This item was published during the term of a previous administration that ended in April 2007
Executive rejects GM report
The Executive today published a substantive response to the Health and Community Care Committee's (HCCC) report on GM crop trials, rejecting all the recommendations.
The response details the 'shortcomings' of the HCCC report; the failure by the Committee to take proper account of the weight of scientific evidence presented during the inquiry, and the rigour of the existing regulations.
Ross Finnie, Minister for the Environment and Rural Development, said:
"The views of the Committee members are clearly at odds with the evidence of the Royal Society of Edinburgh and the Executive's independent scientific advisers. It would be irresponsible of Ministers and the Executive to ignore the knowledge and expertise of expert advisory bodies."
"I am concerned and extremely disappointed that the Committee has ignored the volume of evidence recording confidence in the Advisory Committee on Releases to the Environment's approach to risk assessment and the quality of scientific advice it offers Ministers."
"In particular I support ACRE's case by case approach to considering the risks and benefits associated with the release of GMOs. This approach enables factors such as the variety of GMOs involved and the proposed location and scale of release to be taken into account."
Deputy Health Minister Mary Mulligan said:
"This is a very detailed response from the Executive and it makes clear that the Committee's report, which is critical of aspects of the management of the Farm Scale Evaluations of GM Crops, is not supported by the available evidence.
"It represents what, in fact, the Committee acknowledged - its inability "to deliberate definitively on the complex scientific questions that GM crop trials raise or adjudicate on competing interpretations of scientific evidence.
"The available scientific evidence supports the view that the Farm Scale Evaluation programme is well-founded, well-regulated and designed to increase our knowledge about GM crops, while taking proportionate measures to protect public health."
A spokesman for the Advisory Committee on release to the Environment (ACRE), which advises Scottish Ministers on the regulation of the 'deliberate release' of GMOs into the environment, said:
"ACRE's view remains that the risk assessment of the release of GMOs is careful, thorough and scientifically sound, and is in accordance with the criteria set out in the relevant Directive 2001/18."
The Health and Community Care Committee Report on GM Crop Trials was published on January 14, 2003.
The British Medical Association (BMA) has recently acknowledged that there has been a 'lot more science' since their position statement on GM was published in 1999. On January 31 the BMA indicated plans to convene a round table meeting later this year of scientists with knowledge of the developments in research and other evidence.
Extracts from the Executive Summary response and specific concerns about the H&CC Committee report are attached.
The Executive considers that the Health and Community Care Committee (HCCC) Report on the Inquiry into genetically modified (GM) crops is fundamentally flawed. The Executive is required to reach a view on new applications for the release of GMOs on a case-by-case basis using the criteria laid down in Directive 2001/18/EC. Such assessments involve particular consideration of the possible risks to human health and the environment.
The Executive's view is informed by advice from a number of independent expert groups and by specific scientific concerns arising from public consultation. The Executive authorised the farm-scale evaluation trials only after a wide and rigorous range of safety assessments had been completed to the satisfaction of our expert advisers. No substantive evidence has emerged which might call into question the safety of any of the crop trials and the Executive remains of the view that the farm-scale evaluations are well founded and well regulated.
The Committee acknowledges "that it is not qualified to deliberate definitively on the complex scientific questions that GM crops raise or to adjudicate on competing interpretations of scientific evidence" yet goes on to do precisely that by challenging internationally established scientific practice and methodology.
The Committee argues the basis for risk assessment is unsound and not in accordance with the precautionary principle. The Committee also questions the competence of ACRE to assess the health implications of an applications for deliberate release.
In preparing its report the Committee seems not to have had regard to oral and written evidence, as well as substantial volumes of peer reviewed research, which confirm, as far as is scientifically possible, that current GM crops pose no greater risk to human health or the environment than comparable non-GM varieties.
In reaching its findings, the Committee has placed heavy reliance on evidence presented by those with little relevant or current knowledge of GM technology.
The views of the Committee members are clearly at odds with those of the Executive's scientific advisers, but it would be irresponsible of the Executive to ignore the advice of the expert bodies whose role is precisely to provide such advice.
In particular, the Executive supports ACRE's case by case approach in considering the risks associated with the release of GMOs. This approach enables factors such as the variety of GMO involved and the proposed location and scale of the release to be taken into account. The Health Committee has ignored the volume of evidence recording confidence in ACRE's approach to risk assessment and the quality of scientific advice it offers Ministers.
While the Executive acknowledges that the HCCC conducted this inquiry in response to public concern, the Report serves to increase the level of anxiety which has existed. The Committee has not given sufficient attention to the evidence it has heard on the science of GM crops, genetics more generally and the precautions which Government and its advisers have recommended and put in place. A Report which should have explained a matter of concern to the public has served to obscure the facts and heighten concern
Below is the Executive's response to specific concerns raised by the Committee:
- The Executive is satisfied that the precautionary principle is being applied in a robust, consistent and appropriate manner.
- The Directive and implementing regulations prescribe a structured approach to the analysis of risk in line with the precautionary principle.
- The Scottish Executive is entirely satisfied with ACRE's approach to risk assessment and the quality of advice it offers the Scottish Ministers.
- There is no evidence to indicate that GM crops grown in Scotland pose any greater risk to human health or the environment than non-GM varieties. If the Scottish Ministers were not satisfied that this was the case, consent for a release would not be given.
- The Executive is not convinced that pharmaceutical-style testing is better suited to GM crop trials and will continue to apply the underlying principles and basic procedures for the approval of GMOs in Directive 2001/18/EC.
- The Executive considers that it would be impracticable to undertake comprehensive food and feed testing on all GM lines that were intended for small-scale research and development releases - most of which will never be marketed due to commercial or agronomic reasons.
- In reaching decisions on applications for deliberate release the Executive, as well as its expert advisory committees and the HSE and FSA, has access to all information relating to that application, including that deemed for the purposes of the Environmental Protection Act to be "commercial in confidence".
- Any consent which is granted involves limiting terms and conditions. Some of the SCIMAC guidelines - which are not themselves legally binding - are mirrored in the limitations and conditions of individual consents and as such have legal force.
- The Executive notes the concerns of the Health and Community Care Committee but remains satisfied that the environmental risk assessment includes consideration of the safety implications of any exposure to pollen from GM crops through ingestion or inhalation from the air, or from the pollen landing on other crops.
- The Executive agrees that any major scientific intervention into the environment must be scrupulously monitored and is satisfied that appropriate and proportionate health and environmental monitoring arrangements are in place .
- The Executive agrees with the HCCC that antibiotic resistance marker genes (ARMs) should be phased out. The revised Directive and the implementing regulations make this a legal requirement.
- In line with the Directive the Executive has introduced mandatory public consultation before decisions are taken on applications for consent to release GMOs. For the farm-scale evaluation programme the Executive put additional steps in place that went beyond the statutory requirements at the time.
The Executive acknowledges there are some generic lessons arising from the HCCC inquiry relating to the importance of communication of science and risk. The Executive will continue to develop policies and practices which seek to engage and inform stakeholders more fully.