Memorandum submitted by the Agricultural
Biotechnology Council (abc)
GM MAIZE DECISION
1. BACKGROUND
1.1 The Agricultural Biotechnology Council
(abc) was set up in 2002 to provide a forum for debate and education
surrounding GM technology in the United Kingdom. The members of
abc are BASF, Bayer CropScience, Dow AgroSciences, DuPont, Monsanto
and Syngenta. These companies are working together to promote
a fair debate surrounding the production of GM crops and also
to provide education about GM in the UK.
1.2 In light of the recent extensive reviews,
consultation process and decision by the UK Government, we welcome
the Committee's inquiry and wish to submit the following evidence.
1.3 The industry fully recognises and supports
the need for a regulatory environment to work within, but believes
that, where legislation is required, that this should be enabling
and not disabling such that it becomes an unjustified barrier
to entry or fair competition.
2. CO -EXISTENCE
AND SEPARATION
DISTANCES
2.1 abc represents the companies which sell
products for all types of farming, be it GM, non-GM or organic.
It is therefore extremely important to the industry that all forms
of farming are able to co-exist.
2.2 abc welcomed the recent Government decision
that, in principle, allowed the growing of GM crops in the UK,
once sensible and proportionate co-existence measures are developed
and put in place. abc looks forward to consulting with government
and other stakeholders to develop such measures to ensure the
UK and UK farmers can choose to benefit from the full range of
agricultural practises that eight million farmers from around
the world are already able to.
2.3 In agriculture, a zero percent tolerance
is not measurable, not achievable and is therefore not a requirement
in non-GM and organic farming. This is true, regarding genetic
purity standards just as it is for natural or man-made toxicants.
Many types of agriculture have thresholds set that are readily
achievable through standard agricultural stewardship.
2.4 For example, the durum wheat used for
pasta must contain less than 3% of other cereals. Likewise, organic
food must be more than 95% organic to be labelled as such. Certified
cereal seed production works to standards of up to 99.7% purity.
2.5 The agricultural biotechnology industry
and the Supply Chain Initiative on Modified Agricultural Crops
(SCIMAC), recognise the importance of managing cross-pollination
between GM and non-GM crops in a practical way, to achieve within
reason standards requested by consumers.
2.6 The co-existence guidelines, which include
separation distances and other measures, proposed by SCIMAC, have
evolved over many years and aim to reduce cross-pollination to
below 0.9% in a worst-case scenario. In practice, if GM crops
are grown in accordance with these SCIMAC guidelines, an independent
review by the National Institute of Botany (NIAB) demonstrates
that the actual level of cross-pollination between GM crops and
nearby non-GM crops would be well below the 0.9% threshold. These
guidelines are currently undergoing further consultation and we
believe that this approach will offer a proportionate solution.
2.7 Clearly, no measure can entirely prevent
cross-pollination. It is important to remember that zero tolerance
cannot be achieved in any agricultural situation, including non-GM
and organic, hence the need for appropriate and sensible thresholds.
It is not acceptable for one form of farming to have a veto on
another; nor is it reasonable to impose the marketing wishes of
a small sector of the agricultural community on others. To allow
this would be to allow anti-competitive practice and market protectionism.
Industry has, and will continue to work with farmers to deliver
practices that reduce potential cross-pollination to an absolute
minimum within the farming situation. And we have many years of
experience in developing and implementing management practices
to produce certified seed crops, within strict purity standards.
2.8 Finally, it is worth noting that despite
extensive open-air trials of GM crops in the UK since 1989, the
SCIMAC guidelines employed have meant that no organic farmer has
lost their accreditation. This shows that the guidelines are effective
and allow genuine co-existence.
3. LIABILITY
3.1 "Contamination" is an emotive
word and one that industry does not support. The term implies
some harmful effect, which is not supported by the rigour of the
regulatory process for those crops approved for cultivation and
use. The question posed implies liability if cross-pollination
should occur even at minimal levels, well below legal thresholds.
It must be remembered that approved GM crops have been demonstrated
to be safe to both human health and the environment and therefore
do not pose a risk or cost on either of these grounds if they
are present at any level. The safety pre-requisite of each GM
crop is ensured because they are the tested extensively prior
to being brought to market and are no more likely to pose a risk
to human health or the environment than non-GM food.
3.2 However, like all industries, the biotechnology
industry is responsible for all its products, including GM products.
3.3 On the subject of co-existence, we maintain
that there is nothing unique about GM and the requirement for
it to co-exist with other agricultural practices that require
specific legal arrangements. Current laws are more than adequate
to adjudicate on issues of agricultural liability, whether that
liability may result from non-GM, organic or GM practices.
3.4 abc will enter into dialogue with the
Government on this issue in due course as part of their consultation
process and look forward to establishing practical, equitable
and proportionate rules for co-existence, allowing all forms of
agriculture to co-exist.
4. GM-FREE ZONES
4.1 The above discussions have shown that
GM crops can co-exist within the patchwork of farming that makes
up UK agriculture and for this reason we do not feel they should
be excluded as a choice for any UK farmer, should he or she decide
to grow them, regardless of where in the UK they farm.
4.2 Given that co-existence has been shown
to work, we do not feel that GM-free zones are required. All farmers
should be free to choose the agricultural practice they wish to
use, especially as their choice does not and will not impact the
agricultural choice of neighbouring farms. It will be for government
to decide how best to handle the pressure being generated by some
minorities to exclude GM agriculture from certain "zones".
5. WHAT CHANGES
TO LEGISLATION
WILL BE
REQUIRED TO
ALLOW GM CROPS
TO BE
GROWN?
5.1 This will be determined in the next
year, with the participation of industry and many other stakeholders.
abc looks forward to that process and reasonable practical and
proportionate requirements being introduced to ensure all forms
of agriculture are available for UK farmers to choose and benefit
from.
6. SCOPE AND
SCALE OF
THE 2006 RE
-LICENSING PROCEDURES
6.1 Under EU directives and UK regulations
governing the licensing of GM crops and food, approvals are time
limited. This is a normal regulatory requirement that industry
is happy to work within. Products, especially agricultural crops
and varieties have natural, and limited life spans. With this
in mind, the consent holders of some products may not seek re-licensing
in future years, but instead prefer to bring new and improved
versions of their products to the market. Again there is nothing
new or distinct to GM crops in this regard.
7. CONCLUSIONS
7.1 It is essential that government strikes
an appropriate balance between regulation and innovation. abc
looks forward to future consultations with government to ensure
this occurs in reference to GM crops.
7.2 abc believes that GM crops have been
shown to be a safe, reliable and environmentally responsible form
of agriculture. 67.7 million hectares are now grown globally by
eight million farmers in 18 countries. Cost savings, more targeted
pesticide use, water and soil conservation, reduced fuel use and
increased profit for farmers are the principal benefits that have
been realised as a result of using GM crops around the world in
the last nine years.
7.3 At the same time, this increased use
of GM crops offers no sign of environmental damage, human health
risk or safety concerns. We feel it is time that the UK joined
the rest of the world, including several of our EU neighbours,
in promoting the choice of using GM crops, rather than allowing
excessive restrictions, at the request of a vocal minority, to
limit the choices and economically disadvantage UK farmers.
The Agricultural Biotechnology Council (abc)
April 2004
| 
