The Independent Science Panel
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Letter to UK Ministers on EU Seed Directive 4 September, 2004To: Romano Prodi, President of Commission [email protected] Cc: Margaret Beckett MP, Secretary of State for Environment,
Re: EU SEED DIRECTIVE -- Levels of GM Contamination in SeedsDear Commissioner or Minister, The Independent Science Panel (ISP) on Genetic Modification (GM) consists of two dozen scientists1 from seven countries, spanning diverse disciplines, who are concerned to provide critical scientific information to the global debate over genetically engineered crops. The Panel was formed in view of the importance of this debate for the future of our food and agriculture. It is expected that a proposal will be made to establish a threshold for adventitious or technically unavoidable contamination of seeds by genetically modified varieties, at a level of 0.3% or 0.5% depending on the variety of the crop. These levels should be reduced to 0.1%, in accordance with the present limit of technical ability to detect GM material, for the reasons given below. 1. Build-up of chain of contamination Seeds are the starting point of a chain in which GM genes may be successively accumulated in a final food product during growing, transport, storage, processing and distribution. An unnecessarily high level at this starting point will increase the total amount of transgenes in the final product. The spread of GM genes in North America has been much faster than had been anticipated. It has become extremely difficult for American farmers to purchase uncontaminated seeds of crops for which there is a GM variety2. The Union of Concerned Scientists commissioned a study 3of the presence of GM genes in traditional crops and found that �seeds thought to be free of GE material are in fact pervasively contaminated.' 2. High costs of monitoring for compliance Who will judge whether an admixture of GM seed was indeed 'adventitious or technically unavoidable'? Who will pay the costs of such an inquiry and of any prosecution? Maintenance of compliance with the threshold that is set will require continuous monitoring of harvests within a radius of GM fields -- and the radius may be very large. If a high threshold is set, many fields assumed to be below the allowed limit will probably not be monitored. If they should subsequently be found to have levels of GM genes above the limit, those who are adversely affected are likely to seek financial redress. Who will pay? Who will pay for the annual testing to determine whether the produce from any given farm complies with the limiting threshold? Seed companies will not assume these responsibilities; and farmers must not be held liable; many are already in financial difficulty because farmgate prices are so low. Thus it seems that it will be the taxpayer who bears the burden � for on-going scrutiny of products the clear majority of people do not want.
3. Problem with crops not mixed in harvests Vegetables, fruits and 'corn-on-the-cob' are sold individually and are not averaged over a whole field, as is done with grains that are mixed from all parts of a field and perhaps from different farms. Parts of a field nearest another field donating pollen to the first field receive the highest concentration of donated pollen. Moreover, experiments and research 4 demonstrate that the distribution of the pollen received is by no means uniform but occurs in patches. Plants that happen to experience a pocket of high density of pollen can be well over the level predicted for that distance. For individual fruits and vegetables, compliance of the average of the harvest over the entire field is irrelevant. 4. Unreliability of predicted levels of transgenes in seeds Extrapolations of experimental data for the purpose of setting separation distances are highly unreliable5 , and our argument is corroborated by observed incidents of contamination. For example, a rare variety of blue maize was planted by an Illinois farmer and found to contaminate three neighbouring farms, one of which was as far away as three miles. On the latter farm, the number of blue kernels on the yellow cobs was said to be 'quite noticeable' and might have been as high as 1%. Yet a contamination level as low as 1% should, according to current UK standards, be attained at a separation distance of only 200 m. In the wild regions of Mexico, indigenous varieties of maize were found to have been contaminated at levels well above 1% in some regions. 5. EU consumers reject GM food European polls consistently show that many more people reject GM foods than favour them � and attitudes are continuing to harden. More people than ever before are concerned about possible long-term health effects and environmental effects. Conversely, more people than ever are buying organic foods; and organic standards do not permit any genetic modification. Democracy therefore demands that the food supply should be protected from GM contamination. Commissioners will be failing in their duty if they thwart the will of the European people. Increasing numbers of Americans are also rejecting genetic modification of their food. 6. Unproved safety for health and the environment While maintaining its position that GM foods are safe, the Royal Society of London has recommended that the health of the people of the United Kingdom be monitored for adverse effects resulting from the consumption of GM foods, especially the health of vulnerable groups like young children and the elderly. The ISP's report, The Case for a GM-Free Sustainable World 6, is an extensive review of the scientific and other evidence on the problems and hazards of GM crops and the manifold benefits of all forms of sustainable agriculture. Based on this, we are calling for a global ban on the environmental release of GM crops, to make way for agroecology, organic farming and other forms of sustainable agriculture. It is clear, from the evidence presented in the ISP Report, that there are many unanswered questions about the safety of GM crops. Very few studies have been conducted, particularly as to the effects of GM foods on human health; and the few independent studies that have been carried out raise serious concerns. Research increasingly shows that GM crops can affect the environment and wildlife negatively. A recently published book 7 exposes the falseness of the claims that GM foods have been thoroughly tested and are safe. Many fraudulent practices of GM companies in the testing of GM crops for health safety are cited, and the lack of oversight of health safety by supposedly regulatory agencies, especially in the United States, is also revealed. Even the World Trade Organisation (WTO) has concerns about safety and, in the current dispute between United States, Argentina and Canada on the one hand, and the European Union on the other, the WTO has delayed making a decision and has announced that it will seek expert advice from scientists about these issues. Published studies 8 on GM-fed rats describe harmful physiological changes. In the only test on human beings 9, genetically engineered DNA became incorporated into gut bacteria; but the consequences of this are not known. Another worrying and unexplained fact is that a survey carried out by the Centers for Disease Control suggests that, during the time since GM foods have been introduced into the American diet, food-related illnesses in the United States have at least doubled. 10 7. Permanence of GM genes Unlike agricultural chemicals, which decompose over time, GM genes are passed from one generation to the next and cannot be recalled once they escape into wild plants and into the soil. An attempt could be made to dilute their numbers by ceasing the cultivation of GM varieties. However, the question of whether plants, both cultivated and wild, and soil micro-organisms (on which the fertility of the soil depends) would revert to normal functioning has not been investigated. It must be expected that some GM varieties would continue to propagate. Several experts have warned that soil might be progressively degraded, and that the affected area might spread continually outwards from the original site where GM plants were grown. 11 8. Threshold of 0.1% is possible In view of these serious objections to any growing of GM crops while our knowledge and experience of them are so limited, the Precautionary Principle should be observed. If GM crops are to be grown nevertheless, the spread of their genes to other, similar crops must be minimised. A contamination level as small as 0.1% can be detected with current technology and should be adopted as a legal upper limit. This level has been demonstrated to be realistically realisable in Austria. Yours sincerely, Dr Eva Novotny, References
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© 2003 Independent Science Panel