Genetic Concern

Contact: Ms Sadhbh O’Neill

Preface
The following is an updated version of our submission in
response to the Department of the Environment’s
Consultation Paper on GMOs. It outlines Genetic Concern’s
views and research in relation to genetic engineering in food
and agriculture, and sets out the case for Ireland to become a
GE-free zone.

We believe it is the most appropriate submission to make to
the Department of Agriculture, in preparing its policies for
agricultural reform following the EU’s Agenda 2000, for
while the government position in relation to GMOs is led by
the Department of the Environment, the Departments of
Agriculture and Enterprise and Employment also play a key
role in formulating policy in this area. In addition, the
absence of these departments at the Department of the
Environment’s consultation forum in June of this year has
tended to reinforce the sectoral division of responsibility in
an area that has huge implications for many areas of
government policy.

It is regrettable that the Department of Agriculture has to
date not participated in debate about the introduction of GM
crops in Ireland since we believe it has profound
implications for agricultural and food policy, and for
Ireland’s image as a major food processor, exporter and
tourist destination. However the Department’s Agrifood
2010 committee appears to be an excellent opportunity to
invite debate and Genetic Concern is pleased to be able to
contribute to this process.

Introduction
Public Perception.

With the entry of genetic engineering into food and
agriculture, people with little or no interest in science are
being asked to eat the produce of a technology which they do not understand.

What is Genetic Concern?

Genetic Concern is a voluntary organisation,
established in April 1997, to highlight the potential
risks of genetic engineering in food and agriculture.

Genetic Concern is calling for:

a moratorium on the planting of genetically
engineered crops, and the use of genetic
engineering in any part of the food chain, until
independent research has been carried to prove
that it is safe
balanced and informed debate on the issue,
covering consumer, health, environmental and
ethical issues.
full segregation of GE crops, and the
implementation of clear and accurate labelling, so
that consumers can choose whether or not to
support the industry.

Genetic Concern:

provides information in the form of leaflets, fliers,
information packs
organises awareness events
offers speakers for talks, debates and conferences
raises political awareness of the issues, both on a
national and international level
highlights the issue in the media
supports Clare Watson in her High Court Judicial
Review of Monsanto’s 1997 GE sugar beet trials
liases with other like-minded groups both at home
and abroad

We all have some idea that “genes” and “DNA” are hereditary material which may give us brown or blue eyes from our parents. Few would have realised until recently that plants, viruses and bacteria share the same system of carrying hereditary information from parent to child.

Genetic Engineering is often described in very simple terms as a technology which enables a single gene to be taken from one organism and inserted into another.

In practice, foods produced involve the insertion of several “genes”, or fragments of DNA from several different organisms in an arrangement of DNA which would never occur in nature.

Scientists are clearly divided on the issue of how safe this technology actually is, but there is one thing we do know - that genetic engineering is an unravelling science. That is, we are still at early stages in terms of fully understanding the function of genes. For example, no single plant or animal has had its DNA fully studied from end to end. The first plant to have had its DNA sequenced will be completed in or around the year 2002. Yet we already have foods on the market which have had their DNA altered to introduced desirable traits.

Desirable for whom? So far, all genetically engineered foods introduced to the market have had agronomic traits - herbicide tolerance or crops which produce their own pesticide. None of these products presents any benefit whatsoever to the consumer.

If reduced production costs are to be taken as a consumer benefit, then the consumer has been denied that benefit by the refusal of the industry to segregate its produce. Thus the cost reduction is exclusively of benefit to farmers and agribusiness.

Cheaper (and often from the consumers point of view undesirable) produce is sold unsegregated at the same price. Market forces are not allowed to prevail, and the consumer has been denied any choice of whether or not to consume this produce.

The nuclear industry was an unravelling science at the time of its introduction. As soon as our ability to split the atom produced a commercial proposition, early Magnox reactors were built on the basis of unfounded promises that the technology was safe and would produce electricity “too cheap to meter”.

We must learn from our mistakes of the past and ensure that the perceived benefits of a technology are not introduced on a widespread basis until that technology is fully understood.

The premise on which this document is based is largely that the release of genetically engineered crops into the environment and the food chain is an irreversible action. With such technology it is not acceptable to say that it has not been proven to be dangerous. The widespread release of genetically engineered crops should not be allowed to happen until research over a number of years has proven it to be safe.

Such a call for a moratorium is supported by groups such as the Union of Concerned Scientists in the USA, and English Nature in the UK. It has been adopted by countries such as Norway, and in a limited form by Austria. Public pressure and a spate of food scares resulted in a landmark EU Environment Council meeting in June which resulted in a de facto moratorium on new crop approvals until amendments to the Directive 90/220 have been adopted. However the position in relation to crops already in the pipeline for approval, including Monsanto’s Roundup Ready sugar beet which is on trial in Ireland, is not clear. Nor is the position of the Irish government, which has often abstained on crucial EU votes in relation to both crop approvals and the revision of the directive.

Genetic Concern believes that even the claimed benefits of farming using genetically modified organisms is more than outweighed by the benefits of keeping Ireland as a GMO-free zone. Preserving Ireland’s green-clean image may prove to be far more beneficial. This would provide Irish farmers with premium prices for traditional foods in a European market where consumers have clearly rejected the technology, as well as facilitating sustained growth of the tourist industry.

KEY RECOMMENDATIONS

The Irish Government should;

Establish Ireland as a “GMO-free zone” so that as genetically engineered crops such as potatoes come on stream, Ireland can avail of a price premium within Europe for supplying the growing market for segregated materials
Implement an immediate moratorium on field trials until such time as risks from horizontal gene flow have been evaluated and science has achieved a full understanding of pleiotropic effects, position effects, gene silencing and other unexplained and unpredictable phenomena.

France has announced a two-year moratorium on the commercial use of GE crops that may outbreed such as oilseed rape and sugar beet.

Support Austria’s ban on Novartis maize, and enforce a similar ban in Ireland in accordance with Article 16. This would protect the population from risks associated with anti resistance genes, consumption of a new variant of Bt the herbicide glufosinate. Such a policy would also help to secure supplies of segregated maize crops.
Lobby for segregation of genetically engineered crops through all the appropriate channels.
Set up an Independent Watchdog Committee on GMOs who would look at the ethics of genetic engineering as well as the practical effects of genetically engineered crops on human health and the environment. The panel should include a cross-section of consumer, environmental and health representatives, alongside scientists and academics. A similar body is being set up in the U.K.
Assist in the establishment of forensic testing facilities to facilitate certification of crops guaranteed not to be genetically engineered, and to ensure that EU labelling regulations are enforced.
Lobby for the introduction within the EU of a mandatory register and a form of certification throughout the supply chain identifying the designated product approval.
Implement strong environmental liability regimes for the developers of genetically engineered crops. At present it is not clear who would be liable for environmental damage caused by genetic engineering.
Widen the scope of the consultation process by organising a consensus conference similar to those held in France and Norway.
Support the development of organic agriculture to enable Irish farmers pursue this niche market sector
Implement special national law for activities or products which are not yet regulated under Community law such as genetically engineered animal feeds.
Organise an information session for interested bodies on the regulatory process. We would suggest that representatives from the relevant departments be invited to explain how the system works, how decisions are made, who is responsible for what, the scope of the different regulations, and where Ireland has a say in the process.

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