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Government Response to "Crops on Trial"
This document sets out Government's response to the recommendations
of the Agriculture and Environment Biotechnology Commission's report 'Crops
on Trial'. The response is presented on behalf of the UK Government, the
Scottish Executive and the Department of the Environment in Northern Ireland.
Introduction:
- Government set up the Agriculture and Environment Biotechnology Commission
(AEBC) in 2000 to look at social and ethical issues relating to developments
in biotechnology which have implications for agriculture and the environment,
and to provide strategic advice to government on this important policy
area. The AEBC has selected a very significant topic for its first report,
the Farm Scale Evaluations (FSE) of Genetically Modified Herbicide Tolerant
(GMHT) crops. This topic was chosen by the AEBC as a case study of regulatory
decision-making in relation to GM because there has been a high level
of public concern about the trials that have become a focus for wider
concerns about GM crops and foods.
- The Commission includes a range of interests from all sides of the
GM debate and has heard evidence over the past year from the public,
politicians, farming and industry groups, non-governmental organisations
and technical experts. They have produced a detailed analysis of the
context in which the FSEs are being conducted as well as a thorough
consideration of the issues raised by the intense interest in the evaluations,
resulting in a list of recommendations regarding future decision-making.
- The Farm Scale Evaluations are a research programme designed to examine
whether there are any differences in the diversity and abundance of
farmland wildlife associated with the management of GM herbicide tolerant
crops when compared with equivalent non-GM crops. The programme involves
between 240 and 300 fields in total, across Britain, where half the
field is sown with a GM crop and the other half with its conventional
equivalent. Biodiversity indicator species are studied in both halves
of the field while the crops are grown as they would be if planted commercially.
The programme will last until harvest 2002 for spring-sown crops and
harvest 2003 for autumn-sown crops.
- The crops involved are maize, beet (sugar and fodder varieties) and
oilseed rape (spring and autumn sown varieties). The maize being grown
in the FSEs has marketing consent under Part C of the European Directive
governing GMO releases. This consent was issued at EU level and imposes
no restrictions on where or when the crop can be grown. Both the beet
and oilseed rape have pending applications for Part C consent but are
being grown in the FSEs under research consents for the UK under Part
B of the Directive; these impose tight restrictions upon the consent
holder. The restrictions vary for individual Part B consents but all
consent holders have to notify Defra, the Devolved Administrations and
the public of the locations of the trial sites before they are sown.
All the crops being grown in the evaluations have been subject to detailed
risk assessments as part of the requirements for these consents. The
Advisory Committee on Releases to the Environment (ACRE), which is made
up of independent experts and scientists, has considered this information
and concluded that the crops themselves do not pose risks either to
human or animal health and the environment.
- The results of the research undertaken at the sites will be peer reviewed
and made publicly available at the end of the evaluations. The results
will help provide answers to some of the important questions government
and the public have about the impact on our environment of the herbicide
management practices involved in growing GMHT crops. Under an agreement
with the farming and biotechnology industry group SCIMAC there will
be no commercial cultivation of GM crops in the UK until the end of
the FSEs.
- The AEBC have made ten recommendations in their report: two relate
to the operation of the Farm Scale Evaluations themselves, seven deal
with decision-making on the results and any subsequent commercialisation
of the GM crops involved and one deals with the need for a wider public
debate about the role of GM crops in UK agriculture in the future. This
response deals with each recommendation in turn. Recommendations appear
in bold text with government's response set out below.
General response
- We welcome the Commission's detailed analysis of the context in which
the FSE programme is being conducted as well as the thorough consideration
of the broader issues raised by the intense public interest in the evaluations.
The report is a positive contribution to the debate surrounding GM crops.
We agree with the Commission's view that the report can help illuminate
public discussion of the issues surrounding GM crops.
- As a result of the report Government asks the AEBC to provide further
advice by the end of April 2002. The advice should cover how and when
to promote an effective public debate on possible commercialisation
of the FSE crops, and how to make best use of the results of such a
debate. The advice should also cover how to determine the public acceptability
of GM crops, in particular, cross-pollination thresholds and GM presence
in organic crops.
Recommendation 1:
The programme of FSEs should be completed subject to:
- the Government confirming its commitment to no commercial cultivation
of GM crops in the UK at least until the trials are complete and the
results have been evaluated alongside other factors and other evidence
identified below;
- the Government working with SCIMAC and representatives of the organic
farming industry to set adequate separation distances for the remaining
trials to ensure that the interests of all parties are accommodated.
By "adequate" we mean separation distances that allow current
organic standards to continue to be maintained, but recognising that
some flexibility will be required to ensure that the trials can be completed;
- the objectives and limitations of the trials being clearly stated
and communicated to the public;
- effective local consultation taking place on the selection of plots,
which, whilst maintaining the scientific basis of site selection, takes
into account within the SCIMAC agreement other factors beyond the current
regulatory regime, and in particular the interests of local stakeholders.
Government Response:
- We welcome the qualified recommendation that the evaluations be completed.
As the AEBC explain in their report, the evaluations are an important
research programme (the biggest independent study of this type ever)
providing new insight for scientists and government into the environmental
impact of both GM and non-GM agriculture.
- The report records the Commission's concerns about the operation of
the evaluations. Paragraph 30 of the report refers to the perceived
absence of consultation, the short notification and unfortunate location
of some of the chosen sites. These issues are addressed below.
A commitment to no commercialisation until the end of the
FSEs and until the results have been considered alongside other factors
and evidence.
- Government's agreement (dated November 1999) with the farming and
biotechnology industry on the Farm Scale Evaluations states that there
will be no commercial plantings of GM crops in the UK until the end
of the programme in 2002/3. Government remains committed to the undertakings
in this agreement. The policy has been restated by government throughout
the evaluations. For example, the Defra news release of 23 July 2001
announcing the proposed sites for the autumn 2001 round of Farm Scale
Evaluations stated: "There will be no commercial growing of GM
crops until the FSEs are completed and only then if the crops and associated
farming practices are assessed as causing no unacceptable effects on
the environment".
- Government takes the position that the scientific results from the
Farm Scale Evaluations are only one part of the decision-making framework.
In any case the FSEs are a voluntary arrangement and do not form part
of the regulatory process governing the release of GM crops. Before
a GM crop can be grown commercially it will have to satisfy a number
of additional regulatory requirements. These include requirements on
safety for human health and the environment under Directive 90/220 (to
be replaced by 2001/18 by October 2002) as well as those under the variety
listing legislation (to show distinctiveness, uniformity and stability
and value for cultivation and use). GMHT crops will also require approval
for the commercial use of the pesticide with the crop to which it is
specific. Any food products from the GM crops will also have to meet
the requirements laid down in the EU Novel Foods Regulations.
- Ministers have indicated that decision-making on commercialisation
of each of the GMHT crops grown in the FSEs will be as inclusive as
possible. Members of the public will have the chance to make known their
views on commercialisation through a process of public debate. Government
sees the AEBC's fourth recommendation - to have an independent review
of the other research and evidence concerning the crops grown in the
FSEs - as an important input to the process of public debate and decision-making.
Final decisions on commercialisation will be for the UK Government to
take in conjunction with the Devolved Administrations and other Member
States. Decisions must be taken with reference to the science-based
criteria set down in the European legislation, but will be based on
more than an analysis of the FSE results. Although general ethical and
socio-economic implications of the marketing of GMOs may be taken into
account in reviewing the operation of this legislation, the criterion
for taking decisions on individual applications is the avoidance of
adverse effects on human health and the environment.
Adequate separation distances between GM and non-GM production:
- Government is committed to ensuring co-existence between the different
types of farming (GM, organic and conventional) both during the remainder
of the FSE programme and for any eventual commercialisation that might
take place. Separation distances are being kept under review during
the evaluations. It is important that the evaluations themselves should
not result in any unacceptable cross-pollination.
- Organic organisations have pressed for the greatest separation distances.
AEBC notes that no organic farmer has lost their accreditation as a
result of the 184 evaluations sites that have been sown to date. Upon
the recommendation of the AEBC we are working with organic organisations
and SCIMAC to ensure that this situation continues in the final year
of the evaluations.
Objectives and limitations being clearly stated and communicated:
- Ministers are committed to ensuring that the purpose and limitations
of the FSEs are communicated clearly. Government hosted a meeting for
stakeholders to discuss the evaluations in July 1999 prior to first
round of plantings. The Scientific Steering Committee overseeing the
evaluations has produced a paper setting out the science involved and
its limitations. This has been published on the Defra website at www.defra.gov.uk.
In order to improve the communication of these issues the UK Government
has recently revised its leaflet on the FSEs ('Genetically Modified
Crops - take a closer look') and, together with the Scottish Executive,
has made available a new leaflet ('Genetically Modified Organisms -
The Regulatory Process') explaining the processes behind the approval
of a GMO release. These go further than previous texts to explain what
is being studied in the FSEs and why. Copies of the leaflets are distributed
at public meetings and can be obtained free of charge from Defra publications
(Tel: 08459 556000). They are also available on the Defra website. The
Scottish Executive has also prepared up-to-date factual booklets about
GM Crops. The research consortium has published a number of papers describing
the evaluations in scientific journals and half-yearly progress reports
that are available on the website. Further information on the research
methods will also become more widely available as the research consortium
start the process of submitting them to peer reviewed journals for publication,
at the end of the programme.
Effective local consultation on the plots selected, which maintains
the scientific basis of the study but takes into account within the SCIMAC
agreement other factors beyond the regulatory framework and in particular
local stakeholders:
- Government agrees with this recommendation and welcomes the commendation
of current consultation practices in Scotland. Responsibility for the
selection of sites for the evaluations rests with SCIMAC, the independent
research consortium and the Scientific Steering Committee. The Scientific
Steering Committee approves a distribution of sites that is representative
of regional geographical differences and the range of current farming
methods, biodiversity and production intensities across Britain. This
is necessary to ensure that the FSE results will be scientifically valid.
- Government is discussing with interested groups (such as organic accreditation
bodies, and farmers) how their interests might be better considered
when SCIMAC are compiling the preliminary pool of locations from which
the researchers select the proposed sites. Arrangements for the spring
2002 round of the evaluations involve seeking information from the organic
bodies about certified organic growers cultivating compatible crops
and SCIMAC using the information to inform the selection of potential
FSE sites. This process is intended to avoid the most obvious conflicts
between local interests and the evaluations.
- On the specific issue of notification the AEBC states that there should
be no reduction in the government's policy to have four weeks notice.
They urge SCIMAC to strive for six weeks notice. Government has asked
SCIMAC to operate a six-week notification period in spring 2002 to allow
more time for people to make their views known.
- Looking broader than FSE site selection, government is currently constrained
when taking into account the results of consultation on issuing consents,
by Directive 90/220. Under the Directive consents for the release and
marketing of GMOs can only be prevented on valid safety grounds supported
by sound scientific evidence. This remains the basis for decision-making
under the revised Deliberate Release Directive (2001/18). Consultations
with the public prior to the issuing of either Part B or Part C consents
will be mandatory under the revised Directive, although this does not
extend to a requirement for consultations on the planting of crops cleared
for commercial cultivation under Part C of the Directive. Government
has consulted on the implementation of the revised Deliberate Release
Directive. One of the issues on which we have actively sought views
is how consultation about release sites can be improved within the context
of the European regulatory framework.
- Government will continue to meet its obligations under the legislation
and will ensure that no releases are allowed unless they are safe and
pose no unacceptable risks to the environment. Government will continue
to consider any comments from local communities about the safety assessments
that have been made on the crops or the proposed sites in their area,
as is provided for in the legislation.
Recommendation 2:
Take particular care to ensure that Government press releases and
publications are expressed in clear and precise language, so that messages
are not distorted and cannot easily be misinterpreted.
Government Response:
- Government welcomes this recommendation. Government is constantly
seeking to improve its literature on the evaluations. Government is
committed to explaining the results of the FSEs, once they are complete,
in a clear way that will be easily understood by a non-scientific audience.
Recommendation 3:
Start developing policy now on how to use the results of the FSEs
in future decision-making.
Government Response:
- We agree with this recommendation. The Scientific Steering Committee
overseeing the evaluations has considered what statistical tests and
scientific assessments will be needed to present the results in a scientifically
robust way. The Advisory Committee on Releases to the Environment (ACRE)
and the Advisory Committee on Pesticides (ACP), will advise Ministers
on the significance of the FSE results in scientific terms and the degree
to which the FSE findings will be applicable to any future risk assessments
associated with applications to grow GMHT crops and the use of herbicides.
ACRE and ACP will give their advice in the light of the best scientific
evidence available at the time. The advice from ACRE and ACP will be
made public, as will the raw data produced from the FSEs and the scientific
analysis of that data. The wider scientific community and others will
have an opportunity to comment on the FSE results and the advisory committees'
advice as part of the overall process of public debate on possible commercialisation
of the FSE crops. UK Ministers are committed to using all available
research and advice in making future decisions regarding commercialisation
of GM crops.
- In paragraph 47 of the report there is the proposal that the AEBC
hold a series of discussions with stakeholders, in conjunction with
ACRE. ACRE has expressed a willingness to help in the decision-making
process wherever it can within the Committee's strict science-based
terms of reference. The Chairman of AEBC and the Chairman of ACRE have
met to discuss how best the two advisory bodies can work together synergistically
to provide Ministers with a balanced view of the many complex science
and societal issues associated with the possible commercialisation of
GM crops. The Government supports and encourages this helpful dialogue.
Recommendation 4:
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;
- information collated by ACRE on any direct and indirect effects
of these crops compared to conventional varieties;
- information from other studies such as BRIGHT and the Brooms Barn
trials which have investigated a range of management regimes under which
these crops could operate;
- any relevant information from other countries in which these crops
are grown commercially.
Government Response:
- This recommendation contributes to the thinking about how the process
of an informed debate on the FSE results might work. We believe that
it will be very important to set the results of the FSEs, and the decision-making
process, in the proper scientific and social context. Much of the evidence
considered by the advisory committees named, and their advice to Ministers,
is already publicly available and hence open to independent review.
ACRE and ACP are responsible for reviewing independently the information
with which they are provided about the GM crops and the herbicide. They
are already working together on this. There is therefore no need for
further independent review of this information. However, the review
proposed of the information from other relevant studies and countries
could provide a useful component of the background against which to
consider the possible commercialisation of the GM crops grown in the
FSEs.
- Government will consider what further information is needed before
decisions are taken. Government will also fund independent researchers
to review other studies relating to the crops grown in the FSEs and
any relevant information from other countries where the crops are grown
commercially. Any review of information from other countries will have
to consider carefully the type and representativeness of the information
obtained and clearly set out how it relates to UK ecosystems and conditions.
The researchers will be asked to present their review to government
by spring 2003, before the end of the FSEs. ACRE and ACP will review
the researchers' findings and make recommendations to government as
appropriate.
Recommendation 5:
Ensure that the level of publicly funded research is such as to secure
an objective independent assessment of the potential impacts of both current
practices and new technologies on agriculture and the wider environment.
Government Response:
- Government agrees with this recommendation and has been trying to
achieve it prior to the AEBC's recommendation. To obtain a full picture,
it is important that Government draws on a broad range of the best relevant
expert sources. These may not all of course be publicly funded, but
government recognises the importance of ensuring that research is sufficiently
wide-ranging to address all relevant issues and subject to sufficiently
questioning review and assessment. The review of studies that we will
commission as a result of recommendation 4 above will serve this purpose
with respect to the crops being grown in the FSEs.
- Government, through its departments and research councils, funds research
into the effects of agricultural practices on the environment. The FSEs
are just one example of this. The Biotechnology and Biological Sciences
Research Council and the Natural Environment Research Council have substantial
separate programmes in this area and also have a joint 'Gene Flow in
Plants and Micro-organisms Initiative' with a budget of £5.7 million
available in grants for research in this area. Defra, the former Ministry
of Agriculture, Fisheries and Food and the Scottish Executive has funded
research into the risks to the agricultural environment from GM crops
since 1991.
Recommendation 6:
Commit to an open and inclusive process of decision-making around
whether the GM crops being grown in the FSEs should be commercialised,
within a framework, which extends to broader questions.
Government Response:
- Ministers will have to decide, within the framework of European legislation,
whether the crops grown in the FSEs should be commercialised. Government
is committed to taking public opinion into account as far as possible
through an open decision-making process. There will be a public debate
on the possible commercial growing of GM crops. The debate will cover
the FSE results and the wider review of the other information gathered
to complement the FSEs outlined under the AEBC's recommendation 4. Members
of the public will continue to be able to make their views known on
proposed variety listing, on the National Seeds List or EU Common Catalogue,
of the crops involved.
- Government asks the AEBC to advise, by the end of April 2002,
on how and when to promote an effective public debate on possible commercialisation
of the FSE crops and how to make the best use of the results of such
a debate. The advice should also cover how to determine the public acceptability
of GM crops, in particular cross-pollination thresholds and GM presence
in organic crops.
- The AEBC are asked to be imaginative in the options they consider
but to bear in mind that their recommendations must be practical and
cost effective. The debate should involve interest groups but also reach
beyond them to the wider public. The methods advocated by the Royal
Commission on Environmental Pollution in its 1998 report on environmental
standards and in the March 2001 report of the Parliamentary Office of
Science and Technology (Open channels: public dialogue in science and
technology) should be considered. The AEBC will not necessarily be asked
to carry out all aspects of its recommendations - Defra, the Devolved
Administrations and Government Offices might each participate in different
areas of the dialogue with the public. AEBC should advise on which are
the most appropriate organisations to carry out the different parts
of the process.
- The separation distances for the FSEs have been set to ensure that
cross-pollination is a maximum of 1%. However, as the AEBC notes in
paragraph 65 of the report, there is a case for separation distances
to be greater so as to ensure a maximum of, for example, 0.1% cross-pollination.
- In paragraph 61 of the report, it is stated that better mechanisms
are needed to prevent the upward drift of GM presence in conventional
seeds and produce. Such mechanisms are being developed. Given the amount
of GM crops grown worldwide it would be very difficult to guarantee
that any product or seed is completely GM-free. The presence of GM material
should be kept as low as possible and thresholds should continue to
reflect the capability of detection methods and the ability of the supply
chain to deliver. The European Commission has tabled proposals to amend
the Seeds Marketing Directives in order to establish statutory thresholds
for adventitious presence of GMs in conventional seeds. These would
create a purity standard for conventional seed that would make it illegal
to market seed containing levels of GMs that breached the relevant threshold.
Further, we believe that the threshold would also apply to GM seed which
contained an adventitious presence of an additional modification. These
proposals have been the subject of public consultation and are currently
under discussion in Brussels. With regard to produce European legislation
already requires products containing GM ingredients to be labelled as
such. However, Regulation 49/2000/EC contains a threshold, below which
labelling is not required, for foods obtained from non-GM sources in
which the adventitious presence of GM material is less than 1%. The
recently proposed EC regulation on GM food and feed also contains such
a threshold and a provision to keep the level under review.
- Applications for EU-wide approval for general cultivation are still
under consideration for two of the crops involved in the FSEs (the oilseed
rape and beet). Any eventual decision on commercialisation will be taken
using the criteria in Directive 2001/18, which requires more by way
of consultation with the public on applications for approval. However
the decision-making process will continue to be evidence based. Government
has sought views from the public on how consultation arrangements under
the new Directive might work. The procedures in the Directive dictate
that, in cases where the competent authority in one or more Member States
raises and maintains an objection to another Member State's favourable
assessment of an application for a marketing consent, decisions will
be taken in conjunction with other European Member States and through
a qualified majority voting procedure.
- The GM maize involved in the FSEs already has Part C (marketing) approval
under the Deliberate Release Directive. The FSE results will provide
important information to inform any eventual decision by Ministers on
whether to take action under the safeguard clause in the Directive to
restrict or prohibit the use of this crop in the UK. The decision would
be one for Ministers and the Devolved Administrations to take jointly,
with the advice of ACRE and in the light of the informed debate on the
FSE results. If action were to be taken, it would have to be notified
to the European Commission and other Member States, who would confirm
or reject the restriction or prohibition measure by qualified majority
vote. An action of this nature has already been taken by the National
Assembly for Wales under the safeguard clause, to introduce legally
enforceable separation distances. This action has been notified to the
European Commission and a proposal from the Commission on the action
is awaited.
Recommendation 7:
Give early attention to the framework for post-commercialisation monitoring.
Without prejudging the issue of whether GM crops will be approved
for commercialisation in the UK, the Government should be prepared to
publish and consult widely on its proposals for the post-commercialisation
monitoring which would be needed, and for the action to be taken if adverse
effects were discovered.
Government Response:
- Government has already made provisions for post-commercialisation
monitoring. Post-commercialisation (sometimes called post-market) monitoring
is an important addition to the regulatory framework, introduced formally
by the new Directive on Deliberate Releases (2001/18). ACRE has a sub-group
working on the detailed requirements for post-market monitoring arrangements
under the new Directive. Once their proposals are agreed, government
will consult on them as part of the implementation process for the new
Directive. Any adverse effects detected by monitoring could be tackled
by use of the safeguard provisions in the Deliberate Release Directive,
which allows Member States to take action to restrict or prohibit cultivation
of GM crops where new evidence of risk to the environment comes to light.
Recommendation 8:
Improve understanding of the basis of public views by drawing on the
work of social scientists in this field.
Government Response:
- We acknowledge the need for improved understanding of public views.
This is an objective for which all involved in the GM crops debate should
strive. It would be helpful if the AEBC would consider this issue further
and take this work forward as part of the advice requested in paragraph
30 of this document, under recommendation 6, as to the best methods
of promoting an effective public debate on possible commercialisation.
Recommendation 9:
Improve methods of dealing with risk and uncertainty in relation to
the use of biotechnology in agriculture:
- by ensuring that all the relevant regulatory processes incorporate
the principles developed by Phillips and by May, and that the regulators
are publicly explicit about where areas of uncertainty occur in their
deliberations and how they have tried to take them into account; and
- by developing and disseminating examples of best practice
Government Response:
- We welcome the Commission's recommendation. Government is committed
to greater transparency and openness and providing clear information
about levels of uncertainty. Government wants to have approaches in
place for effective dialogue, which will allow for the views of the
public to feed into policy development and ensure that scientific information
is presented in an accessible way.
- Government will assess, manage and co-ordinate risk as part of its
policy-making process, and is committed to better promotion, co-ordination
and implementation of risk best practice. In July 2000 the UK Government
published Guidelines 2000, a revised and strengthened version
of the 1997 guidance from the former Chief Scientific Adviser, Lord
May, on the use of scientific advice in policy making. Departments assess
how well Guidelines 2000 have been assimilated into their departmental
practice, how successful they have been in raising awareness of the
principles; and the adequacy of the arrangements for monitoring how
well policy makers apply them. The Chief Scientific Adviser reports
to Ministers on the implementation of Guidelines 2000 across
departments. These reports will be published shortly.
- Government also welcomes the Commission's recognition that ACRE is
operating in accordance with the principles recommended by Lord Phillips.
However we recognise that there are no grounds for complacency and in
order to strengthen good practice by scientific advisory committees,
government will shortly publish a new Code of Practice for Scientific
Advisory Committees that all such committees will be expected to follow.
- We believe that an open and consultative approach can lead to better
decisions as well as help to build public confidence in the regulatory
system. We will be working actively to ensure that progress is maintained
to take forward this approach.
Recommendation 10:
Include specific consideration of the future of GM crops in the discussions
about the future of agriculture in the UK.
The various strategic reviews of farming and food being undertaken
by the UK administrations should explicitly address how to promote the
co-existence of different forms of farming in the UK. There should then
be a wider public debate involving a series of regional discussion meetings
to consider what role GM crops might have in UK agriculture in the future.
The AEBC is willing to contribute to this process.
Government Response:
- We welcome the recommendation that there be a wider public debate
on co-existence between the different farming types. Government acknowledges
the suggestions made in paragraph 69 of the report about the form of
such a debate and is pleased to note the AEBC's interest in advising
on the development of this process. Government is taking up this offer
in asking the AEBC to advise further on how a broad public debate might
be achieved and how the outcome of such a debate should be used (paragraph
30, under recommendation 6 refers).
- The report refers, in paragraphs 57 and 58, to the independent Policy
Commission on the Future of Farming and Food that is to report to the
Prime Minister and the Secretary of State for Environment, Food and
Rural Affairs by 31 January 2002. The Policy Commission's terms of reference
are wide-ranging and relate to England only; however similar exercises
are being carried out by the Devolved Administrations. We will take
into account the AEBC's recommendations in considering our response
to the Policy Commission's report.
- Defra has been discussing with the various interested parties what
measures might be necessary to allow for practical co-existence of GM
and non-GM crops. One of the key issues underpinning this process is
whether there is public acceptability of the presence of GM material
in non-GM produce and if so at what level that might be. Further debate
is needed on this issue. Agreement upon this issue could provide a way
towards practical measures to preserve consumer choice within the context
of commercial GM cultivation, were that to occur. It is against this
background that Government has asked (in paragraph 30, under recommendation
6) the AEBC to consider further the issue of public acceptability.
January 2002
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