Advanced genetic techniques for crop improvement: regulation, risk and precaution - Science and Technology Committee Contents

Conclusions and recommendations

Terminology and the framing of the debate

1.  The term genetic modification, or GM, is most commonly used to describe a transgenic process in which a gene from one organism is inserted, often at random, into the genome of another organism of a different species. This fails to accurately portray the wide range of techniques through which targeted genetic changes can now be introduced into crops, which include same species cisgenic transfers, precise point changes to the plant genome and epigenetic modifications that do not alter the underlying genetic sequence. In our view, it is time to update this imprecise and problematic terminology. (Paragraph 18)

2.  We recognise that the term GM has become embedded in everyday language and is now often used imprecisely to encompass a whole range of technologies. In this report—except when quoting from evidence or using legally significant terminology—we will attempt to avoid using the term 'GM' and will use the phrase 'genetic modification' only when referring specifically to the first generation transgenic techniques to which it has historically been applied. We will avoid this terminology when referring more broadly to the full range of advanced genetic techniques currently in development. We recommend that the Government initiate a reframing of the public conversation by similarly moving away from the overly simple notion of 'GM' in its own policies and communications. (Paragraph 19)

3.  We do respect that people have every right to such views but restate our earlier observation that those views on ethical or moral grounds should not imply or claim that those objections have any basis in scientific evidence. (Paragraph 27)

4.  We received no evidence to suggest that genetic modification, or any other single technology, was widely viewed as a potential cure-all for global agricultural problems. It is clear that a diversity of approaches—technological, social, economic and political—will be required to meet the challenge of delivering sustainable and secure global food production. However, advanced genetic approaches do have a role to play. We are convinced by the evidence provided to us that this suite of technologies is a potentially important tool, particularly in the developing world, which should not be rejected unless there is solid scientific evidence those technologies may cause harm. (Paragraph 30)

5.  By constantly framing genetic modification alongside other novel, controversial or potentially harmful technologies (for example, nanotechnology, animal cloning and pesticides), the Government encourages the public to understand genetic modification in the same terms. By failing to widen its framing beyond the narrow concept of 'GM', the Government also perpetuates old debates and preserves the perceived distinction between genetically modified and conventionally bred plants. Finally, by publicly insisting that decisions about this technology be made on the basis of scientific advice alone, the Government shuts down opportunities for wider debate and encourages those who are simply opposed to the technology to continue to contest the science. We recommend that both the Government and the Food Standards Agency review their public communications on genetic modification and related topics to ensure that these are framed in a way that encourages constructive public debate. Advice on this process should be sought from the Sciencewise expert resource centre and identified changes should be made by the end of 2015. (Paragraph 135)

Devolution of decision making

6.  The hard won amendment to the Deliberate Release Directive is intended to ease problems with the operation of the regulatory system by ceding more power to Member states. However, it does nothing to resolve underlying weaknesses in the regulations or to prevent those hostile to GMOs from voting against authorisation in order to maintain the current EU-wide 'ban' on GMO cultivation. It may also do little to attract the agricultural biotechnology industry back to Europe. We commend those Governments that have provided leadership in attempting to secure more fundamental legislative change but share their view that the agreed amendment is far from satisfactory. (Paragraph 90)

7.  In our view, decisions about access to and use of safe products should be made by national governments on behalf of the populations that elected them, not by the EU. The most significant flaw in the current EU regulatory system for GMOs is its continued failure to enable Member states to make such decisions without prejudice. We remind those in the EU who are opposed to GMO cultivation that the purpose of shared regulation should be to ensure mutual protection from unsafe products, not to unjustifiably restrict the choices available to other elected governments and the citizens whom they represent. We encourage all member states to vote in favour of authorising those products that have been deemed safe by the European Food Safety Authority so that national governments can make their own decisions about how best to act in their electorate's interests. (Paragraph 91)

8.  We also encourage the new President of the European Commission, Mr Jean-Claude Juncker, and the new Health and Consumers Commissioner, Mr Vytenis Andriukaitis, to bear this point in mind in their planned review of the procedural rules governing GMO authorisation. (Paragraph 92)

9.  This Committee does not scrutinise the policies of the Devolved Administrations but we hope that they note the observations of this report and understand that foods, most especially animal feeds, increasingly contain elements of genetically modified crops despite their inclination not to permit the growth of such crops. (Paragraph 24)

10.  While recognising that agricultural policy is a devolved area and respecting the right of the Devolved Administrations to maintain a restrictive approach to the use of advanced genetic crop breeding techniques, we reject the Scottish Government's suggestion that this policy has a scientific basis. We encourage all of the Devolved Administrations to take an evidence-based approach to policy on the use of advanced genetic approaches to crop improvement. Where policies are based on other considerations, this should be made clear: allegations of scientific uncertainty should not be used as a pretence for value-based objections. (Paragraph 25)

Publicly funded research and development

11.  We do not consider an annual Biotechnology and Biological Sciences Research Council investment of £4 million—from a total budget of nearly £500 million and a plant science budget of £70 million—to represent an excessive investment in advanced genetic approaches to crop improvement. We are also content that the Government's approach to agricultural research is balanced and does not focus excessively on genetic techniques. We therefore reject the claim that preferential investment in this field has prevented research from progressing in other areas of agricultural research. (Paragraph 37)

12.  Claims of funding bias are difficult to refute on the basis of the information on government research spend that is currently published. We recommend that the Government's annual Science, Engineering and Technology statistics be enhanced to provide greater aggregate detail on the areas of research in which public funds have been invested. We also recommend that each UK Research Council includes an aggregated breakdown—for example, at the level of each strategic 'theme'—in its annual report and provides additional information on past funding decisions in areas where there are common misconceptions, such as plant science. (Paragraph 39)

13.  We have not been convinced by the argument that the application of intellectual property rights to genetically advanced crops has hindered other innovation trajectories and we have seen little evidence to support claims that patents pose a significant barrier to independent research. However, it is clear that this subject raises strong emotions and we agree with the Royal Society that this is a complex matter that warrants further consideration. We recommend that the Government conduct a review of the intellectual property landscape, specifically in relation to agricultural technologies, and its potential impact on the commercialisation of both conventionally bred and genetically improved crops. We would expect this to be delivered to our successor Committee by the end of 2015. (Paragraph 43)

14.  We recognise that the debate about innovation in agriculture is often too narrowly framed around the single subject of 'GM' and we agree that this has likely led to an unnecessary polarisation of views. However, we see no compelling evidence that this has 'locked out' alternative innovation options: if anything, it may have had the effect of prejudicing the public against advanced genetic approaches. (Paragraph 45)

15.  It is clear from the evidence we have received that fears that the pursuit of advanced genetic approaches to crop improvement inevitably 'locks out' alternative technologies and solutions are ill-founded. Nevertheless, we recognise the need for society to remain open to a variety of innovation trajectories and for policy-makers to look beyond the single dimension of economic growth when considering the potential costs and benefits of any emerging technology. (Paragraph 47)

16.  In this respect, we endorse many of the recommendations of the Nuffield Council's recent report on this subject and reiterate our previous conclusion that the Government Office for Science is not best located in the Department for Business, Innovation and Skills, where its frame of evaluation risks being invariably dominated by economic considerations. In its response to this report, the Government should set out how the Nuffield Council's work on emerging biotechnologies has informed its research policy. We are particularly interested in how it has responded, or intends to respond, to the Council's call for structural reorganisation. (Paragraph 48)

EU regulation and agricultural innovation

17.  It is clear to us that an interpretation of the precautionary principle has significantly influenced the EU's approach to GMO regulation and we consider the claim, made by a representative of the European Commission, that the principle has never been implemented for GMO authorisation to be, at best, disingenuous. If the precautionary principle is to avoid being used as a political tool, greater clarity is needed regarding when, and how, it has been used. In order to avoid future ambiguity, we recommend that the Commission clearly and publicly state when it has drawn on the precautionary principle in the policy formation process. (Paragraph 53)

18.  A regulatory system under which it takes many years—sometimes decades—to reach a decision cannot possibly be considered fit for purpose. Evidence clearly shows that the current EU regulatory regime for GMOs is not working, and has not worked for some time. We await signs of whether the recent changes will significantly change the outcome for companies seeking approval to grow GM crops in Europe. (Paragraph 59)

19.  The current EU legislative framework for novel plants is founded on the premise that genetically modified plants pose inherently greater risk than their conventional counterparts. The weight of peer-reviewed scientific evidence, collected over many years, has shown this to be unjustified. Where genetically modified crops have been shown to pose a risk, this has invariably been a result of the trait displayed—for example, herbicide tolerance—rather than the technology itself. We are disappointed that the Government has not more publicly argued this fact. We recommend that the Government publicly acknowledge that genetically modified crops pose no greater inherent risk than their conventional counterparts. A statement recognising this fact should be included in the Government's response to this report and relevant areas of GOV.UK should be updated to reflect this. (Paragraph 68)

20.  The EU's process-based regulatory system for novel crops is increasingly proving itself to be incapable of dealing with advances in technology. This raises the prospect that potentially important agricultural innovations will be hindered, or even halted, by inappropriate regulation, while potentially harmful crops may escape appropriate control if they are produced using techniques not captured by GMO regulations. (Paragraph 70)

21.  We consider the current process-based EU legislative framework for GMOs to be fundamentally flawed and unfit for purpose. (Paragraph 71)

22.  We acknowledge that there is a need to "tread carefully" with regard to trait-based regulation and recognise that a change in UK policy on this issue is unlikely to pay immediate dividends. However, we consider it likely that a move to trait-based regulation at EU-level will eventually be forced by technological progress and suggest that the Government would be wise to prepare for such a change. We recommend that the Government formally adopt a move to trait-based novel plant regulation as a long-term policy goal and begin to develop its preferred framework for such a system so that this can inform EU discussions. The Government should provide our successor committee with an update on this work by the end of 2015. (Paragraph 73)

23.  In the meantime, we urge the European Commission to take a pragmatic and evidence-based approach to its development of policy regarding emerging techniques for genetic crop improvement. We remind it that such techniques are likely to be vital to ensuring future global food security and that inappropriate regulation may have significant negative consequences for both the UK and the EU as a whole. (Paragraph 74)

24.  In attempting to centralise decision-making about risk management, the current EU regulatory system limits the ability of member states to take local political factors into account. The result is undue politicisation of the risk assessment process. Those opposed to genetic modification seek to exaggerate scientific uncertainty in order to block or delay authorisation. This, in turn, leads to stalemate at the voting stage, where strongly conflicting political positions inevitably prevent agreement from being reached. To resolve this, decision-making about risk management, including the decision whether or not to cultivate an authorised GMO, must be repatriated to member states. We consider the current EU regime to be at variance with the principle of subsidiarity. We remind the Council, the Commission and the Parliament of their responsibility to observe this principle. (Paragraph 85)

25.  We understand the challenge of securing major legislative change in the EU—particularly in relation to this subject—and therefore the Government's inclination towards delivering small improvements to the current regime rather than attempting a more significant overhaul. However, fundamental flaws in the design of this legislative framework have created a regulatory process that is not fit for purpose, has driven research activity out of the EU and which is putting the UK's agricultural future at risk. Substantial regulatory reform is no longer merely an option, it is a necessity. We recommend that the Government publicly state its long-term commitment to major reform of the EU legislative framework for genetically modified organisms and other novel crops. (Paragraph 94)

26.  We urge the European Commission to consider the conclusions and recommendations set out in this report and provide our successor committee with a formal response, by the end of 2015, to those issues for which it has responsibility. (Paragraph 95)

Taking account of risk

27.  Good risk management requires the potential benefits of an action to be thoroughly considered alongside the risks. It also requires a consideration of the risk of failing to act. Current GMO legislation fails to adequately recognise this point and the European Commission, as risk manager, has proved itself incapable of taking (or unwilling to take) these factors into account on a discretionary basis. This has led to a one-sided decision-making process and has sent a misleading message to the public about the potential value of these products, to the economy, society and the environment. We urge the Commission to give greater recognition to the full array of potential social, economic and environmental benefits offered by GMOs and the potential consequences of failing to adopt these products during EU risk assessment and risk management processes. (Paragraph 77)

28.  Science and politics each have a role to play in both risk assessment and risk management. However, while risk management is rightly a politically-led process, risk assessment must be led by science if it is to effectively contribute to evidence-based policy-making. This distinction has not been sufficiently observed in the EU's regulation of GMOs. (Paragraph 84)

29.  We agree with the European Commission that a precautionary approach is appropriate in circumstances where scientific evidence is insufficient, inconclusive or uncertain and when there is reason to believe that potentially dangerous effects on the environment, human, animal or plant health might result if precaution is not exercised. However, it is clear from the evidence that we have received that these conditions are not met simply because a crop has been produced via genetic modification. Continued recourse to the precautionary principle in relation to all genetically modified crops is therefore no longer appropriate. Indeed, it has acted as a barrier to progress in this field. (Paragraph 100)

30.  There are vast discrepancies between the European Commission's stated approach to applying the precautionary principle and its adoption in practice. Uncertainty about how the principle is being used at EU level is not helped by the lack of a consistent definition. We recommend that the European Commission consult with stakeholders in order to update its 2000 'Communication' on the precautionary principle. The updated document should include a clear definition of the principle and should stipulate the necessary conditions for it to be used as a basis for EU policy. In future, when the European Commission draws upon the precautionary principle in its policy making, it should publicly state: a) how the controlled activity meets its specified conditions for recourse to the precautionary principle; b) how measures adopted in response align with the general principles of risk management (described above), and c) what is being done to resolve uncertainties and render continued precautionary measures unnecessary. (Paragraph 102)

31.  We remind the Commission that any legislation guided by the precautionary principle must allow for an exit from precautionary measures once there is strong scientific consensus that any risks are low. (Paragraph 103)

32.  We have already acknowledged the considerable relevance of societal concerns to decision-making about risk and reiterate the need for non-scientific factors to be considered alongside scientific risk assessment during the risk governance process. However, the precautionary principle was designed primarily as a response to scientific uncertainty, not value-based ambiguity. Such ambiguities are common in emerging areas of science and technology and are also often intractable; recourse to the precautionary principle in these scenarios would therefore potentially act as a permanent barrier to the use of safe innovations. Where value-based ambiguities exist, public discourse, not scientific risk assessment, should be pursued as a route to greater legitimacy. (Paragraph 109)

33.  We recommend that the Government give greater consideration to the value that participatory processes might contribute to its own treatment of risk and uncertainty in policy development. We particularly refer the Government to the Risk Governance Framework and Safe Foods Initiative and ask it to set out how the perspectives offered by these documents will inform its future approach to risk governance policy. (Paragraph 110)

34.  The Government recognises the importance of properly understanding and applying the precautionary principle, but it is not clear that it has done so. Government explanations emphasise the need for decisions made under the guidance of the precautionary principle to be based on a "full science-based evaluation", but fail to recognise that such evaluations are often impossible in those circumstances when precaution is most needed—that is, in situations of scientific uncertainty or ignorance. The Government Chief Scientific Adviser's first annual themed report, on the subject of innovation and risk, has done little to clarify this situation. The Government should prepare a short document, informed by wider consultation, detailing its understanding of the principle and the circumstances in which it intends to use the precautionary principle as a guide to policy making. This should be made publicly available by the end of 2015. (Paragraph 113)

Public understanding and debate

35.  The term 'GM' has become a lightning rod for much broader public anxiety, in particular regarding our environmental future and the level of control wielded by large multinationals. These are legitimate concerns, but are currently centred on an inappropriate target. Whether a GM product is 'good' or 'bad', either for the environment or for society more broadly, should focus more clearly on how it is used than the technology utilised to produce it. This fact is lost in the continuing focus on 'GM'. There is a need to reframe and widen the public debate to encourage a more productive conversation about what we, as a society, want from our food supply and what sort of agriculture we would like that supply to be based upon. (Paragraph 121)

36.  Evidence suggests that members of the public currently find it difficult to develop an informed opinion about whether or not they support technologies such as genetic modification. This needs to change if there is to be meaningful public debate and if future policy is to be usefully informed by the insights that such debate can bring. (Paragraph 124)

37.  We have performed no detailed study of BBC coverage for this inquiry; however, we again emphasise the central role that the BBC plays in communicating science and remind it of its responsibility, as a public sector broadcaster, to promote learning and encourage conversation and debate about this important topic. We encourage all of the media, particularly public broadcasters, to conduct a review of their own content on genetic modification, 'GM' and other related topics to ensure that it is fulfilling these public duties. In particular, consideration should be given to how this topic is framed and whether it is being considered broadly enough in the context of other agricultural methods and wider issues of food production and food security. (Paragraph 127)

38.  We are each entitled to our own opinion and value-based opposition to genetic modification, or any other technology, is perfectly legitimate. However, this does not justify knowingly and willingly misinforming the public. We strongly urge those seeking to inform the public about genetic modification and other advanced genetic plant technologies to provide an honest picture of the scientific evidence base and the regulatory controls to which these products are currently subject. Where opposition to such technologies is value-based, this should be openly acknowledged and should not be concealed behind false claims of scientific uncertainty and misleading statements regarding safety. (Paragraph 129)

39.  We question the basis for Greenpeace's opposition to golden rice—a crop that is undergoing rigorous safety evaluations and has the potential to help protect many hundreds of thousands of children in the developing world from preventable blindness and early death—and question its public claim that this crop is "environmentally irresponsible" and "poses risks to human health". We recognise that biofortification cannot replace a balanced diet but remind those who oppose golden rice that the best should not be the enemy of the good. We urge those organisations that actively campaign against the take-up of golden rice in other regions of the world to carefully consider how this position impacts on their professed humanitarian aims. We recommend that all such organisations—and specifically Greenpeace—review their public communication materials to ensure that they are evidence-based and honest in setting out the reasons for opposition to this technology. (Paragraph 132)

40.  We highlighted in our previous report Communicating climate science that failure by government to engage with the public on controversial topics could create a vacuum in which inaccurate arguments are allowed to flourish without challenge. While the Government has been vocal in its support of genetic modification, it has done little to ensure that the public have access to the resources they need to come to an informed opinion, enabling those with vested interests to dominate the debate and ensure that it remains polarised. No source of information, scientific or otherwise, is ever entirely value-neutral, but the Government must do more to influence the narrative and direct people towards other accurate sources of information. We recommend that the Government work with the National Academies, in collaboration with Sciencewise, to develop a new online information 'hub' covering emerging topics in science and technology. This should include sections on both climate science and new plant breeding technologies. Each topic area should provide a basic overview of the current evidence base, acknowledging uncertainties where they exist, and should make reference to both scientific and non-scientific considerations. A range of links to other reliable sources of information on all of these aspects should be provided, so that people can tailor their learning to their own priorities and concerns. In the longer term, we envisage this resource becoming a centre for both public information and public debate; the starting point for a more active dialogue about developments in science and technology, especially those related to policy. (Paragraph 141)

41.  Public discourse should play a key role in informing policy concerning society's use of science and technology and Sciencewise is central to ensuring that this is ingrained in the policy-making process. We recommend that the Government renew its support for Sciencewise and commit to stable or uplifted funding over the next five years. (Paragraph 148)

42.  The Government Office for Science's planned dialogue project on the UK food system is a positive step and, we hope, will enable the Government to think more broadly about the public's priorities and concerns in relation to food production. However, in our view this small-scale project does not go far enough. What is needed is a far broader, more substantive and inclusive public conversation. We recommend that the Government use the current project as a springboard to a more substantial public dialogue on the future of the UK food system. This should be on a similar scale to the 2003 'GM Nation' debate, but should draw upon the lessons learned from that exercise and should utilise the information hub recommended in paragraph 138 as an additional centre of dialogue. The information gained from this process should inform the direction of future policy in these areas. We ask that the Government set out in its response to this report a high level plan for this exercise, together with a proposed timeframe and initial budget. (Paragraph 151)

The Advisory Committee on Releases to the Environment

43.  In order to shift both regulatory and public focus from process to trait, the Government must lead by example. It must also take steps to ensure that it is receiving appropriate scientific advice on the risks posed by cultivating conventionally-bred novel plants. We recommend that the remit of the Advisory Committee on Releases to the Environment be expanded to include cultivation of all novel plants, including those not legally defined as genetically modified organisms. The name of the committee should be amended to reflect this expanded remit. (Paragraph 137)

44.  When making decisions about emerging issues in science and technology, we consider it important that a broad range of social and ethical factors be taken into consideration. These should be considered alongside scientific advice and evidence, but should remain distinct from it. We recommend that ACRE should, in its recommended expanded role, establish a permanent 'Citizens Council' based on the model developed by the National Institute for Health and Care Excellence. This new Council should be responsible for considering and providing advice on the potential social and ethical impacts of developments within ACRE's remit. Sciencewise could ensure best practice in the framing and facilitation of debate as well as coordinating the work of all such citizen councils. (Paragraph 144)

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