Liberal
Democrat response to Consultation paper on the implementation of Directive
2001/18/EC on the deliberate release into the environment of genetically
modified organisms
We
are committed to the National Assembly of Wales’ line of operating the most
restrictive policy possible within the context of European Union legislation in
regard of GM crop trials and commercial GM crop development in Wales.
The
precautionary principle must be central in the implementation of Directive
2001/18/EC.
We
agree with the consultation document that the implementation of Directive
2001/18/EC must be as open and transparent as possible and reflect Assembly
policy. This is an issue on which the
public needs to be reassured that all information is available in the public
domain.
Separation
distances are of the utmost importance so that if GM crop trials or commercial
development are allowed to go ahead organic and conventional crops are
protected and the livelihoods of the farmers concerned are safe-guarded. This is particularly important in relation
to organic farming.
We
welcome the new measures contained in Directive 2001/18/EC to tighten the
safety criteria for the release and marketing of GMOs including GM crops, seeds
and animal fodder. In particular we are
pleased to see more specific labelling and improved traceability of GMOs and
the new mandatory requirement to consult the public in regard of experimental
releases of GMOs. The public
information requirements and post-marketing plans for each GMO product are also
steps forward.
On
a dissonant note, it is disappointing that there will still not be any
labelling of meat from animals fed on GM feed and of food produced using GM
enzymes.
Further,
we would like to see the threshold for GM contamination in non-GM produce to be
reduced from 1%. We should be aiming to
reduce this to 0.1% if possible, perhaps a sliding scale could be used with a
gradual reduction over a number of years.
What are your
views on the scope and depth of the risk assessment set out in Annex II of the
Directive?
Are there any
specific issues you think should be incorporated into the guidance?
The scope and depth of the environmental risk assessment appears to be wide-ranging and comprehensive.
Regarding
the objective of the environmental risk assessment we agree that it should be
to “on a case by case basis, to identify and evaluate potential adverse effects
of the GMO, either direct and indirect, immediate or delayed, on human health
and the environment which the deliberate release or the placing on the market
of GMOs may have” and that it should be carried out in order to identify if
there is a need for risk management and what measures would be appropriate to
deal with this.
What are your
views on the specific issues to be addressed in designing and carrying out a
monitoring plan in line with the objectives and principles set out in Annex VII
to the Directive?
We
welcome the objective and principles of the monitoring plan. The monitoring plan in each instance should
be case specific and it is vital to identify who should be responsible for
carrying out the tasks of the monitoring plan.
Mechanisms that do not rely on the user being the main monitor need to
be put in place.
Is there a
scientific case to assess all antibiotic resistance markers as having an
adverse effect on the environment or human health?
There
are serious concerns that antibiotic resistance genes used as markers could
cause human health and environmental problems.
There
is some evidence that GM crop DNA can persist for some minutes in the large
intestines of animals. This raises the
possibility that GM crop genes could jump into bacteria in the stomachs of
animals and then possibly be transferred to humans. This could cause problems if
the “jumpers” were the antibiotic resistance marker genes.
We
are therefore in favour of the phasing out of antibiotic resistance markers.
How can the
traceability and labelling requirements outlined in Article 26 and the relevant
sections of Annex IV best be implemented?
As
stated in Article 26 and Annex IV labelling requirements can be accomplished by
the words “This product contains genetically modified organisms” appearing on
either a label or in an accompanying document.
As
mentioned in our General Comments section above, it is disappointing that there
will still not be any labelling of meat from animals fed on GM feed and of food
produced using GM enzymes.
Regarding
traceability, the detailed information required in the notification for placing
on the market of GMOs as set out in Annex IV, should improve this.
How should the
public be consulted on proposals for GMO release and how should their views be
taken into account?
It
is a big step forward that the Directive contains a mandatory requirement for
Member States to consult the public regarding proposed releases.
Consultation
should be as wide and involving as possible and in regard of GM crops should be
undertaken at a local as possible level.
What should be
done to improve the information made available to the public on the deliberate
release and marketing of GMOs?
Mandatory
consultation will hopefully ensure an improvement in the availability of
information.
Information
could be placed in public libraries and on the internet in a form that is both
readily accessible and understandable.
What should be
done to improve the predictability of transparency of decision-making within
the deadlines set by the Directive?
The
setting of deadlines for each stage of the regulatory process as laid out in
the Directive should hopefully do this.
Should the
Assembly make a proposal under the new Directive’s provisions on differentiated
procedures to replace the existing simplified procedure for Part B applications
in Wales?
The
“simplified procedure” should allow for more than 15 days notice of the
planting of GM crops in a locality and the public should have a forum to
express their view and be able to halt such proposals if they wish, possibly
through a local referendum or the local planning process.
We
would wish the Assembly to liase with the UK Government to make use of the
“differentiated procedures” (Article 7 of Directive 2001/18/EC) to ensure a
longer period of notice.
How can the
Assembly best address the general ethical and socio-economic issues raised in
the Directive?
There
are obviously concerns amongst the public and Assembly Members regarding these
issues. One suggestion would be a
rolling programme of seminars in the Assembly addressing these matters with
interested organisations and parties invited to give evidence and to
participate in open discussions.
Do you have
views on the priorities for guidance on issues that would help understanding
and effective implementation of the Directive?
It must be ensured that guidance is in line with the Assembly’s stated view of operating “the most prescriptive policy possible.”