Select Committee on European Communities Minutes of Evidence

Supplementary letter from Greenpeace UK

  With respect to the current enquiry, you were kind enough to send the paper on "Gaps in the regulatory oversight of biotechnology in the US" [not printed] prepared for the committee by Dr Kinderlerer,[20] and you asked for any comments. Thank you for letting us see this. While generally agreeing with Dr Kinderlerer's analysis, we do have some comments.

  Probably the first point to make is that although there has been public criticism of the EU system by both US interests and the genetic engineering industry, the US system has been subject to criticism itself in the US by public interest groups (see, for example, Peril amidst the Promise, Union of Concerned Scientists, 1994).

  Further, harmonisation of the two systems, if indeed that is desirable, should not be blind to the deficiencies of both. Neither system explicitly addresses the handling of uncertainty that is inevitably present with any new technology, especially when dealing with biological systems and ecosystems which are both complex and poorly understood. Whilst at least the EU legislation pays lip service to the "precautionary principle" the latitude with which this has been interpreted in practice—for example in the consent given to the Novartis Bt maize[21] —means that this is not guarantee of precaution in practice. The nature of uncertainty, and indeed factors which are for all practical purposes unknowable, means that neither system takes as an approach "proof of safety" which Dr Kinderlerer states as being the rationale for the EU legislation in his final paragraph.

  Neither of the US or EU legislative systems manage to answer the crushingly obvious (to members of the general public) questions which are required to justify these unknown risks, and some of these questions are outlined in our evidence. In summary they include:

    —  Do we need genetically modified foods?

    —  Who benefits and who has to take the risks?

    —  Is this the direction in which we would want to take agriculture?

    —  What will be their cumulative effect?

  The way the current EU regulations operate is that it is taken for granted that GM crops and GM food are good things unless some specific safety problem is identified in the (industry's own) tests. All the above questions, and many others, are left unasked, and certainly unanswered.

  We will shortly forward a written submission we have made to the Environment Minister, Michael Meacher about the revision of the Deliberate Release Directive 90/220.

  Should you wish us to elaborate on the above please do not hesitate to let us know.

Dictated by Peter Melchett,

Executive Director, Greenpeace UK,

and signed in his absence

26 June 1998

20   Specialist Adviser to the Committee. Back

21   The Novartis Bt maize is the first genetically engineered crop to be planted in Europe. an analysis of how this crop came to be approved, how undemocratic the approval system is, how inherently not precautionary the system is, and how yawning gaps in policy were exposed by the approval process, makes interesting reading. I have enclosed a case study of the process by Greenpeace European Unit. (Not printedBack

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