Source: Agricultural Biotechnology Council

In light of the recent extensive reviews, consultation process and decision by the UK government, we welcome the Committee’s inquiry and wish to submit the following evidence.
The industry fully recognises and supports the need for a regulatory environment to work within, but believes that, where legislation is required, that this should be enabling and not disabling such that it becomes an unjustified barrier to entry or fair competition.

This submission discusses;

Co-existence and separation distances
Liability
GM-free zones
What changes to legislation will be required to allow GM crops to be grown?
Scope and scale of the 2006 re-licensing procedures

Before concluding it is essential that government strikes an appropriate balance between regulation and innovation. abc looks forward to future consultations with government to ensure this occurs in reference to GM crops.

 

1.         Background

1.1       The Agricultural Biotechnology Council (abc) was set up in 2002 to provide a forum for debate and education surrounding GM technology in the United Kingdom. The members of abc are BASF, Bayer CropScience, Dow AgroSciences, DuPont, Monsanto and Syngenta. These companies are working together to promote a fair debate surrounding the production of GM crops and also to provide education about GM in the UK.

1.2       In light of the recent extensive reviews, consultation process and decision by the UK government, we welcome the Committee’s inquiry and wish to submit the following evidence.

1.3       The industry fully recognises and supports the need for a regulatory environment to work within, but believes that, where legislation is required, that this should be enabling and not disabling such that it becomes an unjustified barrier to entry or fair competition.

2.                   Co-existence and separation distances

2.1        abc represents the companies which sell products for all types of farming, be it GM, non-GM or organic. It is therefore extremely important to the industry that all forms of farming are able to co-exist.

2.2        abc welcomed the recent Government decision that, in principle, allowed the growing of GM crops in the UK, once sensible and proportionate co-existence measures are developed and put in place. abc looks forward to consulting with government and other stakeholders to develop such measures to ensure the UK and UK farmers can choose to benefit from the full range of agricultural practises that eight million farmers from around the world are already able to.

2.3       In agriculture, a zero percent tolerance is not measurable, not achievable and is therefore not a requirement in non-GM and organic farming. This is true, regarding genetic purity standards just as it is for natural or man-made toxicants. Many types of agriculture have thresholds set that are readily achievable through standard agricultural stewardship. 

2.4       For example, the durum wheat used for pasta must contain less than 3% of other cereals. Likewise, organic food must be more than 95% organic to be labelled as such.  Certified cereal seed production works to standards of up to 99.7% purity.

2.5       The agricultural biotechnology industry and the Supply Chain Initiative on Modified Agricultural Crops (SCIMAC), recognise the importance of managing cross-pollination between GM and non-GM crops in a practical way, to achieve within reason standards requested by consumers.  

2.6       The co-existence guidelines, which include  separationinclude separation distances and other measures, proposed by SCIMAC, have evolved over many years and aim to reduce cross-pollination to below 0.9% in a worst-case scenario. In practice, if GM crops are grown in accordance with these SCIMAC guidelines,  an, an independent review by the National Institute of Botany (NIAB) demonstrates that the actual level of cross-pollination between GM crops and nearby non-GM crops would be well below the 0.9% threshold. These guidelines are currently undergoing further consultation and we believe that this approach will offer a proportionate solution.

2.7       Clearly, no measure can entirely prevent cross-pollination. It is important to remember that zero tolerance cannot be achieved in any agricultural situation, including non-GM and organic, hence the need for appropriate and sensible thresholds. It is not acceptable for one form of farming to have a veto on another; nor is it reasonable to impose the marketing wishes of a small sector of the agricultural community on others. To allow this would be to allow anti-competitive practice and market protectionism. Industry has, and will continue to work with farmers to deliver practices that reduce potential cross-pollination to an absolute minimum within the farming situation. And we have many years of experience in developing and implementing management practices to produce certified seed crops, within strict purity standards.

2.8       Finally, it is worth noting that despite extensive open-air trials of GM crops in the UK since 1989, the SCIMAC guidelines employed have meant that no organic farmer has lost their accreditation. This shows that the guidelines are effective and allow genuine co-existence.

3.                   Liability

3.1        Contamination’ is an emotive word and one that industry does not support. The term implies some harmful effect, which is not supported by the rigour of the regulatory process for those crops Approved for cultivation and use. The question posed implies liability if cross-pollination should occur even at minimal levels, well below legal thresholds.  It must be remembered that approved GM crops have been demonstrated to be safe to both human health and the environment and therefore do not pose a risk or cost on either of these grounds if they are present at any level. The safety pre-requisite of each GM crop is ensured because they are the tested extensively prior to being brought to market and are no more likely to pose a risk to human health or the environment than non-GM food.

3.2        However, like all industries, the biotechnology industry is responsible for all its products, including GM products.

3.3        On the subject of co-existence, we maintain that there is nothing unique about GM and the requirement for it to co-exist with other agricultural practices that require specific legal arrangements. Current laws are more than adequate to adjudicate on issues of agricultural liability, whether that liability may result from non-GM, organic or GM practices.

3.4        abc will enter into dialogue with the government on this issue in due course as part of their consultation process and look forward to establishing practical, equitable and proportionate rules for co-existence, allowing all forms of agriculture to co-exist.

4.                   GM-free zones

4.1        The above discussions have shown that GM crops can co-exist within the patchwork of farming that makes up UK agriculture and for this reason we do not feel they should be excluded as a choice for any UK farmer, should he or she decide to grow them, regardless of where in the UK they farm. 

4.2        Given that co-existence has been shown to work, we do not feel that GM-free zones are required. All farmers should be free to choose the agricultural practice they wish to use, especially as their choice does not and will not impact the agricultural choice of neighbouring farms. It will be for government to decide how best to handle the pressure being generated by some minorities to exclude GM agriculture from certain ‘zones’. 

5.         What changes to legislation will be required to allow GM crops to be grown?

5.1        This will be determined in the next year, with the participation of industry and many other stakeholders. abc looks forward to that process and reasonable practical and proportionate requirements being introduced to ensure all forms of agriculture are available for UK farmers to choose and benefit from.

6.         Scope and scale of the 2006 re-licensing procedures

6.1        Under EU directives and UK regulations governing the licensing of GM crops and food, approvals are time limited.  This is a normal regulatory requirement that industry is happy to work within. Products, especially agricultural crops and varieties have natural, and limited life spans. With this in mind, the consent holders of some products may not seek re-licensing in future years, but instead prefer to bring new and improved versions of their products to the market. Again there is nothing new or distinct to GM crops in this regard.

7.                   Conclusions

7.1       It is essential that government strikes an appropriate balance between regulation and innovation. abc looks forward to future consultations with government to ensure this occurs in reference to GM crops.

7.2        abc believes that GM crops have been shown to be a safe, reliable and environmentally responsible form of agriculture. 67.7 million hectares are now grown globally by 8 million farmers in 18 countries. Cost savings, more targeted pesticide use, water and soil conservation, reduced fuel use and increased profit for farmers are the principal benefits that have been realised as a result of using GM crops around the world in the last 9 years. 

7.3       At the same time, this increased use of GM crops offers no sign of environmental damage, human health risk or safety concerns.  We feel it is time that the UK joined the rest of the world, including several of our EU neighbours, in promoting the choice of using GM crops, rather than allowing excessive restrictions, at the request of a vocal minority, to limit the choices and economically disadvantage UK farmers.