April 30, 2003

A Food Safety Network Backgrounder
University of Guelph

Introduction

Managing the coexistence of various crop types is not new. It is an integral component of agricultural production, whether it is used to differentiate between crops produced through different management protocols (such as conventional and organic) or to preserve the identity of crops because of quality demands (such as in seed production or for specified end uses).

Political controversy regarding the use of genetic engineering (GE) technology in food production has brought increased attention to the issue. There is perceived to be a substantial market for non-GE crops, and consumer choice is increasingly viewed as a fundamental right.

Managing the coexistence of GE and non-GE production was the focus of two papers released in mid April 2003 by the government of New Zealand in response to recommendations from the Royal Commission on Genetic Modification. (See "New Zealand Prepares for GE Technology Use", Food Safety Network Backgrounder, April 30, 2003) These government papers confirm that the coexistence of the production systems is theoretically possible, and address several of the technical issues involved, including codes of practice for GE crops and managing risks for beekeepers and users of Bt
insecticide.

The coexistence issue was also the focus of an April 24th EU Agriculture Commission Roundtable discussion in Brussels that featured a series of papers presented by EU crop scientists. Agriculture Commissioner Franz Fischler's address provided an overview of both the potential for managing coexistence of different production types in the EU and the benefits for the EU's agriculture industry through the use of a range of production systems, including GE.

In farm-scale evaluation trials conducted in the UK over a three-year period, the coexistence of GE and non-GE crops was successfully managed through the institution of appropriate management protocols, and farmers involved in the trials, which included an independent auditing component, showed a very high level of compliance with management requirements.

Why are measures for coexistence necessary?

The agriculture sector's ability to deliver consumer choice is linked very closely with its ability to maintain different production systems and deliver distinct products that demonstrate a high level of purity. The potential for unintended mixing of GE crops with their non-GE counterparts has created significant concern. Such mixing can result from seed impurities, cross-pollination, "volunteer" plants that carry over to subsequent growing seasons, harvesting and storage practices and transport.

In his address at the recent EU Roundtable discussion, Commissioner Franz Fischler emphasized that the coexistence issue is an economic one, not related to human health or environmental safety. Safety issues are addressed through risk assessments that must be completed before new crops are introduced, so the potential mixing of GE and non-GE crop varieties that could occur through faulty segregation practices would not result in safety concerns.

Decreased purity levels, however, could have economic consequences, diminishing the value of the crop. The size of the potential loss resulting from the unintended mixing of GE with non-GE crops is related directly to the price premium that one class of products is likely to command over the other. Officials in New Zealand indicated in their report that premiums for non-GE production are likely to decline over time.

Other issues of concern include both the feasibility and the cost of measures to reduce the mixing of GE and non-GE crops grown under field conditions.

Special concerns for organic production?

As in the New Zealand work, the EU Agriculture Commission recognizes that organic farming regulations are production standards rather than product standards, specifying the management protocols by which the product must be produced rather than signifying the specific characteristics of the product itself. Although there has been significant concern expressed by the organic sector regarding the potential unintended presence of GE material in organic produce, the EU organic regulation provides nothing specific on the issue of gene flow into organics. The regulation allows for the establishment of a threshold for GE presence in organic products, but no threshold has been set.

How can successful coexistence be achieved?

Similar to the NZ approach, the EU position is that any approach to coexistence must take into account the differences between crops and crop varieties with respect to their potential to spread to neighbouring fields. For the European Community, it is suggested that the initial target for the development of coexistence guidelines should be those crops for which GE varieties have been approved or are expected to be approved in the near future, and for which there is a comparatively high probability of admixture. It is anticipated that for some crops, particularly oilseed rape but also, to a lesser extent, maize (corn), measures to achieve coexistence could involve significant changes in farming practices.

Because of the nature of agricultural production, it is considered imperative that legal thresholds be established for the unintended presence of approved GE crops in non-GE crops, including organics. Even when appropriate and crop-specific management practices are followed, it is not expected that a level of 0 is attainable under real-world conditions.

Guidelines for effective coexistence may include areas such as isolation distances between fields, buffer zones, pollen barriers, control of "volunteer" plants, crop rotations and planting arrangements for differing flowering periods, monitoring during cultivation, harvest, storage, transport and processing.
In the UK, the Supply Chain Initiative on Modified Agricultural Crops (SCIMAC) established a Code of Practice for the management of GE crops that has been tested over three years of farm-scale evaluation trials. Independent teams of agronomists who were charged with the responsibility of evaluating the trials both for their success at achieving separation of GE and non-GE varieties and for farmers and ability to meet compliance guidelines, focused on eight critical control points through the production process where it was believed that unintended mixing was most likely to occur:

• seed delivery, storage and handling
• drilling operations, including cleaning
• handling of surplus seed
• separation distances
• field operations, including harvest preparation
• harvesting operations
• transport and storage
• record-keeping and post-harvest monitoring.

Compliance: Who is responsible?

As previously noted, the EU Agriculture Commission views the coexistence issue as primarily an economic one. As a result, it is believed that those who intend to gain a benefit from the specific production model they have chosen (farmers, seed suppliers, etc.) bear the responsibility of ensuring that adequate measures are taken to assure the purity of their products. Some measures may require cooperation between neighbouring farms.

There is recognition, however, of the need for mandatory management guidelines that establish a duty to conform to certain standards and conduct. This is similar to the "conditional release" amendment proposed for NZ, which would require, as a condition of new product approval, that specified protocols be met to minimize potential risks in cases where such management protocols were deemed necessary. In the EU case, it is unclear whether such guidelines would be inherent within the product approval process or applied through other means.

Rules for economic liability in cases where cross-pollination occurs between neighbouring crops will also need to be established.

Research Results

According to the study conducted in the UK, three years of field-scale evaluation trials of GE herbicide-tolerant crops grown under a Code of Practice designed to promote successful coexistence resulted in no loss of non-GE or organic status in surrounding areas.

Farmers who participated in the trials found few practical difficulties in managing GE and non-GE crops according to the coexistence guidelines, and an independent audit confirmed very high levels of compliance. Growers believed that the guidelines provided an effective basis for managing coexistence between crops on the same farm (97%) and between neighbouring farms (91%), and 95% of participants said they would grow GE crops if such crops were commercially available. They cited advantages such as the opportunity to reduce sprays and cultivations as well as reduced dependence on residual herbicides as the primary reasons for preferring GE crop varieties.

Research conducted in Denmark and presented at the EU Roundtable discussion indicates that coexistence is achievable for most crops grown there ˆ beet, maize (corn), potatoes, barley, wheat, oats, triticale, rye, lupine, broad beans and peas.

It is recognized that achieving coexistence may include some modification of current farming practices, and that effective guidelines must be crop-specific.

Next Steps

EU Agriculture Commissioner Franz Fischler expects that the first official guidance regarding the future production of genetically engineered crops alongside traditional plants will be available within the next few months. EU agriculture ministers will be informed of progress at their upcoming meeting in May 2003.

References

Agriculture Biotechnology Council. Two New Reports Support Prospects for GM Crop Coexistence. April 25, 2003.
http://abcinformation.org/news_display.php?news_id=47

Commission of the European Communities. Coexistence of Genetically Modified, Conventional and Organic Crops. Communication from Mr. Fischler to the Commission.
http://europa.eu.int/rapid/start/cgi/guesten.ksh?p_action.gettxt=gt&doc=SPE
ECH/03/205|0|RAPID&lg=EN&display=

EuropaBio, Farming Systems Must be Tolerant of each other. News Release. April 25, 2003.
http://www.europabio.org

Government of New Zealand. Treasury Report Briefing on Genetic Modification Economic Analysis Cabinet Paper. March 28, 2003.
http://www.treasury.govt.nz/gmeconomic/tr2003-461.asp

Smith, Jeremy. EU to draft GMO crop mix guidelines in next months. Reuters. April 24, 2003.
http://www.forbes.com/newswire/2003/04/24/rtr950220.html

SCIMAC (Supply Chain Initiative on Modified Agricultural Crops). New Reports Support Prospects for GM Crop Coexistence. News Release. April 25, 2003.
http://www.scimac.org.uk/

ADAS Consulting Ltd. Audits of GM-HT Crops Within the Farm Scale Evaluation Trial, Harvest years 2000-2002. Summary Report. April 2003.
http://www.scimac.org.uk/