 |
Agriculture and Environment Biotechnology Commission (AEBC) | |||
 |
Sub Groups |
 |
 |
|
|
CONSUMER CHOICE SUB-GROUP
NOTE OF SIXTH MEETING: TUESDAY 28 JANUARY 2003, 1 VICTORIA STREET, LONDON, 11.00am-3.00pm MINUTES OF MEETING Note: These are the views of the sub-group, not necessarily of the full Commission Present Ms Helen Browning Dr Dave Carmichael Dr Rosie Hails Professor Jeff Maxwell Dr Roger Turner (Convener) Secretariat Richard Abel Apologies 1. Julie Hill had sent apologies. Minutes of previous meeting 2. The minutes of the 29 October meeting were agreed. Options for co-existence 3. The group had before it the draft revised outline report structure. They discussed some of the issues raised in it in the light of points made in the discussion at the whole Commission meeting in December 2002. 4. The group discussed the parameters within which the AEBC report could give advice to Government on co-existence under any commercial growing of GM crops. The group would explore the extent to which there could be a solution that would command general support from a broad range of stakeholders, particularly farmers, and the general public. Broad support would be needed for the approach or approaches adopted in the UK if commercialisation went ahead. The group thought that the approach adopted had to be firmly rooted in the reality of present farming practices, be practicable, and be based initially on the GM crops that were likely to be introduced first, taking account of where there might in practice be pressure points (e.g. which crops were widely grown organically) and how widespread would these be geographically. 5. Like the liability group, the sub-group confirmed that they had ruled out a statutory zoning arrangement across the country as too dirigiste and an unacceptable constraint on farmers’ freedom to grow the crops they judged best for the market. 6. Could there be ‘voluntary’ zoning, however? One option could perhaps be farmers in a particular locality agreeing together, perhaps under the auspices of a local government body, that the presumption would be that farmers in that area did or did not grow GM varieties of a particular crop or crops. To work, this would need to avoid individual farmers being pressurised to go one way or another. Good will would be needed. It might be that the very nature of this solution was such that it would arise if at all only spontaneously and locally as a result of discussions among farmers, landowners and others involved in agricultural production. 7. The group again discussed the rate of uptake of GM crops by farmers in the UK, which if it went ahead at all would probably be a gradual process. This could allow a de facto ‘phasing in’ of commercial growing, with opportunity to monitor how co-existence was or was not being achieved in practice. Gradual uptake seemed likely due to the nature of the GM crops available or close to approval for commercial cultivation and suitable for cultivation in the UK, and the fact that many farmers seemed likely to wait to see how their markets reacted to cultivation of GM crops. Some members thought that the present market conditions in the UK and EU and perceived state of public opinion would mean that any take-up of GM food and feed crops would be slower than for conventional new varieties. 8. The likelihood of gradual take-up could allow the development of a national protocol for farmers who wanted to use the technology to be tested in commercial practice and adjusted if necessary in the light of experience, so not preventing those farmers who did wish to grow GM crops from doing so but providing measures to limit adventitious presence affecting those who were growing organic or other non-GM crops. 9. What might a protocol look like? Some members thought that the SCIMAC guidelines would be a sufficient basis. They considered that the implementation of these guidelines had been effective in the course of the FSEs. A protocol would probably need to be UK-wide (or there should be at least a national protocol for each of England, Scotland and Wales) rather than lots of local arrangements, to give the public and farmers confidence that a consistent and widely agreed arrangement had been put in place. But the protocol would have to take account of any relevant regional differences, for example in respect of volunteer persistence or farming practices. 10. The group discussed the extent to which monitoring environmental impact might be part of any co-existence protocol. The Part C consent to market GM seeds would require provision for long-term environmental monitoring (under the terms of EC/2001/18). ACRE was looking at the area of long-term monitoring requirements. The sub-group could see merit in integrating this sort of monitoring of GM crops with other monitoring of the environmental impact of agriculture. Environmental monitoring of the impact of any GM agriculture would be usefully considered and undertaken as part of more general monitoring of agricultural impacts, as set out in the Curry Commission report (and parallel exercises in the devolved territories), in a wider context of increasing the financial incentives for agri-environmental schemes and monitoring compliance with such schemes. It would be part of getting a better overall picture of the impact of all sorts of farming on the environment for society to decide what sort of countryside it wanted and was willing to pay farmers to look after and develop. A national protocol, however, would not itself be the vehicle for long term monitoring of environmental impact of GM agriculture as it would be focussed on co-existence of GM and other crop-growing a way of protecting economic interests of all farmers in relation to possible GM cultivation. A broader integrated programme of environmental monitoring would be better. 11. There would need to be monitoring – perhaps a transitional scheme – to establish whether in practice the agronomic practices in the protocol were avoiding breaches of the agreed thresholds for adventitious contamination. The group reiterated that both the thresholds and the provisions of the protocol set for this purpose had to be practicable. If achieving a particular threshold depended inter alia on farmers always following a highly demanding standard of ‘best practice’ rather than normal (acceptable) practice for maintaining separation of crops, then it seemed reasonable to assume that the threshold would probably be breached. Certainly the assumptions about agronomic practice in setting policy on co-existence needed to be explicit. The group would assume in its advice that these would be the levels set in the relevant proposed European directives i.e. 0.9% for food and feed crops, with correspondingly lower thresholds for seed crops. The group noted that the European Commission had set no threshold for acceptable AP in organic crops. 12. For organic producers in the UK, a ‘zero’ threshold in practice meant the lowest detectable limit, 0.1%, the threshold if commercialisation went ahead. It seemed to the group that a threshold for organic produce needed to be negotiated and agreed before any crop commercialisation. It could be that if detectability could be reliably achieved at levels lower than 0.1% then the organic movement might seek a lower threshold. The group noted that the evidence they had heard to date was that for most crops 1% or 0.9% would probably be deliverable for co-existence at least in the short to medium term; but 0.1% for crops such as oil seed rape or cereals under conditions of widespread GM cultivation, would be very difficult to achieve (although the very low level of organic production of oil seed rape in the UK might mean that in practice 0.1% might well be achievable). The report would need to spell out the reasons why. 13. Keeping below 0.1%, even under widespread GM cultivation, might be much easier for some other crops, however, particularly sugar beet, which had a different life-cycle. The approach to the co-existence question seemed to the group to be something that had to be undertaken on a crop-by-crop basis. One had to consider also the extent to which particular crops were grown organically in the UK and the geographical distributions. But the group’s advice would need to flag up the expected extreme difficulty in respect of some crops of keeping AP invariably below 0.1% if those crops were grown widely. For the AEBC’s advice, the group agreed that 0.9% and 0.1% would be the thresholds used for developing scenarios and possible co-existence solutions for non-GM and organic agriculture. The AEBC report needed to test the scenarios based on these thresholds against provisions of a draft protocol to see what was deliverable. 14. How could a protocol be enforced? Members could see merit in terms of building confidence in making the protocol statutory with penalties for non-compliance. The British Society of Plant Breeders (BSPB) could enforce the protocol through its existing system of licensing of seed sales (within a statutory framework). Farmers and seed merchants were familiar with how the present system worked. The BSPB would audit the sale of GM crops. There would also be an onus on farmers to follow any consent conditions attached to the growing of particular varieties and labelled as such on the seed. Members thought that DEFRA’s position would be that the IACS (arable crops payment scheme) could not be used to police co-existence measures. 15. It could be that a statutory protocol would be adopted, initially at least, as a transitional arrangement only. The statutory scheme might be time-limited or reviewed at a defined point to see if it was working effectively or whether in fact it might be possible to dispense with it. Industry and farmers would probably take the view, however, that transitional schemes tended to become permanent even if not initially intended to be so, and so instituting a statutory protocol probably would be seen from the outset as an inevitable long-term increase in the regulatory burden on agriculture. Building on the existing statutory arrangements overseen by the BSPB might therefore be more acceptable to industry and farmers who wished to use GM technology. If this enforcement model was adopted i.e. it was industry monitored implementation of the protocol’s provisions to maintain successful co-existence - organic and some other farmers would be very likely to demand that the protocol was indeed statutory so that the protocol was backed up by legal provision. The group agreed that the draft report should consider the provisions of a protocol for a possible transitional period where commercial growing of GM crops was gradually and sporadically undertaken as well as against possible scenarios in which to achieve successful co-existence further down the line based on more widespread growing. This last point would need some work in the report to flesh out what it might mean in practice. 16. The protocol and the report would concentrate on what happened on the farm and go up to but not beyond the point where the crop from the farm was delivered to a processor or handler. Pharmaceutical crops 17. The sub-group discussed the possible production of pharmaceuticals in crops. Some development was already taking place on farms in the USA. Some drugs were being produced in food crops, particularly maize, which has a high dry matter content and so is an attractive vehicle for drug delivery. The sub-group agreed that there was a strong case for recommending in the report that if drugs produced in GM plants were to be licensed for production on the farm then the presumption should be that this should only be allowed if the plant was a non-food crop or it could be demonstrated by some other means – such as containment - that there was no reasonable likelihood of the drug-bearing crop contaminating food and feed crops. Incorporating ‘terminator’ technology in a drug-producing food crop did not seem adequate as a solution because it could not deal with possible physical mixing of the drug-bearing crop product with conventional counterparts. 18. The group agreed that it would be useful to set out in the report a brief account of the options for where expression of drugs could take place in the plants in case there were others solutions to the perceived problem. 19. Food crops enhanced with vitamins or designed to deliver vaccines would need to be considered on a case-by-case basis. There might be a general presumption that vaccines should preferably not be included in common foodstuffs to avoid possible mixing in the foodchain. But there could be exceptions, say if a vaccine for AIDS was produced which could most practicably be delivered using a food crop. The answer would depend on what was realistic and desirable in terms of vaccine delivery, particularly in the developing world. The group asked the secretariat to investigate further the rationale for why food-related crops were being considered for vaccine delivery. It was unclear whether they offered advantages over other means of delivery sufficient to make them a likely prospect, speaking to Dr Ed Dart in the first instance, and exploring with him the rationale for why companies had gone down this route for research and why particular food crops were seen as especially suitable. Action: secretariat 20. Growing GM vaccine-delivery crops for the developing world (bananas were commonly cited as a delivery mechanism) seemed unlikely to occur in the UK and so probably would not give rise to co-existence issues here. Looking further ahead, if GM ‘UK’ food crops were produced with enhanced vitamin content there might be a co-existence issue – but this would depend on the crop and mixing might be less problematic in terms of consumer attitudes for vitamins compared with pharmaceutical or other production. In any case before getting to the stage of growing vitamin-enhanced GM crops in the UK it was reasonable to expect that there would have been some experience of growing other GM crops and evidence of public attitudes towards growing those crops, and it would probably be premature to anticipate the situation at this stage. Other points on the draft report 21. For OSR, maize and sugar beet, farm-saved seed was not a major factor in thinking about AP thresholds and co-existence because these were hybrid crops and legally could not be farm-saved. 22. The section on crop lifecycles and critical control points would be developed to look at this section further to see the practical implications of different thresholds. The secretariat would consult Dave Carmichael, Helen Browning and Roger Turner in developing this section so that it reflected both best practice and farming practicalities. Action: secretariat 23. The group agreed that it would look at the issues around consumer choice in relation to animal products insofar as there were co-existence issues around production of animal feedstuffs in the UK, but would not focus on the use of GM and non-GM animal feeds in the report. The report would cross-refer to developments at EU level in Europe in respect of the cope of labelling of products but the report would focus on co-existence of growing GM and other crops. 24. The sub-group agreed that the report should examine the implications of the 0.9% threshold and correspondingly lower thresholds (0.7%/0.5%/0.3%) for seed production in the UK. 25. The group also agreed that there should be a forward-looking paragraph early in the report setting out the possible opportunities and difficulties associated with future GM developments, particularly in relation to production of non-food crops, although the report’s recommendations would focus on the crops most likely to be commercialised in the short and medium term. Action: secretariat Next steps 26. The group agreed that it had probably assembled and heard sufficient evidence to proceed with analysis and developing conclusions. 27. They agreed that the consumer choice report should be published close too and preferably alongside the AEBC’s liability report. The aim would be to produce both reports by the summer. 28. The secretary said that a new member of staff, Laura McMahon, would be joining the secretariat from the start of February. Laura’s main area of work would be supporting the work of the consumer choice and co-existence sub-group. In addition, the secretary said that he was actively seeking a suitable serving or retired civil servant on a short-term basis to boost the development of a draft report, given that supporting the GM debate was continuing to prevent the secretary himself taking forward work on the draft report. The sub-group welcomed these proposals. 29. The group agreed that work on the terms of a draft co-existence protocol would be the first job for the drafter, although it was recognised that engaging with the wider issues set out in the draft outline report would be necessary in order to develop the terms of a protocol. The protocol would be predicated on what would be practicable in terms of co-existence and how practicable solutions might be delivered. Action: secretariat Future meetings 30. The next sub-group meeting on 4 March was already in Members’ diaries. 31. A further sub-group meeting was scheduled for 26 March. 32. In addition a stakeholder seminar to discuss emerging conclusions was scheduled for 28 April. The secretariat would draw up a draft list of possible attendees. Action: secretariat AEBC Secretariat February 2003 |
 |
|||||||||||||||||||||||||||||||||||||||||
|
 |
||||
| Back to top |  |
|
 |
