Memorandum from the Supply Chain Initiative
on Modified Agricultural Crops (SCIMAC)
INTRODUCTION
SCIMAC welcomes the opportunity to contribute
to the Environmental Audit Committee's inquiry into the UK Farm
Scale Evaluations (FSEs).
Established in June 1998, SCIMAC (Supply Chain
Initiative on Modified Agricultural Crops) is a grouping of industry
organisations along the UK farm supply chain. Member organisations
are:
British Society of Plant Breeders
Crop Protection Association
Agricultural Industries Confederation (formerly
UKASTA)
British Sugar Beet Seed Producers Association
The focus of SCIMAC's activity is to ensure
appropriate arrangements are in place to support the open and
responsible development of GM crop technology in the UK. Member
organisations share a commitment to ensuring UK adoption of the
technology is carefully managed and delivers a meaningful choice
for farmers, the food industry and consumers.
BACKGROUND TO
THE FSES
The UK Farm Scale Evaluations were established
in 1999 in response to specific questions raised about potential
effects on farmland wildlife and biodiversity of the weed management
practices associated with growing particular types of GM herbicide
tolerant crops on a whole field scale.
A review by the former DETR of available ecological
data during 1998 concluded that not enough was known about the
potential biodiversity impact of GM herbicide tolerant crops in
the UK context to answer these questions. In addition, it was
clear that proposed revisions to the European regulations governing
the environmental safety of growing GM crops would introduce new
requirements to take account of indirect effects on wildlife and
biodiversity. In December 1998, EU Environment Ministers agreed
that the proposed requirements for risk assessment, including
the potential impact of changes in the management of GM crops,
should be implemented with immediate effect.
This provided the background rationale and basis
for a unique agreement between the UK Government and SCIMAC to
carry out the Farm Scale Evaluations. A formal agreement was announced
in November 1999 that there would be no move to widespread commercial
cultivation of GM crops in the UK until completion of the research.
Through this process, industry voluntarily submitted the technology
to independent scientific scrutiny. No other agricultural technology
has ever undergone such a comprehensive programme of testing and
evaluation in advance of its permitted commercial use.
SCIMAC Role in the FSEs
SCIMAC's role as industry partner within the
FSEs has essentially been fourfold:
— to identify a pool of potential sites
and growers for final selection by the independent research consortium
and FSE Scientific Steering Committee;
— to supply seed and herbicides for
the GM component of the trials;
— to provide guidelines on the management
of the GM crops, designed to ensure best agricultural practice
and support co-existence between GM and neighbouring non-GM crops;
— to organise appropriate disposal
of the harvested GM crops, since none have all the approvals necessary
to enter the food or feed chain.
Contrary to earlier evidence provided to the
Committee by the former Environment Minister with lead responsibility
for establishing the FSEs, SCIMAC had no direct involvement
in determining the design of the trials, the questions to
be answered, the structure, scope or methodology. These issues
were entirely the responsibility of the independent research consortium
conducting the scientific monitoring, and the Scientific Steering
Committee appointed by Mr Meacher to oversee the programme (see
DETR press notice 507 of 25 May 1999).
Furthermore, the on-farm guidelines developed
by SCIMAC and applied within the FSEs were formally endorsed by
the UK Government in May 1999 (see Cabinet Office press notice
CAB 109/99 of 21 May 1999). This followed a lengthy and wide-ranging
process of consultation with Government departments, advisory
committees and other interested parties.
It is vital for the Committee's proper understanding
of the conduct and operation of the Farm-Scale Evaluations that
factually inaccurate evidence provided by the Minister formerly
in charge of the FSE programme is corrected.
On the specific issues raised by the Committee,
SCIMAC has the following comments:
1. The adequacy of the design of the
farm scale trials and their ability to answer the questions posed
at the outset of the trials
1.1 Since this is not our field of expertise,
SCIMAC is not in a position to comment in detail on the design
or scope of the FSEs, other than to note that it represents the
largest programme of ecological research ever conducted in arable
agriculture, and that the results have effectively been subjected
to a double peer-review process: firstly by the Scientific Steering
Committee overseeing the programme, and secondly by the Royal
Society prior to publication. This duplicates the normal process
of scrutiny and review applied to scientific research.
1.2 It is also worth noting, contrary to
earlier evidence provided to the Committee by Mr Meacher, that
separate, DEFRA-funded research conducted at FSE trials has included
gene flow studies, not only between GM crops and neighbouring
non-GM crops of the same species, but also between GM crops and
wild relatives. This research has provided strong support to the
approach taken by SCIMAC in drawing up management guidelines for
the minimisation of such gene flow arising from the cultivation
of these crops.
2. The Conduct and Operation of the Trials
2.1 The successful completion of more than
280 field-scale trials over a four-year period is an achievement
of which all involved can be justly proud. It has been the largest
ever series of co-ordinated field trials conducted in UK agriculture.
In particular, SCIMAC wishes to pay tribute to the contribution
of individual FSE growers. Without their resolve and commitment
the completion of this programme would not have been possible.
2.2 As previously stated, final selection
of growers to participate in the FSEs was carried out by researchers
and the Scientific Steering Committee from a pool of potential
growers submitted by SCIMAC. Growers were financially compensated
for the income foregone by taking part in trials. Average compensation
paid to growers was around £400/acre. This is in line with
the gross margin a farmer would expect to earn from growing a
commercial seed crop.
2.3 The practices observed by trial growers
in managing the trials were subject to three separate audit processes:
— statutory inspection by the GM Inspectorate
(Central Science Laboratory in England and Wales, Scottish Agricultural
Science Agency in Scotland), to ensure compliance with consent
conditions;
— independent audit of growers' compliance
with the SCIMAC management guidelines, commissioned by SCIMAC
and conducted by ADAS Consulting Ltd;
— evaluation of growers' management
decisions by qualified (ie BASIS approved) agronomists, to ensure
they were consistent with good agronomic practice.
Reports issued by both the GM Inspectorate and
ADAS have confirmed very high levels of compliance across all
sites throughout the FSE programme.
2.4 A number of myths have surrounded the
conduct and operation of the trials, perpetuated by organisations
campaigning against the technology. It is worth taking this opportunity
to set the record straight with some simple facts and figures:
Myth 1. Not enough farmers would be found
to deliver the programme
240=the minimum number of sites specified
by researchers
283=the number of FSE trial sites conducted
since 1999
Myth 2. GM crops threaten neighbouring organic
farms
277=the number of organic farms claimed
by the Soil Association to be at risk of decertification
0=the number of organic crops decertified
as a result of the FSE trials
Myth 3. GM Crops will transfer herbicide
tolerance to weedy wild relatives
55,000=the number of gene flow tests
conducted by the Centre for Ecology & Hydrology on related
wild species at FSE sites
0=the number of cases in which transfer
of GM to wild relatives was detected
Myth 4. FSE trials (maize) were conducted
in a climate of secrecy
0=the number of days' public notification
prior to planting legally required for GM maize site locations
53=the average number of days' notification
prior to planting actually provided (voluntarily) for FSE
maize trial site locations
Myth 5. FSE trails (other crops) were conducted
in a climate of secrecy
15=the number of days' public notification
prior to planting legally required for GM oilseed rape and
beet site locations
56=the average number of days' prior
notification actually provided (voluntarily) for FSE site
locations of these crops
Myth 6. Farmers won't comply with on-farm
guidelines
2,096=the number of independent audit
checks at Critical Control Points carried out by ADAS at
FSE sites
0=the actual number of incidents of non-compliance
identified at these Critical Control Points
Myth 7. Farmers don't want to grow these
crops
95=after growing the crops, the percentage
of FSE trial growers who said they definitely would grow
GM crops if available commercially
0=after growing the crops, the number
of FSE trial growers who said they would not grow GM crops
if available commercially
Distinguish between GM impacts and management/herbicide
impacts
A clear distinction must be drawn between the
effects on biodiversity which can be attributed to the GM crop
itself, and those associated with the herbicide and/or management
regime used. The FSE results demonstrate that the differences
identified between the crops studied are governed above all by
the crop type, herbicides and weed control practices involved,
not by the use of genetic modification. This distinction is important
because some opponents of agricultural biotechnology seek to apply
unjustified generalisations across the whole technology rather
than the clearly established principle of case-by-case regulation.
While other GM crop traits such as insect or
disease resistance may in themselves have implications for farmland
biodiversity, the FSE results demonstrate that the indirect environmental
effects of growing GMHT crops are uniquely linked to the way in
which the companion herbicide is used. The critical issue for
ACRE (and the Advisory Committee on Pesticides) to consider, therefore,
is the way in which these crops and their associated herbicides
would be used in commercial cultivation, and how this is described
in the respective consent applications.
3.3.2 Distinguish between different management
approaches
It is clear from the FSE results that the farms
selected comprised a broad spread of management approaches, according
to intensity of production. The researchers have indicated that
they sought to over-represent the proportion of less intensive
sites than would be found in normal commercial agriculture. Intensity
of farming practice was assessed according to a combination of
factors, including average yields, use of ICM systems such as
LEAF, crop rotations, the levels of inputs used and the management
of field margins and headlands.
By contrast, the management regime applied to
the GM component of the trials was consistent across all sites,
and was agreed between consent-holders and the FSE Scientific
Steering Committee with the objective of delivering "cost-effective
weed control". A key advantage of the new type of GM herbicide
tolerance studied in the FSEs lies in its flexibility and ability
to deliver a range of farming and/or environmental objectives,
as has already been demonstrated by sugar beet research at Broom's
Barn showing positive benefits for biodiversity when alternative
management practices are applied (Dewar et al 2003). Similar work
by SAC (Scottish Agricultural Colleges), has shown that GMHT oilseed
rape could facilitate the use of minimal cultivation techniques
and improve the diversity of weed species within the crop, while
still allowing cost-effective production (Booth et al 2002). Despite
the spread of farming practice represented in the non-GM crops,
such alternative management approaches were not applied or available
in the GM component of the trials. In this sense, the FSEs represented
a "worst case" scenario for the GMHT treatments.
3.3.3 Distinguish between "statistical"
and "biological" significance
In using the FSE results as a basis for evaluating
the potential biodiversity impact of GMHT crops, it is imperative
that a clear distinction is drawn between differences which have
statistical significance, and those which have biological significance.
Clearly the latter is the most important consideration.
Thus, for example, the researchers have acknowledged
that while a small reduction in butterfly numbers within the GMHT
beet fields is statistically significant, it is not biologically
significant. A similar conclusion can be reached in relation to
bees which, like butterflies, are species which forage over large
distances, and are not normally associated with or dependent on
the beet crop as a nectar source. By contrast, oilseed rape can
be regarded as biologically significant as a nectar and pollen
source for foraging bees. The FSE results showed no significant
differences between the number of bees in GM and non-GM oilseed
rape fields.
3.3.4 Distinguish between "impact"
and "harm"
SCIMAC is concerned that the headline presentation
of the FSE results, that two of the three GM crops studied were
"more harmful to wildlife", was misleading. Firstly,
it fails to convey the qualification made repeatedly throughout
the published papers that this is not a GM issue. Secondly, it
is not a question of "harm" but of impact, whose implications
will depend on a range of factors—scale of adoption, crop
type, rotation and management practice to name but a few. Thirdly,
it is a generalisation not supported by the balance of the scientific
results. SCIMAC has urged ACRE to clarify this important distinction
as part of its advice.
3.4 Based on these guiding principles, the
priority now lies in the development and application of management
options, which can address the issues raised by the FSE results.
One of the key advantages of GM herbicide tolerance technology
is the increased flexibility it offers growers in their control
of weeds. The FSE results must be considered in the context of
other research which has shown that:
(i) varying the timing, rate and targeting
of herbicide applications in GM crops can have a significant influence
on biodiversity impact;
(ii) relatively minor (low or zero cost)
adjustments to the management of field margins or rotations can,
if necessary, be applied to mitigate the biodiversity effects
identified in the FSEs.
3.5 The FSEs have provided a unique opportunity
to demonstrate that management guidelines for growing GM and non-GM
crops can be successfully applied and audited under practical
farming conditions. This framework of management guidelines can
equally be adapted to address other objectives, such as the protection
of farmland biodiversity. As such, they offer a sound basis to
proceed with the carefully managed introduction of GM crops in
the UK.
3.6 The FSE results will also play a key
role in informing wider agricultural policy. Delivery of environmental
goods, such as the promotion of farmland biodiversity, is now
integral to future policy objectives.
3.7 A key consideration, therefore, is how
such objectives can be achieved in the context of a radical reform
of the Common Agricultural Policy (Mid Term Review), due to take
effect from 2005. Most commentators agree that decoupling CAP
support from production will further concentrate arable farming
in the hands of more efficient producers who can farm profitably
without support. Access to new technology will be vital to these
producers.
3.8 Essentially, UK agriculture is faced
with choices. The key issue is how to manage those choices. What
do we want from farmland in terms of biodiversity vs productivity?
Should decisions be driven by the characteristics of individual
crops, or by their role as part of a rotation? Should the delivery
of biodiversity objectives be promoted in cropped or un-cropped
areas?
3.9 However we opt to manage these choices,
SCIMAC is firmly of the view that access to the advantages of
a technology already adopted by millions of farmers worldwide
will improve the prospects for a competitive, progressive and
diverse agricultural industry, best equipped to meet future environmental
and economic demands.
4. The Implications of the Trial Results for
Government and Other Decision-makers
4.1 In addition to the points raised in
response to Question 3, the FSEs have provided a unique opportunity
to apply and evaluate the performance of on-farm guidelines for
managing GM herbicide tolerant crops, designed to ensure best
practice in the way the crops are grown, while providing choice
for farmers via co-existence between GM and neighbouring non-GM
crops.
4.2 This experience has demonstrated that
the protocols are workable in practice, robust in safeguarding
the integrity of GM and neighbouring non-GM crops, and capable
of being audited. As such they represent a significant contribution
to the development of effective policies which will allow the
co-existence of GM and non-GM (including organic) crops within
UK agriculture.
4.3 The SCIMAC guidelines build on existing
principles of good agricultural practice, and closely mirror the
proven system operated for more than 30 years to control the production
of certified seed crops. All aspects of on-farm operations are
covered, from seed storage and planting procedures to crop separation
distances, harvesting procedures, post-harvest management and
record-keeping.
4.4 In developing this approach, SCIMAC
has identified four key principles for co-existence between GM
and non-GM crops:
— Farmers, consumers & environment
must not be denied access & choice to approved new technologies
— No legitimate sector of agriculture
can veto another—access & choice work both ways
— Reality is that farming takes place
in the open air—zero is impossible but co-existence is achieved
(eg industrial vs food grade oilseed rape, certified seed production)
— Arrangements must be proportionate,
non-discriminatory, and determined by legal, practical & scientific
realities, not particular commercial or campaign objectives
4.5 Earlier this year, SCIMAC conducted
a survey of all growers involved in the FSE trials. Feedback suggests
that the vast majority (94%) found the SCIMAC guidelines straightforward
to follow. While growers identified increased requirements for
record-keeping and segregation, the overwhelming consensus was
that the guidelines offered an effective basis for managing co-existence
between crops on the same farm (97% of growers) and between neighbouring
farms (91% of growers).
4.6 An independent audit of farmers' compliance
with the SCIMAC guidelines was conducted at all FSE sites by ADAS
Consulting Ltd. The audit process, involving on-farm and telephone
checks, focused on eight critical control points throughout the
production process, from seed storage and planting to separation
distances, harvesting procedures and record-keeping.
4.7 ADAS confirmed there were no incidents
of non-compliance at these critical control points over the three
years of the trials from 2000 to 2002. There has been no loss
of non-GM or organic status throughout the trials process.
4.8 Taken together, this information indicates
that co-existence guidelines can be managed at the practical farm
level, and need not represent a major departure from current best
practice within the industry. SCIMAC's objective is to protect
choice and access to both current and new technologies, and to
develop arrangements which allow GM crops to co-exist with other
crop production systems. More remains to be done, but the FSE
experience indicates that significant progress has been made and
a sound framework established relevant to UK conditions.
5. The Costs and Benefits of GM Food, Bearing
in Mind the Potential Market, in the Light of the Farm-scale Trials
and the Recent Strategy Unit Report
5.1 It should perhaps be an explicit assumption
of the Committee's work that no technology provider, plant breeder,
farmer, processor or manufacturer would pursue the commercial
introduction of GM crop technology in the UK if there were simply
no market for it.
5.2 There are at least four potential markets
for GM crops grown in the UK. Food is one of them. Others are
animal feed, export or non-food use. There is significant potential
to apply GM technology in a non-food context, whether in improving
the economic viability of crop-derived biofuels (whose increased
use is a UK policy commitment) or in providing renewable sources
of specialist chemicals and fibres.
5.3 The current situation in relation to
GM crops and foods in the UK is largely one of restriction or
denial of choice—either to consumers themselves or to farmers
and others within the supply chain. In relation to imported GM
food ingredients, this may change with the introduction of new
GM traceability and labelling rules in April 2004. A recent survey
conducted by the Institute of Grocery Distribution indicated that
13% of consumers would use labels to avoid GM foods, 13% would
use labels to choose GM foods, while 74% were not sufficiently
concerned to take any action either way.
5.4 To date, the only clear example of UK
consumer reaction when offered a choice between comparable GM
and non-GM products was the tomato paste sold by Safeway and Sainsbury's
in the mid-1990s. As has been well documented, the GM product
outsold the non-GM equivalent by some considerable margin. While
recognising that the GM issue has moved on considerably since
that time, we do not subscribe to the view that there is wholesale
consumer rejection of the technology and its products in the UK.
The only meaningful way to gauge market response or consumer attitudes
is to provide a choice.
5.5 Equally, it is questionable whether
helpful projections of potential economic costs and benefits can
be developed on a generic basis. Genetic modification is a tool,
not an end in itself. As such it can be applied in different crops
to deliver a wide range of different traits.
5.6 The potential economic implications
of GM herbicide tolerance, for example, may be very different
from applications of the technology which are directed more towards
the processor or final consumer. Even within a single trait such
as herbicide tolerance, the economic implications at the farm
level will depend upon the specific management regime applied.
As recent research conducted by Broom's Barn on sugar beet has
demonstrated, it is possible to adapt the management of GM herbicide
tolerant crops to deliver specific environmental and/or economic
objectives. The economic benefits of GM sugar beet, for example,
were equivalent to £150/hectare. At the individual farm level
that is very significant indeed. The Strategy Unit report failed
to give adequate recognition of such opportunities, by focusing
on the overall economic impact likely to accrue from the limited
examples of GM crops currently in development to the UK economy.
It was hardly surprising that the headline result was little immediate
benefit, when one considers that the whole of agriculture represents
little over 1% of UK GDP.
November 2003
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