Examination of Witnesses (Questions 360-379)
10 DECEMBER 2003
DR ROGER
TURNER, MR
DANIEL PEARSALL,
DR PAUL
RYLOTT AND
DR COLIN
MERRITT
Q360 Mr Challen: What does SCIMAC
say? Is SCIMAC happy with the way that the legislative developments
have taken place? It seems to me that to a certain extent we have
had the cart before the horse—getting close to commercialisation
and then we have some kind of halt whilst tests are taken and
assessments made. I am looking particularly at the effect on your
business of Annex 2, the European Directive 90/220/EEC, which
says that that requires an assessment of all direct, indirect,
immediate and delayed effects of the GM crops in the environment
to make sure that that is included in the application for consent
for the crop to be massed in the EU. Are you satisfied that that
is the right way forward and, if so, why was this kind of approach
not adopted before? That is, if I am right and I am just a layman.
Dr Merritt: In a way, this gets
into some fairly complex regulatory matters, which I would probably
even myself refer to more directly involved regulatory experts.
Let me try to give you some lead on that. I think certainly we
were at the time, as a company, of the opinion that the Directive
that you spoke of, which was 90/220, as we commonly refer to it,
did have within it many of the provisions to look at direct and
indirect effects of the crops on safety and the environment. Over
a period of time, it was becoming clear that there was going to
be a substantial change in terms of some additional elements under
this revised Directive, which we now have, to work with. At any
one time, we always find ourselves in a position of uncertainty
about what future regulation changes may be, and so we have to
work, as an industry, within what we see at the time, what we
anticipate to be going to happen. We had already been doing work
with the crops we were developing to address those kinds of questions.
I am sure you will be aware that we were involved in similar kinds
of biodiversity trials through the Danish Environmental Research
Institute and also through an institute in the UK called Broom'
Barn Research Centre. Those trials carried on and were already
ongoing at the time that the discussion about farm scale trials
came about. We are always trying to anticipate change, obviously;
we have to take into account what is going to help us bring our
products to market, but we do not always have very good crystal
balls about telling how things are going to change and when. That
is how we saw things. Does that help?
Q361 Mr Challen: Is it just purely
a case of anticipating what the legislation is going to be? Surely
you yourselves would want to test the safety of your crops, and
so on? It has been suggested that you did very little to look
at the biodiversity aspects.
Dr Merritt: Certainly in our regard
we do enormous amounts of testing. If I can make the comparison
with conventional plant breeding, that is orders of magnitude
different in terms of how much safety testing and environmental
types of tests are done on products of biotechnology. Indeed,
as was made very clear by government departments at the time of
the farm scale trials—and I think this is a very important
question to the public—had not many of these kinds of tests
for safety already been done, the crops would never have been
approved for field release in the first place to do trials. We
had been conducting trials, literally hundreds of trials, in the
field for about eight years before that discussion came up for
farm scale trials.
Q362 Chairman: Is it not the case,
though, and perhaps Dr Turner would like to answer this question,
that the bearing of what you have told us is that if it had not
been for English Nature stirring things up in 1998 and expressing
concern about the impact on biodiversity, commercial planting
would have taken place a great deal earlier and could even have
taken place as early as 1999-2000?
Dr Turner: In theory, yes. I think
there was a lot more going on as well as that with English Nature.
The environmental groups were also pretty active. English Nature
had a bigger role because, as an adviser to government, they would
have to be listened to in that sort of respect. I do not know
if the right words are that the flow to the market place was getting
constipated and English Nature helped stop that process.
Mr Pearsall: Perhaps I could add
that the whole issue of how any potential commercial introduction
of the technology might occur stretches back really to July 1997,
which was the origins of the SCIMAC group and when the newly-elected
Labour Government issued a consultation, a fairly technical consultation,
into the agronomic implications of new types of herbicide tolerance
on the farm. It was made quite clear within that consultation
that the status quo was not an option. New legislation
at a European level, or new legislation at a UK level, or a complete
ban on the technology were among the options, as was a code of
practice for managing the agronomic implications of herbicide
tolerance. This was to look at issues like volunteer control,
which are of relevance at a farming level; they do not have any
safety implications. From that point, certainly industry, through
the umbrella group SCIMAC, developed a code of practice and a
set of guidelines for managing these crops on the farm. I think
that gave rise to a concept of managed development of the technology
in terms of its commercialisation. I do not think at any stage,
post-1997, there was a question of a free-for-all or a rush to
market. This was a question of looking at guidelines and how the
technology could be managed. Industry took the lead, through SCIMAC,
in acknowledging that there was a need to respond to the question
of choice, both in terms of choice for the farmers to access different
forms of production, be it GM or conventional, or organic, and
choice for consumers too. Certainly that underpinned of the development
of the guidelines with the objective of best agricultural practice
in the agronomic sense and co-existence between GM and non-GM
crops in the context of choice. The issue of managed, step-wise
progress towards commercialisation was an issue well before any
concerns around biodiversity raised by English Nature.
Q363 David Wright: I am interested
in that last response because one of the problems that we seem
to have uncovered throughout this inquiry is that there has not
been enough comparator evidence with organic farming. It is all
very well Dr Merritt suggesting that GM crops have been compared
with conventional crops extensively. I think one of the problems
you have presentationally, and also technically, is that there
is not enough understanding about comparing GM crops with organic
growing. What is your reaction to that? You seem to be indicating
that that was considered in your initial work in 1997?
Mr Pearsall: I have to draw a
distinction here between biodiversity considerations, which I
think are what you are referring to, and these agricultural issues.
The guidelines that were developed by SCIMAC were not in any way
designed to further or promote biodiversity; they were about delivering
good agricultural practice. In relation to the question of different
farming systems, the background again to the farm scale evaluations
lay in a consultation in late 1998, issued again by the UK Government,
into the calls for a moratorium: were there any grounds for the
calls for a moratorium? Clearly, there were different viewpoints
put forward, but the overriding conclusion of that consultation
was that there was precious little data about the ecological impact
of conventional agriculture generally, let alone the impact of
new types of herbicide-tolerant crops developed using genetic
modification; hence, the rationale for a comparison between conventional
and GM technology. In relation to the crops involved in the FSEs,
I think the scale of cropping under organic systems of those particular
crop species is very limited. Sugar beet and oil seed rape particularly
are not commonly grown in the UK under organic systems.
Dr Turner: There was another problem
as well. It may sound facetious but the organic rules said: keep
three miles distance between the GM crop and its organic counterpart.
It would be very difficult to do a valid scientific comparison
if you have one plot in Suffolk and another one in Norfolk.
Chairman: That does sound, if I may say
so, a little facetious.
Q364 Mr Thomas: We are obviously
looking, as a Committee, at trying to understand exactly how these
trials came about, the reasons for them and their impact now on
the results that we have been seeing. I think it would be fair
to say that the public at least, if they know anything about these
trials at all, saw them as a sort of quid pro quo with
the industry, that there was going to be a moratorium on commercial
GM crops in this country while the trials went on looking into
the impact of such GM crops and the herbicide regime that went
with them. Could I start with Dr Turner from SCIMAC: would you
agree that this was a moratorium in that sense?
Dr Turner: I do not think so.
I think we saw it more as a breathing space. I spoke earlier about
the regulatory process slowing down. I think we felt that, if
there was going to be this breathing space, there was an opportunity
to do something positive within that breathing space. The questions
raised about seed impact on biodiversity, et cetera, sounded
like a very good idea, to fill that apparent blank spot.
Q365 Mr Thomas: Could I ask the companies
if they agree with that? Do you think this was a de facto
moratorium?
Dr Rylott: No, not at all. It
was very clear from the start of the discussions, as Daniel Pearsall
mentioned earlier, from these original consultations, that on
the horizon was the advent of 2001-18. What we saw here were four
crops that were already through the regulations and therefore
would not be backdated to come under the 2001-18. They would come
under the 2001-18 when they were renewed in 2006-07 on that sort
of basis. It was very clear, from discussions with the UK Government,
that they saw that this was not necessarily the most helpful approach
and that they wanted to regulate in advance of the 2001-18 coming
into place on 17 October, 2002 and that the UK would look at everything
as if 2001-18 had come into place. Therefore, there was a need
to look at indirect effects, for example. Clearly there were two
opinions on what the indirect effects would be from the growing
of GMHT crops. One view was that adopted by some of the environmental
groups and English Nature, that it would stimulate this sort of
green concrete approach; there would be no weeds in the crops,
therefore there would be less biodiversity and less food for birds.
The other approach was that coming from industry, and that was
very clearly taken from work that Colin Merritt referred to earlier
at such places as Brooms' Barn but also from our commercial experiences
around the world, that said: actually these crops can be grown
in a much more flexible way and can improve the biodiversity in
the areas in which they are being grown. There was this dichotomy
and there was a need to take it forward on a sensible, case-by-case
basis. The farm scale evaluations were seen to be answering the
question. Clearly, I think everyone would agree there was not
UK-specific, truly independent data that everybody could look
at, and also it was addressing the situation about this regulatory
gap between 90/220 and 2001-18. We never saw it as a de facto
moratorium. The other point that needs to be stressed here as
well is that we were very clear with Government at that time,
and it came all around the voluntary agreement there was with
Government, that it was not a de facto moratorium, and
in fact all of the regulatory clearances, such as National Listing
and herbicide clearances and whatever, could continue during this
period of the farm scale evaluations. It was not a close-down
of the progress of regulation at all.
Q366 Mr Thomas: I am sure that later
on the Committee will come to the results of the trials and how
we interpret those results. Just focusing at the moment on what
you are saying, that the agreement with Government was more, as
Mr Pearsall referred to earlier, about this programme of managed
change, if you like, within the environment, again to Dr Merritt
and Dr Rylott: now that we have had the field scale evaluations,
moratorium or not as the public may have seen it, are you now
intending to go ahead with the introduction of either of these
crops or any other crops through the regulatory process within
the United Kingdom? Do you now see the field clear? Your agreement
with the Government to withhold a little bit, if you like, while
you look at the field scale evaluations is now over; we have the
results of the evaluations and we await the final results of the
winter Soya coming out next year. Do you now see your way clear
to move forward with this technology?
Dr Rylott: The first thing to
say, in answer, is that, following on from the farm scale evaluations
but also from the whole of the GM debate that we had this year,
what we now have is even more evidence that there is absolutely
no case whatsoever to be banning GM crops. We are looking forward
to the case-by-case, scientifically-based, regulatory clearances
to allow choice to go ahead. We will be taking the crops forward
on an economic, case-by-case, scientific basis as soon as possible.
Q367 Mr Thomas: Do you agree that
these farm scale evaluations give that evidence for all three
crops that were tested?
Dr Rylott: Yes.
Q368 Mr Thomas: You do not see any
reason not to go ahead with any of these crops on the basis of
these results and their effect on biodiversity?
Dr Rylott: No.
Q369 Mr Thomas: Do you agree with
that, Dr Merritt?
Dr Merritt: I think that if you
look at the scientific papers, which we have now had a chance
to do in detail, and you compare that to a number of other pieces
of work, if all the information is put together, then we are faced
with a situation of some choices to be made maybe and some further
discussions. If all the right parties are able to take part in
that process and the regulatory system is finally working again,
I certainly think a balanced judgment would conclude that there
are ways in which to introduce these crops for the benefit of
farming and the environment right now.
Q370 Mr Thomas: Could anyone from
SCIMAC make a prediction as to when we will see commercial GM
crops grown in this country?
Dr Merritt: We never like to predict
regulatory outcomes, I am afraid. We have learnt that.
Q371 Mr Thomas: But you do see it
as only being a question of regulatory outcomes, is that right?
Dr Merritt: I think regulatory
decisions must be the primary driver of this, but obviously clearly
within Europe and in the UK politics plays a very strong part
in it as well.
Mr Pearsall: I think we would
recognise the fact that there will not be such a thing as an unconditional
consent or an unconditional route to market. That is now enshrined
in the new Deliberate Release Directive requiring management measures
like post-market monitoring. Any consent to market will inevitably
be linked to conditions. Besides those specific regulatory requirements,
certainly within SCIMAC we are acutely aware of the need to develop
arrangements which will allow coexistence and choice. That ultimately
is our objective.
Q372 Mr Thomas: Is it fair to say
that you are keen to get back on this programme of management
development now. The field scale evaluations were not a hiatus
but time out, if you like—that is a better way of putting
it than a moratorium perhaps—and you are keen to crack on
with that?
Dr Merritt: Yes.
Mr Pearsall: It is worth pointing
out that the two issues that we have referred to, the agronomic
questions raised in the consultation in July 1997 and the questions
over wider indirect effects, would, in the normal run of things,
in normal commercial agriculture, be addressed post-commercialisation.
We have had 30 years to develop low input systems, such as ICM
(Integrated Crop Management). A complete halt to commercial activity
in agriculture was not required to develop and refine those kinds
of management systems. We would look at the farm scale evaluations
as an investigation of a particular management option, which we
described in our memorandum as a worst case scenario, and point
to other research and other experience, which suggests that one
of the great advantages of this technology lies in its flexibility.
We would see that as the focus of a phased approach to managed
introduction, with biodiversity considerations as well as economic
considerations for the farmer very firmly in mind.
Q373 Mr Thomas: Finally, may I turn
to one particular crop which we have been trying to understand
as a Committee, and that is beet. I understand, Dr Merritt, that
Monsanto originally offered to pay for the FSEs on beet. Is that
correct?
Dr Merritt: I do not recall that,
no. If I can clarify that perhaps, first of all beet is a co-operative
crop between ourselves and other companies which are involved
in the seed production. We are actually not involved in the seed
production of beet. In particular, in the UK it is Sygenta; at
the beginning of that; they have changed hands during that time
but it was originally Novartis Seeds before Sygenta. Because at
that stage Government had already seen the regulatory programme
or dossiers and they dealt with two approvals, as Dr Rylott has
explained for the other crops, the beet crops were a little behind
that in the regulatory system under the Commission. Fodder beet
was in the lead and had actually then, during that first year
of discussions, been seen by our competent authority, the Chemicals
and Biotechnology Directorate, and they were still I discussion
as to whether to include that crop in the programme. That was
actually what we called the preliminary year in which some methodology
was being established on a small number of trials prior to the
full three to four year programme, which started in 2000.
Q374 Mr Thomas: Was beet one of those?
Dr Merritt: At that stage, beet
was not one of the crops. As it was only a methodology year for
the scientists to understand how best to do these trials, to work
out the best assessments and statistics, between ourselves and
Sygenta, we agreed to set up a single trial, which we did fund,
to enable that methodology work to be done, or at least some methodology
work to be done. Then, by the end of that year, when in fact fodder
beet had actually been up for a vote twice, which was then subsequently
postponed for various reasons in the European Commission, at least
by that stage it was much more clear to Government that beet was
very close to the situation that the other crops were in. They
then decided that, yes, after all, they would like to include
the beet crop.
Q375 Mr Thomas: Can I ask Dr Turner
from the SCIMAC perspective, because we have heard about the relationship
with the Government on beet. SCIMAC itself had to take beet on
board at some stage. How did that happen? Was it the company that
approached you? Was it Government that said that you had to look
at this? Can you explain to us how that came about?
Dr Turner: It was much more a
consultative approach. No one wanted beet left out and then three
years later commercially it would be slowed right down. I think
it was a whole series of interactions between SCIMAC, the individual
companies and Government as to which was the best way forward
that met all the legal approvals and all the scientific criteria
as well.
Q376 Mr Thomas: There was no concern
there that beet was not quite ready for such a field scale evaluation?
Dr Rylott: No. In fact, if you
go back right to the instigation of SCIMAC and the original codes
of practice and guidelines that were ratified by Government at
the end of 1998, there were clear guidelines for all the crops
that were involved in farm scale evaluations, and so we saw the
commercial introduction of all the crops coming at about the same
time. It was clear to the industry group that they needed to be
taken together so that you had guidelines for growing sugar beet,
maize and oil seed rape.
Q377 Chairman: Before moving on from
that very interesting series of questions, it would be pertinent
to suggest to you that your confidence that the farm trial evaluations
showed that there was no problem whatsoever about the commercial
development of some of these crops is highly contentious. But,
if you were to go ahead, where would those seeds come from? Presumably
they would have to be imported, would they?
Dr Merritt: It varies from crop
to crop.
Q378 Chairman: Do they exist within
the United Kingdom in sufficient quantity for commercial operations?
Dr Merritt: Most of those crops
are not actually involved in seed production in the United Kingdom.
Sugar beet seed production is predominantly either in Scandinavia,
southern France or the United States. Maize and rape seed you
can explain. Rape seed you can scale up fairly quickly.
Dr Rylott: Obviously rape seed
can be grown in the UK quite successfully. You cannot grow forage
maize seed in the UK because of the climate. It is produced in
Hungary, Chile and places like that.
Q379 Mrs Clark: Can I take us on
to a different topic in terms of farmers and the actual provision
of sites? I would like to start by addressing SCIMAC. I had understood
that you actually did come up with a list for the SSC of farmers
who were willing to co-operate in trials and the SSC then went
on and provided that to the research consortium. It has been noted,
and correct me if I am wrong, that the farmers who actually self-selected
and put themselves forward were on board anyway, that they were
pro-GM, and therefore, shall we say, rather more positive friends
to the industry than others might have been. I would like to ask
SCIMAC what the specific criteria were for the sites that you
passed on to the consortium and the SSC. Was it in fact just simply
that farmers were on board and were willing to co-operate and
had grown the conventional varieties involved before? Was it anything
more definite than that?
Dr Turner: You have some misconceptions
there. We have a network of contacts because we all work in agriculture
but it was not a pre-selection that they were pro the technology.
In fact, many came in with a neutral view and subsequently, if
you like, have become converted, having seen the crops in action.
In many cases one of the key criteria was that they had actually
grown the crop before. Some farmers said, "Yes, I would like
to have a bash at crop X", and we said, "No, you do
not actually grow that on your land. You are not familiar with
it and so there is no point in you coming into that". We
then used a range of networks through the NFU, the Maize Growers'
Association, our own contacts with seed producers, et cetera,
to produce that list. That was then subsequently offered on to
the scientific consortium to make their pick from within it, using
their technical and scientific criteria.
|
