GM Crop Farm-Scale Evaluations:
Background Papers
The History of the Farm-Scale Evaluations
Paper by the DETR Biotechnology Safety Group and the Scottish Executive
Introduction
1. The purpose of this paper is to provide a summary of the development of the Farm-Scale Evaluations (FSE) of herbicide-tolerant genetically modified crops (GMHT).
2. In 1998 three types of GMHT crops were on the verge of entering commercial agriculture in the UK when real concerns were raised about the impact the management of these crops would have on the environment. The Government, through a voluntary agreement with industry, has halted their commercial introduction until further evaluations are completed.
3. European legislation covering the release of GMOs in Europe (90/220/EEC) is currently under revision. Part of the revision will require that an assessment of such changes in the management of the crops is included in the application for consent for the GM crop to be marketed in the EU. Environment ministers in December 1998 agreed that the updated risk assessment requirements in the proposed revision of the directive should be implemented straight away using the powers in the existing directive. In future all applications will automatically have to consider the likely impact on wildlife brought about by changes in management practice.
Chronology
4. The first releases of GM herbicide tolerant crops took place in the UK in the late 1980s. Following the step by step approach in the European legislation plant breeders developed and tested a small number of GM crops. GMHT oilseed rape was first considered for placing on the European market in 1994 closely followed by various maize varieties. In advising the UK government on the application, the Advisory Committee on Releases to the Environment (ACRE) was concerned that while the risks of the GM crop by itself appeared to be low, the potential environmental effects associated with the use of broad spectrum herbicides on the crop should also be assessed.
5. In 1996 ACRE discussed the specific issues relating to GM herbicide tolerant crops in detail, with officials from the Pesticides Safety Directorate (PSD) in attendance. ACRE's main concern was to identify whether or not impacts of the use of herbicides are adequately covered under the Pesticides legislation, and whether there are any gaps in the legislation. Their discussions and conclusions are published in Chapter 3 of the ACRE Annual Report No 4 (1996/7).
6. In subsequent marketing notifications, ACRE continued to raise issues regarding the impact of herbicide use on GMHT crops with the Pesticides Safety Directorate.
7. By early 1998, DETR had started in depth discussions with English Nature to lay the ground for development of policy to address wider biodiversity issues related to GM crops. English Nature (EN) with the other statutory nature conservation bodies called publicly for a moratorium on the commercial use of genetically modified herbicide tolerant (GMHT) and genetically modified insect resistant (GMIR) crops until further research is carried out. They were specifically concerned about the continuing impact of farming practices on farmland wildlife. GM crops could exacerbate wildlife declines if they encouraged higher levels of weed control than necessary, which in turn would reduce invertebrate and bird numbers.
8. In June 1998 Michael Meacher hosted a meeting to discuss the wider biodiversity issues with experts from English Nature, RSPB, Green Alliance, National Institute of Agricultural Botany, MAFF and ACRE members. The feedback from this meeting was used to prepare the more detailed draft paper. In consultation with ACRE, other Government Departments and English Nature the text was developed along the lines of:
- Severe declines in farmland wildlife have been detected, which are the result of increasingly intensive agricultural practices;
- The UK has a statutory responsibility under EU Directives (e.g. 79/409/EEC, relating to birds and habitats) and other international agreements to maintain populations of farm-dependent wildlife, especially birds);
- Biodiversity Action Plans are in place to address this;
- Decisions on the marketing of GM crops must not encourage further intensification, or Biodiversity Action Plan targets will be prejudiced;
- Investigation of potential adverse effects on farmland wildlife of GM crop management is needed as well as statutory investigations already carried out on the GM crop itself;
- A more strategic approach is needed, in terms of what is wanted from agriculture in terms of food and biodiversity, against which regulatory decisions can be made.
9. By October 1998: DETR was exploring the possibilities of a moratorium on the commercial planting of GM crops. Discussions were held with Friends of the Earth (FoE), English Nature (EN), RSPB and Genewatch and separately with industry. Calls for a moratorium (which would be illegal under EU law) were rejected but instead the Government introduced a programme of closely monitored commercial-scale plantings of GM crops to assess the impact on wildlife of the new herbicide regime. A voluntary agreement was made with industry to delay commercial planting of GM crops for one year whilst research was carried out. On 21 October, Michael Meacher and Jeff Rooker appeared before the House of Lords European Communities Committee on Agriculture and announced the concept of managed development and the agreement with industry.
10. Following the announcement the specifications for the letting of contracts for the ecological research were developed in consultation with English Nature and other well known ecologists. The research is funded by DETR with contributions from MAFF and the Scottish Executive. Then 15 major research organisations were invited to tender for research contracts investigating effects of management of herbicide tolerant oilseed rape (both spring and autumn sown) and maize. DETR consulted on the proposals in February 1999.
11. In autumn 1998 negotiations started in earnest under the EU Austrian Presidency about the amendment of Council Directive 90/220/EEC on the release of GMOs into the environment. The UK was instrumental in the development of the technical annexes on risk assessment and included text to ensure that the potential impact of the management of GM crops is considered in addition to the impact of the crops themselves. The UK also played a key role in developing a technical annex on post-market monitoring.
12. At their Council in December 1998, EU environment ministers agreed that the technical annexes on Risk Assessment and Post-Market Monitoring should be implemented with immediate effect whilst other provisions of the Directive continued to be negotiated.
13. In February 1999 public concern about GM crops reached fever pitch with daily headlines in the media. ACRE published the discussion paper entitled 'The commercial use of GM crops in the UK: the potential wider impact on farmland wildlife' prepared by the ACRE Secretariat. The following month the ACRE Sub-Group on Wider Biodiversity Issues was appointed and held its first meeting, adopting the 'Wider Issues' Paper as the basis for its deliberations. Its agreed priority was to develop guidance for consent applicants on how the wider biodiversity impacts of the management of GM crops should be addressed in future applications for consent to market.
14. In April 1999 the contract for the farm scale evaluations was let to a Consortium of three research organisations: Institute of Terrestrial Ecology (ITE), now (Centre for Ecology and Hydrology, CEH), Institute of Arable Crops Research (IACR) and Scottish Crop Research Institute (SCRI). The Evaluations started with pilot plantings of 2 spring oilseed rape fields and 4 fodder maize fields, followed by three autumn sown rape fields. One field of sugar beet was also sown, with the ecological research funded by SCIMAC using the same protocols.
15. The Secretary of State appointed an independent Scientific Steering Committee (SSC), chaired by Professor Chris Pollock to oversee the evaluations. The members of the committee are Professor Mick Crawley, Imperial College, London, Dr David Gibbons, RSPB, Dr Nick Southerton, Game Conservancy Trust, Mr Jim Orson, Morley College, Dr Alastair Burn, English Nature and Dr Nicholas Aebisher, GCT. The SSC first met in June1999 and endorsed the FSE programme. They have subsequently met four times. The minutes of meetings and interim reports are published on the FSE page of the DETR web site.
16. After the pilot phase of the programme, in November 1999, the government negotiated a new agreement with the industry body SCIMAC. There will be no widespread planting leading to general market access of GM crops grown in the UK until farm-scale evaluations are complete. Subsequent freedom to pursue widespread plantings leading to general market access of GM crops grown in the UK will be dependent upon the recommendations and advice Government receives from the Scientific Steering Committee and ACRE. This advice will be based on the results of the Farm Scale Evaluations (FSE), together with all other relevant approvals required under current UK and EU legislation.
17. In spring 2000 SSC met twice and agreed the programme for the first full year of the evaluations. They have set criteria for the type of farms to be included and the minimum number of fields. The Committee approves the number and types of farm presented by SCIMAC and selected as suitable for research by the Consortium. They also agreed the inclusion of GMHT beet, both sugar and fodder, in the programme.
18. The FSE for this year have included 12 spring rape, 12 maize and 23 beet. There was one rape site in Scotland and one maize in Wales, otherwise all the sites were in England. In august 25 winter oilseed rape FSE sites were announced.
19. Since 1996 ACRE has completed consideration of dossiers supporting applications for five GMHT crops, three rape and one maize tolerant to glufosinate ammonium and one fodder beet tolerant to glyphosate. In each case they have advised that, subject to the outcome of the FSE, there are no human health or environmental reasons why consent should not be granted.
20. Before GMHT crops can be exploited commercially they also need separate approvals under:
- seeds legislation,
- pesticides legislation and
- novel foods regulations.
Biotechnology Safety Unit: August 2000
Page published20 February
2001;
Page last modified
10 August, 2002