Examination of Witnesses (Questions 320-339)
3 DECEMBER 2003
PROFESSOR CHRISTOPHER
POLLOCK, DR
NICK BRICKLE,
DR BRIAN
JOHNSON AND
DR MARK
AVERY
Q320 Mr Thomas: Earlier on, Dr Johnson,
you specifically mentioned the true cost for beet and oilseed
rape as having a detrimental effect on the environment. In your
view, from these trials, it should not be licensed in the United
Kingdom for growing. Does that mean that you think these trials
were robust enough to license this particular type of GM fodder
maize?
Dr Avery: No, because the situation
has changed. That is why I said, in answer to a previous question,
that I think the trial was scientifically valid but not particularly
relevant looking forward. I think the point about whether you
put atrazine in with your broad spectrum herbicide relates to
the point I made earlier, that the industry stipulated the management
regime. Defra would have the ability to make those guidelines
for the way that this crop would be managed if it were given commercial
approval. If SCIMAC did not say, "Let us put some atrazine
in as well", then they can hardly moan now if they would
not get commercial approval for that change in management.
Professor Pollock: I would stress
again, as was indicated throughout all of this, that they did
achieve perfectly good levels of weed control without the use
of an ATZ-type approach.
Q321 Paul Flynn: Were you happy with
the weed control, that it was what farmers would normally use?
There was some suggestion from possibly the Soil Association,
Friends of the Earth and one or two others that there was an excessive
amount of attempts to take out the weeds manually and that that
was not what would happen in the usual situation as far as farmers
are concerned. There was pressure to take out the weeds on a basis
that was far too frequent.
Professor Pollock: The data are
in the paper by Champion, which show that the number of visits
to the field by the farmers to use pesticides on both sides of
the paired field lay within, on the one hand, for the conventional
field, the realm of the agronomic practice that farmers would
normally employ and nothing outside of those limits, and, on the
other hand, conformity with the guidelines of SCIMAC.
Q322 Paul Flynn: Can I ask you to state
again what your conclusion is, if that is not too strong a word,
on the timing? Are you saying that the publication of the winter
oilseed rape figures some time later next year and your re-analysis
of the figures are very unlikely to make any difference to the
situation when you made your announcement?
Professor Pollock: I would say
that as far as the three crops for which the data already exists
is concerned, we have been able to advise ministers with confidence
on whether the "null hypothesis" was supported, and
in no case it was, and what the implications of those results
were. We will be doing the same for the winter oilseed rape, assuming
that the papers are accepted for publication in the same way.
Then there will be a period of continued evaluation of this data
and integration of it with others, which will produce other information
not directly applicable to the "null hypothesis" but
of value to the community as a whole.
Q323 Paul Flynn: As a Committee, we have
seen a great many pieces of evidence coming in on the results
of the trials. Those vary between what SCIMAC are saying and what
Friends of the Earth are saying. Can I ask you gentlemen each
to say what in your view, perhaps in a few sentences, was the
result of the trials?
Dr Avery: Looking at the effects
of growing these crops, their associated management and the herbicides
used with them, on biodiversity, it is clear that for GM oilseed
rape and GM beet fewer seeds are returned to the soil. In fact,
they lead to up to a trebling in the loss of seeds in the seed
bank, so the seed bank is declining by about 3% per annum at the
moment and these two crops would increase that rate to 10% per
annum, which is a very big and dramatic change. That would have
implications for farmland UK systems and for many farmland birds
which are covered by the Defra PSA target to reverse the decline
in farmland birds. I have no doubt at all that were they given
the go-ahead, those two crops would worsen the situation for farmland
birds. On the face of it, GM maize would improve things, but because
the comparison was done with a conventional management system
which involved atrazine, which is a very nasty pesticide that
is now banned, we cannot be sure what the implications would be
in the future.
Dr Johnson: The first thing I
would say is that the results were fair and conclusive to my mind.
There is no doubt that the use of these broad spectrum herbicides
over the herbicide-tolerant beet and oilseed rape gave large reductions
in what I call the primary trophic level; in other word, weeds,
non-crop plants. It also gave large reductions in seed rain and
seed banks. From my knowledge of biodiversity and arable areas,
it would mean that if those crops were released and managed in
the way that they were in the field scale evaluations, we would
see significant reductions in the weed populations of farmers'
fields, farmers growing those kinds of crops. That would be compounded
year on year. It is a very clear indication of what is very likely
to happen. I think that the results for maize are, as Dr Avery
said, difficult predict into the future, but the results from
the experiment are quire clear, that the GMHT system is better
for biodiversity than using atrazine. That does not particularly
surprise me because atrazine turns a maize field from what was
once a diverse grass field that has been ploughed and had biodiversity
into a wildlife desert. It is really ground zero as far as wildlife
is concerned. It is not surprising that a herbicide-tolerant system
is better for biodiversity. Whether it will be better for biodiversity
than the herbicide systems that replace atrazine is open to question.
We do not know what those systems will be. We do not know what
the constraints placed on those systems by the pesticide and herbicide
regulatory authorities will be. That does not really tell us very
much.
Professor Pollock: I am going
to restrict my comments to the experiments and not extrapolate;
I do not believe it is my role to do that. This was the largest
piece of agroecology ever carried out anywhere. To my mind, it
has provided invaluable data, first of all to support the hypothesis
which has always received support but not a great deal of validating
evidence, that what we are talking about in terms of the interaction
between the "managed" and the "natural" environment
is really effectively competition for sunshine. Therefore, weed
control is critical to the balance between the preservation of
natural weed systems, which eventually will feed through into
the higher trophic levels, and what the farmer removes. I think
having datasets that support that is of considerable value. The
second thing is that it indicated that there are big differences
between crops. If you take the data on their face value, then,
if you like, the best and the worst crop were both conventional.
The third thing it did was to show that the effects were wholly
attributable to the herbicide management regime, that this is
not in fact a GM study but a study about weed control. Fourthly,
it exposed the sorts of differences that my colleagues have told
you about.
Q324 Paul Flynn: The final point you
made was the virtual by-product of these trials. Do you think
it is scientifically of value with the differences between the
crops themselves rather than the differences in GM crops and non-GM?
Professor Pollock: I think that
is of inestimable value if you are to have a rational debate about
land use in the United Kingdom in the 21st century.
Dr Brickle: I support what has
been said. The only thing I would add is that I think we should
be thankful that risks are actually assessed with GM crops because
herbicides are used throughout conventional agriculture and these
sorts of impacts are unassessed and unrecognised and have led
to a decline in wildlife.
Q325 Paul Flynn: The Soil Association
has sent us a follow-up memorandum. They have said that the AEBC[9]in
their definitive view of the trials recommended to the Government
that the trials would not provide anything like all the information
needed for the Government to decide whether the commercial growing
of GM crops should go ahead in the UK. To what extent do you think
that the centrality of these trials through the approval process
has been undermined by their view and by the consequent setting
up of the Economic and Scientific Reviews?
Professor Pollock: I do not think
the trials were ever central to the regulatory process. They were
part of it. They were necessary but not sufficient.
Dr Avery: I think the Government
only has two real ways of banning GM in this country, and that
is if there is evidence of environmental harm or if there is evidence
of food safety problems. I think that these trials could be central
to those decisions. They are not necessarily central to whether
if approved anybody will want to grow these crops or anybody will
want to eat them or use their products. I think that is the much
wider debate that the AEBC was looking at. Government has to decide
whether these crops are going to come into the UK or not and that
is going to have to be made on environmental or human health grounds,
so these trials, with their very clear results, are very important
to that decision.
Q326 Paul Flynn: Do you agree that there
is enormous confusion among the general public about the GM crops
and that by focusing on this one tiny part of the spectrum of
possible objections this was something of a wasted opportunity,
although it did produce a by-product of other results? Would you
foresee trials based on many of the other concerns that the general
public have?
Dr Avery: I think that these trials
have been incredibly valuable and a very good piece of science.
In a way they have bought time for everybody to learn more about
GM crops as a whole and potential benefits and downsides they
could bring. Maybe as a country we have not capitalised quite
enough on that opportunity because I would agree with you that
there is quite a lot of confusion about the issues. I do not think
you can criticise the trials because of that, the trials were
an exceptionally good bit of science which were well designed
and came up with a very clear answer.
Q327 Paul Flynn: Do you all agree with
the decision to look at this area only?
Dr Johnson: I can only comment
about the environmental issues that are germane to GM crops. Those
fall into two broad categories. One is: "will the management
of the crops have an impact on the environment that is either
beneficial or damaging?", and these trials look at that aspect.
The other aspect is: "will gene flow from the crops, and
to the crops in some cases, actually cause either agronomic problems
or problems with natural systems?". There is already a wealth
of information available about gene flow, we know a lot about
rates of gene flow, but what we perhaps do not know so much about
is what the impact of gene flow might be, in other words if wild
plants or weeds acquire these genes what might be the effect on
farm practice or on wildlife. We know a bit about that; I think
probably enough to make decisions in some cases.
Q328 Paul Flynn: What decisions?
Dr Johnson: Regulatory decisions
in some cases, perhaps in other cases not. I think these experiments
really address this central issue that is important for GM herbicide
tolerant crops or, indeed, any herbicide tolerant crops: should
they be used and, if they are used, what is likely to be the impact.
The data from these trials give us a lot of insight into that
and without the trials having been done we would still be making
regulatory decisions that were ill-informed in my view.
Q329 Paul Flynn: Professor Pollock, you
nodded during that answer.
Professor Pollock: Whilst I would
not wish to dissent from your view that there was public confusion,
I do not think that should be taken as an indication that there
were not other scientific experiments going on that were germane
to the regulatory process. Dr Johnson has mentioned the work on
gene flow which, again, has quite broad impact and has raised
some very interesting questions about fitness that go beyond just
the GM debate as well because we have left an agricultural footprint
on this island since the Iron Age and the use of molecular techniques
has allowed us to see the ghosts of some of these plant breeding
footprints as we move around the countryside. Assessing the impact
of genetic change within natural and crop systems that are related
is something that will continue to concern regulators in the case
of GM, but continue to concern scientists in the case of the whole
range of agronomies that are used in this country.
Q330 Paul Flynn: The trials failed to
back up many of the claims of the industry. There is great worry
in Canada about the commercial success of GM in the future and
many other worries exist, as you have mentioned. Is this the end
of GM in Britain?
Professor Pollock: I think in
the early stages one of the people around this table made the
case that regulation of GM in particular, and novel agronomies
in general, must be on a case by case basis. I think everything
that the farm scale trials have shown has justified that approach
and to that extent I would not like to make predictions about
an entire technology, only about the specific uses to which that
technology is being put. Given time and money, I could produce
an extremely undesirable product by conventional plant breeding
if you really wanted me to.
Q331 Paul Flynn: Dr Johnson?
Dr Johnson: I tend to agree with
that. I think the issue for me and for English Nature is not so
much the technology but that the technology produces plant varieties.
We know, and have known for a long time, that new plant varieties
can have a profound impact on the way our countryside is managed.
We have seen that by the introduction of new varieties that have
not been grown here before and by the introduction of new varieties
of previously grown crops that change crop management quite radically,
and this is an example of how that happens. The technology that
is used to change those crops is not the issue, it is the crops
themselves and the systems that go with them.
Q332 Paul Flynn: Dr Avery?
Dr Avery: I would agree with what
the previous two people have said.
Q333 Paul Flynn: There is a pleasant
unanimity. I am sure it means it will lead us to a sensible conclusion.
Can I ask one final question of Professor Pollock. There was a
comment made by SCIMAC that the results misrepresented the effect
of GM crops, as opposed to herbicide use, upon biodiversity and
that the trials represented "a worst case scenario for GHMT
treatments". Was that a sensible thing to say?
Professor Pollock: I think there
is still debate to be had with the data there are in the literature,
in particular about the rates of recovery of seed banks in following
years because, as I said, the number of samples upon which these
data are based is smaller than the trials themselves of necessity
because not all the information has been collected and the error
bars are larger. I think the experiments and the data and the
conclusions that are drawn in the papers, rather than some of
the more hyperbolical conclusions drawn in the newspapers, are
robust and valid, but there are differences of scientific opinion
and interpretation.
Paul Flynn: God save us from the hyperbole
in newspapers. Thank you, gentlemen.
Q334 Sue Doughty: I want to talk about
where do we go in the future. One of the terms of reference of
the steering committee is to advise the Government on the need
for further tests. We have got the issues we have already rehearsed
that were thrown up by the trials: that they showed greater differences
in biodiversity crop against crop than GMHT versus conventional
within each crop; that they should have included organic farming
alongside GMHT and conventional farming; that similar trials should
be held (or should already have been held) simply to compare conventional
and organic farming, and to assess differences in biodiversity,
crop against crop in each category; and that each further GM crop,
whether it is HT or IR or whatever, should require its own mini-field
scale evaluations in future, to be paid for by the industry, before
permission to plant commercially is given and it can go ahead.
Within those terms of reference, have you reported your advice
to the Government on the need, or lack of it, for further trials,
further tests?
Professor Pollock: No. The advice
that the Scientific Steering Committee has given Government is
exclusively in terms of its terms of reference, to advise on whether
the trials had been carried out appropriately in their view and
whether the "null hypothesis" was supported or invalidated.
Further discussion on this moves then into the regime of committees
like ACRE. I do not think the SSC has a view on those issues.
Q335 Sue Doughty: Having reported the
results of the trials to ACRE, when do you expect to hear what
their findings are? Are they going to have to respond separately?
Professor Pollock: Yes, they will
be responding separately.
Q336 Sue Doughty: So we will be expecting
to hear that. Do we know when that is likely to be?
Professor Pollock: What I can
tell you is what is on the website. There are two open meetings
at which people are permitted to make representations about the
impact of the trials, the second of those is tomorrow, and then
they could well be meeting to formulate their advice. Although
I am a member of ACRE, in fact I am nominally the Chairman, I
am not part of that process for this particular cycle.
Q337 Sue Doughty: Thank you, Professor
Pollock. Turning to Dr Avery and the other people here today,
do these tests simply represent the beginning of a long and protracted
series of detailed studies on GM crops? Are we going to go test
by test, crop by crop, or do we think we know enough about beet
and rape to conclude that there should be no permission to grow
these varieties in the UK? In other words, where are we with the
ones we have tested, where are we with ones that might come along
in the future?
Dr Avery: I would say that we
know where we are with GHMT spring oilseed rape and beet and that
the results are sufficiently clear that growing those crops would
cause damage to farmland wildlife, that they should not get commercial
approval. Were other GM crops to be brought along for approval
in the future then I think it would depend how similar they were
in type to the crops already tested whether there should be similar
types of large scale, farm scale evaluations or not. This type
of study is now required under EU regulations to look at the indirect
effects of growing this type of crop on the environment, so we
would say that any further crops coming along ought to be subject
to a similar assessment process, but quite what that would look
like would depend on the crop involved, if that is clear.
Q338 Sue Doughty: Thank you. Dr Johnson?
Dr Johnson: Just to pick up on
that last point, I think really the case by case principle applies
very strongly here. It depends on the crop and it depends on the
transformation. What the regulatory system needs to do, and what
its advisors need to do, is to look at a specific crop type that
is coming up through the pipeline and ask the question "Is
this likely to have an impact on biodiversity in the countryside?
Is it the kind of transformation in that crop that would give
those results?" It would be nice if we had some preliminary
scientific information to raise that problem, if there is a problem,
but in the absence of it we have to use our best judgment. In
some cases there will be a chance that there is some impact on
the environment, in other cases it would be very unlikely, and
perhaps in those cases it would not be necessary to hold these
kinds of trials but it all depends on the crop and the transformation.
Q339 Sue Doughty: Professor Pollock?
Professor Pollock: I would agree
with that completely.
9 The Agriculture and Environment Biotechnology Commission. Back
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