Thank you for your recent email, which is one of many to the Minister for Environment and Rural Development calling for an immediate halt to GM crop trials in light of possible new evidence which may have implications for the safety of these trials.
The Scottish Executive is conscious of the genuine concerns which exist about the possible effects of growing GM crops. That is why, with the co-operation of the biotechnology companies and key environmental groups, the farm scale evaluation programme was introduced and the first Scottish sites identified in spring 2000. It is not a programme which has been embarked upon without regard to public or environmental safety. On the contrary, it is only because we have sought and obtained the necessary reassurances from those best qualified to advise us (Scottish Natural Heritage, the Food Standards Agency, the Health and Safety Executive) that we were prepared to give approval for individual GM crops to be released on a handful of sites in Scotland. All GM crops, prior to their release into the wider environment, are grown in laboratories, greenhouses and small scale plots. The results of these earlier trials are considered carefully by the statutory Advisory Committee on Releases to the Environment (ACRE).
ACRE is an independent expert body, established to provide government with up-to-date scientific advice on the potential impacts (direct and indirect, immediate and delayed) of 'releasing' non-native species, including GM crops. Based on the evidence of over a decade's research on this particular GM crop the Committee has determined that the oilseed rape being grown in the farm scale trials does not pose a threat to public health or the environment. It would be irresponsible and illegal for Scottish Ministers to ignore the unequivocal assurances of their expert advisors and withhold consent on the basis of doubts or concerns which are not supported by the evidence. It remains open for consent for the trial of a GM crop to be withdrawn if evidence emerges to suggest that it would be harmful to proceed. If that was to happen after a crop had been planted, Ministers have powers to order its destruction. However, to do so without sound scientific justification would be in contravention of European law.
Many of the letters the Minister has received advocate the consideration of possible new evidence which may call into question the safety of the GM crop trials currently being undertaken in Scotland. ACRE in discharging its statutory duty to provide best quality advice to Ministers continues to take account of the latest scientific evidence and developments. Scientists in the regulatory authority and ACRE consider new information as it is published to evaluate whether it has any implications for risk assessment for both new applications and in relation to existing consents. ACRE advice is then considered by the Scottish Executive in the context of GM crop trials and the farm scale evaluation programme.
Our scientific advisers are satisfied that no new potential hazards have been identified in recent studies although in some cases more detailed information of previously considered risks have been published. They are also satisfied that no previously unknown hazards associated with growing genetically modified plants have been raised which might call into question the safety of any of the Scottish trials.
The possible new evidence mentioned in letters and ACRE's conclusions are described below.
English Nature Commissioned Report 05/02/2002: Gene Stacking - lessons from Canada
ACRE considered this document on 21 February 2002. The potential issue of gene stacking of herbicide tolerance was identified by ACRE in the early 1990s and is always taken into account in assessing risks. The English Nature commissioned report documents the incidence of herbicide tolerance gene-stacking in practice in commercial crops in Canada but does not identify any new issues. In the UK only one herbicide tolerant GM trait in oilseed rape is being trialled in the UK farm scale evaluations. So gene stacking is not an issue. Should a different herbicide tolerance in oilseed rape be proposed the issue of gene stacking will be considered.
The Royal Society Policy Document 4/02. February 2002: Genetically modified plants for food use and human health- an update.
This report reviews the safety of the currently available GM foods and plants on human health. The report found no evidence that such GM foods cause allergenic reactions or that GM pollen poses any greater risk than pollen from conventional crops. The report does not present any new evidence that has safety implications for the farm scale trials.
Environmental Issue Report no. 28 for the European Science Foundation and the European Environment Agency : Genetically Modified Organisms (GMOs) : The Significance of Gene Flow through Pollen Transfer (Katie Eastham and Jeremy Sweet).
This is a valuable review of currently available information on gene flow but does not present any new information or information which was not available to ACRE when the committee gave advice on the GM oilseed rape crop to be used in the farm scale evaluations.
Report of the Royal Commission (for New Zealand) on Genetic Modification October 2000 - March 2001.
This report reviews currently available information on genetic modification and does not present any information which would lead to a re-assessment of the risks of oilseed rape in the farm scale evaluations. The report considers issues related to gene flow between crops, molecular characteristics of transgenes and genome stability. ACRE took all these issues into account when the Committee gave advice.
As well as the issue of new evidence a number of reported allegations about leaked results from the farm scale evaluations claim to indicate that the trials of GM oilseed rape are damaging the environment. In fact no interim results from these ecological studies yet exist for any of the crops which are being assessed as part of the UK farm scale evaluation programme. The data from the three years of field trials will be collated upon completion of the programme and the results will be peer reviewed and published thereafter. At that stage the Scottish Executive will be in a position to determine how to respond to the results.
In conclusion I must stress that Scottish Ministers have powers to modify, suspend or terminate a release, including the farm scale evaluations, at any time where new evidence becomes available which could have significant consequences for the risks posed by the release. Any such evidence would be evaluated by the scientific advisers to Ministers. If the conclusions of those advisers were that evidence did indeed suggest that a particular GM release could harm human health or the environment then Ministers would have no hesitation in withdrawing consent for the release. As I indicated earlier, no sound evidence has emerged which might call into question the safety of any of the Scottish trials.
I recognise that you may be disappointed by this letter, but hope you will understand the basis on which decisions have been taken. Ministers place public and the environmental safety foremost and the trials are proceeding on the basis that Ministers are satisfied that this particular crop can be grown on these sites in safety, both for the people living near the sites and for the wider environment.
Graeme Hunter GM Co-ordination Team Scottish Executive