Select Committee on European Communities Minutes of Evidence

Memorandum by Greenpeace Ltd

  1. Greenpeace is an international campaigning organisation with 2.5 million supporters world-wide and 194,000 paying supporters in the UK. Greenpeace has been campaigning on environmental issues for over 25 years.

  2. How we, as a society, handle the issue of genetically modified organisms (GMOs) is the best illustration of a broader question about the relationship between science, policy and the handling of risk in modern society. Food problems like BSE, pesticide residues and food poisoning all require that available science is interpreted to form policy in a way that carries conviction with the public. But what happens when the science is uncertain? In complex arenas like health and environment uncertainty is a given—there will always be uncertainty because it is almost inconceivable that research can provide all the knowledge required for certainty about the risks involved.

  3. Governments have struggled with this basic truth. Official assurances of safety have unravelled as new knowledge about environmental or health impacts has overwhelmingly shown that problems are present, with the consequent loss of public confidence and faith in the systems and institutions that were meant to protect the public good. This occurred most famously with BSE, but a similar pattern played itself out with pesticide use, the effects of low levels of nuclear radiation and, longer ago, with the health impacts of smoking. One can see the same dynamic playing currently with Gulf War Syndrome and the side effects of vaccinations.

  4. Genetic Engineering (GE) introduces new risks that do not come from traditional breeding methods and there are many opportunities for unpredictability to appear (see Appendix 1 by Dr Michael Antoniou, Senior Lecturer in Molecular Pathology, London).

  5. This is not to say that traditional breeding methods are risk free, but GE provides new and unknown risks about which we have little experience.

  6. This evidence sets out to show that the risks from genetic engineering in food and agriculture are real, and that there are major political and commercial risks being taken as a consequence.

  7. Although the Select Committee is not seeking to duplicate the work of the Nuffield Committee on the ethics of genetic modification, it should be noted that many of the issues that affect food production are focused beyond that of a narrow "scientific" analysis of food content but on traceability, provenance and the process of production. A key part of retailer and food producer requirements is now that of traceability all the way back down the food chain to farm or even field of origin. For example, crop assurance schemes run by supermarkets and independent companies have been introduced, and some supermarkets are now buying beef from farmers rather than from livestock auctions. Examples of "process-led" choice available in the shops are organic production, dolphin-friendly tuna, free-range eggs, fair-trade products and an aversion to food irradiation. It is a mistake to dismiss these values as "unscientific", indeed any scientific analysis or presentation of results will have imbedded in it value-laden assumptions.


  8. Genetic engineering has produced results that can—and have—been unpredictable. Examples are documented at Appendix 2 (Too Good to Go Wrong, Greenpeace 1997) (Not printed) and include microbes proving to be unexpectedly resilient, the transfer of allergy by genetic engineering, unexpected pathways of escape for genetically modified bacteria and problems for genetically engineered crops when moving into real world situations. Further examples have come to light since that report was written.

  9. Roundup Ready cotton produced by Monsanto and Delta Pine and Land seed company has experienced problems with the cotton bolls shrivelling up and dropping off in an effect looking similar to that in tests involving large quantities of herbicide. The problems are only associated with the Roundup Ready cotton although the mechanism is not clear[2]. Sixty Mississippi farmers have considered taking legal action and Monsanto has settled out of court with most of them. Some are holding out for more than the $100,000 offered[3]. Reportedly, state officials say that complaints have been received from farmers in as many as seven other states[4]. Monsanto have explained the failure as being a result of exceptional cold weather and wrong use of varieties[5]. As Robert McCarty, Mississippi Agriculture and Commerce Department chief regulator put it to farmers "I sure couldn't recommend they plant one of these varieties and take that kind of risk unless someone could assure them they wouldn't have the same kind of problems we had in 1997.[6]

  10. Three hundred kilos of pulp coming from a field trial of genetically engineered sugar beet (which had not received clearance for marketing) were mixed with conventional varieties and went for processing to a sugar company CSM. The pulp was traced but only after it had ben incorporated into a much larger block of 12.3 million kilos of sugar[7].

  11. Other reports have indicated that a number of GE crops, such as Bt cotton in Arkansas, are not producing the financial returns expected because of low yields. A Monsanto competitor has also claimed that farmers planting Roundup Ready soybeans have experienced losses of $43 per acre[8].

  12. Already science has shown that some risks are close at hand in terms of out-crossing of GE crops (see, for example, Appendix 3, excerpt from "Genetically engineered oil seed rape (AgrEvo/PGS) A Critical assessment and Background Information"), that small genetic changes are capable of producing significant changes in the invasive capability of plants[9], and that argumentation to inform "ecological safety" is often naive[10]. Some of the proposed genetic modifications could have impacts on insects, presumably not considered in the approval process judging by the insistence by the European Commission on the authorisation of Novartis Bt maize.

  13. Question marks need to be raised over the authorisation of the Novartis maize and other Bt crops by the recent work of Hillbeck et al[11]. Bt-maize is produced to deal with insect attack from, amongst other things, the European corn borer. Lacewing larvae (lacewings are generally considered to be beneficial predator insects) were fed on the corn borer larvae fed on the Bt maize and they survived less well than the controls. This is very alarming as Bt crops have already been authorised for growing and have been planted in France.

  14. Potatoes engineered to resist aphid attack by the incorporation of a gene from a snowdrop (to produce a lectin which interferes with insect digestion) were found to have affected ladybirds. The engineered potato plants did indeed affect aphids but female ladybirds fed on aphids which had eaten from the engineered plants survived only half as long as those fed on controls. The females also laid fewer viable eggs[12].


  15. Both novel foods and deliberate release need to take into account the need for justification of the risks involved. This involves answering "big picture" questions that have not been answered, either by the EU or the UK, either at a regulatory or a policy level. Examples of such questions would be:

    —  Is genetically modified food necessary?

    —  Is genetically modified food wanted?

    —  Is genetically modified food the right direction for long-term food policy?

    —  What is the justification to allow companies which wish to commercialise GM foods to expose the public to GM food risks, when the public themselves do not presently stand to benefit?

    —  Will herbicide-tolerant crops encourage more damaging use of herbicides in the long-term?

    —  Are GM crops a disincentive to investment in further research and development of (genuine) environmentally friendly agricultural practices, and is this acceptable?

    —  What will be the cumulative effects on natural ecosystems from introduction of many different herbicide-tolerant or pest resistant crops on a widespread scale?

    —  Will widespread introduction of pesticide-resistant crops have a long-term impact on biodiversity (e.g., on soil organisms, on microflora, microfauna, on flora, on birds, on other fauna)?

  16. Of course many of these questions are obvious to members of the public when exposed to possible development in GE but that is all the more reason the regulatory process should not leave them out. The enquiry cannot just set these issues aside as "ethical" issues to be dealt with elsewhere.


  17. There are substantial commercial risks being run because of the fragile nature of public support as revealed by surveys, and particularly by focus groups which can reveal the real reasons for people's uneasiness.

  18. The introduction of GMO food is coming at a time when sensitivity to food integrity and safety is high. It is also occurring at a time when the ability of political institutions to handle risks is at crisis point, and when people are much more likely to take definite action as a result of what they see as failures of the bodies around them. All this puts farmers and food companies in the front line in relation to any potential "backlash" when something goes wrong with a GMO product.

  19. There has been much opinion polling done on GMO food including by Greenpeace. These polls generally show around 60 per cent or more of Europeans taking a negative view of GMO food, and about 20 per cent supportive. Of more significance is what underlies the general antipathy towards GM food.

  20. It is clear from the Eurobarometer survey[13] that the distaste for GM food is not a matter of lack of knowledge, because the survey shows that, overall, if they know more about the issue people are not more inclined to view GE favourably. Thus the often repeated mantra that "Public Understanding" will enhance people's views towards a liking of the technology is misplaced. The Eurobarometer authors linked this to moral or value-based unease about some GE applications. Thus there is a mismatch between the regulatory framework with its intense focus on risk management, and a powerful value-based distaste for GE.

  21. Further, in complex arenas like environmental or health impacts the Eurobarometer survey showed that trust acts as a functional substitute for knowledge. Levels of trust in political institutions are low. Reassurance from political actors in the event of some problem or crisis with GMO food will be ineffective.

  22. The focus group research by University of Lancaster,[14] sponsored by Unilever was not pan-European but limited to the UK. However some of the findings are closely reflected in the Eurobarometer research outlined above. The Lancaster work provided additional knowledge on the public feelings, which show a high degree of fatalism that GMO food will arrive, despite deep and largely latent unease about the prospect.

  23. Further, people would buy genetically engineered food even though they were not happy about it, showing the limitations of marketing data if it is the only means used to gather knowledge about public reactions. As consumers, people recognised that they may well purchase GM food, but would in general prefer that society were not embarking on this course, or if it were, only with a good deal more justification. This apparent contradiction has been interpreted by some to mean that people's expressed opinions in polls are not the same as their "real" views, but this would be a misguided interpretation. Labelling of GM food, although necessary (essential even) it is an inadequate response on its own.

  24. Public attitudes to GMOs are complex and not easily understood. More broadly we see that UK consumers are becoming more ready to take action on the basis of inadequate service or ethical and moral concerns. Research by GGT[15] in 1996 showed that 64 per cent of people said they were more likely to take action against a company than five years ago. Fifty-nine per cent believed disobeying the law could be justified in protest against something that is unjust, 14 per cent would boycott a company, three per cent would damage property as a form of protest action. How can this be reconciled with the conclusion of the Lancaster research showing apparent fatalism about GM foods? There was no fatalism about the protests over live animal exports (in the UK), road building, Brent Spar and nuclear testing by the French in the Pacific. So what is the Lancaster research telling us?

  25. The answer may lie in a quote from an article written in 1995 about consumer protest: "What has driven the ordinary citizen to stop buying Shell petrol and French goods is latent anger about the power of international companies and foreign governments to do these things with such scant regard for public feeling. Nuclear testing is the lightning rod of much more than environmental concern. It is the focus of a much deeper frustration with institutions over which they have no control".[16]

  26. The fatalism only converts to militant action when a "lightning rod" is provided to push people into a different mode of action. Greenpeace's own research into attitudes to environmental protest indicates that people distinguish between local-scale action where there is a sense of agency to individual action, and international issues like climate change where, generally, there is not. The global scale problems provoke an apathetic and fatalistic approach, the local scale issues (local pollution and planning issues, or shoddy service from company) a more active role.[17] Such fatalism is understandable given that often people are put in a position of having no choice about what they want to happen—we are all in the position of having to trust regulatory processes whether we like them or not.

  27. But when a "lightning rod" is provided that turns a global issue into one that can be influenced by individual (albeit collective) action, then the agency gap is bridged.

  28. The same situation could apply to GM food, but what is lacking for widespread action to start is a trigger—something to identify the "lightning rod". The export of live animals through Brightlingsea had been going on for years before the protest started; once local people became aware that their action could influence things, the activities snowballed into something that local police could not control. What is awaited for the societal tensions in the GM food issue to find expression is a trigger, most likely for something to "go wrong", which, as outlined above, is almost inevitable.

  29. What, then will be the "lightning rod" for the public frustration? The most likely answer is that it will be the brands implicated and companies selling the products which are tarnished either by association or directly in a food health issue. Further, those farmers who are engaged in the growing of GE crops or for whom their crops will inevitably become contaminated by the crops of others will be seen as legitimate targets for public anger. With BSE it was the farmers, not the food or even animal feed companies who suffered most. Who knows where the axe will fall with a GM crisis.

2   On learning of this allegation, the Pioneer Overseas Corporation supplied the Committee with the following: "In response to your call for evidence, we understand Greenpeace stated to the committee on 3rd June that Pioneer is recommending 50% refuge populations for genetically modified crops with genes from Bacillus thuringiensis (Bt) to confer insect resistance. This is not true, and it has never been true. We are developing Bt-maize varieties with insect resistance. We are committed to maintaining the efficacy of Bt-maize and have developed a comprehensive insect resistance management programme to ensure that Bt-maize is cultivated in a sustainable manner. The programme addresses the need for refuge populations where appropriate and it recommends either 5% untreated or 20% treated maize refuges. There has been no change to this original position." This means that Pioneer recommend that, should a farmer wish to maintain the insect population and slow down the development of Bt resistant insects, he can either grow 5 per cent non-GM seed and use no pesticide at all (As the GM maize is resistant to pests it does not need to be sprayed with a pesticide.) or grow 20 per cent non-GM seed and use a pesticide. Back

3   A paper by the Committee's Specialist Adviser (not printed). Back

4   Kleiner, K, 1997. Monsanto's cotton gets the Mississippi blues. New Scientist, 1 November 1997, p. 4. Back

5   GenEthics News, 1998. Transgenic crop problems continue, Issue 22 February/March 1998, p. 12. Back

6   Myerson, A, 1997. Breeding Seeds of Discontent; cotton Growers say strain cuts yields, New York Times, 19 November 1997. Back

7   Colin Merritt, Technical manager, Monsanto. pers. comm. Back

8   Myerson, A, 1997, op cit. Back

9   Agarisch Dagblad (Agricultural Daily), Transgene Beet Pulp on market, 2 December 1997. Back

10   Pesticide Action Network North America Updates Service, Disappointing Biotech Crops, April 24 1998. Back

11   Williamson, M, 1993. Invaders, weeds and the risk from genetically modified organisms, Experientia, Vol. 49(3), 1993. p. 219. The case study on Impatiens showing how small morphological differences can make a large impact on ecological fitness begins on p. 222. Back

12   Kareiva, P and Parker, I, 1994. Environmental risks of genetically engineered organisms and key regulatory issues, An independent report prepared for Greenpeace International. Back

13   Hilbeck, A, Baumgartner, M, Fried, P M and Bigler, F, 1998. Effects of transgenic Bacillus thuringiensis corn-fed prey on mortality and development time of immature Chrysoperla carnea (Neuroptera: Chrysopidae), Environmental Entomology, April 1998, p. 480. Back

14   Gledhill, M. and McGrath P., 1997. Call for a spin doctor, New Scientist, 1 November 1997, p. 4. Back

15   Biotechnology and the European Public Concerted Action Group, Nature, vol. 387, 26 June 1997, p. 845. Back

16   Grove-White et al, Uncertain World, Food and public attitudes in Britain, University of Lancaster, March 1997. Back

17   GGT Research services, Uncomplaining Brits are turning into a nation of vigilante consumers, 28 June 1996. Back

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