GM Crops
GM co-existence consultation: Summary of workshop discussions
Introduction
As the first phase of engagement with stakeholders on the co-existence issue Defra and the Devolved Administrations held a series of workshops between August and October 2004. These were helpful in providing evidence to inform the further development of our policy thinking. We are now preparing a written consultation package of co-existence proposals and options to be issued in 2005. Everyone will be able to comment on this.
Defra and the Devolved Administrations are collaborating on the co-existence consultation process because the same basic questions will arise across the UK. However, co-existence is a devolved matter and the authorities in Wales, Scotland and Northern Ireland are therefore responsible for developing the policies to apply in their respective territories.Like Defra, they will publish their own consultation papers in due course.
This note is not intended to be a comprehensive record of the discussions that took place in every workshop. Rather it is intended to provide an overview of the main points that emerged. It has been arranged by theme rather than by workshop. This is because while some workshops were held with specific interest groups or on specific topics, a number of issues were raised in some or all of the workshops. At each of the workshops it was outlined that the basic measures being considered for co-existence were:
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a farmer-to-farmer notification rule (i.e. GM grower tells neighbouring producer of his intention to sow a GM crop, if the neighbour's land is within a specified separation distance)
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the application of crop separation distances to minimise GM cross-pollination
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the control of GM 'volunteers' and 'bolting' plants
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the cleaning of farm machinery to minimise the possible transfer of GM seed (where machinery is to be shared between farms)
Key Points Arising
The aim of co-existence measures
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The aim of co-existence measures needs to be clearly defined and explained.
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The 0.9% EU labelling threshold should be seen as an upper limit and in designing and explaining co-existence measures it should be made clear that the aim is not routinely to permit this level of GM presence, but rather to minimise it so that on a worst case basis it is at least below the 0.9% level.
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Different interpretations can be argued of the current EU legislation in relation to adventitious and technically unavoidable GM presence.
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If Government facilitates co-existence based on the 0.9% statutory threshold it is possible that the market will work to a lower threshold
Organic issue
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The general view within the organic movement favours a special standard for GM presence in organic production if at all possible; this is in line with the position it has adopted on GM technology, and what it perceives may be necessary or desirable in terms of meeting consumer expectations.
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Different interpretations can be argued of the current EU legislation on organic production in relation to GM presence.
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There are different viewpoints on the practicality of a 0.1% limit of detection threshold, including in relation to the reliability of PCR testing at this level.
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The idea of a process-based standard rather than a specific value for a lower GM threshold should be explored further. It was noted that in general organic standards adopt a process based approach rather than analysis of the composition of the end product.
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The organic sector would obviously favour the view that the GM sector should be responsible for taking the measures necessary to deliver any lower organic standard, and should provide redress for any economic losses that organic farmers might suffer.
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If the UK favoured a lower GM threshold imported organic produce could not be prevented from entering the UK which complied with the 0.9% threshold. This may well put the UK organic industry at an economic disadvantage unless a lower threshold was adopted by the EU on a statutory basis.
Agronomic measures
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While crop specific separation distances are accepted it was also noted that local conditions such as field size, shape and topography could influence the required separation distance.
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There was some discussion as to whether separation distances should be varied to take account of such local circumstances but it was generally felt that a 'one size fits all' conservative distance would have the clear advantage of simplicity, certainly in the early years of any potential GM cropping.
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Alternative means of minimising cross-pollination were discussed, such as the use of barrier strips.
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It was noted that there would be a 'scale effect' if GM cropping became more widespread which would mean that cross-pollination would have to be considered on more than a single field-to-field basis.
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It would be very difficult to minimise cross-pollination in varietal associations of oilseed rape. However, it was noted that the use of such varieties had all but stopped.
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If existing good practice on volunteer control was followed it was generally not considered to be a problem for farm-to-farm co-existence. It would be more of an issue for co-existence within a farm (i.e. where it is intended to grow GM and non-GM rape in the same field)
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Due to the likely very high level of volunteers the situation of set aside or fallow land following on from an oilseed rape crop would need to be considered as a special case.
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It was considered that existing machinery cleaning protocols could be successfully built upon, although current best practice needed further investigation. However, there was an acknowledgement that no cleaning protocol would be entirely effective and at busy times might be even less so. One option might be to consider dedicated machinery for either GM or non-GM cropping.
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Monitoring to validate the success of co-existence measures would need to be an integral part of any agreed system.
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Further information will become available over the coming years which may lead to refinements of the measures needed. In addition the practical experience of any early years of GM crop cultivation will add to our pool of knowledge in this area.
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Relevant experience of GM crop management in other countries was noted as a possible source of evidence.
Voluntary GM Free Zones
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The general view which emerged from the workshop was that it would be very difficult if not impossible to establish effective voluntary zones.
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Different definitions of what a GM-free zone might entail were discussed. This included discussions of what auditable criteria produce of a zone might have to meet, and what GM inputs might or not be permitted (e.g GM animal feed/ GM medicines/vaccines). This relates to the labelling claims that might be made on any produce from a zone.
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A variety of stakeholders, other than farmers, were highlighted as possibly involving themselves or instigating the establishment of a zone. These included local authorities or supermarkets.
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While a zone could comprise a very small area in theory it was noted that in general for a zone to be meaningful it would have to comprise a reasonably substantial size.
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In general it would be easier for farmers within the middle of the zone to meet whatever criteria are set than those on the edge of a zone.
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It was thought likely that it would be resource intensive to establish and maintain a zone, and would thus place costs on farmers within the zone.
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In light of the above there would therefore need to be a clear commercial incentive for farmers before they might consider participating in a zone. It was not clear whether this would be the case.
Notification
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If compliance with a rule on notification needs to be demonstrated then a specific document is likely to be required which both the GM farmer and the neighbouring non-GM farmer would have to sign up to.
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Therefore it was noted that some element of co-operation would be required from neighbours, and flowing from that some expectation of 'reasonable behaviour'. Some termed this as 'co-responsibility', for example a non-GM neighbour might be responsible for responding to a notification within a set timeframe.
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The requirements on the timing of any notification would have to finely judged between providing clarity and certainty on the one hand, while maintaining flexibility on the other.
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What constituted a 'neighbour' and a 'farmer' would have to be clearly defined.
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People other than immediate farming neighbours might want to know where GM crops are being grown e.g. other growers or beekeepers.
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Therefore a GM crop register should be considered for those who have an interest in the location of any GM crop cultivation but will not be informed under the notification rule.
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A GM crop register was also raised for other purposes, including as a record of land use.
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Various practical issues were raised concerning a GM crop register such as the level of detail required; whether access should be to all or limited in some manner; the advantages and disadvantages of pre and post sowing additions to the register; and how a register might relate to existing crop cultivation data collection exercises.
Inspection and Enforcement
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The expectation is that a high level of inspection and monitoring would be required during any introductory period to validate the measures introduced.
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In the longer term if co-existence measures are demonstrated to work then the level of inspections could fall.
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Appropriate means of ensuring compliance with measures, including suitable penalties as necessary, would be required.
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The potential role of assurance schemes in ensuring compliance with co-existence measures was noted.
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Ideas such as registering and training GM farmers were suggested for consideration.
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There were different views on what level of testing would be needed to validate the system.
Compensation and Liability
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The issue of having a workable and practical means of redress for non-GM farmers who suffer economic loss as a result of excessive GM presence needs to be considered.
Page last modified
14 December, 2004
Page published 14 December 2004