Select Committee on European Communities Second Report - Written Evidence

Letter from United Nations Industrial Development Organization

  I write further to your invitation to provide written evidence to Sub-Committee D, in the course of its enquiry into genetic modification in agriculture, especially with regard to its regulation by the EC. I should make clear at outset that I do not have direct involvement in the implementation of the European Directives governing the environmental release of genetically modified organisms. However, I do have extensive experience of the implementation of regulatory frameworks elsewhere in the world. It is possible that my more general comments, drawing on this broader experience, will provide a useful perspective upon the specificities of European legislation.

  1. I draw attention to the need to preserve a degree of national autonomy in the course of implementing frameworks governing the use of genetically modified organisms, without compromising the effort to maintain agreed common denominators within European legislation. This need is reflected in the diversity of national interpretations of Directive 90/220/EEC, as revealed in a recent study (see An appraisal of the working in practice of directive 90/220/EEC on the deliberate release of Genetically Modified Organisms, Working Document for the STOA Panel. Luxembourg, January, 1998). It is a need that is confirmed by my experience elsewhere in the world.

  2. Whilst harmonisation of biosafety legislation is desirable in the course of promoting free trade, I would point to legitimate differences of national interest which may be compromised in the course of such harmonisation. For example, a concern on the part of some European countries to critically examine the possible impact of transgenic crops in the light of a desire to move towards systems of organic agriculture.

  3. In particular, consideration should be given to the further narrowing of the genetic base and a commensurate increase in genetic vulnerability following widespread use of transgenic crops.

  4. The impact of transgenic crops upon the long-term use of pesticides and herbicides will also vary from product-to-product, and requires case-specific review.

  5. Whilst commercial use of transgenic crops in the EU is as yet inchoate, it is premature to consider a relaxation of the regulatory procedures preceding environmental release of genetically modified organisms. Many of the environmental impacts of transgenic crops may only become apparent after many years' use, and it is important that mechanisms are in place for long-term monitoring of such possible effects.

  6. Such relaxation would be particularly inappropriate in view of the widespread public scepticism of the efficacy of the regulation of biotechnology, as revealed in the recent Eurobarometer study.

  7. In view of the corresponding public distrust of scientists, who are increasingly perceived as operating to political or industrial agenda, it is evident that there is a need for the strengthening of public involvement in the regulatory process. I suggest that provisions for public information should be strengthened, ultimately to provide for public participation in the regulatory process. Precedents for such public involvement have been set elsewhere in Europe (in Norway, for example). In the long-term, such involvement will benefit the biotechnology industry, through public confidence building.

  Please do not hesitate to contact me if you would like me to elaborate further on any of these points.

George T Tzotzos

4 June 1998

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