Memorandum submitted by SCIMAC (D2)
1. SCIMAC view
of the current state of the public debate on GM crops and foods,
and whether the Government is taking enough of a role in promoting
and moving the debate forward.
As the vehicle for presenting and mirroring
the public debate, much of the media hysteria which surrounded
the issue two or three years ago appears to have subsided. If
media interest can be taken as a barometer of controversy or public
concern, successive announcements of each new round of plantings
with the Farm-Scale Evaluations have attracted less and less media
attention, particularly at a national level.
From a regulatory perspective, public debate
and consultation continues on a number of fronts—in relation
to the implementation of new EU rules for the approval of GMOs
for environmental release, for example, as well as future requirements
for seed purity and the traceability and labelling of GM products.
In SCIMAC's view, the Government does have an
important role within that debate which it must not neglect. Clearly,
issues of public and consumer attitudes towards GM crops and foods
are the preserve of commercial and market forces, not the responsibility
or concern of regulators.
It is, however, the responsibility of Government
to provide clear, transparent and unequivocal public information
about the regulatory processes, and to ensure the public communication
of risk, whether in relation to human health, food, feed or environmental
safety is accurate and proportionate. This is imperative to strengthen
public confidence in the regulations which address these issues,
and the science behind them.
2. Whether public opinion has moved on since
the Committee last considered the issue in 1999-2000—are
people more willing to accept GM foods and crops?
Certainly one can point to recent public opinion
surveys which suggest that public hostility towards GM foods and
crops is not as universal as it is often portrayed.
Earlier this year, the Food Standards Agency
reported in the findings of its second annual consumer attitudes
survey that:
"In 2001, there were significant drops in
the level of concern over the safety of eggs (from 26 per cent
in 2000 to 21 per cent in 2001), dairy products (30 per cent in
2000 to 25 per cent in 2001), and foods with genetically modified
ingredients (27 per cent in 2000 to 21 per cent in 2001)."
An NOP survey conducted for CropGen in Spring
2001 suggested that 48 per cent of consumers would eat food if
they knew it was GM or contained GM ingredients, against 44 per
cent who would not and 8 per cent don't knows.
The recently established agricultural biotechnology
council also commissioned research which showed that more than
half of people surveyed would be more likely to accept GM foods
and crops if, for example, the technology resulted in more targeted
use of pesticides, if the products were clearly labelled, and
if GM crops supported environmental benefits, such as an increase
in farmland bird populations. But the overwhelming conclusion
of the abc research was the public's need and desire to be better
informed. Two-thirds of people felt they did not know enough about
GM foods.
From SCIMAC's perspective, however, perhaps
the most immediate way to gauge the development in public attitudes
is through the local response to individual trial sites. It is
important to set the relatively small number of sites which have
encountered local protest and opposition into context against
the vast majority of trial sites which have proceeded smoothly,
often with significant local support. Requests for public meetings
in the wake of successive rounds of plantings have certainly fallen
since the first year of the trials. This year one Parish Council
even took the trouble to write to their local MP to express their
support for the trials. And at a Parish Council meeting just last
night (Monday 15 April) at Frampton Cotterell in South Gloucestershire,
parishioners voted in favour of the trial.
These are clearly anecdotal examples, but do
suggest that the temperature may be coming out of the debate,
certainly in relation to the trials themselves.
3. AEBC report "Crops on Trial"
described the Farm-Scale Evaluations as a "cooling off"
period—do you agree?
Neither agree nor disagree. We would view it
in different terms. The Farm-Scale Evaluations are an important
programme of ecological research in which industry has voluntarily
put its technology out to independent scientific scrutiny—over
and above any regulatory requirements. No other agricultural technology
has ever undergone such a comprehensive programme of testing and
evaluation, and SCIMAC's overriding objective within that process
is to ensure the successful completion of the research.
The agreement between SCIMAC and Government
which established the basis for the Farm-Scale Evaluations is
a measure not only of the industry's confidence in the technology,
but also its commitment to ensuring the public is able to make
informed judgements, based on independent scientific information.
If that process has brought about any constructive change in the
level or nature of the public debate during the period of the
Farm-Scale Evaluations, then clearly it is welcome, but as a consequence
rather than as an objective of the programme.
4. Question regarding alleged contamination
of non-GM crops
SCIMAC is not aware of any incidents in which
the non-GM status of neighbouring crops, whether organic, seed
or other, has been compromised as a result of the farm-scale evaluations.
This is a measure of the precautionary and scientific basis on
which the SCIMAC approach has been developed, combining practical
experience and evidence of worst case scenarios as a benchmark
to reduce any potential cross-pollination to an absolute minimum
within a practical farming situation.
As the Committee advised in its last report,
we will continue to be responsive to new scientific evidence and
information in developing the Code—indeed since the Committee's
previous inquiry SCIMAC has agreed two minor changes to the separation
distances, in the case of forage maize which has been increased
from 50 to 80 metres, and between GM oilseed rape and neighbouring
crops of Varietal Associations and partially restored hybrids,
which has been increased from 50 metres to 100 metres. Both changes
were based on the scientific review conducted by NIAB and published
in August 2000.
5. What is the SCIMAC response to the recent
English Nature report on gene-stacking in Canada and EN's suggestion
that the SCIMAC guidelines are inadequate to prevent gene-stacking
in the UK?
This is an interesting question, given the apparent
discrepancy between the EN press release announcing the report:
"Our report shows that the SCIMAC code is
probably inadequate to prevent gene-stacking happening in Britain,
if these crops were commercialised."
and the relevant passages in the report itself:
"UK organisation SCIMAC have issued guidelines
that address the specific on-farm issues raised in relation to
HT crops. . ."
"The SCIMAC guidelines include separating
a HT crop from other oilseed rape crops by at least 50 metres.
Both UK gene flow data and Canadian experience suggest that this
would be effective in reducing significantly the occurrence of
gene flow to other canola crops that are not varietal associations
or possible partially restored hybrids, and perhaps both the practicalities
and the data suggest that there is little benefit in aiming for
a greater separation distance."
It is puzzling that English Nature have chosen
to highlight Canadian research when English Nature themselves
repeatedly argued that the different agricultural, climatic and
geographical conditions in other parts of the world could not
be used to inform decisions about the impact of growing GM crops
in the UK. Indeed the unique FSE trials were set up in response
to English Nature's concerns to assess biodiversity impact in
a specific UK context.
Within the SCIMAC guidelines, action to address
any potential problems in controlling volunteers is not just covered
through the application of separation distances, but comprises
a package of measures from pre-harvesting measures to optimise
evenness of maturity, harvesting procedures, post-harvest cultivation,
as well as volunteer monitoring and control throughout the rotation.
SCIMAC is confident, and the English Nature
report appears to confirm, that the combination of these measures
will prove effective in controlling the incidence of volunteers
and minimising the potential for "gene-stacking".
It is also worth noting that no GM crops have
yet been fully cleared for commercial cultivation in the UK. The
potential development of multiple herbicide tolerance, or gene-stacking,
is an issue considered in detail by the regulatory authorities,
who will not approve GM crops for commercial cultivation unless
satisfied that there will be no adverse effects on the environment.
English Nature is a statutory consultee in that process.
All non-GM crops currently grown commercially
are tolerant to a large number of herbicides. GMHT adds one more
to the list—it does not make the GM crop resistant to alternative
herbicides or methods of weed control. Volunteers of GMHT rape
will continue to be as susceptible to conventional methods of
weed control—cultural, mechanical and chemical—as
conventional varieties.
A 10 year study of research conducted by scientists
at Imperial College, published last year, effectively dismissed
concerns over the development of so-called GM superweeds, concluding
that these crops were no more likely to survive or persist than
their conventionally-bred equivalents. A similar conclusion was
reached in a 1999 review of the environmental risks associated
with herbicide tolerant GM oilseed rape commissioned by the former-DETR.
6. SCIMAC response to Nature article about
GM contamination of landrace maize varieties in Mexico.
SCIMAC can add little to the recent conclusions
of the Advisory Committee on Releases to the Environment which,
in addition to concerns raised about the testing methodologies
involved, advised that long-range cross pollination was an unlikely
explanation for the detection of transgenes in landrace maize
in remote areas of Mexico.
ACRE concluded that the simplest explanation
was that imported GM maize seed destined for human consumption
had been deliberately mixed by Mexican farmers with the local
seed for their crops. ACRE categorically stated:
"Therefore this work does not have any implications
for the separation distances used in the UK GM maize farm-scale
evaluation programme."
Furthermore, SCIMAC notes that complaints about
perceived flaws in the authors' experimental procedures have led
the editor of Nature magazine to conclude that the paper should
not have been published.
7. Farm-Scale Evaluations—what has
been learned?
Within the Government's programme of GM crop
Farm-Scale Evaluations, the SCIMAC guidelines have been applied
within a normal farming situation at more than 180 field-scale
sites across the UK. This experience has demonstrated that the
protocols are workable in practice, robust in safeguarding the
integrity of GM and neighbouring non-GM crops (including certified
seed and organic crops) and capable of being audited.
In its previous inquiry into the issue, the
Committee concluded that the SCIMAC approach "offered a firm
basis on which to build in order to segregate GM and non-GM crops
in the UK countryside". Our experience of applying the guidelines
in practice has borne out that analysis.
No data or results will be published until the
Farm-Scale Evaluations have been completed. This was agreed at
the outset of the programme. Clear timescales for the completion
of the programme and provision of advice to Ministers are set
out in the written agreement between SCIMAC and Government.
It is imperative that the results of the programme
are placed in the public domain and made available to the relevant
advisory committees as soon as is practicably possible. The Scientific
Steering Committee overseeing the programme has been asked to
provide advice to Ministers on a single question—that of
comparative impact on farmland biodiversity. It is vital that
the conclusion of the trials and publication of data take place
in line with the original agreement, and are not delayed unnecessarily
or used as the basis for denying regulatory progress in other,
unrelated, areas.
8. Separation distances—AEBC report
"Crops on Trial" calls for "adequate separation
distances"—how does SCIMAC respond?
SCIMAC shares the AEBC's concern to ensure that
adequate arrangements are in place to promote mutual co-existence
between GM and non-GM crops, and to accommodate the interests
of all parties. The SCIMAC stewardship programme, which includes
crop-specific separation distances, was established to support
the effective integration of GM crop technology alongside other
farming systems.
The separation distances specified by SCIMAC
aim to reduce the potential for cross-pollination to an absolute
minimum within a practical farming situation. These distances
are based on well-established scientific knowledge of the characteristics
of each crop species in terms of pollen distribution and gene
flow, as confirmed in a Government-commissioned review of scientific
literature conducted by NIAB in 2000.
SCIMAC notes that the AEBC report referred to
"adequate" separation distances which will allow current
organic standards to "continue to be maintained." The
report separately noted that after two years of the three-year
FSE trials programme, not a single grower's organic status has
been affected. This is an achievement on which all parties must
seek to build.
9. Crops on Trial" also suggested that
the FSEs had been conceived and designed in a secretive way, with
key stakeholders (eg local people, organic farmers, beekeepers
etc) not fully engaged. How does SCIMAC respond?
Firstly there are simply no grounds to suggest
that the FSEs were conceived or designed in a secretive way. The
former DETR issued a public consultation on the design, methodology
and objective of the trials at the very outset.
SCIMAC remains committed to the principles of
openness and transparency within the FSE programme. That's why,
for example, consent-holders within SCIMAC took the voluntary
step of disclosing precise locations for forage maize sites in
2000 and 2001, and of providing early publication of site locations—in
both cases going further than the regulatory requirements for
site notification.
However, it is also necessary to strike a balance
between the legitimate ability of researchers and industry to
conduct the trials safely and in accordance with the appropriate
regulatory framework, and the need to keep local people informed.
Selection of trial sites must continue to be carried out on a
scientific basis.
Throughout the process, SCIMAC has continued
to seek improvements in arrangements for providing information
about the trials and to give local people an opportunity to find
out and comment on what is happening in their area. This has applied
to successive rounds of plantings, and will continue to apply
where possible within the scientific and agricultural parameters
of the programme.
In particular, SCIMAC has:
— promoted early consultation between
trial growers and their farming neighbours; and
— sent information about individual
trials to Parish Councils, District Councils, County Councils,
local MPs and MEPs, as well as beekeepers' organisations.
For this year's FSE plantings, SCIMAC has provided
six weeks' notification of trial sites, in line with the AEBC's
recommendation. This has certainly added to the pressures of delivering
the programme on target, but is a signal of our commitment to
the principles of openness and transparency on which the FSE programme
is based.
Current GMO regulations require 15 days' public
notification—no notification at all in the case of forage
maize. Charges of secrecy ring somewhat hollow against the efforts
we have made to support transparency and openness within the programme.
10. How does SCIMAC respond to the AEBC's
concern at the "particularly unfortunate" location of
some of the chosen sites?
SCIMAC is concerned primarily with meeting the
scientific conditions and objectives of the FSE programme. The
term "particularly unfortunate" has little relevance
in this context provided it meets the scientific criteria of the
research. As previously stated, SCIMAC has made significant efforts—over
and above any legal requirements, to ensure details of the FSE
sites are made public as soon as is practicably possible within
the scientific and agricultural conditions of the programme. Out
of the 250 or so sites either completed, under way or planned
this year, the vast majority have proceeded without major issue.
11. Regulatory and advisory framework—how
are new bodies, such as AEBC, Food Standards Agency, helping the
situation?
SCIMAC welcomes the role of the Food Standards
Agency in providing independent, transparent and science-based
advice on food and feed safety issues, as part of the information
required by Government to carry out their statutory responsibilities
in relation to the regulation of GMOs.
SCIMAC also recognises the important role of
the AEBC in providing a forum for exchange of views and advice
to Ministers on the many diverse issues surrounding GM technology.
SCIMAC welcomed the Commission's "Crops on Trial" report
as an important contribution to the debate, and has acted upon
many of the Commission's specific recommendations in relation
to the voluntary programme of Farm-Scale Evaluations.
However, AEBC's role in relation to the regulatory
framework which governs GMOs is less clear. Government has repeatedly
made it clear, most recently in its response to the AEBC report
"Crops on Trial", that the decision-making processes
which govern the approval or restriction of individual GM crop
applications will continue to be evidence-based. While there is
an important general requirement to consider ethical and socio-economic
issues, and to consult widely with the public, "consents
for the release and marketing of GMOs can only be prevented on
valid safety grounds supported by sound scientific evidence."
This point is reiterated several times in the Government response:
"Although general ethical and socio-economic
implications of the marketing of GMOs may be taken into account
in reviewing the operation of this legislation, the criterion
for taking decisions on individual applications is the avoidance
of adverse effects on human health and the environment."
[paragraph 13]
"Under the Directive consents for the release
and marketing of GMOs can only be prevented on valid safety grounds
supported by sound scientific evidence". [paragraph 20]
"Any eventual decision on commercialisation
will be taken using the criteria in Directive 2001/18, which requires
more by way of consultation with the public on applications for
approval. However the decision-making process will continue to
be evidence based." [paragraph 34]
It could be argued that two, three or perhaps
even five years ago a body such as AEBC would have contributed
more significantly to the direction and nature of the public debate.
From SCIMAC's own experience, there are clear signs that the debate
is on the move, and that the degree of hostility towards or rejection
of the technology is by no means as universal as is often portrayed.
AEBC must therefore guard against a situation
in which, by its very existence and the nature of its membership,
it serves to perpetuate tensions in the debate rather than to
work constructively towards consensus positions or to reflect
the genuine extent of public concerns. In this respect, SCIMAC
would welcome re-clarification of the AEBC's role and remit.
SCIMAC
22 April 2002
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