they are unable to do this because of genetic pollution
then they have to take measures not to introduce those crops.
359. I have got two questions about the Soil
Association's position. The first is this on livestock: when you
sell organic meat I think a certain amount of non-organic foodstuff
is allowed in the feed of those animals. Is that correct?
(Mr Holden) That is correct.
360. It is quite high, it is about 20 per cent.
(Mr Holden) That is correct.
361. Do you not feel that consumers of organic
foodstuff would be surprised that organic pig meat has been fed
20 per cent non-organic product?
(Mr Holden) No, I do not think so because we have
always been very transparent about the standards. In fact, the
standards are what we consider to be a contract between consumers
and producers. The producers are saying, "Look, we will produce
in this way and guarantee that through our inspection system if
you wish to buy products which are produced that way." I
was involved back in the early 1980s when the livestock standards
were set which included the derogation—because that is really
what it is—for a non-organic percentage of livestock feed
because of the shortage of organic protein sources at that time.
The derogation for the non-organic percentage of livestock feed
is going to be closed, I think in 2003, by the recently published
EU Livestock Regulation. The justification for allowing a non-organic
percentage of livestock feed was when the standards were set that
the consumer would rather have a product which got as close to
as was practically possible to organic status at that time and
then for us to tighten that up, than not to have it at all. Our
perception is, (and we have consulted with the public) that the
difference with GM comes from the fact that genetically modified
organisms are living and therefore once released into the environment
unrecallable, and also because GMOs have not been properly tested
in food products and that is a completely different threshold
from allowing non-organic percentages in livestock feed for a
limited period.
362. I understand that argument but most of
the traits currently being engineered into crops by genetic modification—most,
not all, particularly not the trans-genic traits—are capable
of being bred in by conventional plant technology, and pesticide
resistance and so on can be bred in conventionally. Is it not
the traits that ought to worry you and not the technology? Why
have you not raised the same concerns about the traits engineered
in using conventional plant technology?
(Mr Holden) I am not a geneticist but I have heard
from a number of geneticists including people working in the medical
field that the genetic engineering process involves the implanting
of a gene carrying a trait from the species where the trait comes
from into the parent species and into the genome of the host species
in a random way, and that literally the new gene is fired into
the genome of the host species with a gun. As a result it implants
on the genome in such a way that there are almost always secondary
consequences that cannot be predicted. For that reason alone genetic
engineering is not the same as any conventional form of plant
or animal breeding.
Mr Jack
363. Can I ask a technical question from that.
If as a result of the conventional breeding of an F1 hybrid you
had the same characteristics as the variety which had been produced
by genetic modification, how would you tell the difference in
terms of the seed of one versus the seed of another to guarantee
that what members adhering to your standards put into the ground
was not the subject of genetic manipulation? How would you distinguish
between the two if they are the same?
(Mr Holden) They are not the same and the difference
can be tested in a laboratory. That is the point. Genetically
engineered plant material, even if the genetic characteristics
were the same, would still show up in a laboratory. That is what
I am told.
Chairman
364. You say in your evidence to us that the
whole row about GM cross-contamination must be having an adverse
impact on the organic sector's ability to grow, yet all we hear
is that there is a massive over-subscription to the conversion
schemes of the Government. We had a farmer sitting where you are
sitting now a few weeks back saying she could not get the help
she needed. She was desperate to convert and could not. Are you
overstating the case in saying that there is an adverse impact
on your own sector?
(Mr Holden) Possibly, but I think there is a real
concern here that the impact of genetic pollution on existing,
and aspiring, organic producers could become a major problem.
At the moment we are in negotiation with the DETR and MAFF in
relation to notification zones which will hopefully enable us
to offer more security to organic producers who may be threatened
by genetic pollution particularly from oilseed rape, maize and
sugar beet, which we consider to be the most risky crops. But
it is a worry for both producers and processors to be aware of
the fact that they might be decertified because of genetic pollution
which might have happened through no fault of their own. We are
looking at possible legal channels for what would happen in terms
of liability should such a case arise.
365. Can we turn specifically to the regulatory
framework. We are going to ask you about the issue of segregation,
but looking particularly at regulation you express concerns about
the inadequacy of the regulation of segregation, and you give
a helpful memorandum for us. Could you explain how you think your
concerns might best be addressed, not the mechanics of regulation
but the regulation?
(Mr Holden) The labelling directives—I caught
the tail end of the previous submission from Marks & Spencer's—are
in a way a tacit admission that genetic pollution is inevitable
once commercial cropping goes ahead because if you set a threshold,
whether it is one per cent or 0.1 per cent, in a sense what you
are saying is that one cannot segregate completely and therefore
you have to write in the thresholds. We would say that it is incumbent
upon regulatory agencies to ensure that genetic pollution is avoided.
If that means that through wind and insect-pollinated plants genetic
pollution cannot be avoided then those crops should not be grown.
It is as simple as that. In a world where genetically modified
crops are commercially grown it is very difficult to see any long-term
outcome other than what your previous witness described as GM
pollution becoming ubiquitous.
366. Okay. I can anticipate your answer to my
next question. We heard a seed company saying that it was their
ambition to promote GM foods, non-GM foods and organic foods.
You would say that is impossible, that the two are incompatible?
(Mr Holden) I think if people imagine they will be
able to walk down a supermarket aisle in the early part the 21st
Century and have a world of choice where half of Britain is growing
industrial GM crops and the other half is growing GM free crops
or organic crops and that choice can reliably be maintained by
the food chain, they are deluding themselves. You only have to
look at the threshold regulation legislation which is a recognition,
as I have already said, that pollution is already occurring and
it is going to get worse. I would argue cynically that the thresholds
are a wonderful way of opening the door for commercial cropping
and the higher the thresholds are set the easier it will be for
government to justify that commercial cropping should go ahead.
That is why we have resisted the idea of thresholds because we
think it is effectively "lying back and enjoying it"
rather than recognising and upholding the rights of consumers
to remain GM free.
Chairman: I will move on to Mr Todd.
Mr Todd
367. That is a useful prompt because really
the question is do you think 100 per cent GM free is attainable
now?
(Mr Holden) We are doing our best to offer consumers
a 100 per cent GM free choice through the purchase of organic
foods. We are not seeking to derive market advantage from that
because that was never our intention. Our intention is to get
rid of GMOs throughout the food chain because we do not think
in the long run it will be easy for us to uphold that choice.
We are not going to give up in anticipation of losing that battle.
368. Not quite the answer to my question, however,
because you rightly said that you were doing your best and the
question was is 100 per cent GM free attainable now?
(Mr Holden) Yes, I think that the majority of organic
crops that are on sale are GM free or as near to 100 per cent
as it is practically possible to get. If one is talking about
grains of pollen in the stratosphere which might be landing on
an organic crop, that kind of physical contamination, there may
be some physical contamination of that kind and it is not impossible
that the odd kernel of sweetcorn may be contaminated. All we can
do is use all the means at our disposal to uphold the right of
choice through the testing procedures and the identity preservation
procedures which we have got at our disposal, which is what we
are doing.
369. In a sense you have said the same thing
as the people from Marks & Spencer's said earlier—I
do not know whether you caught that part of their evidence—in
that they really said to use the term "GM free", they
felt, was inaccurate and unhelpful and that all you could do was
use your very best endeavours by choosing the correct seed sources
and then segregating processes as appropriate to produce something
which was non-GM as a deliberate product, but you could not claim
GM free.
(Mr Holden) No, we are not saying that. We are saying
that we do not claim that organic products are GM free, but we
do do everything within our power to maintain GM free status in
our inspection and certification process. We also recognise the
right of licensed producers and processors to market their crops
as GM free. That is their decision and their responsibility. We
would take the view that there are still, if I can put it that
way, crops and processed foods which can legitimately make that
claim.
370. Which ones?
(Mr Holden) I would say the majority of the crops
which are grown in the United Kingdom and many processed foods
as well.
371. Could legitimately claim to be 100 per
cent GM free?
(Mr Holden) Yes, a very large number of them. If you
want to ask me specific questions I will try and answer them,
but yes.
372. You see the point I am making. You made
a considerable point of the slippery slope approach to establishing
thresholds. I am trying to establish with you whether the threshold
has really gone already.
(Mr Holden) I think in North America they are further
down the slippery slope than we are by quite a long way but in
this country because we have only got a limited number of trial
plots, and probably only two of those varieties are pollution
risks at the present time, we are only dealing with imports and
those two forms of genetic pollution and I think that there are
a large number of foods being grown and processed organically
that are able to stand right outside those risks.
373. Obviously partly due to the fact that cross-pollination
could not occur and that the only risk would be contamination
by landing on the product which would then be sold to somebody,
presumably?
(Mr Holden) Cross-pollination could occur between
oilseed rape or maize and sweetcorn produced organically.
Mr Todd: But there are many organic crops where
cross-pollination could not occur.
Chairman: You did mention imports—
Mr Todd
374. I was going to make the distinction that
obviously quite a number of organic producers from outside this
country sell into this country. Indeed, something like 70 per
cent of organic produce consumed in this country does come from
overseas and is claimed to be organic. Do you feel, firstly, that
those claims that those products are GM free are sustainable?
(Mr Holden) You are asking in relation to their GM
free status?
375. Yes.
(Mr Holden) Yes, the majority of them are certainly
sustainable because the same conditions apply to the answer I
have just given in relation to the United Kingdom, namely that
the vast majority of crops being grown globally for organic markets
are not threatened by genetic pollution by related varieties because
those varieties are neither being grown commercially nor trialled.
Where your question becomes more pertinent is in the area of commodity
crops like soya or maize where the organic crop might be grown
within a region where cross-pollination might occur and in terms
of the chain, the identity preservation of the commodity, and
the sourcing of that commodity, there is clearly more risk there.
All I can tell you is what we are doing on two levels. One is
(I think I have already addressed this) that we are doing everything
possible to maintain the GM free integrity of crops in the UK.
We are also working in the standards area through collaboration
with certification bodies in other countries.
Mr Todd: I was going to ask you that question.
The other issue of uncertainty is if the certification in other
countries differed from your own in this respect on whether they
are GM free or not. Is there evidence of significant differences
in the approaches taken by the organic sectors in other exporting
countries?
Chairman
376. I remember the row about the American standards
of course.
(Mr Holden) I will mention that. I will just touch
on one or two issues. The International Federation of Organic
Agricultural Movements took a lead on excluding genetically modified
organisms from organic production altogether as early 1992 and
so that basic framework, which is used around the world for setting
organic standards, excludes GMOs. I understand that there are
some Member States whose Article 14 Committee representatives,
who are their Ministry officials, are actually lobbying the Committee
in favour of thresholds presumably in anticipation of inevitable
genetic pollution, which is a worrying development, but that lobbying
does not necessarily reflect the positions which are taken by
the independent certification organisations in those countries.
In respect of North America I expect you know about the consultation
that received 276,000 responses. I spoke to Dan Glickman about
it and he said it was the largest response that had ever been
received to any consultation document in the history of the United
States.
377. And mankind, I suspect.
(Mr Holden) No doubt. The overwhelming majority of
those were opposed to genetic engineering in organic agriculture.
In relation to the inspection and certification of North American
products, they are facing a nightmare at the moment. They are
using identity preservation and testing procedures to try to preserve
the GM free status of commodity crops like maize and soya. I have
already heard about batches of organic products which have been
contaminated and therefore rendered useless for sale in organic
markets. I gather there are various liability suits pending on
those issues.
Mr Todd
378. So it has highlighted international differences
of angle in your sector and also particular differences in some
individual countries where organic farmers are having a much tougher
time than here?
(Mr Holden) Can I just comment on that. I think this
highlights the issue that the industry as a whole is facing because
there are two possible perspectives you can take on genetic engineering.
Either you can say, as I think was said by the last witness, it
has got to the point where the environment is irreversibly genetically
contaminated, therefore we have got to adopt plan B, as it were,
which is thresholds and the thresholds will move depending on
how great the pollution comes, or you could take the position
(which we believe is the view that most consumers adopt although
they have not been properly consulted, certainly not by governments)
that most consumers believe it is their right to remain GM free
and it is up to their governments to enable them so to do. That
leads into a whole chain of events. I would say the food industry,
which is in an extremely difficult position, has had to adopt
plan B in anticipation of endemic genetic pollution to safeguard
their commercial interests as much as anything else. If they say
that their products are GM free and then somebody proves they
are not, they are in great trouble. We have taken a more difficult
position (plan A)and it has caused us enormous difficulty and
cost where we have gone as far as excluding derivatives of GMOs
and also animal feeds and even animal manures from organic agriculture.
We are carrying the costs of producing those standards and their
policing which we think is a cost that should by borne by the
industry or by government but not by the people who are looking
after the interests of the majority of consumers to remain GM
free. We think that cost issue should be looked at by your Committee.
379. Can I turn to the specific measures you
are seeking to take in the United Kingdom to ensure segregation.
We have already had evidence from other bodies on the appropriate
distances that one should keep GM crops away from non-GM crops
to ensure identity preservation. Your figures, which are very
helpfully attached to your evidence, differ substantially from
the opinions expressed by others. Could you explain that?
(Mr Holden) We have had some research conducted by
the National Pollen Research Unit to try to quantify the extent
of pollen pollution from the GM crops which are being trialled
at the moment. We have already had one submission and just literally
in the last few days we have received a draft of the second research
phase which indicates, as I said earlier, that with oilseed rapes,
maize and sugar beats, the likelihood of pollination occurring
far further than the distances which are incorporated in the SCIMAC
codes is very high. These need to be quantified. We are in discussion,
as I said earlier, with DETR and MAFF on protecting the interests
of organic growers and we will incorporate the results of that
research into our procedures for assessing the risk of pollution
within the six-mile radius that we have set for the notification
zone should MAFF and the DETR accept our proposals for prior notification,
which is what we have asked them to do. Shall I explain what that
means? Prior notification means that we believe it is the responsibility
of the Government or its agencies to notify the organic sector
before any future trial plots are licensed so that we can do some
research based on our research to determine the likelihood of
genetic pollution and advise ACRE accordingly so that the licensing
of trial plots should in future be made taking into account the
interests of organic growers or aspiring organic growers who lie
within a six-mile radius of the plots. Actually, we do not think
that this process should be confined to organic growers but their
interests lie within our regulatory area, as it were.
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