ACRE Advice

Advice on Notification of Locations of GM Crop Releases

Introduction

ACRE was asked to clarify its position on the notification of six figure grid references for proposed GM release sites under part B of Directive 90/220/EEC.

Current Practice

The locations of sites for releases of GM plants are required to be notified to enable the authorities to assess the risk that might arise from the growing of the crop. However, for well characterised GM crops, consent is normally granted under the so-called first simplified procedures. Here the applicant carries out a risk assessment for one release site which is notified with the application. Consent is granted on this basis. Further sites are notified just prior to sowing and are accepted if the authorities are satisfied that the original risk assessment applies to the additional sites. Currently, officials in the Joint Regulatory Authority (JRA) make the decision whether or not to accept the additional sites based on the advice given by ACRE at the time the consent was granted. In cases of doubt the notification would be referred to ACRE for further advice. For consents issued under the simplified procedure ACRE has usually taken the view that a release on suitable arable farmland anywhere within the geographical scope of the consent would be acceptable. The JRA also seeks advice from the statutory Nature Conservation Agencies, such as English Nature.

The location of a release site is relevant for the following reasons:

• Assessment of the impact of the environment on the release;

• Assessment of the impact of the release on the local environment;

• Compliance with limitations and conditions of consent, such as

• border crops or pollen barriers,

• management of the crop,

• proximity of other releases of GM plants,

• separation from other crops;

• Post release monitoring particularly in subsequent years;

• Records and information in case of future problems;

• Information for those who wish to avoid the GM crop, such as bee keepers or organic farmers.

We are firmly of the view that for research releases of GM plants both we and the regulatory authorities need to know the exact physical location of the release site.

However in some circumstances this information is not necessary prior to release.

For certain releases of well characterised GM plants which satisfy the criteria for the first simplified procedure under Directive 90/220 the initial notification of the location need not be precise but the exact location must be recorded and notified to the regulatory authorities once the release trial is sown.

In giving advice we assume the following criteria:

• A well characterised GM crop plant satisfying the criteria for the First Simplified Procedures;

• Experience of growing the crop in UK and satisfactory post trial monitoring;

• A limitation to arable farmland in a defined geographical area, such as England;

• A risk assessment addressing all the expected environmental impacts within the geographical scope of the application, for example, impact on nature reserves and impacts on other habitats, assuming they could be adjacent to the GM crop or at the specified separation distance;

• Specified limitations on the area to be sown;

• Appropriate restrictions on proximity to other GM crops.

If these criteria are met our advice on specification of location is:

• Where the release is small, no more than 0.5 hectares (5000m2), such as for statutory seed trials, the initial information provided need only be at parish level.

• The exact location must be confirmed to the regulatory authorities after sowing and before the crop is harvested or the plants removed. This information must be placed on the public register

• The regulatory authorities must know the location of the site in order to carry out independent inspection and enforcement of the conditions of the consent and monitoring.

In all other cases the location must be specified exactly, by 6 figure grid reference or equivalent level of definition, before or at the time of sowing.