4: SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
Potential benefits and
172. Biotechnology in general and genetic modification
in particular offer great potential benefits to agriculture, industry,
consumers and even to the environment.
We consider that GM technology may offer much to organic systems,
for example through reduced inputs (paragraphs 65-72, 78).
173. There are potential risks relating to the
environment, including the impact on ecosystems of out-crossing,
pest resistance and stress and multiple tolerances (paragraphs
174. We consider that environmental risks and
benefits should be assessed at the same time (paragraphs 87-88).
175. The risks involved in genetic modification
can, we believe, be controlled, if a strict risk management process
is in place. A clear, coherent set of principles for environmental
impact analysis is needed which allows for consistent interpretation
by Member States (paragraphs 89, 92-93).
recommend that risk assessment should include direct, indirect,
immediate and delayed effects. The regulatory system should attempt
to predict interactions. A system which attempted to identify
an integrated approach would be preferable to what amounts to
a first come, first served approach (paragraphs 94-95).
177. In assessing risk, we recommend that modified
plants and their management schedules should be compared with
the use of a similar non-modified crop and best agricultural practice
178. We recommend that there should be triggers
other than genetic modification which bring the assessment and
management system into action, as is the case for novel foods.
We recommend that, from now on, any crop with novel traits which
may have the potential to impact significantly on the environment
should be subject to an oversight system (paragraph 91).
179. The knowledge of how a crop grown on farm
and commercial scales will interact with the environment can only
be acquired by growing it on such scales. Large scale trials are
needed. We consider that an outright moratorium would be inappropriate
180. We welcome the ability to set specific conditions
for each commercial release. We are however concerned that the
draft Directive does not envisage an end-point at which the GM
crop is considered safe enough to be released into the environment
without such constraints (though perhaps with certain management
conditions) (paragraphs 100-101, 170).
181. Conditions and regulations should only be
imposed where necessary, but must be adhered to when imposed.
The general conditions may best be established through a (preferably
pan-European) government-sponsored code of practice. It may be
the case in this instance that a voluntary code of practice will
not be sufficient; if so, the code of practice should be backed
up by regulation (paragraphs 105-107).
182. Monitoring is not a substitute for risk
assessment but can complement it. We consider that those involved
should report on any predicted effects which do not occur and
any unexpected events which do occur. We recommend that monitoring
(to Community-wide standards) should be performed by an independent
organisation, funded through levies on applicants. There must
also be a Community-wide audit of enforcement as monitoring standards
(in many fields) have in the past been subject to too great a
variation (paragraphs 102-104).
183. We consider the regulatory process for assessing
the safety of novel foods to be thorough and proper and we see
no reason to doubt the safety of foods which have been approved
by the regulatory process. The emphasis should not be on "genetically
modified" but on the new characteristics of any individual
product (paragraphs 109-116).
184. Antibiotic-resistant marker genes should
be phased out as swiftly as possible. Research needs to be conducted
into how best to consider applications involving genes without
proven track records of food use. We support the call for the
accumulation and sharing of national data to assist regulators
(paragraphs 75, 109-116).
185. Internal work at MAFF to prepare for the
Food Standards Agency is poor substitute for its launch. We would
be encouraged if legislation were to be brought forward in this
Session (paragraphs 118-122).
186. Genetic modification does not concern a
single product or variety but will soon affect the whole spectrum
of agriculture. To require traceability for all agricultural commodities
would be an exceedingly costly exercise for little benefit, especially
when there is no anticipated risk to human health (paragraph 117).
187. Once the regulatory process has ensured
safety, the success or failure of the technology must be left
to consumer choice in the marketplace. The two issues involved
in providing choice are the supply of GM and non-GM products and
labelling (paragraph 128).
188. Segregation must be driven by the market
and not required by Government. Producers and manufacturers should
however be under no illusion as to the climate of consumer opinion
in Europe and it would be advisable for the immediate future for
segregation to occur to facilitate consumer choice. The identity
preservation system is to be commended. The crop and product must
still be subject to the standard testing and labelling regimes
as GM material has often been found in supposedly unmodified shipments
189. We welcome the requirement for the explicit
labelling of GM products in order to help provide consumer choice.
We agree with the Commission and Government that only products
where the transgene or its product are detectable should be labelled.
To demand labelling where such detection is impossible would be
meaningless. A Community list of products which do not require
labelling is urgently required (paragraphs 135-139, 145).
190. Any ingredient or additive to a product
should be identified as GM when the presence of GM material can
be detected above an established threshold. No labelling should
be required below the threshold. Additionally, if a finished product
contains GM material above a threshold the product itself should
191. The absence of a testing and thresholds
policy is a serious gap in current European and domestic legislation.
Until a Community policy is agreed we recommend that MAFF should
issue interim guidelines. A workable but cautious threshold for
GM presence would perhaps be 2 per cent. (paragraphs 136-139,
192. Information supplementary
to that provided on the label of GM foods must be available to
the consumer. We recommend that Member State governments co-ordinate
(but not necessarily be responsible for) the establishment within
each State of a source of information regarding GM foods, to which
the consumer may resort for information not provided on the product
label. In the United Kingdom, this should as soon as possible
fall under the remit of the proposed Food Standards Agency (paragraph
193. It is highly desirable that there should
be competition between a sufficient number of agro-chemical/seed
companies on a world-wide basis. We consider that consolidation
should not progress any further (paragraph 85).
194. Provided that the farmer can afford any
extra costs, we do not consider either the licensing of the right
to plant or the sale of seeds which will produce sterile crops
to be a problematic development (paragraph 86).
195. The regulatory process should only judge
products on safety: ethical questions should be addressed before
regulation, not during or after. In the same way as agreeing the
principles for risk assessment, the Council of Ministers will
need to agree on how to deal with potentially ethically sensitive
modifications such as the inclusion of animal or fish genes in
crops. The market might be a suitable arbiter. For some people
the use of GM products to any extent is an ethical issue (paragraphs
196. The destruction of trials of GM crops by
certain groups fundamentally opposed to the technology must be
condemned, but increasing confidentiality is not the answer. The
advisory committees should continue to place as much information
as possible in the public domain. We welcome the Commission's
proposal to do the same at Community level. We agree that public
comment should be taken into account formally before ACRE makes
its recommendation, rather than informally as at present. Transparency,
however, must not affect the efficient working of the regulatory
committees (paragraphs 123-125).
197. We do not question ACRE's integrity, but
it and its members must be seen to be acting independently. The
remit of ACRE should be adjusted so that it considers, for example,
indirect and cumulative environmental effects when judging individual
applications (paragraphs 148-150).
198. We believe that a new committee, similar
to that proposed by the Royal Society, is needed to examine more
general issues which arise from the use of genetic modification
in agriculture and to co-ordinate and plan policy as a seamless
whole (paragraphs 151-153).
199. Domestic pressures, ecological and agricultural
conditions vary across the Community. We consider that Member
States should have the right to opt-out of growing certain GM
crops for domestic or environmental reasons. The products of such
crops, food or other, should however be available throughout the
Community and the market will determine their acceptability and
so success or failure (paragraph 160).
200. We consider that consultation of the Commission's
scientific committees will be useful for resolving inter-Member
State disputes. The appointment, membership and operation of the
committees must be open to scrutiny. The current method of appointment
is inadequate. The structure of the committees could also be streamlined
to increase their relevance to the regulation of GM releases.
The committees require improved resources in Brussels (paragraphs
201. We welcome the introduction of strict time
limits and the definition of risk assessment which should help
end discrepancies between Member States and provide the predictable
system desired by industry. There are however two flaws. The first
is too ready a willingness to stop the clock. We consider that
the efficiency of the scientific committees' working should be
improved before resorting to stopping the clock. If this proves
impossible, consideration will need to be given as to whether
it would be preferable to make the committees permanent or to
stop the clock. Additionally, the Commission has failed to set
itself a time limit for approving or rejecting a release following
the (in)decision of the Council (paragraphs 165-168).
202. We find no merit in the proposal to limit
marketing consents to seven year periods (paragraph 170).
203. GMOs need to be regulated, at least until
our knowledge develops further, but it would be extremely damaging
if Europe's access to this technology was subjected to inappropriate
impediments (paragraph 171).
204. The Committee considers that the proposed
revisions to the EC regulation of genetic modification in agriculture
raise important questions to which the attention of the House
should be drawn, and makes this report to the House for debate.