APPENDIX 8
Memorandum submitted by the United Kingdom
Agricultural Supply Trade Association (UKASTA) (G 9)
UKASTA represents over 300 companies involved
in compound animal feed manufacture, the supply of agricultural
inputs, such as seeds, fertilisers and agrochemicals, to farmers
and the marketing of combinable crops on farmers' behalf. The
annual turnover of members' businesses is in excess of £5
billion annually.
UKASTA welcomes the decision of the Committee
to hold this short inquiry, especially following the detection
by Advanta Seeds of genetically modified rapeseed in supplies
of conventional rapeseed sold in the UK. The case has highlighted
an area which has been of wider concern to those within the industry
for some time and it is an issue our European bodies have sought
to move forward in discussions with the Commission.
The incident has however produced a series of
what might only be described as "knee-jerk" reactions
by legislators and our concern is that we are now to be pushed
down a road which will be extremely costly for the seed supply
industry but which may do little, if anything, to address the
real issues, or indeed provide any greater degree of information
or choice for the final consumer.
The question of a possible GM presence in non-GM
seed supplies was raised in a European industry context during
1999 and at a meeting in October last year it was agreed that
the maize industry would introduce a 1 per cent threshold for
the sale of non-GM seed in response to movement by maize seed
consumers, particularly in France. In November last year a meeting
was held with Commission representatives to discuss the situation
and reference to the need for community wide action was indicated
in the Annexes to the Commission White Paper on Food Safety which
was issued earlier this year.
As a result of the White Paper the Commission
is looking to introduce regulatory measures to address the situation
and has now suggested that these measures could be in place later
this year, a time period which history might suggest is not going
to be feasible. In the interim it is intended that a plan for
co-ordinated and harmonised (voluntary) action be introduced.
The most important point relating to this intended interim action
is that a threshold of 0.5 per cent be established where a GM
content of an approved consent, under Directive 90/220/EEC, is
detected.
We believe that the reasoning behind the desire
for such action is flawed and most importantly, at this present
moment, the industry does not have the scientific tools at its
disposal to meet a threshold at the level being proposed. Our
concerns cover two specific areas: that the process of elimination
to determine presence or absence of all approved constructs will
create severe logistical problems for the industry; and that there
is no validated methodology for the assessment of GM content,
certainly at a quantitative level below 5 per cent.
There are a number of techniques used to determine
the presence or absence of modified material in a sample but most
relate to Polymerase Chain Reaction (PCR) forms of determination.
Whilst multiple tests can be done the method is, in effect, a
process of elimination. Given that the EU approval process remains
in a suspended state the number of constructs to be eliminated
is not becoming any less when viewed against the global progress
of the technology.
If the intention is that all seed lots are subject
to this testing process then not only would the costs involved
prove to be prohibitive for all but the very largest of companies,
there would also be the time implications for crops such as winter
sown oilseed rape which require a rapid turn-round between harvest
and re-sowing.
The continued viability of small and medium
sized enterprises in the seed production area is a real matter
for concern and one which we trust the Committee will give appropriate
consideration to in any recommendations it may wish to put forward
as a result of this inquiry.
The recent events with spring oilseed rape have
brought to the fore issues of methodology. Whilst there are efforts
within the EU to produce standardised methodology for GM testing
procedures, a resolution remains some way off. Results from ring
tests carried out both in this country and within the EU suggest
that at this moment in time there is not an acceptable level of
accuracy in testing, particularly on a repeatable basis and at
levels down as low as 0.5 per cent. With that in mind we remain
very concerned at what the Commission and others may be wishing
to see introduced as a political fix, irrespective of whether
or not it is deliverable in terms of scientific reality.
We trust this brief memorandum is of use in
highlighting some of the areas of concern thrown up by recent
events.
10 July 2000
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