APPENDIX 7
Memorandum submitted by the National Farmers'
Union of England and Wales (G 8)
INTRODUCTION
The NFU would like to note that at this time
of year, when farming activities are at a high level, a deadline
of nine days for response to such an inquiry, presents difficulties
of adequate consultation of our members. Another difficulty is
that to our knowledge the actual reason for the contamination
of the Hyola oilseed rape in the recent incident has not yet been
determined, although it is said to have been caused by cross pollination.
SEPARATION DISTANCES
The separation distances used in the production
of non-GM certified seed do not, or never can, guarantee 100 per
cent purity of the crop. The distances are based upon well understood
principles of pollen dispersal and hybridisation. On a crop by
crop basis these latter processes are characterised in the form
of a leptokurtic curve. When moving away from the plant that is
producing the pollen a point is quickly reached beyond which hybridisation,
which is already extremely low, does not significantly decline
with increasing distance. In practical terms this has allowed
the generation of a set of crop by crop separation distances for
the production of certified seed that over 30 years of experience
have been shown to usually produce a seed purity level in the
order of 99.9 per cent in the case of basic seed.
THE HYOLA
OILSEED RAPE
SITUATION
The NFU is in general satisfied with the separation
distances presently used for certified seed production. However,
there are several potential causes of contamination of certified
seed such as has happened in the case of Hyola oilseed rape. These
are:
— Recommended separation distances
for seed production not used.
— Hybridisation caused by cross-pollination.
— GM volunteers in crop leading to
hybridisation.
— Accidental seed mixing.
— Deliberate contamination of seed.
— Two or more of the above.
(a) Recommended separation distances not
used
The recommended separation distances for seed
production for crops such as Hyola oilseed rape in Canada is 800
metres, and in practice companies usually specify 1,600 metres.
This is considerably more than that recommended for other oilseed
rape varieties. The greater distance is recommended for varieties
that contain a significant proportion of male sterile plants as
these require greater isolation distances than fully fertile crops.
The reason is that each field contains a few male plants. If these
are non-functional, of limited function for some reason (eg extreme
weather conditions that may debilitate or kill them), or the female
plants become fertile before or after the male plants, pollen
from adjacent fields, being the only pollen available, could cause
cross pollination.
(b) Hybridisation
As has already been pointed out, hybridisation
would only occur at a very low level if the presently specified
separation distances for generating the seed had been used. If
the recommended Canadian separation distances of 800 metres still
produce a considerable level of cross pollination they will have
to be reviewed and extended. This will be a matter for the Canadian
authorities. However, seed suppliers should be restrained by EU/UK
regulations that specify an acceptable level for seed "contamination".
(c) Volunteers
It would always be potentially possible for
inadequate destruction of volunteers in a field that is to be
used for seed generation to allow these to grow with the seed
crop and hybridise with it. Of course it would have to be a compatible
variety of the same species. This would be unlikely if appropriate
crop rotation schedules and volunteer control methods are used.
(d) Accidental seed mixing
There have been at least two cases where unauthorised
seed has been provided for growing purposes. One occurred in Canada,
and one in Switzerland/Germany. So human error, which presumably
was the cause of the mixing, can be a cause of seed contamination.
(e) Deliberate contamination
There has been a case in France where non-GM
seed was deliberately contaminated with unauthorised GM seed.
This is another potential cause of the contamination of non-GM
with GM material.
CONCLUSIONS
The NFU is satisfied that the present separation
distances used for certified seed production will produce an acceptable
high level of seed purity assuming that they are properly implemented.
However, the situation with Hyola oilseed rape may lead to the
need for the review of the separation distances required for crops
where there are a significant proportion of male sterile plants.
There are many possible methods that seed can be contaminated.
Some of them are by means of accidental or deliberate human intervention.
12 July 2000
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