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GM Crops

REPORT ON CONSULTATION VISITS TO FARMERS AND AGRICULTURAL CONTRACTORS

  1. As part of the fact-finding process to help develop pragmatic co-existence proposals, Defra undertook a number of visits to farms and agricultural contractors to find out their views on how easy and practical it would be to apply the range of possible measures to minimise GM crops contaminating non-GM crops grown in the UK. A total of forty visits were made, representing 48 businesses responsible for farming more than 18,616 hectares (46,000 acres).
  2. The interviewees included farmers who had taken part in the GM Farm Scale Evaluation trials, organic producers, seed growers and farmers with little knowledge or current interest in GM crops to ensure a cross-section of views were taken.
  3. The following co-existence measures were discussed: notification, separation distances, use of machinery, volunteer control and use of a GM register.

Notification to neighbours of intention to grow GM crops

  1. Most growers had a good knowledge of their neighbouring growers and would meet or contact them on a regular basis. Cropping was a common general discussion topic amongst these growers although only a few would coordinate any crop planning.
  2. Significantly the knowledge of neighbours and contact with these decreased when land was farmed at a distance from the main farm unit or taken on short term lets for grazing or potato/vegetable production. Often in these cases the only contact by the growers would be with the landowner or agent and not the neighbouring growers.

Separation distances

  1. Farmers were asked about how easy it would be to apply a separation distance should they choose to grow GM crops. Just as indicative distances, the figures quoted for oilseed rape (OSR) was expressed as 50 metres (200 metres for varietal associations and seed crops), 80 metres for maize, and 6 metres for beet.
Field boundaries
  1. Boundary types were predominately hedges, fences, and ditches. A number of growers had rivers (up to 20 metres wide) and woodland (10-20 metres but could extend to several kms) as boundaries. Often roads, housing, industrial or other uncultivated land provided separation from cropped land in tens of metres or kilometres. A number of units with cropped land bordered permanent hill grazing land that again could isolate cropped land by significant distances.
  2. In the majority of cases, common farm boundaries made up of hedges, fence-lines and simple drainage ditches provided an uncultivated area of between 2 and 5 metres. This was increased in some areas by conservation headlands or other uncropped land but these additional features by their nature and the schemes they operate under could be easily removed.
Ability to achieve separation
  1. The ability to achieve separation from a neighbouring compatible crop at the current proposed distances varied between growers. Both large and small units could envisage the ability to accommodate either their own requirements for separation or that of a neighbour without the need to subdivide fields. The smaller the unit or block of land the lower percentage of cropped land that could accommodate any neighbouring GM crops in this way. On some farms all fields would be within 50-80 metres of a neighbouring growers fields. A number of farms were only one field wide.
  2. The larger the farm units or blocks of land the greater the ability to achieve whole field separation, and units with residential/industrial or hill land on adjacent boundaries also had greater flexibility.
  3. Some growers indicated that it might be possible to subdivide cropping in fields in order to achieve a desired separation distance.
  4. A number of the growers who had considered growing GM crops indicated that they would only proceed if they could accommodate the required separation distances within their own land, or that if they received objections or concerns from neighbours after notification where the required separation distance would be partly on the neighbours land, they would withdraw from planting that GM crop.

Crop Rotations

  1. Due to the spread of farming enterprises visited in the study, rotations were varied although some established practices were present. The use of Winter OSR as a regular or possible choice of break crop was common in many of the arable units visited. Many units also retained the option to grow Spring OSR as a fall back position to guard against poor autumn weather/ground conditions for drilling Winter OSR or cereals, or severe winter conditions such as frost heave or pigeon damage to autumn crops
  2. Maize for silage was grown by a number of the stock farms and although some units planned ahead the position of this crop, it was also commonly seen as a flexible part of the rotation with the exact cropping area often being adjusted to take account of poorly performing grass swards in early spring.
  3. Potato seed, ware and processing crops were the significant crops of a number of the growers. These each have strict rotation requirements predominately due to pest and volunteer pressures, and limitations such as access to irrigation. The planned cropping areas for these are some of the least flexible.
Synchronisation of neighbours rotation
  1. Planned synchronisation of adjacent cropping by neighbouring growers was very rare and restricted to OSR plantings. The reasons for this cooperation by growers included the dilution of pest pressure and concentrating the pollination activity of bees and insects.
  2. Farmers recalled that cereals and grass were most commonly grown immediately adjacent to identical neighbouring crops. OSR also met without coordination at farm boundaries although less often as it was a less frequent component of the rotation, and unless rotations were synchronised between growers, minor changes could easily disrupt previous synchronicity.
Ability to adapt rotation
  1. The ability to adapt rotations is closely linked to the current cropping regime and the various controlling elements within any particular cropping programme. Where growers were willing to consider adapting a rotation to accommodate an element of a separation distance for a neighbouring grower, too early an agreement may limit the flexibility for both the GM and non-GM farmer to subsequently change plans in response to changes due to weather, crop failure or seed supply problems.
  2. A number of growers expressed willingness to assist GM growers as long as there was no financial or logistical penalty for their business. Some growers might be willing to seek a financial compensation agreement between themselves and the GM grower to accommodate any lower margins achieved by substituting a different crop.
  3. Where the growers considered that the required changes imposed an unreasonable requirement to change their plans or accept an alternative crop, they stated they would be unwilling to agree to accommodate the GM crop

Use of machinery

Contractors used
  1. A wide range of contractors were used by the growers for everything from basic farm duties to land drainage, hedge trimming and manure/fertiliser spreading. Some growers employed contractors for all farm operations. The most common tasks undertaken by contractors were cultivations, seed drilling, harvesting (cereals and forage) and baling.
Current check of contractors' equipment for cleanliness
  1. Growers conceded that generally very few checks on the hygiene of contractors' equipment were carried out. Most could illustrate situations where contractors would clean down equipment, for example if repairs or maintenance were required or where excess soil might be deposited on the highway after leaving a field.
  2. Significantly seed production, organic, specialist fruit stock and some sugar beet growers were the most diligent, regarding the cleaning down of machinery prior to entry on to their units as essential and an obligatory job for contactors undertaking this work. The level of expectation in these cases was high but the frequency of checking compliance with contractors varied. Often the grower believed that the request/expectation would be carried out because of previous experience with the contractor.
  3. Where cleaning was undertaken it was currently absorbed in the overall contracting business and the costs spread over all work. Contractors intimated that if the work became a requirement and the time/labour cost significant, then they would need to either increase overall costs or adjust those costs to GM growers. Overall contractors felt that their 'maintenance level' of hygiene, which they operated to ensure safety and correct machinery operation, was already a good standard. One contractor intimated that he would be in favour of specific 'requirements' to clean down, as these would create transparency for the customer if he were forced to increase costs to undertake this work.
Additional burden to clean machinery
  1. The differences in perception and machine type were apparent when asked about any additional burden that would be apparent if strict requirements to clean equipment whilst moving between GM and non- GM crops. Machinery such as combine harvesters used in OSR were identified as requiring extensive cleaning to remove all traces of seed.10-15 kgs of OSR seed was suggested by several interviewees as the amount remaining within a combine harvester after use, and prior to any manual intervention by an operator to clean the machine.
  2. Simpler machinery such as soil cultivation equipment could be easily manually cleaned down or washed. Forage harvesting equipment used for grass/maize harvesting retained less reproducible material and was generally easier to clean.
  3. Weather conditions are a significant factor in the ease of cleaning equipment especially when dealing with soils residues and a number of growers and contractors highlighted the problems of access to suitable cleaning equipment at remote locations.
  4. A number of growers raised the possibility of dedicated GM equipment of contractors specialising in GM work
  5. The main burden was described as the additional labour cost and the possibility of 'lost time' at critical periods' - both in terms of the revenue earning potential of the contactor and in the ability of the grower to complete tasks within weather windows.
  6. This would be exacerbated where there was a requirement to move between fields/crops over a short space of time. This scenario could and regularly did occur for growers due to local variations in weather/ground conditions or differences in the maturity of a crop over a field or farm unit or where high capacity equipment is used to work in small fields. Some growers intimated that they have carried out harvesting work in sections of five or more fields in any one day.
Sharing machinery
  1. The sharing of equipment either formally or informally between growers or within business units was common. A significant amount of this 'sharing' was at critical times either to boost capacity for example when harvesting or drilling seed, or during emergencies due to breakdowns or impending adverse weather. The work and equipment 'shared' at these critical periods were likely to be that carrying most risk of transfer of GM material at a time when time and labour to undertake any required cleaning was at a premium.
  2. A number of growers indicated that significant requirements to clean down equipment between GM and non GM crops would make then reconsider the sharing or use of neighbours equipment. Others indicated that the compliance rates during peak times may well decrease due to the pressure of completing the work in an acceptable time period or weather window. Other growers could envisage creating simple hygiene rules or separation between business units to reduce any operational burden.
Volunteer control
  1. Volunteer control was generally described as being undertaken as Good Agricultural Practice (GAP). In cereals and OSR this was commonly described as involving surface cultivations after harvest to stimulate seed on the surface to germinate and then controlling these small plants by further physical cultivations or a herbicide spray. On conventional farms herbicides in the following rotation were used to control later emerging volunteers. On organic units physical cultivations during the following rotations, or after fallowing were used.
  2. Maize volunteers were not considered to be a problem with no survival of fallen seed over winter. Potato volunteers or ground keepers were controlled by cultivations and subsequent herbicide applications. Volunteer potatoes in some subsequent broadleaf crops could present a problem due to the lack of suitable herbicides.

Notification

  1. Most growers who considered that they might one day grow GM crops were content with the requirement to notify neighbouring growers of their intentions, and many stated that would be likely to informally notify their neighbours out with any statutory requirements either to allow these growers, organic or non GM, to make informed choices for the management of their crops or to assist in promoting the transparency of GM cropping. Similarly some of these growers would expect a reciprocal arrangement from other GM growers informing them.
  2. There was evidence of effective informal notification and agreement for the physical separation of industrial OSR crops between growers.
  3. A standard format or proforma for notification was requested to assist in the notification process
  4. Some growers were concerned about the administrative burden if the notification requirement for their units extended to a large number of neighbouring growers, and any additional requirement to record responses or chase non-replies.
  5. A few growers felt that they would wish to notify to wider group of growers outwith the proposed immediate neighbours either to allow these growers, organic or non GM, to make informed choices for the management of their crops or to assist in promoting the transparency of GM cropping
  6. There was a good indication that most growers would respond to notifications received from GM growers.
  7. Farmers gave a number of reasons why they would want to be notified even if their fields were not within the crop separation distance:
    • The effect on organic status possibly driven by certification body or their own requirements;
    • Personal desire to remain GM-free below any defined threshold;
    • Lack of current information on which to base the possible risks to compatible crops/weeds flora;
    • GM status declaration now required on conventional OSR grain passport;
    • Would like to know what was happening locally;
    • Unsure of any implications for own non-GM crop;
    • Seed producers would require to know locations of GM crops out with the planned notification area to allow own risk assessments for UK conventional seed production;
    • Requested an individual say in where GM crops are grown;
    • Concerned that customers will require the provision of information relating to GM plantings even if the plantings are not within the notification area
  8. A smaller number of growers saw no need to be notified of any GM plantings.
When should notification be given?
  1. The notification period requirements expressed varied by personal choice, current crop rotation system, certification body requirements and degree of flexibility available or wished to be retained.
  2. Some of the organic producers interviewed are now required to submit forward cropping plans 2 years in advance. Some conventional growers had already made decisions for cropping 1 year ahead.
  3. Other growers make reasonably firm decisions in early spring. Crops which were not allocated a rigid place in a rotation (e.g. required break crops) or where a wider choice of location is not precluded, due to disease/pest burdens, can often adapt with shorter notification periods. Of these growers, requests for notification were around 4-6 weeks before planting winter crops, and 6-8 weeks for spring crops.
  4. Notification in May/June prior to planting autumn crops was quoted by a number of growers as allowing them some flexibility.
  5. It was noted that availability of seed for a particular variety or crop and the prevailing weather conditions at harvest or immediately afterwards could result in a significant changes to a proposed crop plan.
  6. Some growers stated that they would appreciate early notification of proposed spring plantings as this could influence their planned winter plantings.

GM Register

  1. Farmers were canvassed on whether there should be a GM crop register, either 'real time' or as an historic record. They were asked to consider the question from the viewpoint of both a GM and a non-GM grower. A wide range of views were expressed:
    • It would automatically be seen as part of the conditions;
    • Any benefit would only be in the light of any risk to other crops;
    • Wary of other uses for such a register especially in early stages where grower numbers were lower and crops new;
    • Against a register as it may facilitate crop trashing;
    • Could replace the need to notify;
    • Could merely be an extension of IACS data collection;
    • No problem once technology accepted and growing GM as one of a large body of growers;
    • No need if growers communicate with neighbours;
    • A register would assist in demonstrating openness of technology;
    • Should be mandatory;
    • Would like to know what was happening locally (if not in notification area);
    • Need to know location of GM crops as seed producer of compatible crops;
    • Not convinced of any benefit to non GM growers;
    • Essential as non GM grower - already asked for declaration on non GM inputs to farm produce - need to know where all inputs that are not tested are produced;
    • Would want to know if GM production outside notification area could compromise own organic status;
    • Shouldn't be needed if co-existence system robust, but could see the benefit for land purchases where cropping information not available;
    • Needed to demonstrate confidence in industry and to satisfy customers;
    • Would welcome to allay concerns over compliance with requirements by neighbouring GM growers. Even GM growers would want to know what other growers were doing
    • Historic data needed where land changes hands without cropping data;
    • Believe that customers will want information on GM plantings, a register may be a vital tool in providing that reassurance to customers;
    • No need if crops not compatible, expect separate scheme for organic growers;
    • Shouldn't be needed if scheme works, but may assist in reassurance;
    • Requirement dependant on the extent and effectiveness of notification scheme;
    • Can see no current need.

GM Crops Policy Team
Defra
March 2005

Page last modified 7 March, 2005
Page published 07 March 2005

Department for Environment, Food and Rural Affairs