Memorandum submitted by the Consumers'
Association (A15)
INTRODUCTION
1. Consumers' Association (CA) is an independent,
not-for-profit consumer organisation with around 700,000 members.
Entirely independent of government and industry, we are funded
through the sale of our Which? range of consumer magazines and
books. On the EU level we are members of BEUC, the European Consumer
Organisation, and we are represented on the international arena
by Consumers International. We are also members of the Transatlantic
Consumer Dialogue, and co-chair its food working group.
2. CA has campaigned and worked on food
issues for many years, and has a long record of researching and
communicating food issues to our members and the UK public in
general to enable them to make informed choices about the food
they consume. The introduction and control of genetically modified
(GM) foods has been an important issue for us because of its implications
and importance for consumers. We first reported on GM foods in
our magazine Which? way to Health in 1989, and have continued
to investigate various aspects of the issue such as labelling
and safety, the use of GM ingredients, and whether GMOs could
aid food allergy sufferers through our Which? and Health Which?
magazines[16].
Our most recent policy report "GM dilemmas", a copy
of which is attached with this submission, was published at the
end of last year. This sets out our most recent consumer research,
but we have tracked consumer attitudes to the technology since
the early 1990s.
BACKGROUND
3. We have always advocated that consumers
should be consulted about GM foods with their views forming the
basis of any future decision by government. Consequently we felt
that a public debate on GM foods was long over-due, and welcomed
the Government's announcement in June 2002 that a debate would
be organised and over-seen by an independent steering board. We
emphasised that that it should not be a public relations exercise,
and that the results should be reflected in future government
policy.
4. Our concern has been that consumer attitudes
and unease have largely been neglected. The approach to GM stands
in stark contrast to a general emphasis within government, since
the publication of the Curry Commission report on farming and
food, to reconnect agriculture with the end consumer. Instead,
consumer concerns have too easily been dismissed as irrational
and ill informed, with even the Prime Minister in the past referring
to anti-GM campaigners as being anti-science. The "debate"
has become polarised between those who are in favour and those
who are against the technology, neglecting the vast majority of
consumers who our research shows are concerned about the long-term
implications of GM, want to have a proper choice, but have not
been listened to.
5. Before considering how the debate has
been conducted, it is therefore important to consider what it
should have achieved. We saw it as an opportunity for an effective,
wide-ranging public debate about the future for GM foods and the
conditions and limitations of public acceptance. In order to be
meaningful, we felt that the debate needed to address the following:
consider why the majority of consumers
are concerned about GM and what further steps are needed to address
these concerns;
determine whether any GM products
could be developed which consumers would find beneficial;
find out how consumers are likely
to react to those products that are already under-development,
including modifications involving fish, animals and micro-organisms;
develop a greater understanding of
how food is now produced, where GM is likely to be involved throughout
the process and where the limits of consumer acceptability lie;
determine consumer attitudes towards
commercial growing of GM crops now and in the future.
CONDUCT OF
GM PUBLIC DEBATE
Contact with Central Office of Information
6. As the UK's largest consumer organisation,
CA was keen from the outset for the debate to be meaningful, and
to inform and engage our members in the process as well as the
public more generally by providing information via Which? magazines.
We also wanted to ensure that those attending the public meetings
would have access to information on CA's research and policy on
GM foods to help inform the debate. Consequently, we first contacted
the Central Office for Communications (COI) on 21 March to find
out the timing of the national GM public debate meetings. On 25
March we were informed by COI that the main launch date would
be the second week in May.
7. Information from COI was always vague
and non-committal. Contact was made again with COI in April and
May. A date was given for the press launch of the public debate,
but there was no information on the venue and no details on what
interest had been shown by county councils for second tier regional
debates or how to ensure CA material could be distributed at the
meetings. We became increasingly alarmed that COI did not have
the expertise to deal with such a wide-ranging exercise, and that
the lack of publicity surrounding the debate would mean that consumers
would be excluded from one of the key issues for the future of
food and farming in the UK.
8. CA was advised by COI on 28 May to send
literature directly to COI for distribution to the second tier
meetings, but that the venues and dates were still to be confirmed.
9. Throughout June we contacted COI again
for information about the second tier meetings but to no avail.
Phone lines were constantly engaged, e-mails were not replied
to and the information posted on the GM Nation Public Debate webiste
was minimal. In the end, we liaised directly with members of the
GM Public Debate Steering Board for information on the venues
and dates for the second tier meetings. It was only by this means
that CA was able to contact organisers directly.
10. CA was also contacted directly by members
of the public with requests for copies of our policy report and
handouts. In talking with them on the telephone we learned that
they also shared the concerns felt by CA and other groups about
the way the debate was being organised (as highlighted in the
following section), but wanted to at least try to organise local
events.
11. The lack of advance knowledge about
meetings meant that the only information we were able to communicate
through our magazines was a very short piece informing members
to refer to the GM Public Debate website in the `Inside Story'
section of April's Which? magazine.[17]
This meant that those without with access to the web were automatically
excluded from participating.
12. If we faced these difficulties as a
major consumer organisation, we are very concerned that members
of the public wishing to participate would have faced similar
problems and many may not have even been aware that the debate
was taking place. It is interesting to note that this view was
felt and recorded by the recent independent GM jury process, as
funded by Consumers' Association, the Co-operative Group, Greenpeace
and Unilever. The two juries of fifteen people from two areas
in the UK concluded, after 8 weeks of deliberations and hearing
evidence from a wide range of stakeholders, that the GM Public
Debate had been "invisible"[18]
The jurors were critical of the lack of publicity surrounding
the details of the debate and the fact that most of the information
was communicated via the GM Public Debate website despite many
people not having access to the internet. In the aims and objectives
for the GM Public Debate, it seeks to "create widespread
awareness among the UK population of the programme of the debate"[19],
yet this is clearly not the experience of the GM Jury.
Role of Defra
13. Contact with other stakeholders that
were also closely following the GM public debate process, showed
that our concerns and general sense of frustration at how the
debate was being managed and co-ordinated were shared. This led
seven leading UK wide organisations; Friends of the Earth, Greenpeace,
National Trust, RSPB, Sustain, National Federation of Women's
Institutes, Unison, along with CA, to write jointly to the Secretary
of State on 30 May outlining our mutual concerns. A copy of this
letter is attached.
14. These concerns centred on:
Lack of clarity on how the views
of the public will be fed into the decision-making process. The
impression given was one of consultation without inclusion.
Only very few second and third tier
meetings had been confirmed.
The failure to pilot the stimulus
materials for the debate and to provide sufficient depth for an
informed discussion.
Insufficient thought given to guidance
on how local meetings were to be facilitated to ensure that all
participants can be fully involved and that all views expressed
could be accurately recorded for the steering committee.
15. In light of the above, all signatories
felt that the conclusion of the public debate should be extended
until the end of October rather than July 18 to allow more time
for the public to take part. This was reinforced by the delay
in the release of the farm scale evaluation results which will
not now be until later this autumn. Our research on consumer attitudes
in relation to GM crops shows that just 32% of those questioned
felt that they should be grown commercially in the UK at the moment.[20]
The main reason given by those who did not think that they should
be grown was lack of information. For the debate to conclude without
the results of such an important piece of research is quite baffling.
16. Subsequent correspondence with the Secretary
of State reiterates Defra's view that it is, and always has been,
the independent Steering Board which is responsible for the handling
of the public debate not Defra. CA appreciates the need for the
debate to have been run independently from government, but to
deny ultimate responsibility for an initiative it announced is
nonsensical. This hands off approach seems to contradict the fact
that Defra officials were kept informed about the organisation
of the debate in regular meetings with COI and set the budget
and timing for the debate.
Experience of national GM Public Debate meetings
17. CA sent members of staff to the national
meetings in Birmingham and Glasgow to see at first hand how the
events were structured, what information was given, and how the
participants viewed the process.
18. Our experience at the meeting held in
Birmingham on the afternoon of 3 June, and in Glasgow on the evening
of 11 June, confirmed a number of our concerns as outlined in
our joint letter to the Secretary of State on 30 May. There was
real anger over the lack of publicity surrounding the meeting
with some participants only finding out a very short notice that
such a debate was taking place. This meant that those that work,
or have other commitments, were prevented from attending from
the outset due to insufficient time for making alternative arrangements.
There was also a feeling of general scepticism as to what extent,
if any, the government would take the views expressed into account.
The format of the meeting was also criticised as it did not enable
an effective debate to take place. The level of discussion was
based on the existing knowledge of those in the individual groups.
The series of questions for each session did act as useful prompts
and attempted to focus the debate, but more in depth discussions
could have taken place if experts had addressed the meeting which
was then followed by a question and answer session and a general
debate.
19. At the press launch on 3 June, Professor
Malcolm Grant is quoted in the press release saying that the GM
Public Debate provided the "chance for people from every
section of society to have their say".[21]
Yet it was quite clear from our experience in Birmingham and Glasgow,
that the majority of participants were from groups/organisations
often with pre determined and steadfast views on GM technology.
The message to engage in the GM Public Debate had clearly not
reached the UK public as a whole. Our experience from the Birmingham
meeting also showed that while a variety of age groups were represented,
the audience did not reflect the multi-ethnicity of the UK population.
CONCLUSIONS
20. Hindsight is obviously something that
the Government can look to when assessing the GM Public Debate
process, but CA, along with many other groups, were highlighting
key weaknesses and concerns about the process while there was
still adequate time for them to be addressed and rectified. For
instance, we expressed our concerns to Lord Whitty, and one of
Defra's leading civil servants on GM policy on 1 July at the meeting
between Defra and consumer groups. Unfortunately, Defra failed
to take action.
21. While it is encouraging that many people
did participate with over 36,000 feedback forms being returned
via e-mail and post, and we look forward to reading the Steering
Board's report, we are concerned that an opportunity was lost
for a much more wide-ranging and informed debate. This was one
of the reasons why we decided to part fund the GM Jury, in order
to provide a more deliberative process that could feed into the
public debate. The government must also find additional opportunities
to enable consumer reactions to the forthcoming results of the
Farm Scale Evaluations to be heard.
22. We have concerns that COI did not run
the debate effectively. No visible effort was made to contact
any large membership based organisations, such as CA, to co-ordinate
raising awareness and thereby enhance publicity of the debate.
This lack of publicity in general can only make those who were
not engaged in the debate even more sceptical about the consultation
process and how it will be used by the government when making
the final decision on whether or not to grow GM crops commercially
in the UK.
23. Finally, we hope that Government will
learn from this process and we hope that the public debate can
be just the beginning of amore effective dialogue and on-going
engagement with the public on this important issue.
September 2003
16 For example: "Food Biotechnology: food of
the future?, Which?, July 1996; `Gene Cuisine', Which?, March
1999, and `GM and food allergies", Health Which?, June 2002. Back
17
"Inside Story", Which? magazine, April 2003. Back
18
The GM Jury published its conclusions on GM crops on 8 September.
For further information about the process, and the jurors conclusions,
please refer to www.gmjury.org. Back
19
`Aims and Objectives for the GM Public Debate', www.gmpublicdebate.org.uk.
Back
20
Response to figure 16, "Do you think that GM crops should
be grown commercially in the UK at the moment?" Annex I [not
printed], CA Research Findings, May 2002, GM Dilemmas Policy report,
2002. Back
21
Press Notice released by GM Nation, The Public Debate, "GM
Nation-The National Public Debate Starts", 3 June 2003. Back
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