Submission to the Prime Minister's Strategy Unit's GM Crops Team

20th February 2003

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

Dear Sir/ Madam,

In its determination to rely solely on the scientific issues surrounding the genetically modified crop controversy the Strategy Unit is in danger of overlooking the moral and ethical issues involved.
A large majority of the population, both here and abroad, have no great wish to consume food from crops which have been contaminated with DNA from animals, insects, fish or even humans.
Scientists seem to have developed the attitude that just because something is possible and then they must do it but it is clear that the harm done by some processes is both irreversible and potentially dangerous. On the matter of GM crops scientists appear to have adopted a similar attitude to those who process condemned meat and then sell that meat on to consumers as if it was a clean and quality product.
It seems to be a case of what the consumer doesn't know won't worry them.
In reality this is a massive experiments with human and animal life and the environment as its subjects.
According to the Nuremberg Code it is necessary for human subjects of experimentation to give their informed consent and to be able to opt out of any experiments at any time.
Clearly in this unprecedented experiment on all humans on the planet none of us have been given the right of opt out and none of us were given the information necessary for informed consent before being forced to take part in experimental work which has involved the entire food chain.
Ethically therefore the entire GM programme is in breach of the Nuremberg code.

Tragically it would seem from recent reports around the world that already it may be too late and that this experiment has now contaminated the entire food chain. It was reported that it is now almost impossible to obtain soya products which are not contaminated to some degree by genetically modified DNA.
Environmentalists warned that this would happen before the first GM crops were ever grown commercially but they were both ignored and condemned for using scare mongering tactics.
In recent years those same environmentalists have been warning of even greater dangers from these crops and despite having been proved correct with their initial concerns they are still accused of scare mongering.
The government has a duty to protect its people. In allowing the import and the open air trials of GM crops and their produce both our health and our environment has been put at serious risk.
It is possible that any dangerous effects resulting from this failure may not be seen for decades.
It is quite wrong for a government spokesman to accuse those who are against this experiment as being "Luddites" for the Luddites were simply trying to protect their jobs. The environmentalists who have protested against GM crops are attempting to protect nature herself from the ignorance and arrogance of scientists who have little true understanding of the consequences of their meddling.

I will attempt to explain the reasons for my comments with reference to the various documents released.

In the Overview methodology paper the following points are raised.

The issue of trust in our political representatives is one which is worsening as the result of perceived influence over political decisions by those powerful multinational companies who will benefit enormously if genetically modified crop technology is embraced around the world.
I recall in the early days of the BSE crisis that politicians were suspected as being the representatives of the farming industry rather than their own electorate. In the GM debate it seems that the interests of the electorate have taken second place to the drive for profit and influence from the multinationals.
Trust can only be claimed when there is openness and with genetically modified crops there is far too much secrecy. We only have to look at the controversy surrounding the organophosphorus herbicides upon which did genetically modified crop industry depends to understand why there is lack of trust.

There are serious worries over the accuracy of safety data for these chemicals and yet those whose task it is to ensure the safety of the public seemed to be ignoring the increasing scientific evidence showing true danger from the use of these chemicals.
The issue of trust in government spokesman in respect to chemical safety is one which is again coming to the fore as a result of the current crisis in Iraq.
Trust in politicians is not high.
With the controversy over cloning and the adverse effects of genetically engineered medical treatments it would seem that the trust in scientists is not high either.

The paper asks
A. Do you agree with the boundaries that have been put on SU’s analysis, given the overall remit for the study as a whole? Do the boundaries provide sufficient clarity on what will and will not be in scope?

I do not believe it is possible to include all the considerations required for true cost benefit and risk assessment because so much is unknown. This is evidenced by the refusal of the insurers to cover the companies who are pushing forward this technology in respect to any potential harm, either to the environment or to animal and human health. Any analysis is therefore flawed before it begins.

B. Do you agree that the SU has successfully captured the key challenges that need to be addressed in its methodology? If not, what other challenges do you think need to be taken into account?

Obviously some of the key challenges are not “captured” because the effects on all related aspects, from organic production, through resistance issues, to potential for harm, cannot be predicted with certainty.

C. Do you agree with SU’s overall methodological approach? Do you think it successfully deals with the challenges identified for the study?

How is it possible to agree with an approach which ignores, or is unable to evaluate, major risk factors such as harmful effects of the chemicals used, the potential for DNA transfer and the harm to future generations, and the control over food production by a handful of multi-national companies?

D. Do you find the proposed scenarios helpful in considering the different ways in which GM crops may or may not be used in the UK in the future? If not, how could they be improved?

So much of the “future use” of GM crops is pure conjecture. If resistance is encountered to either the chemicals used or to the insecticides produced by the crops then all the GM programme will fail and the high price paid by conventional and organic agriculture will not be recoverable. Since gene transfer is already proving problematical even the future of non-food GM crops must be in doubt. This will be especially the case with pharmaceutical GM crop varieties.

E. Do you think that the SU has captured the full range of factors that will impact significantly on the costs and benefits associated with each scenario? If not, what other factors ought to be included?

I see little mention of the potential cost impacts of any adverse health effects which may show themselves in the future or which may result from increased use of the organophosphorus herbicides used.
Nor is the cost of removing such herbicide residues from the water supply or the development of new herbicides and insecticides, which will be needed to combat any induced resistance.
Already it is clear that the manufacturers and the regulators are denying known chemical risks in order to allow the continued use of many dangerous chemicals. Those used on GM crops are an example.
Clearing the contamination already seen would be an incredibly difficult and impossibly expensive task.
As I have suggested before. If we cannot trust the scientists to fully understand and to properly inform us about the dangers of chemicals in our environment, food and water then how much greater will be the mistrust in respect to tampering with life itself in ways not possible in nature?
I suggest that the track record of these companies demands that we do not trust what they tell us.
For example, we are told that GM crops are “substantially equivalent” to conventional varieties but this cannot be true since they are man-made organisms with strategic DNA changes which allow science to determine contamination of conventional varieties with GM sources at very low levels. They are by no means “equivalent” or that task would be impossible. I suggest that if introducing these varieties produces irreversible harm then the cost of that introduction is too great. I would further suggest that it is already too late since environmental contamination has already taken place and the field scale trials will have added to an ever-increasing contamination problem.

F. Do you agree with the proposed approach to sensitivity analysis? How can the SU most effectively capture the potential range of outcomes for each influencing factor?

Again I cannot see how the Strategy Unit can make any real analysis of the situation now or in the future unless it has a full and accurate understanding of all the influencing factors. Given the uncertainties found in the science regarding the chemicals, the DNA transfer process itself, the contamination risks, the cross fertilisation risks, and the unknown potential for an adverse health effects in decades to come, I can see no way that any accurate predictive analysis is possible.
Even if there are anticipated benefits to be gained from new developments in GM crops in the future, there is no way that science can ever know if there will be an expected and adverse effects from such developments. What is clear is that the promises by those promoting GM crops have already been broken. We already have serious problems, as was predicted by those who opposed the introduction of the technology.

G. Do you agree with the proposed approach to the precautionary principle?
What sources of data and other information can the SU use in seeking to compare the costs associated with the precautionary principle in different scenarios?

It seems to me that many of the points raised in respect to the costs of enforcing the precautionary principle involved costs which should be borne by those wishing to develop the technology.
Even in conventional farming it seems to me that the government has taken on responsibility for ensuring that the chemicals manufactured by those same companies are not used to the detriment of the health of the population. On the principle that the polluter pays it seems to me that the chemical companies themselves should be responsible for paying for the costs of monitoring the use of their chemicals.

It is interesting to see that the document states " A key element of the precautionary principle is activity to prevent potentially harmful impacts from taking place (possibly in conjunction with activity to promote potentially beneficial impacts)."
One of the disturbing aspects about this debate is that we are told that GM crops will reduce the use of pesticides. This is unlikely to be true. Most GM crops are designed to withstand repeated applications of the organophosphorus herbicides.
Others are designed to continuously release insecticidal chemicals.
It is clear that already there are issues of weed and insect resistance and in the long-term this will require the use of new and possibly more powerful pesticides.
I suggest that this is yet another "potentially harmful impact" which has already occurred.
While it is argued by some that enacting the precautionary principle would bring stagnation it is becoming increasingly clear that failing to enact such a principle endangers us all. The repercussions for every life form on this planet, should things go wrong, could be enormous and with some proposed advances there will be no escape and no way back. Unseen dangers are unforeseeable.

H. Do you think that the SU is now taking into account all of the categories of costs and benefits that can be usefully considered, given the remit ofthe study? If not, what additional areas should be included? And what sources of information should be used?

I wonder how it is possible to take account of the costs of clear up when it is clear that it is not possible to eliminate the contamination that has already occurred around the globe.
How is it possible to quantify the costs of harm to human health and the medical treatments, which may need to be endured by the sufferer for many years. The costs to society could be enormous and I would suggest that no one can predict the long-term outcome from the introduction of these genetic changes.

The paper suggests " “GM technologies have the potential to provide significant benefits for poor farmers if applied safely and responsibly to the crops they rely on.”
“Developing countries need to be able to make their own informed choices about whether to adopt GM technologies or not and build the capacity to manage their safe development and use.”

There seems to be a contradiction in terms here.
GM technology appears to be removing the choice for farmers in developing countries who have for centuries grown crops suitable for their own soil and climatic conditions.
Current GM technology cannot complement traditional agriculture. It is designed to replace traditional agriculture and, because of contamination and DNA transfer, it has already happened.
As a result the farmers in developing countries no longer have a choice. As in the developed world any choices they did have are now being made for them because of the controlling influence of the multinationals and their political allies.
As farmers around the world are forced to rely on ever fewer varieties of crop, most of which will either be genetically modified, or will be contaminated with genetically modified DNA. This in turn will render the entire world food supply unstable and susceptible to both disease and seed supply difficulties.
How can such costs be included in any analysis?

I. Do you think that it is sensible to report on different groups’ prioritisation of different types of costs and benefits?

It seems to me that it is vital in a public debate that those involved should be able to see which groups are promoting which aspects of the debate. In this way the public will be able to better judge the reasons behind the ideas that are raised. One thing seems to me to be certain and that is the GM technology was devised for and by the industry which will most profit from it. This was not an invention born out of need in order to benefit the population. It is possible with the advancement of science that sometime in the future, when the science fully understands the implications of tampering with the vital templates for life itself, there may be a way that genetic modification can be safely found to benefit mankind. However, the current situation seems to be that science does not understand as much as it claims to understand and that as a result we risk serious cross contamination problems and the formation of unintentional hybrids which will in turn create additional risks of their own.
The strategy unit must therefore, in my view, state clearly the source of all the arguments used in favour of this technology since it has already changed the world to the detriment of our environment.

In the paper on the costs and benefits for the environment and human health much of the discussion surrounds the potential impact of food derived from the GM crops themselves.
The paper states that " The Government’s recently published strategy identifies eight key principles for sustainable farming and food 6 .
Two of these state that British agriculture should:
-Respect and operate within the biological limits of natural resources (especially soil, water and biodiversity).
- Achieve consistently high standards of environmental performance by reducing energy consumption, by minimising resource inputs, and use renewable energy where possible.

I would suggest in the former that biodiversity is threatened by GM crops since we have already seen contamination in cultivated and wild plants. New varieties may increase this in the future. In the latter is clear that there are no real indicators that the GM crops can minimise resource inputs in the long-term. In the UK soil conditions at sowing time and at harvest often lead to deep compaction which reduces the option for farmers to use the minimum tillage techniques, which are suggested as resource savers and as an advantage for GM cropping. Farmers growing conventional crops have discovered this problem in the past but they have also found that such techniques invariably result in difficulties with problem weeds despite regular herbicide use.
Minimum tillage is unlikely to succeed in the long term.

Again, the comment "This study’s assessment of the costs and benefits of environmental impacts of GM crops will recognise that the scientific evidence is complex, can be provisional in its findings, and is in some cases subject to contradictory interpretations." demonstrates that the science relied on in any analysis for GM crops and their safety is at best uncertain and as a result entirely unpredictable.
Effectively the multinationals have blindfolded the public and are asking them to take a leap forward in faith towards a promised paradise.
Unfortunately there is no way that the multinationals or the public can know if that leap brings with it a disaster from which there is no return.
Serious doubts are being expressed over the way in which current varieties of GM crops have been approved. Even more serious doubts are being expressed over the safety of the data relied upon the chemicals which a use in a growing of GM crops. There has already been proven, and unexpected contamination, both physical contamination of seeds and foods, and cross pollination.
Surely what we have seen already is warning enough?

In summary.

I believe that the government has already made up its mind on this issue and is now simply trying to persuade us all to agree.
Were this not the case the authorities would not be suppressing adverse information such as that on the dangers of the chemicals used, the growing problem of resistance in weeds and insects, and the increasing problems of contamination.
I suggest that far from being the answer to our dreams GM technology has brought us into dangerous conflict with nature in a battle that we can never win because nature changes so easily.
There is little doubt in my mind that a handful of very powerful companies saw a way to massive profit and total control over the world food supply, making every country dependent upon their seeds and their chemicals, with the farming community trapped in permanent contractual dependency.
I also believe that powerful marketing ploys and influential individuals have deceived the government into believing that it is necessary to grow GM crops in order to keep abreast of the technology.
In my view that is nonsense. We must first obtain a full understanding of all the processes in life before we start tinkering with vital life forces that we do not fully comprehend.
As we have seen with the drug, pesticide and chemical industry, what we believe to be “safe” more often than not turns out to have hidden dangers and far reaching consequences.

I urge the Strategy Unit to resist the temptation to take the easy route in succumbing to the pressure from those multinational forces. Ban their crops but continue studying in the laboratory so that we have better understanding of the advantages of centuries old techniques. We can on these islands work to establish centres of excellence and commit to producing high quality foods for home consumption, even replacing increasing organic imports with home grown produce, and supplying world markets once again.
Until there is a realisation that it is not ecologically safe to continually draw in foods from around the world whilst at the same time running down our own production I fear we will all be in difficulty.
Embracing GM crops will only hasten our dependence on others for the basic necessities of life.

I hope that my observations are of interest. I am sure that others will provide the supporting science.

Yours sincerely,

Dated 20/02/2003    Updated 20/02/2016

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