Comments on the future of Genetically Modified Crops

20th October 2002

GM Crops Team,
Prime Minister's Strategy Unit,
Cabinet Office,
4th Floor Admiralty Arch,
The Mall, London, SW1A 2WH.

Dear Sir/ Madam,

It is extremely difficult to comprehend how any informed and right-thinking person could support the cultivation of genetically modified crops, given the dangerous adverse effects already reported.
Life has evolved on this planet for millions of years and produced a wide variety of plant, insect and animal life, which was balanced and would continue to evolve for millions more years without any interference from man. In the process of evolution the life forms created safeguards to minimise the risks of cross fertilisation from one independent species to another. Man has a built-in abhorrence for such actions and for cannibalism as an integral part of that protection system.
Then along came commercial companies determined to profit from research into DNA and all that evolution is now in danger. These companies have cast aside the natural laws and now insert genes from animals, insects or even worse, humans and bacteria into crops destined for food production. Now and in the future we could all consume human DNA, if we survive the potential to create malevolent forms of super bacteria, viruses or other unintentional life forms so far unseen.
Worse still, because politicians are allied to the powerful leaders of this new so-called “science”, a handful of companies are now responsible for the deliberate contamination of the entire globe, and our food supply with man-made versions of the precious templates for life, the DNA, which carries hidden messages into the future. No one can know what those changes will cause in years to come and yet those companies forge ahead with ever more daring DNA exchanges, and they are supported by their political allies, despite the real concerns voiced by the people whose interests those politicians claim to represent.
There is scepticism as to the real agenda behind this “consultation process”, and suspicion that the government has already caved in to the pressure from those few powerful, foreign-owned companies.
The government seems willing to gamble the health of the entire nation in order to remain involved with the science of genetic engineering, and that no matter what evidence is presented, the policy will remain as dictated by those companies.
There are promises of riches beyond our wildest dreams, with crops designed to withstand both floods and drought, poor and saline soils, herbicide applications and insect attack, with the added bonus of being able to produce pharmaceuticals and fuel oils whilst at the same time reducing the requirement for pesticides and fertilisers. All this represents a veritable miracle worthy of our wildest dreams.
The reality however is somewhat different.

The government refers to the need to educate the people into accepting “sound science” but many of us are well enough educated to know that tampering with DNA is nothing at all like “sound science”.
Much publicity surrounded the publication of the research into mapping the “human genome” but in truth we know little more than we did before about the interactions between the various parts of the DNA.
Evidence of this is shown in the fact that the scientists must employ “marker genes” in order to be certain that the insertion of the gene string has been successful. Even then unpredictable effects have been created in the resulting organism, much to the surprise of those who created the new life form.
It is, as I have suggested in the past, no better than allowing a child to repair a computer using a hammer.
All this would be worry enough to cause wise individuals to examine their support of the technology more carefully but this is but a fraction of the real problems involved.
I understand that the government is to “Commission an independent review of all information that will complement the results from the FSEs including: information collated by the Advisory Committee on Pesticides (ACP) on the herbicides in question;” and “ information collated by ACRE on any direct and indirect effects of these crops compared to conventional varieties”
On those grounds alone the current series of genetically modified crops should by rights be banned.
The reasons for that statement are that

1. The ACP must be aware, even if they fail to report the fact to Ministers, that the organophosphate herbicides used on those resistant crops are by no means as “safe” as they are claimed to be by those who manufacture and promote their use. I have personally sent information to the Prime Minister, and to the Pesticide Safety Directorate and others, which indicates real cause for concern but all evidence against this form of pesticide is ignored, seemingly for political reasons. However. As time passes scientists are beginning to confirm that there is a major problem with the safety data and have linked the chemical to nervous system damage, cancer causation, and more recently to hormone disruption. Even in their home country the manufacturers were ordered to stop the false advertising of one of the products as “environmentally friendly” and the claims in this country that it is “almost safe enough to drink” are shown to be a falsehood.
It should be remembered that despite the mounting evidence against this chemical the Maximum Residue Levels permitted were raised 200-fold in order to permit the import into this country of genetically modified foods, which had been repeatedly sprayed with the systemic organophosphorus chemical.
The dangers posed by such chemicals have been recognised by Act of Parliament since 1958 here in the UK and yet still they are denied in the effort to hide the true facts.
If the commercial growing of crops which can resist these chemicals is permitted in this country it will be done despite the warnings, and the evidence of harm seen elsewhere in the world, and will be in opposition to the declared intent to reduce pesticide inputs on UK farms. It will also endanger what remains of the organic movement in this country, which the government claims to be supporting.
It is a disgraceful abdication of the responsibility to protect our people and our environment.

2. Officials state that the seeds must be "distinct, uniform and stable (DUS) and have value for cultivation and use in the UK." I would suggest that the very fact that these modified crops have contaminated conventional crops and supplies of honey demonstrate that they are far from stable.
We have all seen the reports of farmers who have unwittingly discovered that either their seed supply or their growing crops have been contaminated by GM varieties and it is becoming increasingly clear that the separation distances so far considered are wholly inadequate. As was pointed out by many people, if sand from the Sahara can reach the UK it is nonsense to suggest that pollen or even seeds from GM crops could not travel as far – especially as pollen and seeds can be transported by birds, mammals and man. The oilseed rape growing along motorways offers simple and scientific proof that such seeds are impossible to contain.
It is suspected that the contamination by these pollutants was intentional, as with the GM contamination of non-GM seed as a means to undermine the protest against the worldwide use of these crops but there is also a suspicion that the trial crops were also intended as a means to introduce these man-made defective genes into our environment. Once here they are now going to be extremely difficult to remove and it was in my view an extremely shortsighted action when those trials were approved.

3. This tragedy was compounded by the introduction of contaminated seeds as sold to unwitting farmers and growers here in the UK. Sadly the GM companies now often control the seed companies and we have already seen what appears to be deliberate contamination of seed supply with GM varieties. Having been a farm manager I am aware of the seed purity laws and yet the government has not taken action to ensure that these companies comply with their duty to supply seed of the correct variety. Even with wild oat control 100% purity is vital if chemical control is to be avoided. Even 1% contamination will lead to enormous problems if left unchecked and with GM varieties cross pollination within the crop and with surrounding plants will inevitably lead to total crop and environmental contamination.

I suspect that the companies involved hope that it is already too late to act. There is also the question of uniformity and, since it is impossible for the recipient of the seed to check for genetic contamination, it would not be possible in the commercial world for growers to be sure that the variety purchased contains the correct genetic alterations. I understand that the manufacturers have had to recall at least one batch of seed because they had inserted the wrong genetic sequence. This at a time when the technology is under scrutiny for safety and when every effort is supposedly made to ensure that this new technology does not present a risk to health or the environment. Such “errors” can only become more frequent with increased use as “familiarity breeds contempt”. It is also clear that the same companies have allowed their seeds to contaminate conventional varieties already. Even with current varieties this is bad enough but proposed medicinal varieties could have serious consequences should they contaminate food crops. How long will it take to remove the GM contamination already present in the environment? Is that even possible? Dare we risk further GM pollution?

4. In addition to the dangers presented by the herbicide resistant crops there is even greater reason for concern in respect to the crops that are modified to produce their own insecticides. These crops will continuously release their poisons throughout the growing season – and beyond, if the roots remain viable and if self-setting seeds continue to grow in the soil. In addition this is contrary to the recommendations that farmers should only use insecticides when certain threshold numbers are reached in order to protect the environment. The reason why these thresholds were introduced was to protect insect eating birds and to reduce the chance of insecticide resistance. In both of these areas the continuous action of the GM crops will not only fail but they will also accelerate the known problems. Farmers have been advised for years to change the type of insecticide and to use them only when necessary if resistance is to be avoided – the exact opposite to the scenario presented by all forms of GM crops and this may well explain why weeds resistant to the commonly used herbicide are now developing.

5. It is claimed that these risks are similar to those in conventional crops but that is not the case. GM crops were not designed to avoid resistance but to promote resistance and to increase shelf life as a result of the resistance to the natural process of decay. The enormous variety of pesticides available for use on what is now termed “conventionally” grown crops should have been far more likely to prevent resistance that the limited releases used with GM crops and yet concerns were being raised before the GM crops and their restricted chemicals were developed. The high level of pesticide use has destroyed the “balance” and it will take decades to re-establish the controls naturally found in Nature.
If we decide to travel down the GM road then these problems can only become worse – and there is no way back.

6. I understand that the use of “antibiotic resistant marker genes” is to be phased out due to a recognised risk that the resistance could be transferred to humans. In so many areas of this technology what we are told is “perfectly safe” later proves to present a danger of unknown proportions.
Only a few years ago we were told that “cross-pollination” from GM to natural plants and crops was “not possible” or at worse only possible at “insignificant levels”. Experience with the crops shows that neither claim was true. We are repeatedly told that organophosphorus chemical residues, and now mixtures of pesticides, do not present a risk to human health and yet we know that this is completely untrue. This is the true nature of “sound science” here in the UK where it seems that officials, who only recognise the work of those who agree with the policy, suppress all true science that expresses doubts as to the viability of official policy. Any scientific work by “outsiders” is criticised by any means possible as a means to hide information that could be damaging to those who control policy decisions.

7. This is why supporters of GM crops are entirely wrong to argue that ”singling out GM technology for special attention is unwarranted and unfair”. This is an entirely new path and it has risks far exceeding any that have gone before, including the complete devastation of organic production due to contamination and the possibility of serious long-term harm to human and animal health. As they claim “There is no special liability regime for other developments in crop improvement or agronomic practice,” but this is because no other form of crop has managed to contaminate the food supply of the entire world before - and no other organism has been artificially created by science without the full understanding of the implications. The claim that “the release of GMOs is already more tightly regulated than any other agriculturally-related activity” is an inaccurate overstatement proven by the failures already seen in seed, crop and feed contamination. Perhaps there is a real and urgent need to introduce firm liability procedures into all aspects of chemical assisted agricultural production? Victims of poisoning would no doubt say that they are surprised that no proper liability regime is currently in force. Was this an oversight or a deliberate ploy by successive governments to ensure that the industry is protected no matter what harm is caused?

It is clear therefore that there is ample evidence against the further use of Genetically Modified crops but it is also clear that the government does not intend to recognise those dangers unless those who are advising Ministers admit them.
In my experience that advice is frequently inaccurate and often false.

In addition to the environmental concerns and the potential health hazards there is also the question of control of the food and seed supply, which we are also surrendering to foreign powers to the detriment of our own once high International reputation for quality. The UK was once a world-renowned centre of excellence in plant and animal breeding. We had dedicated scientists who by natural means had achieved incredible results, always of a high standard, and as a result we were world leaders in yield and quality with a highly valuable export market. We then allowed multi-national interests to take over those breeding programmes and they were then no longer geared to produce the best plants and animals for our own climate and needs. In fact the chemical companies, many of whom now own the seed supply, could increase their profits by producing crops requiring the use of expensive pesticides in order to survive. This cannot be denied. Many of the proposed GM varieties are so tightly controlled by the chemical industry that farmers have no choice but to apply certain chemicals if they wish to have any harvest at all.
This is a cause for considerable concern as the government could find itself in the unenviable position of being forced to agree to policies not in the best interest of the country in order to obtain the essential supplies of seeds and chemicals required to feed the population - a form of food blackmail.
Sometimes it appears that this is already happening and that this is why the government is determined to undermine the sensible safety approach in the labelling of GM content in foods and medicines.
The Prime Minister’s “Scoping” Document suggests that considerations will ”include the implications of UK commercialisation decisions on the ability of developing countries to make an informed choice about GM crops.” We are not given the information by government to be able to make an informed decision ourselves and in any event the current forms of GM crops are not intended to aid the third world but to make profits for a handful of companies. In fact there are reports that some GM crops have been developed to administer contraceptives to those who eat them. Not only is this an infringement of their human rights but it is also an additional risk in respect to the contamination of our food supply. There are obvious additional risks in respect to cross-pollination, traceability and food safety. This also raises serious doubts in respect to the real agenda behind the GM crop plans which no one needed and no one asked for but which was forced upon us in order to increase profitability and control for the multinational chemical industry. There may be potential benefits in this research in the future but this will not become a reality if the serious issues regarding lack of knowledge and safety are not addressed now.
To forge ahead in the mistaken belief that the current crops will be the answer to all our prayers would be a disaster. Had we spent a fraction of the cost studying natural methods of pest control and fertility enhancement we would have found the answers to waste management and biological controls by now.
Instead we are moving towards total chemical dependency, often with lower yields that we had obtained through traditional breeding, with the proven potential for resistance development and health damage.
I urge the government to think very carefully before surrendering control over safety and our food supply to unaccountable foreign-owned companies who simply strive for profit and control.

To this end I suggest that the government should not allow any of the current GM crops to be commercially grown and should insist on honest science and truly open debate. If we cannot trust the Government or the chemical companies to tell the truth about basic chemical safety how can we trust them when they say that they understand how to control the unpredictable and long-term effects of gene tampering?
The commercial planting of GM crops or the sale of the seeds from which they will grow must not be permitted and it would be wise to ensure that the scientists already employed in this work were re-directed to study the interactions between the various life-forms on this planet before creating “monsters” of their own which they cannot control. The GM monster is already out of control.

The Government list the potential benefits as • Stress & disease resistant plant lines; These are likely to be temporary benefits due to evolution.
• New cash crops, e.g. antimicrobials, therapeutic proteins; These will add to the dangers through contamination and cross-pollination.
• Diversification of activities; What exactly is meant buy this phrase is not clear but perhaps the implication is that a wider variety of crops could be grown. However these will also have serious environmental impacts.
• Low input crops, e.g. decreased nitrogen requirement therefore lower production costs; Once again this is based on a predicted and not proven advantage. In fact I understand that non-GM varieties of some crops fix nitrogen efficiently but GM varieties of the same crop fail to do so – hardly an advantage.
Production costs have been reported as higher when GM crops are grown and the contractual arrangements with the seed supplier must also be considered when making such judgments.
It is clear that non-GM growers are already paying a high price for GM contamination.
• Higher yields; Again this is theoretical. I have long been of the belief that the pro-GM trials would take two forms. One would use very little herbicide as so “prove” that the crops offer greater plant and insect diversity. The other would be managed in a way that would produce the highest yields irrespective of cost in an attempt to claim yield benefits. The reality will be the worst of both worlds.
• Better quality of life through time savings. This is not a benefit of GM Crops but one resulting from “minimal cultivation techniques”, which have been tried before with “conventional crops”. Many farmers in UK conditions had to abandon the practice as the result of compacted soils, increased disease and persistent weed problems, even with the use of the wonder OP herbicides.

The government list benefits to consumers as

• Lower product prices; This is a prediction likely to be unfulfilled, especially if GM crops do not provide the yield benefits promised or if crop failures become widespread, as has already occurred
• Better quality food; This depends on the criteria for measuring quality. Many would suggest that true quality is found in organic produce grown on local holdings – the opposite to GM crops.
No mention is made of the ethical and religious pitfalls when human and animal DNA is incorporated into crops intended for human consumption.
• Food for specific consumer groups, e.g. coeliacs; Again this is an unproven benefit and there may be better ways of giving such people a more comfortable life, such as avoiding the gut irritating pesticides.
• Novel bioactive molecules and drugs; Again this is unproven and carries with it serious risks of contamination and ingestion by the wrong people and wildlife.
• Novel functionalities in proteins, carbohydrates/chemical intermediates/fibres; This form of crop does seem to have a greater potential than do food crops but there remains the problem of DNA escape, and contamination and cross-contamination.
• Reduced likelihood of contamination with toxins and biocides. I would seriously question the honesty of this claim. GM crops are designed for use only in a pesticide programme and many exude toxins throughout the growth period.
In reality residue levels are likely to increase not decrease in GM crops, as evidenced by the massively increased MRLs for the herbicide used on these new GM crops.

Other potential advantages are listed as

• Low environmental footprint crops and farming systems; I am afraid that this cannot be true. Many GM crops are intended to grow in areas where no conventional crop can grow – one of the much-publicised “advantages” of the technology. This will inevitably be detrimental to the environment. It was reported many years ago that in the USA the only living thing found in fields of GM crops were the crops themselves.
• Availability of renewable raw materials; All of agriculture existed for centuries on “renewable materials” – until chemical means of growing crops became the “norm”. GM crops depend on chemical inputs and they will not return us to sustainable agriculture.
• Stronger rural economy; This is pure nonsense. GM crops will encourage bigger farms and fewer people working on them. It is a continuation of the move towards a weaker rural economy, but worse, since, because of the contracts with the seed supplier’s, farmers will be virtually enslaved to the chemical companies and ruled by their contracts. I understand that this is why the number of farmers in the USA using GM crops is rising – there is no escape once they sign those contracts because they can be charged enormous sums of money if the persistent seeds are later found growing unintentionally on their land.
• Decreased use of fossil fuels; This claim depends on the use of minimal tillage techniques. This is not an advantage found only in GM crops and so it is not a benefit linked to the technology. All other costs in which the fuel is a major part will be exactly the same.
• Benefits to biodiversity. As already mentioned this is a false statement. True biodiversity is found in areas with small farms, hedges, ditches and crop rotation and that diversity is greater still in areas of organic production and minimal pesticide use. The opposite to GM techniques.

Disadvantages to non-GM producers are listed as

• Are GM foods safe to eat? Any adverse effects may not show themselves for decades. It may already be too late to stop any adverse reactions.
• Would GM crops have an adverse effect on the environment? Obviously they have already with reports that DNA from GM crops have escaped into surrounding plants, crops and even honey.
• What would the introduction of GM crops mean for conventional and organic farming and for consumer choice?
The introduction of GM crops has already adversely affected conventional and organic agriculture with seed supplies contaminated, cross-pollination and crops ordered to be destroyed.
• How would GM crops interact with future developments in UK agriculture and the rural economy?
UK agriculture will eventually be wholly dependent on seed and chemical suppliers from overseas.
Effectively their chemical company paymasters will enslave our farmers.
• How will the implications of UK decisions be affected by decisions on commercial growing of GM crops in other countries? It is likely that the UK could find itself at a great advantage with a ready and willing market for high quality GM free produce and if we can find a way of persuading the rest of Europe to adopt a similar policy that GM free status would be enhanced and better protected. Going for commercial GM crop production on the other hand will destroy the once great British Agricultural system forever.

“The several years of experience in commercial growing of GM crops around the world” may “ provide useful evidence that can be used in the SU study” but extreme caution should be used when trying to compare the use of GM crops in other parts of the world with their use in UK conditions. Land use, field areas, environmental and climatic conditions are not, and cannot be assumed to be, similar.

The “Categories of costs and benefits” should include the full costs of covering for any potential health and environmental liabilities which may be found to occur in years to come and the loss of exports to countries which will require GM free food. It should also include the added cost of GM free organic products which will doubtless be imported in greater quantities to supply the demand for those who wish to exercise their human rights to avoid such contaminated and potentially harmful foods. It would be quite wrong to start “including the costs and benefits of conventional products (e.g. animal meat) that rely significantly on GM materials in their production (e.g. GM soya in animal feed)” because that was a non-GM sourced input before the food supply was contaminated unlawfully by unwanted GM feeds.

“Environmental costs and benefits, including impacts on biodiversity, soil pollution, water pollution and energy use.” Should also take into account the reported adverse effects caused by the horizontal movement of the herbicides used and their contamination of the soils with the resulting loss of fertility.
If the study is to include “any relating to the UK’s overall reputation as a centre for excellence in scientific research”, then it must also include the losses of revenue for the UK as a centre of excellence for conventional breeding programmes and honest scientific research – a reputation currently at dire risk.
“The natural habitats and biodiversity found across the UK; and the levels and types of tourism” are all likely to reduce in the UK if GM crops are introduced. It should not be forgotten that organic food production over thousands of years created the diversity of nature in these islands. Only since chemical agriculture took over from organic farming as the “conventional” approach has that diversity been slowly but surely destroyed. This, coupled with increasing population density in our already overcrowded islands, has seen a steady decline in wild plants, birds and beneficial insects as the fields and built-up areas spread ever larger across the countryside. It is in the nature of the type of farmer who wishes to use GM crops to further this approach, inevitably resulting in greater erosion of precious soils and reduction in habitat for the endangered species of plants and animals. The contamination by GM crops and pollen will further result in reduced availability of pure varieties of traditional seeds in agriculture and horticulture to the point where the plans for total control by the multinationals is complete.
It is inevitable unless the government takes a firm stand now.

The Food Standards Agency and the Health & Safety Executive have already demonstrated bias towards GM crops and it is clear that the HSE failed to enforce the basic rules intended to control the conduct of the GM trial sites with separation distances breached and seed quality standards ignored.
How is the public to rely on organizations that refuse to recognise the science that demonstrates the potential environmental and human harm caused by the very chemicals upon which GM crops depend?
How will the trial sites ever indicate the environmental impact of widespread commercialization of these crops. Wild life can enter the trials from non-GM areas at the current time. This will not be possible if these crops are widely grown.

It is officially recognised that “No agrochemical company today has its headquarters in the UK” and as a result the government’s promotion of this cropping regime is aiding our commercial competitors to the detriment of our own country. This cannot be the right approach. Perhaps it would be more beneficial for UK scientists to accurately study ways of improving organic production methods that could be used in the developing world to assist their local production of food. Again these countries were self sufficient until we destroyed their traditional methods and began to import their food crops.
Such research will put us in an even stronger position in years to come as, independent of the multinationals, we would then have the technical information to help rebuild the world’s agricultural systems when GM production inevitably fails to deliver the promised benefits.

In Summary. The promotion of GM crops is environmental vandalism and, with the potential to contaminate growing crops across the country, and across borders, and to induce resistance in problem weeds and insect pests, I am surprised that the Government is not taking action against the companies in order to protect the environment. This would help to assure us that the consultation really is an open and transparent process. A truly open public debate is unlikely because the public, and ministers, are not being given the full picture. Any evidence against the use of glyphosate, for example, is suppressed - and has been for years. If we cannot be honest about the risks of a chemical how can we believe that there will be honesty over such a dangerous process as interfering with the process of life itself?
The moral, religious and ethical issues are also being suppressed. Will vegetarians want to eat the genes taken from animals and insects? Is it right to insert human genetic material into our food?
The dangers are obvious.
No GM seed should be allowed until we have certainty over the risks and trust in the companies who are so determined to force their seeds on the world. I suggest that will be never, given their current record.

Yours sincerely,

Dated 20/10/2002    Updated 20/02/2016

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