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| Comments
for the National Debate on Genetic Modification |
CFG
11/03
Comments for
the National Debate on Genetic Modification
Economic
Issues
Environmental Considerations
Farming implications
Acceptability to consumers
Health implications
Regulatory Issues
Additional Comments
General remarks
Foodaware welcomes the opportunity to present its collective views
for consideration by the GM Debate Steering Board and some individuals
from Member organisations have completed the feedback questionnaire.
For ease of analysis by the Board, we have tried to structure our
response in line with the main topics covered by the feedback questionnaire.
This has been somewhat difficult given the complexity of the issues
under consideration and the simplicity and subjective nature of the
questions asked.
Although primarily concerned with the production, processing and marketing
of GM foods and food ingredients, Foodaware supports the principle
that agricultural production systems s hould be sustainable and the
use of agri-chemicals limited to those which are essential. We believe
regulations should be established to protect the health and well being
of consumers, and to help them make fully informed choices. We do
not comment specifically on the environmental aspects of GM production
which is outside our main remit and expertise. It is particularly
regrettable, however, that the Steering Board has not asked any specific
questions about transparency or labelling which are known to be matters
of considerable concern to UK consumers. We have nevertheless provided
our views on these issues in relation to Question 1 - Economic issues
and Question 10 concerning Regulation.
Specific Comments
1. Economic Issues
Q1: I believe GM crops could help to provide cheaper
food for consumers in the UK and Q4: I am worried
that this new technology is being driven more by profit than by the
public interest.
Foodaware's over-riding consideration is that consumers should have
access to a reliable supply of safe, nutritious food at a variety
of prices to meet the needs of customers Whatever their economic circumstances.
To make informed choices, consumers need to know what they are buying,
its defining characteristics, how it has been produced and any specific
implications for their health or safety. Any economic assessment of
the costs and benefits of permitting commercial production of gm crops
must take account of the willingness of UK and European consumers
to purchase raw and processed products of this technology.
Consumer decisions regarding food are complex. They are influenced
by many factors, including life-style choices, ethical and religious
beliefs, price, availability and taste. The introduction by some supermarkets
of gm tomato paste and of cheese using a genetically modified enzyme
showed that some consumers are prepared to consume these products.
Foodaware believes that people should be able to make their own choice,
but that alternative products should remain on the market so that
those who do not wish to consume products which result from this technology
have an alternative. We are also aware that the price premium for
organic produce makes it unaffordable for many low-income consumers.
Foodaware supports the development of sustainable agriculture. We
would not support distortion of the market by the use of farm subsidies
or other production aids to promote the application of this technology
to food crops. American and WTO pressure on the EU to admit gm commodity
crops and other products on to the European market despite the lack
of consumer support or regulatory clearance, strongly suggests that
financial considerations are being given precedence over the public
interest in determining this issue.
2. Environmental Considerations
Q2: I am concerned about the potential negative impact
of gm crops on the environment and Q6: I think that
some GM crops could benefit the environment by using less pesticides
and chemical fertilisers than traditional crops and Q12:
I think that GM interferes with nature in an unacceptable way. Members
consider that the jury is still out on the potential for environmental
damage from gm production. We support measures to reduce the use of
pesticides, herbicides and agri-chemicals in food production. The
evidence that the use of gm seed can reduce the use of pesticides
and other chemicals is inconclusive. Long term use may require changes
in the type of pesticides and herbicides required rather than a reduction
in the levels in the final products on sale to the consumer. Foodaware
wants people to have the opportunity to purchase products which have
not been produced using gm technology. If commercial production of
gm crops is permitted in the UK, the production systems must allow
for adequate separation between those areas growing gm products and
those which are not. This has not been the experience in the United
States where problems of contamination have occurred from cross-fertilisation
during the growing phase and during harvesting, processing and distribution.
3. Farming implications
Q3: I believe that GM crops could improve the prospects
of British farmers by helping them to compete with farmers around
the world and Q7: I think GM crops would mainly benefit
the producers, and not ordinary people.
We are not convinced that the introduction of this technology into
the UK will assist British farmers whose reputation has suffered from
the impact of BSE, foot and mouth disease and other high profile food
safety problems. While these have diminished in recent months, the
answer to the question above will vary depending on the particular
market, the crop being produced and the potential consumer benefits.
We see little benefit to British farmers unless there is a demonstrable
consumer benefit from gm production. To date, the claimed consumer
benefits have been lower price for gm tomato paste, and the ability
to produce vegetarian cheese using a gm enzyme. It is unclear whether
the development of gm commodity crops has produced benefits for consumers
or whether future production of gm oils, potatoes and sugar beet will
bring price or quality benefits to UK consumers.
European agricultural support systems should not be used to encourage
the continued production of non-gm crops.
4. Acceptability to consumers
Q5: I would be happy to eat GM food.
Consumer surveys in recent years have consistently shown that a significant
number of consumers do not wish to eat GM foods and wish to retain
the right to choose alternative products. The Food Standards Agency's
annual consumer survey of a representative sample of 3000 people shows
that while there has been a gradual decline in concern about GM foods,
in 2002, 36% still registered concern. Three quarters of these people
were sufficiently concerned to claim it affected their eating habits
[FSA 03/05/04].
Even more pronounced is the desire of UK consumers to know what is
in the food they eat and how it has been produced. Research by the
National Consumer Council found that two thirds of consumers say it
is important that food made from gm plants is labelled, and a third
say information on gm ingredients is among the three most important
pieces of information that should be provided on food labels. More
specifically, 8 out of 10 people want meat and other animal products
fed gm feed to be labelled which goes beyond current EU requirements.
Without such information consumers cannot make effective choices [See
section 6].
5. Health implications
Q8: I don't think we know enough about the long-term
effects of GM food on our health and Q9: I believe
that some GM non-food crops could have useful medical benefits.
There is insufficient knowledge of the potential long-term health
consequences to judge this question and we are unaware of any research
currently being undertaken in the UK or elsewhere into this vitally
important aspect of potential long term health risks. We applaud current
research into potential long-term health benefits, but we find it
astonishing that the UK Government does not appear to have commissioned
further studies into potential health risks either directly or through
the EU or other international bodies. See comments under section 6.
While knowledge of potential medical benefits is also limited, we
believe that research in this area would be valuable and should continue.
6. Regulatory Issues
Q10: I am confident that the development of GM crops
is being carefully regulated, Q11: I am worried that
if GM crops are introduced it will be very difficult to ensure that
other crops are GM free and Q14: Under what circumstances,
if any, would you find it acceptable for GM crops to be grown in this
country.
At European level, Foodaware believes that the framework put in place
for the regulation of GM foods and ingredients is satisfactory and
commented in detail on the European Union proposals regarding novel
foods (Regulation EC No 258/97) before its adoption in 2002 (Attached
as an Appendix). Safety assessments are designed to ensure that the
final food products are safe but we recognise that safety is a relative
concept and there is always some risk associated with the introduction
of new technologies and processes. European Regulations require the
safety of gm food and animal feed to be evaluated before it is marketed
and we strongly support this approach.
We are concerned, however, that assessments that products are safe
for consumption in a third country may not be considered acceptable
within the EU. Standards vary and what may be deemed an acceptable
risk in a third country may differ from standards and consumer expectations
in the UK. Furthermore, there are genetic differences between populations,
different consumption patterns etc and these can affect the outcome
of a risk assessment. There needs to be international agreement on
the nature of the testing which is acceptable worldwide and the criteria
for determining safety. It is also important in the public interest
for the process of safety assessment to be open and transparent so
that those who wish can study the basis on which both the scientific
assessments and regulatory judgements have been made.
Health considerations are important for the population as a whole
and for particular subgroups with particular needs. There is no satisfactory
means of monitoring the population as a whole for potential long term
effects. Foodaware is keen that arrangements for post-marketing surveillance
should be introduced to enable unexpected outcomes to be identified.
Increased prevalence of allergies would be a particular risk for which
monitoring should be established. Competent authorities should always
be able to review a decision, withdraw or limit marketing authorisations,
and introduce additional labelling requirements.
Consumer choice is a fundamental issue for consumers in the context
of gm production. Public authorities should assist suppliers seeking
non-gm sources of food and encourage the maintenance of diversity
within the European Union. Regulators should seek to ensure appropriate
separation of the different production streams for gm and non-gm produce,
and to limit the risk of cross-contamination to a minimum. This is
vital for consumer confidence. In the EU, labelling is required if
0.9% gm material is in a food and there is a temporary tolerance threshold
of 0.5% for accidental presence. These levels may warrant review in
the future in the light of consumer views and in the face of opposition
from some Member States. Foodaware would prefer the regulatory limits
to be at or near the limit of detection which will change as testing
methods improve. Any threshold should be based on best practice and
the avoidance of contamination.
We are concerned about the ability of regulators and suppliers to
maintain the integrity of the European market and the effectiveness
of regulation in the face of global pressure to expand the area under
production with gm crops and to extend the market particularly for
commodity crops. Traceability has been an ongoing issue and the systems
do not seem adequate to ensure clear separation throughout the food
chain. Attempts are being made with in the EU to improve traceability
and testing methods. We strongly support these developments. Gm produce
in transit should be accompanied by detailed records so that an audit
trail can be established throughout the supply chain. Unique designations
will not be meaningful where bulk transportation results in cross
contamination and a number of different gmos are present. Nevertheless,
this should not prevent continued work to achieve segregation and
the transmission of information on the content and sources of bulk
supplies.
The European authorities cannot impose binding obligations on exporting
countries, so there is a significant reliance on importers to obtain
appropriate documentation from suppliers or carry out compliance testing.
Knowing the origin, method of production and processing of foods and
their ingredients is a necessary part of a firm's due diligence and
we believe is good business practice. Such requirements should not
therefore be unduly onerous or add inappropriately to costs. Whatever
regulations are introduced to ensure that food is safe, wholesome
and properly labelled, it comes to nothing if not properly enforced
and all in the food chain have a part to play in securing this.
Accurate labelling is fundamental to the exercise of consumer choice.
The final consumer (whether a private individual, retailer or caterer)
should always be clearly informed about the product, its production
method and its characteristics and particularly whether it has been
produced using gm technology. The recently adopted EU regulations
are a significant step forward in this regard but it is too early
to say how well they will be applied in practice. Consumers need to
be able to rely on the accuracy of information on labels and to know
that as methods of testing improve, levels of enforcement are adequate
to prevent them being misled.
7. Additional Comments
Q15: Additional views
Foodaware has long supported innovation to improve consultation processes,
and particularly encourages the feeding back of the outcomes of such
processes into government policy (which did not happen after the 1994
consensus conference on plant biotechnology). However, before relying
on the outcomes of this initiative to influence policy development,
the effectiveness of the process needs to be evaluated and taken into
consideration. It is not clear whether, or how, this might be done
and how the outcome of the Steering Group's work will be taken forward.
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