Submission to the Consultation on proposals for managing the coexistence of GM, conventional and organic crops

18th October 2006

Renaud Wilson
Department for Environment, Food and Rural Affairs
GM Policy Team
Zone 4/E5
Ashdown House
123 Victoria Street
London SW1E 6DE

Dear Mr Wilson,

I do not represent any Group but merely comment as a former farm manager and now a small-scale grower of the family’s organic food and a member of the public with an interest in the issues of safety in food production. In writing this submission I cannot help but feel that precious time and energy is being wasted because the decisions have already been made and as usual the consultation process is just a sham to give the impression that the views of the public are taken into account. It takes a very long time for me to write submissions because I have been poisoned as the result of regulatory failures and the efforts to hide the true dangers of pesticides and I would not be able to do this without much help from others but similar issues are involved with GM crops as have been in pesticides so I feel I should not do nothing.

I find it interesting that almost every warning given by those with serious doubts about GM crops are now proven to be sound predictions. More importantly perhaps almost all of the promises and assurances made by pro-GM governments and company spokespeople have proven to be wildly optimistic at best and a danger to human and environmental health at worst.
I have serious concerns regarding the claims for Genetic Engineering, the current situation in which we already have frequent reports of contamination, and the increasing numbers of reported adverse effects.
It would seem that experiences to date do not support any possibility of either the sustainable use of GM crops and the chemicals upon which they depend or any prospect of satisfactory co-existence.

1) Sustainability

True sustainability in agriculture and horticulture requires by necessity the ability to control what is grown and the quality of the produce in ways that both protect the industry and future generations of plants, wildlife, domesticated animals and humans.
The industry promised that Genetically Modified (GM) crops would reduce costs, reduce pesticide use, and increase yields, but in reality the opposite is often true and both the agricultural industry and the environment have suffered as a result.

2) Co-existence

It is suggested that GM crops can be treated in the same way as other seed crops but this is a dangerous simplification and makes assumptions that cannot be validated.

3) Contamination

Those who introduced GM crops promised no contamination and complete segregation.
We have the opposite.

4) Quality

They said that the crops were substantially equivalent.
Yet contamination by GM varieties can be assessed down to less than 1%.

5) Unintentional DNA transfer

They said that the crops would not cross-pollinate.
But they have.

6) Resistance

They said that the growing of GM crops would not lead to the creation of resistant varieties of weeds and insects, which would make vital pesticides useless.
Already we have those resistant varieties and stronger pesticides have to be used.

7) Independent Science

Powerful lobbyists who have the ear of influential individuals and organisations have systematically destroyed the livelihoods of those scientists who dared to warn of the potential adverse health effects.
Now the reality has shown those warnings proven to be well founded.

8) Scientific Knowledge

The scientists promoting genetic engineering thought they could tamper with DNA when they had only limited knowledge of the coding and they still have as much understanding of the real power within life forces as a child has when attempting to "repair" a computer with a hammer.
The recent drug trial disaster demonstrates the danger in assuming greater knowledge than is possessed.

9) Risks for the future

Although those who promote GM crops suggest that there will be great benefits in the future for mankind it would seem the “blind eyes” are being turned on the potential for serious and irreversible harm to human health and to the environment.

Returning to the above sections in more detail.

1) Sustainability

Since the introduction of chemical controls over insects and weeds and chemical fertilisers to encourage growth and increase output the changes to the environment have been dramatic. Wild bird species have been declining rapidly mirroring the decline in both habitat and the insects upon which they rely.
The human population has grown and the demand for ever increasing and varied volumes of food has risen as the amount of fertile land per head of the population falls.
That situation can never be sustainable, no matter how much we tinker with varieties of plant and new ways to provide nutrients. The water resources alone will limit production and the soils and the organisms that sustain them are being denatured at an alarming rate.
Furthermore it was not an environmental concern that led to the introduction of GM crops. It was a commercial enterprise initially to maintain the profits from a lucrative herbicide market, which is why by far the majority of GM crops are made to be resistant to that group of herbicides.
Even if it is assumed that those herbicides are environmentally “safe”, which is a very dubious claim in itself, there is no possibility that the use of GM crops will be sustainable in the long-term.
In some areas there are already signs that their introduction has merely added to pest and weed problems and that the harm done to wildlife species is being recognised.
The GM crop trials in the UK demonstrated just such environmental damage and continued use of the technology could only be justified by comparing with other dangerous chemicals for which there have long been calls for limitation of use.
The fact that the “European Commission has advised that any GM pollen in honey can generally be regarded as adventitious and unavoidable” demonstrates that the promises made to retain GM crops and their effects were impossible to maintain.
It is clear that GM crops do not provide the answer to the problem of sustainability.

2) Co-existence

Any discussion on methods that might be devised to allow GM crops and “conventional” or “organic” crops to be grown in the same district should first examine the history of all these methods.
“Organic” was for centuries the only “conventional” way of farming even though the rather inappropriate term “organic” was coined to indicate a more natural way of growing crops and rearing livestock only relatively recently. “Conventional” farming as it is referred to currently is a method that relies very much on chemical inputs both to encourage growth, replacing some of the lost nutrients in the soil, and to combat the numerous weeds and diseases that lead to yield reduction or diseased produce.
It is advantageous to those selling the chemicals to encourage the belief amongst growers and decision makers that farming would be impossible without chemicals but that is obviously not the case or mankind would not have survived over the centuries using more natural methods. Those traditional methods that are now referred to as “organic” actually kept the soil in good condition so that the current generation of farmers could exploit the fertility built up slowly over centuries.
Sadly in recent years the “organic” process has been eroded by vested interests from the once high standards and as a result farmers using that system have been permitted to grow their crops within areas of potential contamination by chemicals used in “conventional” systems. For example the separation distances for the two types of crop are considerably less than the distance some chemicals are known to travel after application.
Seed growers will often claim that the distances between their seed crops and others without the required purity are sufficient to prevent cross-pollination but in reality the results of contamination in such circumstances are not as serious as it potentially will be when GM contamination is involved.
I know some farmers who have grown seed crops but who still had to discard some areas because of contamination. I was actually asked by one of them to adjust my cropping programme to enable him to grow seed crops near the boundary hedge. That was before GM crops were even thought of.
The measure of the implausibility of the proposal to allow co-existence of GM and conventional, to say nothing of the greater difficulty with organic crops, is the experience of farmers where GM crops are grown and the rather heavy handed treatment meted out by the patent holders to those who find their own crops contaminated through no fault of their own.
This is further supported by the steadfast refusal of insurers to offer cover to growers for the risk of harm to neighbouring crops or to consumers down the line.

3) Contamination

When the first proposals to introduce GM crops were made those who opposed the introduction warned that there was a great danger that our food and seed supplies would be contaminated. The industry made great play on the assurances that sufficient controls would be in place to ensure that the crops would never be able to enter the food chain and that there would be no escape into the environment.
Those pledges were built on shifting sands and the resulting contamination could hardly have been less common had it been deliberately planned by the industry to weaken the resolve of those opposed to being force-fed GM material.
We have had the contamination of rice recently and the Food Standards Agency reluctance to enforce the laws regarding GM presence in food. It is widely admitted that it is now extremely difficult to source truly GM free foodstuffs and amazingly there is no requirement for labelling in some circumstances.
Despite this no company supplying GM crops has ever been forced to pay for cleaning up the contamination caused by their failure to contain their products in a controlled manner. It is common knowledge that conventional crops spread seeds in ways that cannot be controlled.
The oil seed rape plants growing on verges from seeds leaking from transport lorries, wheat growing in fields and gardens from seeds dropped by birds (what about contaminated wild bird seed?), seeds carried on poorly cleaned machinery, dropped undigested by animals, and even carried in the mud on the wheels of vehicles are all ways that have been shown to move plant seeds for great distances from the fields where they were grown.
There is no one who can say with any certainty how GM crops will be contained or controlled, especially when volunteers from a GM crop establish themselves in following Non-GM varieties.
Probably the worst problem facing farmers who wish to remain free of the charge of abusing the patent laws by growing GM seed not purchased from the seed supplier is that it seems efforts are being made to ensure that the seed supply contains GM seeds. This is the final move by the industry to force acceptance on the world because once the seed is contaminated then cross-pollination within crops is ensured at an increasingly exponential rate. Any suggestion that pollen does not travel any great distance ignores the proven travel of pollen for hundreds of miles as seen recently when pollen from trees in Sweden was deposited in parts of the UK. It would seem that the regulators have been duped into accepting a level of contamination in seed but that spells the end for both conventional and organic crops.
Rather than force the industry to clean up its act they are being given the power to avoid what would be the massive cost of the clean-up process, just as they were with pesticide residues when it was found that pesticides were being found in our food. The “polluter pays” theory is obviously not the practice in the pesticide and GM crop sectors and to allow the growth of GM crops for years will ensure contamination. Of particular concern is the “0.9% threshold for adventitious GM presence adopted by the EU”.
Many years ago I was persuaded to save money by buying seed that was not guaranteed free of Wild Oats. Instead I purchased seed that accepted a 1% contamination level of the persistent weed seed.
The result was more expensive than the saving as before long the fields were all contaminated with Wild Oats which then self-fertilised and sowed themselves every year. There then followed many years of expensive chemical control in attempts to reduce the yield sapping contamination. Can anyone explain how the scientists arrived at figures suggesting that a 0.3% adventitious presence of GM varieties in seed becomes only 0.01% at harvesting? Given the likelihood of cross-pollination within the crop grown from contaminated seed the harvest contamination must be greater than that when sown.
Those who accepted the claim that 0.9% contamination is “acceptable” have obviously had no experience of growing crops. It will guarantee cross-pollination within the growing crop and it will make a mockery of the claims that any separation distances will contain GM crops or protect conventional and organic growers. The decision to allow any contamination is scandalous but it demonstrates that the industry promoting GM crops has gained control of the political system and its regulators.
It is clear from the proposal to “Notify” neighbours of intended use and “voluntary” controls that this is a move towards allowing GM crops to be grown no matter what effects will be induced in the crops or in the food chain.
It is obvious that the profit of these companies is being given priority over the rights and health of the people who are supposedly represented by the political system in this country.

4) Quality

It is extremely interesting that the acceptable level of glyphosate residues in our food was increased in order to allow the import of GM crop produce into Europe.
Presumably this is because the farmers who grow GM crops are finding, as was found in the GM trials in the UK, that to maintain yields multiple applications of the herbicide were required. As a result the residue levels in the harvested food must be higher and yet the promoters of the crops would have us believe that even with changes in the DNA of the crops they are still “substantially equivalent” to conventional or, even more unlikely, “organic” foods.
Those who claim that there are essentially no differences between conventional and genetically modified foods must explain how animals can determine the difference that science claims does not exist.
I understand that an experiment demonstrated that rats refused to eat food from genetically modified crops but were keen to devour non-GM food laid nearby. Are rats more intelligent than humans?
Those who promote the pesticide use upon which GM crops depend suggest that without chemicals the resulting food could be actually harmful to humans and yet in the recent health problems in the USA involving E-Coli the bacteria appear to have been traced to conventional farms and not the organic sector.
The truth appears to be that GM crops do not reduce problems but they are likely to make matters worse.
For example. Little is mentioned of the residues from Bacillus thuringiensis (Bt) GM crops and yet those crops exude a toxin throughout their growing cycle – and possibly beyond via the remaining root system. We are told that Bt is “safe” because organic growers are permitted to use the product but there is a major difference between single applications and continuous use. It is also clear that with prolonged release of these poisons there will be greater risk to non-target organisms and an enhanced risk of inducing resistance to what is considered a valuable weapon in the farmer’s armoury.
Strangely, despite having been proven incorrect in other claims made during his lifetime, Paracelsus (1493-1541) is still relied upon by those who wish to convince the world that it is merely the dose of anything that makes it a poison. Odd too then that organic growers are criticised for the occasional use of Bt and yet continuous excretion by GM crops is somehow regarded as “safe” and advantageous to the world. The claims by Paracelsus and those who repeat them have resulted in the entire planet suffering from at least some level of exposure to what are in many cases deadly toxins.
By definition a man-made life form in which foreign DNA strings have been artificially implanted cannot be “substantially equivalent” to one that has developed and has been proven and tested by nature over the centuries. It may be similar, just as grass is similar to barley but it is not “equivalent”, no more than an apple is to a pear.
When the discussion moves on the pharmaceutical crops then all the arguments about being “equivalent” must be disregarded because contamination then becomes a much more serious issue and the industry has not yet demonstrated how potentially dangerous modified crops will be prevented from entering the food chain or the seed supply. The same is true of the potentially devastating so-called “terminator gene” because if such a sequence moved into wild plants, conventional or organic food crops the entire world could face a situation where food non-GM crops could also become sterile.

5) Unintentional DNA transfer

Reports suggest that inserted gene sequences in GM crops are able to transfer in the gut to the animal that has consumed the produce from those crops. The reassurances given by the industry do not appear to be soundly based given that proteins are always broken down and reconstructed by the digestive system and that there is therefore an obvious means by which transfer is possible.
There have also been reports that resistant weeds and insects have been created in areas where GM crops have been grown but no reports have seemingly been produced to describe how that resistance was induced. Is it a natural process in which weeds and plants survive repeated onslaught by the same toxins or is it a more dangerous result of direct transfer of DNA from the GM crop to the plant, weed or insect?
How will science know?

6) Resistance

As in 5 above resistant plants and insects have already been reported and the opportunistic weeds and insects that take advantage of the situation have often exacerbated that problem.
Farmers have known for decades that they should alternate the types of chemicals used if they are to prevent the creation of chemical resistance. Farmers are well aware that any survivors of chemical poisoning in the insect or plant worlds will quickly create a new generation that will be virtually unaffected by the chemical. Humans do not reproduce quickly enough to do the same.
The chemical industry seems to have ignored this basic and commonsense approach to crop husbandry in it drive for profit. Life is not as simple as these companies would have us believe.
Just as it is not possible to grow good crops without the required nutrients – no matter what the spin claims for “drought resistant” or mineral deficiency tolerant GM crops – it is also not possible to use the same chemical dependent techniques year on year without creating even bigger problems.

7) Independent Science

It is interesting that there is a culture within science at the moment in which any scientist who dares to question the claims of the big corporations whether in the field of poisons, GM crops, drugs or vaccines, will very quickly be attacked from all quarters and face unemployment and ridicule.
Has nothing changed since those brave scientists were killed for daring to tell the world that the Earth was not flat and that it was just one of a number of planets spinning around the Sun?
Have we really not progressed from the “Flat Earth Society” mentality and the determined refusal to accept scientific evidence that does not comply with current majority opinion?

8) Scientific Knowledge

From the earliest days when the claims for genetic modification were made the public was given promises and reassurances by the scientists. The impression was given that genetic modification is a precise science and that gene mapping had allowed mankind to understand the inner workings of DNA to a level at which it was possible to insert sequences from totally unrelated species and predict accurately what effects this would induce in the resulting organism.
If nothing else has been proven in recent years it is now obvious that those were grossly exaggerated claims and we now know that even when genetically engineered drugs have been tested in animals they can induce completely unexpected effects when administered at a fraction of the tested dose in man.
We may now be able to map the gene sequences of plants, insects, animals and humans but it is obvious that we cannot and probably will not know the way each section depends on another for correct reactions in complex processes that may not show their effects for decades after the changes are made.

9) Risks for the future

Care should be taken to ensure that GM crops are not used as “loss leaders” as a means to persuade farmers to grow what appear to be more profitable crops only to find that once trapped into the forced use of GM varieties they then find that the costs rise with no alternative crops available. They may well become “trapped” because by then the control sought for via GM varieties would be well-established.
There is a very strong likelihood that the terms of the contracts for growing GM varieties will make farmers little more than puppets worked by the strings of the contracts written by the seed suppliers with no independence in respect to growing techniques, fertiliser or pesticide use, or even marketing opportunities. It is already suggested that the fear of prosecution for growing GM varieties that have not actually been deliberately sown is making farmers fearful of giving up GM crops in areas where there have been problems. GM crop failure in India has reportedly triggered numerous farmer suicides.
The risk of similar problems happening in the UK must be taken into consideration.
Currently the public and the political representatives who are trying to force through the introduction of GM crops are moving in opposite directions.
The public, increasingly aware of the risks posed by chemicals in their food, are moving towards organic production and the growth in the organic food sector is rapidly reaching levels difficult to supply.
Contrastingly the public is also wary of the clams for GM crops and various studies have shown no decrease in the opposition to the technology, especially in food production. If GM crops are introduced with the level of “contamination” that is seemingly approved the logical result will be the inability of the UK to meet the growing demand for truly organic produce.
The UK would no longer be able to proclaim in the world market that our food is of the highest quality and that it is free of genetically engineered ingredients.
Perhaps the entire plan is to destroy the once great reputation of British agriculture and to make it subservient to the interests of the United States of America and the multinational corporations?
There seems to be little else to support the current plans as the technology comes with no guarantees and very many, often extremely serious, risks.

Recently the BBC broadcast a programme that looked into the science of Epigenetics and the data they obtained has a chilling message for the “gene jockeys”. At least it would be chilling if they cared.
It seems that environmental influences over our grandmothers when they were still in their mother's wombs and those same influences over our grandfathers at puberty can trigger changes in the genetic makeup that will be passed down for generations to come. Even famine had an effect but pesticide exposure was specifically mentioned and, after all, GM crops are designed to withstand greater use of herbicides. All other uses of pesticides remain the same or have to be greater to manage resistance.
The crops exuding Bt toxins do so continuously, for example, and the development of insect resistance by the widespread use of such crops is virtually guaranteed.

Government should be discouraging farmers from forcing GM crops on the nation and encouraging them to move to the much more sustainable “organic” methods that have proven sound over centuries.
They are already being encouraged to move to “minimum tillage” methods because such methods rely entirely on chemical controls for weeds and diseases but perhaps the encouragement should be towards a “minimum chemical” method which, with careful use of soil science, conventional breeding and the use of genetic knowledge to find the varieties that naturally possess the genes that give the traits required, could take our country back to being the leading light in agriculture worldwide.
Not only would this be encouragement for our scientists and the industry but it would also move towards sustainability and help to meet the growing demand for truly organic food.

I think the above provides my views in answer to the question
Do stakeholders have any comments on the proposed scope of the coexistence regime?

Obviously I do not believe that coexistence will be possible without detriment to conventional and organic production. In answer to the questions posed in the consultation document my views follow.

What assumption should be made about GM presence in non-GM seed?

There should be zero presence and if that is not achievable then GM should not be grown and non-GM seed should be sourced from areas that do not grow GM varieties. Essentially if GM seed is permitted in non-GM seed then the authorities are accepting that seed may be sown that is not pure as a variety and farmers will not be in a position to declare variety purity in their harvested produce.

What level of GM presence is expected to arise from sources other than seed impurity and crop-to-crop cross-pollination?

Any assumed figure at the outset of this exercise will soon be outdated, as the rate of contamination from all routes will rise rapidly if GM crops are grown.

Do stakeholders accept the above analysis of the potential sources of GM presence and the assumptions that Defra is proposing should underpin the coexistence regime?

The analysis is based on flawed assumptions and therefore cannot be accepted for all the above reasons.
The Defra proposals will underpin the right to grow GM crops but undermine the right to be GM-Free.

What measures will be given statutory backing?

There should be compulsory insurance cover to provide compensation for those growers and processors who do not wish to have their produce contaminated with GM crops or substances derived from them.
No GM crops should be permitted in the UK or Europe without that insurance cover.
Voluntary codes for the control of volunteer plants, cleaning farm machinery, informing neighbours, and separation distances are unlikely to work because they cannot easily be enforced and would require co-operation and the compliance of all involved coupled with scientific analysis of the crop to check the purity of the varieties grown. Because voluntary controls are unlikely to work we now have the contamination that was supposedly never going to happen at the outset.
Some of the legal constraints were ignored even in the Government’s own trials so what chance have voluntary codes to succeed?
This is another strong argument against permitting the growing of GM crops.

Do stakeholders have particular comments on the analysis in the draft Regulatory Impact Assessment (at Annex B), and on what it says about Defra’s plans to enforce, monitor and review the coexistence regime?

As with pesticides it is claimed that GM crops are “already heavily regulated” but also as with pesticides there have been serious breaches of regulations and yet no action has been taken against the perpetrators.
There is no use in boasting of regulatory powers if they are never, or rarely ever, enforced.
Regulations and laws that are not enforced are no laws at all.
If the am for co-existence is to minimise unwanted GM presence then Defra should examine the current situation and the admitted contamination that is happening now even though the crops are supposedly not even grown commercially in the UK. The co-existence plan appears to be just another step in the process intended to ensure that GM crops will be grown and as such it is inevitably biased towards the GM industry using methods that will eventually enable those companies to take control of the entire food supply of the UK via the seeds and the contracts linked to the seeds. To suggest that segregation of GM crops and conventional is akin to separation of seed and food/industrial grade crops is as irrational as it is dishonest, just as is referring to GM crops as being the same as hybrid breeding. How much worse must things get before Defra wakes up and sees the reality of what it has done?

Risk assessments are themselves an indication as to why it was wrong to start down this uncertain road.
There is a risk. Risks should be avoided where possible. Why take the risk when there is no need?
Europe is a more densely populated area that the arable areas of North and South America and we have more history to learn from in unforeseen disasters due to bad policy, with BSE being just an example.
Things are different here in the UK with population areas very close to arable farms.

Is it justifiable for those who have deliberately introduced polluting crops to expect others to take measures to keep the contamination out of seeds and produce? Surely the burden for the additional costs imposed on the innocent parties who have suffered as the result of the induced problems should fall on the companies that pushed through the GM experiment without thought for the effects on the world seed and food markets. Why is the polluter not being made to pay? The proposals seem to place the burden for ensuring that seeds and produce are GM free on the innocent bystanders and not on the perpetrators.

If the co-existence arrangements are to be allowed to proceed for 2-3 years before being reviewed there is a strong likelihood that GM contamination will be out of control with no way back should the need arise.
Option A will do nothing to control GM crops. They are already out of control and spreading.
The EU Traceability and Labelling Regulations did not prevent many hectares of GM seed being grown in the UK in error, or the associated costs of the clean-up programme.
Option B does not appear to provide any statutory controls and is vague on the detail regarding testing and enforcement of any of the suggested “measures” and “mechanisms” to be introduced.
Option C represents a half-hearted statutory control mechanism but again there is reliance on voluntary codes which have already been seen to fail as in pesticide use and the related problems. Without enforcement all statutory instruments are useless and voluntary codes can be worse than useless because it is assumed that all involved will act responsibly. Experience of human nature suggests otherwise.

“Good Farm Practice” is an ideal but how many growers always adhere to the rules, especially if there is more profit to be had by ignoring those rules? The real world situation is not so clear-cut or honest.
Government regulatory controls will not work without the co-operation of the industry and it is unlikely that industry will rigorously enforce controls unless the Government imposes statutory regulation and ensures that those regulations have the teeth to bite should they be ignored.
Every farmer is aware of Health & Safety obligations in law for example but because they rarely ever face truly hard-hitting sanctions on enforcement the majority can ignore the laws without fear.
The same will be true with the GM issue unless the Government has the will to take firm control over the technology, which it seems determined to introduce no matter what the risks or costs.

I fail to understand how Defra can believe that statutory co-existence rules will be effective since it has admitted that preventing contamination will be all but impossible. That means that co-existence itself is not possible, as the GM varieties will quickly contaminate all other crops of similar type.
If contamination is inevitable co-existence rules will by definition be ineffective, worse than useless.
When it all goes wrong Defra suggest that there will be redress mechanisms. It is to be hoped that those mechanisms will be more effective than those that are supposed to compensate individuals who have had their lives destroyed by failures of pesticide regulation. Those individuals soon discover that the promises of protection at work, compensation, and proper medical treatment, do not represent the reality and that they become sacrifices in efforts to protect the industry. I see no reason why the same situation will not occur in any GM contamination or adverse health effect incidents related to GM crops or the chemicals used. Perhaps Defra is trying to reassure the public that they are valued, even if they are not.

Given that the “risk owner should bear the cost of any measures to prevent harm that would otherwise be caused by their actions or inactions” Defra have stated the obvious in that the industry that has forced these crops on us must be made to pay the full costs of the control measures, analytical procedures, compensation for losses incurred, and for the clean-up of any contaminated land, food stuffs or any other ensuing problem. Non-GM growers and organic farmers did not ask for those additional burdens to be placed on their already difficult businesses and should not be asked to pay any costs to fund Defra’s plans to introduce GM crops as a means to save the biotech industry.
The polluter should be made to pay.

In the current climate the benefits of maintaining a GM-Free agricultural system in the UK, growing premium, high quality produce, probably even to organic standards to fulfill the growing demand for such produce, is likely to be of far greater and cost effective benefit to the UK than any GM crop programme.
Why should Non-GM producers have to foot the bill for testing at £200 per sample simply to ensure that the GM crops have not contaminated their Non-GM varieties? The Government wants GM crops and the multinationals want to force them on agriculture and so they should pay the full costs.
To do otherwise is to make the polluted pay the polluter for the pollution he caused.
Furthermore GM crops cannot be sustainable and there are already weaknesses showing with resistance, induced insect problems, crop failures and a host of other worrying trends.
To destroy sustainable systems at the expense of proven traditional practices at great cost and for doubtful short-term gain is madness.

Do stakeholders agree with these proposed distances? If not, which aspect(s) of the supporting analysis and proposed assumptions made by Defra are thought to need further consideration? What do stakeholders think of Defra’s proposal not to differentiate separation distances by GM Index or field depth?

What does Defra suggest that farmers do with the crops within the separation distances at harvest?
Does the farmer consider the crops in these areas as GM, which they are not, or Non-GM and how does the crop sell in markets that will want either GM-Free or GM varieties?
Much talk was made by those opposing the call for pesticide buffer strips designed to protect human health, suggesting that 5 metres was too much and unnecessary, and yet here we have suggestions of up to 110 metres, which may even affect neighbouring farms. The whole idea is nonsense and is merely being proposed to allow GM crops to be grown. It is better and more effective to remove the polluting source.

Do stakeholders accept how the proposed separation distance requirement would apply? What do stakeholders think of the idea at paragraph 87 that some local discretion might be allowed?

This appears to be suggesting that farmers may freely agree to ignore the statutory laws if the agree amongst themselves to do so. What sort of statute will this be? Is it a voluntary law that applies only if the person agrees with the lawmakers? It is of interest to note that entire counties could voluntarily grow GM crops without the proposed separation distances but Nation States are not permitted to ban GM crops.
As seems always to be the case the law is being written to favour the multi-nationals.

Do stakeholders have any comments on how the proposed notification and liaison requirement would operate? What do stakeholders think about having a single notification deadline for spring-sown crops, rather than separate deadlines for spring rape and maize respectively (paragraphs 91/92)?

Will there be any requirement to notify of spring crops sown before March? Sowing dates appear to be getting earlier every year and it is suggested that global warming will speed that trend.
There is little doubt that the companies will introduce greater GM varieties in the rush to gain control of the seed, fertiliser and pesticide market should the growing of GM crops be approved and so it is likely that August and March notification deadlines will need to be altered if approval follows.

Do stakeholders think this is a reasonable way forward on farm saved seed?

Once again the proposals give more rights to the GM producer than to the non-GM farmer.
Having admitted that contamination can take place via cross-pollination over some distance the Non-GM farmer is then told that he must sacrifice parts of his own seed crop to avoid the risk of growing GM seeds. There are no such restrictions on GM farmers and so there is a proven bias in favour of GM crops in these proposals.
The GM farmer should not be permitted to contaminate his neighbour’s crops and if the only way to avoid that contamination is not to grow GMs then they should not be approved.

Do stakeholders agree that a formal training requirement is unnecessary?

In the event of the introduction of GM crops, and especially the pharmaceutical varieties, will farmers have sufficient skills to contain those crops without specialist training? Some of those crops could have potentially damaging effects on health should they inadvertently find their way into the food chain.
Who will be responsible for such effects? Will the insurers insist on training?
Despite knowledge to the contrary it is claimed that both GM crops and pesticides are “safe” even though some may definitely not be and yet training is insisted upon with pesticides but it is still to be decided on in regard to the potentially equally damaging effects of GM crops in the environment.
Who will pay for this training? Will the taxpayer subsidise the multinational industry again?

Should responsibility for any threshold below 0.9% rest with GM or organic growers? How would organic producers cope with a threshold lower than 0.9% if the onus for meeting it rested with them? Are there important points that are not covered in the arguments outlined above?

In the figures for areas under organic production there appears to be no account taken of the considerable area of land devoted to organic gardening and the wide variety of crops found in gardens, some of which like sweetcorn and brassicas may be at great risk of contamination by GM crops grown nearby.
Organic is organic and it is not genetically modified organic so any threshold above zero will change its status. Is it really unreasonable to suggest that GM growers should not contaminate their neighbour’s crops and land by their actions? Would I be permitted to allow paint to cover my neighbour’s car simply because I wanted to use a spray gun on a fence? Is it really my neighbour’s task to prevent contamination induced by my irresponsible actions? The GM crop grower is the potential polluter in this matter and the pollution is not accidental because it is avoidable by limiting production to non-GM varieties.
Once again the rules are being made to assist the GM industry at the cost of the rest and the bias of Defra towards the introduction of GM crops is obvious.

What do stakeholders think of this analysis – is there any firm evidence that would call this into doubt or support a different conclusion? Is there an alternative analysis that should be considered?

In order to justify the position taken Defra admits that there are many ways that a GM presence could be transferred into a Non-GM crop and that it is unrealistic to expect that this can be stopped. This directly opposes claims that it is possible to have co-existence and for the effectiveness of separation distances.
It is an admission that all the promises made have been misleading.

What do stakeholders think about this? Is the expectation that demand from the organic sector will generate production of enough seed which is below EU labelling thresholds to enable a threshold for organic produce lower than 0.9% to be met? Will consumer demand for organic products distinguish between a GM threshold of 0.9% and, say, 0.5%?

Defra appears to have surrendered to the GM industry but should heed the warnings from the pesticide issue. Many pesticides have been approved as “safe” over the decades but have had to be withdrawn because serious adverse effects were found many years after their approval.
Assuming that there are acceptable levels of GM may prove to have been a misjudgment with equal or even more devastating consequences in the future.


It is not true to say that GM crops will only be grown in the UK if there is a market for them since they have already been grown both in trials and by accident through the contaminated seed.
Nor is it true to suggest that any economic losses would be rare and of low value given the costs involved already when accidental contamination has occurred. The same arguments are used here as have been used in regard to pesticides. “It is difficult to find the right defendant”. Cases are “untested and uncertain”
These are excuses to avoid litigation rather than justifiable arguments regarding those who have caused avoidable economic loss. The government will permit the growing of GM crops and it will also control access to the courts, just as it has done on other issues where Government is a co-defendant.
It is not the “accepted threshold” that should be the determining factor for compensation but the actual financial losses caused to the innocent party. An example could be where people refuse to buy honey from bee producers near where GM crops are grown. The economic loss would be very real even if there were no great contamination, even if such contamination is excused as merely “adventitious” by officials.
Who is going to pay for all this monitoring for GM presence? Is it the government or the industry?
There is also the potential, in the event of a serious problem showing with GM crops in the future, that all areas where the crops have been grown could face restrictions and resulting loss in land value. Resistant weeds or residual toxic effects are just two areas of potential concern.
It is very interesting to see the comment that to avoid this would be a “disproportionate burden on the GM sector”. Surely the GM sector wants this burden or it would not be pressing the entire world to accept the introduction of its crops around the globe. It is their actions that are disproportionate, not the burden caused by those actions, which they should bring upon themselves.
They choose to force these crops on the world. The world did not ask them to do it. They are the polluters and as the Government likes to say “it is the polluter who pays”.
I am sure that the lawyers will hope that the government approves GM crops, as there is a potential for big earnings for them when the predicted problems eventually become reality

How could a crop register aid coexistence? Are there other reasons to justify the establishment of a register? How should any register relate to a notification requirement? If a register is established should the information be available to everyone? How would a register be funded?

There must be a public register so that all growers, including gardeners and smallholders, will be able to know if GM crops are grown near them. How else would they be able to instigate testing to determine if their own crops have been adversely affected? Similarly an historical record of where GM crops have been will be essential in case problems show in the future and their use needs to be traced. However this would presumably have to also include any areas where unplanned contamination has occurred and in the event of problems a short period of 5 years for keeping those records may not be sufficient.
The companies selling the GM seeds should pay for the register and the upkeep of the data with heavy penalties for any failure on their part. Most farmers keep records of their cropping plans and I am sure that Defra can easily obtain the information from the various subsidy forms filled in by farmers on an annual basis. Crop trashing would not be happening if the government had listened to legitimate concerns raised by scientists and farmers as well as the general public. Such actions cannot be easily condoned but it is understandable and Defra faces alienating the public and the farming community further with its proposals to permit the growing of GM crops. Secrecy does no one any good.


It is clear that the EU, like Defra, has surrendered to the multinationals and has allowed its member states to be bullied into accepting GM crops. As a result it has become difficult to declare a GM-Free status, clearly a position intended from the outset. It is obvious that just one farmer in an area could prevent the majority from declaring a GM-Free area. Even if such an area were established it is likely that the farmers in the area would be targeted to encourage them to grow GM crops or to sell the land to a farmer or company that would. The task is made difficult, if not impossible, because officials in Governments around the world have surrendered to commercial pressures.

A final comment.

Many years ago I thought that radiation exposure was the key to the meaning of the Biblical saying that the sins of the fathers shall be visited on the children of the third and fourth generations.
Then I read Rachel Carson's book Silent Spring and saw that an English scientists knew even then that organophosphates were radio-mimetic chemicals that were probably more dangerous to the cells than radiation. This should be no surprise as the body relies on numerous natural organophosphorus compounds and DNA itself as regarded as one. That is presumably why OPs damage DNA and RNA. Defra is taking serious risks by not taking action on these chemicals and approving GM crops will rapidly worsen the situation because of the OP-chemical-dependent nature of the crops.
The BBC programme on Epigenetics as mentioned above seems to confirm that once again man's arrogant stupidity has damaged his own genetic code but only time will show the effects and by then it will be too late to step back from disaster.

It is surely time that those who proclaimed that contamination of our food by GM crops was not going to happen and that glyphosate was a "safe" organophosphate must now be forced to pay for the damage and for the decontamination process that is now required before future generations will be "safe"?
I doubt that it will happen but it is probably already too late?
It is to be hoped that Defra will ensure that every step is taken to control GM Crops but on past record it would seem that the multinational companies have taken control and that the health of the people and of the environment have become less important than the profits of powerful organisations.

Yours sincerely,

Dated 18/10/2006    Updated 20/02/2016

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