GM planting regime: report of the Environment, Food & Rural Affairs Committee ignores important evidence submitted to it

19 July 2004 

PG Economics Ltd[1] notes that evidence presented to the Committee by ourselves (and others such as SCIMAC, NFU and ABC) has largely been ignored.  The report also contains inaccuracies and the use of unrepresentative material - the Committee having taken evidence presented by some Green pressure groups ‘at face value’, without checking the accuracy of such evidence.   

As a result, some of the conclusions and recommendations are flawed; being based on poor understanding and failure to take into account relevant evidence supplied to the Committee: 

Ø   There is clear and consistent understanding of the legal position about adventitious presence of GM material in organic produce.  Any confusion about this lies with some NGOs and organic certifying bodies, not the UK government and the EU Commission;

Ø   To suggest that the EU ‘standard’ threshold for adventitious presence of GM material in organic produce is zero shows poor understanding.  A zero tolerance threshold for adventitious presence of any unwanted material is unattainable in any agricultural production system.  This is widely accepted in all sectors, including organics, where the use of thresholds (and allowances) for the use of non organic materials is commonplace (eg, permitting the use of some pesticides on organic potatoes, the use of up to 5% non organic ingredients in certified organic produce and the use of up to 20% non organic animal feed ingredients).  Organic standards are also process-based, not test-based according to the presence or otherwise of unwanted material;

Ø    To suggest that failure to set a zero tolerance threshold for adventitious presence of GM material in organic crops would ‘be potentially destructive to the UK organic sector’ fails to take into account the context of organic production.  For the crops where GM traits are most likely to be developed in the next few years, and which are relevant to UK agriculture, the organic area of these crops is minute (0.23%).  The share of the total organic area devoted to these crops is also minute (0.23%);

Ø   The development of any government guidelines on separation distances should carry the confidence of all farmers in the UK, not just those who farm organically.

Overall, the issue of GM crop planting in the UK requires the development of practical, proportionate, consistent and equitable co-existence guidelines.  These should be inclusive and facilitate crop production by all production methods (GM, conventional and organic).  To deliver this, there is a need for ‘give and take’ on all sides, and no one sector should be able to veto another – access and choice work both ways.  The Committee’s conclusions, however fail to take all these principles into consideration and hence provide poor leadership on the subject. 

Appendix: Examples of deficiencies in the Select Committee’s report

The points presented below do not constitute an exhaustive review of the report, but highlight examples of inadequacies in the report.   

Ignoring evidence presented to the Committee or giving inadequate weight to relevant evidence 

1. Thresholds.  The report concludes (para 21) that not setting a threshold for the adventitious presence of GM material in organic produce at 0.1% (limit of reliable detection) would be ‘confusing, unworkable, unacceptable to consumers and potentially destructive to the UK organic industry’.  Little evidence has been provided to support this conclusion, other than the subjective views of some bodies which provided submissions to the Committee.  Counter evidence highlighting realities about levels of purity that can be realistically achieved in any agricultural production system and inconsistencies in the stance of some organic certifying bodies and NGOs towards the zero tolerance approach to GMO adventitious presence and the use of derogations for the use of non organic inputs (eg, use of fungicides on organic potatoes and non organic seed) has been ignored.  Furthermore the context of organic production in relevant crops[2] has not been taken into account (for the three ‘UK relevant’ crops most likely to see GM traits commercialsed in the next 5-10 years (forage maize, oilseed rape and sugar beet), the organic area of these crops accounted for only 0.23% of the total plantings of these crops in the UK in 2003[3].  The organic area of these crops also only accounted for 0.23% of the total organic area in the UK.  Given this context, it is surprising that the Committee should perceive the commercialisation of GM crops in a limited number of arable crops could be ‘potentially destructive of the UK organic food industry’.

2. Thresholds.  The report cites evidence (para 13) from the Soil Association about the limit set in European law for the adventitious presence of GM material in organic produce as zero.  It also cites evidence both from the AEBC and the ‘government’ about the clear understanding of the legal position about the adventitious presence of GM material in organic produce (use of GMOs is forbidden in production but no legal threshold has been set in the Organic Production Regulation[4]).  This suggests no confusion in the government’s or the European Commission’s position but only possible ‘confusion’ by the Soil Association.  There are two clear ways forward for the organic sector on this issue:

Ø   Leave the setting of thresholds for adventitious presence of GMOs in organic produce (at thresholds that are lower than the 0.9% stipulated in the 2004 labelling and traceability legislation) to the discretion of individual organic certification bodies.  These can be applied to the members on a voluntary basis;

Ø   Seeking consensus amongst the organic sector across the EU for the 0.1% threshold to apply and hence bring forward a proposal at the EU level to have this threshold inserted into the Organic Production Regulation (2092/91). 

3. Separation distances.  Whilst the report cites evidence presented by SCIMAC and NGOs, it gives undue weight to the NGO evidence by failing to take into account that the SCIMAC guidelines for separation distances derived from an extensive review of literature and consultation with relevant experts in the field of cross pollination.    

4. Economic liability.  This section only discusses the issue of possible economic losses incurred by non GM and organic farmers as a consequence of finding GM adventitious presence in their crops.  The concept of equity in any economic liability provisions that might be developed (relating to the applicability of liability to all farmers regardless of production method, as presented in evidence to the Committee[5]) has been ignored.

Mis-representation of data/factual inaccuracies 

5. Separation distances.  In the section covering separation distances, paragraphs 25 and 26 both cite evidence presented to the Committee that states ‘recommendations made by the National Pollen Research Unit (NPRU) that a separation distance of 3 kilometres would be required for maize in order to ‘keep contamination at negligible levels’’.  The referenced paper by the NPRU[6] does not make any such recommendation.  In fact, the report does not have a recommendations section and the limits of the conclusions offered by the NPRU were ‘pollen distribution, as determined by outcrossing between different maize varieties, has been recorded at up to 800 metres’ (page ii, summary and page 17).  The cited 3 kilometre separation distance does not come from the NPRU paper but represents the recommendation of the Soil Association, based on its interpretation of the NPRU paper.  It is also important to note that (something the Committee failed to take into account) that no instances of adventitious presence of GM material has been reported in any organic crops located near to any of the FSE sites.

Web-site link to original Environment, Food and Rural Affairs Committee Report www.publications.parliament.uk/pa/cm/cmenvfru/607/607.pdf

For further information: contact Graham Brookes 01303 840958 or Peter Barfoot 01300 321501

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