Agriculture and Environment Biotechnology Commission Work Plan
The Royal Society of Edinburgh (RSE) is pleased to respond to the Agriculture and Environment Biotechnology Commission's consultation into its Work Plan. The RSE is Scotland’s premier Learned Society, comprising Fellows elected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. This response has been compiled by the General Secretary with the assistance of a number of Fellows with substantial experience of agriculture and the environment.
As a general comment, the Work Plan is well structured and covers the main areas which one would conclude the Commission might see as priorities. The Commission is therefore to be congratulated on making good progress and quickly setting its agenda. Likewise its approach of having Working Groups is to be commended as a sensible way to approach its work.
The specific questions identified by the consultation paper are addressed below:
General expectations of the Commission
The independence of the Commission is essential if public confidence is to be maintained. It is not clear which part or Department of Government or the Devolved Administrations the Commission will advise, but in the nature of such relationships it is likely that some Government influence will be applied and the Commission must be able to provide proof of its independence. It is clear that the Commission will also need to be proactive in considering which subjects to consider and have a degree of independence in choosing a subject to investigate, and not only investigate those subjects which Government requests it to consider. To this end, it might be useful if periodically, perhaps every 2 years or so, the Commission called from as wide a section of society as possible for ideas on potential target studies.
The appropriateness of the issues proposed for study in the draft Work Plan
With regard to the themes agreed or under development the following comments apply:
Decision-making: The Farm-scale Evaluations and Horizontal Gene Transfer (Sub-group A)
This is an area where the Advisory Committee on Releases to the Environment (ACRE) has already undertaken a considerable amount of work, and the Commission should be cautious not to duplicate what already exists. Likewise, at least in Scotland, many of the issues that are raised by the farm-scale trials are already being considered as part of the emphasis on economic, environmental and social integration in the process of Land Reform policy.
However, an area in which the Commission may be able to bring something new to the table relates to the fact that ACRE’s remit relates only to the identification and quantification of risk – there is no balancing element of consideration of benefit. This is a matter that the Commission might usefully address.
This is again an area where the Farm Animal Welfare Council (FAWC) has had some relevant deliberations, and specific issues have been considered by Government working parties, such as the Banner Committee (on new breeding technologies).
If the Commission takes forward its work in this area it is very important that it takes evidence from those directly involved in the science and its practical application (it is a particularly specialised field). Also the Commission should guard against the danger of concluding that every development that is technically possible will in fact be developed in practice. The industrial sector is now very wary of investing in developing technologies that might not have public approval.
This seems interesting, although it could overlap significantly with the Government's Foresight initiative. For example, the recent Foresight Food Chain and Crops for Industry Panel has a good deal of relevant information.
Consumer Choice and Public Attitudes
As the document notes, this is a core area of work for the Food Standards Agency (FSA), which has already developed a strategy of consumer studies. Surveys are being planned on an annual basis as part of the FSA’s benchmarking of its programmes and of public attitudes. The Commission would need to take care not to duplicate something that is already comprehensively covered by the FSA.
This is a useful area for the Commission to consider. It is an area of potential impact, which will become increasingly evident as new technologies are developed. The statutory Environmental Agencies may already have some work in hand that the Commission would find helpful.
This is an area that is continuously highlighted by the anti-GM campaign groups, and given that it is a focus of public attention it would be useful for the Commission to deliberate on the issues raised. It will be important for the Commission to have access to high level, specialist legal expertise. There seems to be a growing view amongst international companies that regulatory decisions that are not fully ‘evidence-based’ are open to legal challenge, and possibly to claims for compensation.
Other areas which should be added to the Work Plan
There are a number of other areas which the Commission may wish to investigate:
Genetically modified trees. There have been tremendous advances in relation to genetic modification of some tree species, and the potential effects that these could have, when used in forestry, on the environment. Investigation of the technology for GM food crops started rather late; perhaps an investigation into the technology of GM forestry crops ought to start earlier, and may then be able to deal with potential problems before they 'hit the headlines'.
Immuno-contraception could be investigated, especially if these new technologies are to be used more widely in the environment.
There may also be a case for investigating the effects of endocrine disrupting chemicals, which have resulted in the feminisation of many fish species, for example.
Diffuse source pollution of waterways is generally difficult to control and plan for. It is a major source of water pollution and will increase in relative importance as point source pollution is reduced and brought under control.
It is also important to note that, in addition to conventional plants and animals, the Commission should not ignore micro-organisms and the term 'animal' should include invertebrates.
The working methods appropriate to the different issues
The methods to be used look comprehensive. However, the use of consensus-building organisations, such as The Natural Step, could be very useful in bringing together groups with opposing views. Confrontation is likely to happen on these themes and part of the Commission's work should be to bridge gaps.
Monitoring and evaluation will also be important. In particular, are the methods giving useful results; how is it known whether or not they are effective; how will the results and conclusions be used; who is the end user; is the work of the Commission showing value for money? In addition, who will do the work of the Commission and is there adequate support for its members?
Effective ways of involving not only stakeholders but also people beyond the known 'stakeholder' groups in the work of the Commission, and ways of evaluating the quality of that involvement
As mentioned above, the use of consensus-building organisations, such as The Natural Step, could be used. However, GM crops and food, and genetically modified/created animals are subject of concern where public opinion is subject to strong influence from the media and from pressure groups. The largest and most important stakeholder will therefore be the public. It is essential that public confidence is restored and clear uncomplicated advice is given which will allow members of the public to form a balanced view on which to make decisions. They will be both the potential beneficiaries and the potential victims.
Any other aspect of the Work Plan
As noted above, the Commission's area of responsibility will tend to overlap with those of other agencies. It is important that good relations are maintained with them and that the lines are clearly drawn and agreed. The involvement of the Prime Minister in environmental issues as shown by his speech of 24th October 2000 should open the way to a much more serious analysis of the impact of biotechnology on the environment. Monitoring systems to detect pollutants, particularly before much damage is done, assessment systems to analyse the state of an environment, and increased understanding of the role of micro-organisms in agricultural and contaminated land clean up would all be very useful to develop.
Any examples of horizon scanning exercises, or other work that we should be aware of
In addition to the Foresight Food Chain and Crops for Industry Panel, mentioned above, the Commission might find it useful to look at the material produced by the Department For International Development (DFID) under its ‘Sustainable Livelihoods Initiative’. DFID now has a Unit working in this area and much of its output relates to the challenge of integrating technological, social and environmental development. Liaison with the Environment Agency of England and Wales, the Scottish Environment Protection Agency and Scottish Natural Heritage would also reveal a range of cross-cutting activities which link regulatory, environmental, social trends.
In addition, the Scottish Agricultural College has considerable practical experience in GMO trials and technology. The Commission should contact The Information Officer, SAC, King's Buildings, West Mains Road, Edinburgh EH9 3JG for further information. The Macaulay Land Use Research Institute will also have relevant research of relevance to the Commission.
Advice from stakeholders in the biotechnology industry and academic research sectors on how to overcome problems of commercial confidentiality in obtaining a comprehensive view of likely developments
The DTI Link Scheme in its initial phases brought together consortia of commercial organisations by focussing on generic technologies and issues rather than specific projects. In this way all participants benefited from the outputs.
Comments on effective ways of reaching beyond known 'stakeholder' or interest groups to a broader cross-section of UK citizens
It may be possible to involve the supermarkets in this topic as it is in their interest - and most people visit at least one of these retail outlets regularly. Also communication can be made via the Science Centre Network, the Scottish Science Trust, Young Farmers' Clubs, Women's Institutes and the British Association. Some effort could also be made to involve the press, radio and TV.
Views on how our policy on openness and transparency might develop in future.
Transparency is necessary from the beginning and as noted above, the independence of the Commission is essential if public confidence is to be maintained.
In responding to this inquiry the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject: The Scientific Advisory System (June 1998); Review of the Framework for Overseeing Developments in Biotechnology (February 1999); The Food Standards Agency: Draft Legislation (March 1999); The Scientific Advisory System – Genetically Modified Foods Inquiry (March 1999); Science and Society (June 1999); Review of Guidelines on the Use of Scientific Advice in Policy Making (January 2000) and The OECD Edinburgh Conference on the Scientific and Health Aspects of Genetically Modified Foods (February 2000).