- The Royal Society of Edinburgh is pleased to respond to the Select Committee’s request for comments on Genetically Modified (GM) Foods in connection with its Inquiry into the Scientific Advisory System. 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 with the assistance of a number of Fellows with many years experience in biotechnology or working in scientific advisory roles.
- The issues surrounding GM foods include: the development of foods, environmental containment, medical effects on human health, the monitoring and tracing of products (e.g. by public analysts), as well as the effects of genetic modification on plant- and animal- precursors of ‘food’, on agricultural systems, and on animal health through feedstuffs. It will, therefore, be important not to compartmentalise the subject, as such compartmentalisation may lie at the rootof some of the currently perceived problems regarding genetic modification in general. Not taking a holistic view may well expose the Government to criticism but, perhaps more importantly, can prevent solutions to real or perceived problems being reached.
- The specific areas of consideration are addressed below:
i) The adequacy and quality of scientific advice at present
- While the thoroughness and quality of the scientific advice available on this issue is good, GM foods come almost entirely into the category where scientific evidence is, as yet, partial and constantly under review. In terms of environmental impacts, it is worth noting that as genetic modifications are the basis for evolutionary change, we are unlikely to know the full extent of any consequences of escapes into the environment until time on an evolutionary time-scale has passed. The scientific evidence is, therefore, likely to remain incomplete for the foreseeable future. When scientific advice identifies areas of doubt or ignorance, it is important that decisions of policy makers reflect this and, in matters of public safety, err reasonably and in proportion on the side of caution. It is worth noting that much of the research on genetic modification of foods is in the hands of commercial organisations or subject to private sector support.
- For the non-scientist, however, the range of acronyms and the complexities of the terminologies employed in biotechnology (as in other scientific, legal, financial, and sociological disciplines) present significant barriers. Given the necessity of retaining public confidence in the knowledge-based industries of the future it is necessary to ensure that the public has ready access to information. However, this must be presented in a fashion that the public can understand, and which is seen to be independent. The intended Food Standards Agency could be in a position to help with this.
ii) The role and framework of advisory committee
- There is currently a wide array of expertise and Committees to advise Government Departments. This advice should, however, avoid being compartmentalised by Department, and merely reactive to requests for licensing of processes, crops or foods, or R&D funding. What is needed is more pro-active activity on advances in biotechnology and genetic modification and their potential implications for people, animals, plants and the environment, in order to inform the Government of the matters on which it ought to seek advice. Further, to a large extent the present public alarm has arisen because of a failure to prepare the public for the new technology. In ensuring the quality and speed of advice to Government, it is equally important to ensure that the advice and available information are communicated to the public. There would be merit, therefore, in the development of public communications plans for those major areas of science that are likely to arise as areas of public concern.
- Existing committees, such as the Advisory Committee on Novel Foods and Processes (ACNFP), or the proposed Advisory Committee on Animal Feedingstuffs (ACAF), must analyse the experimental data supporting the efficacy and safety of specific GM food products on a case-by-case basis. Much of this information would need to be provided by the commercial sponsor of the GM crop or food product, who in view of the current situation in the UK and EU, may be more motivated to have the results of mandatory compositional analyses, allergenicity testing and rodent feeding trials made public in some encoded or anonymous way.
- Committees should include expertise at an international level in the areas being investigated, and they should have proper administrative support to enable them to function quickly. Provision should also be made to second experts to these committees as and when a response is required to a new scientific development outwith the expertise of the standing committee members.
iii) The ability of the current system to respond to rapid scientific developments
- There would be merit in a complete and co-ordinated register of all those with relevant professional knowledge in higher education institutions and in public sector research establishments, able to advise and provide specific detailed responses to issues raised by particular cases being reviewed by Government advisory committees. If existing advisory committees comprise the appropriate experts, and have sufficient back-up and support, then the current system will be able to cope with the rapid pace of scientific development.
- It should be noted that the matters under consideration are, by their very nature, novel with little or no case history to which to turn. It is, therefore, often necessary to proceed with due caution. Rapid responses may not always be possible if risks to the public and the environment are to be properly assessed. In terms of the flexibility of the present framework it should also be recognised that the UK approach has to fit into a European regulatory framework.
iv) To what extent is there value in the proposal for an overarching body to advise on and oversee all genetically modified food issues.
- The complexity and professional quality of the existing UK Advisory Committees are more than adequate to address all the issues presently being aired. Provided the guidelines and boundaries of the existing committees are well-defined, and that adequate cross-communication takes place, we see no value in establishing yet another body to advise on, or to oversee, GM food issues as a specific subset of the issues addressed by the 16 existing biotechnology advisory committees.
- It is important, however, that there should be an overall committee to discuss and co-ordinate the work of all the biotechnology advisory committees. While the Advisory Committee on Releases into the Environment (ACRE), ACAF and the Food Advisory Committee (FAC) have interests in GM foods, and advise on the issues these novel materials present, part of a central committee’s function would be to ensure that aspects of GM foods did not fall between existing committees. Such a committee could also bring together the findings of different committees, initiate a more pro-active approach to identifying the emerging issues and anticipating the questions Government may have to address, and consider the wider ethical, moral, social and economic issues.
- There should also be some interaction between the committee regulatory process and science funding activity. It can be envisaged that developments in agriculture will impinge on others in medicine, and vice versa. Specific research or development might be needed to harmonise the work in these disciplines, and to identify and fill gaps in knowledge and understanding of the issues concerned
- If the UK cannot resolve the safety issues without delaying all potential developments, we are likely to lose out in the biotechnology stakes and, in the longer term, will not be able to resist the pervasiveness of the ultimate products, as genetically modified soya has demonstrated.
v) The capacity of Government to be an ‘intelligent customer’ for the advice it receives
- The Government’s capacity to be an ‘intelligent customer’ in this matter is difficult. In a democratic society it is recognised that political judgements can override other considerations. It is essential, however, to accept that many real questions do not have yes/no answers, either in the present state of knowledge or at all.
- With regard to GM foods, there are difficulties in being an intelligent customer because sound scientific evidence on environmental effects is unlikely to be available for a long time, while financial resources are likely to remain constrained. In addition, long-term politico-economic considerations are difficult within our 5-year election cycle.
In responding to this inquiry the Society would like to draw attention to the following Royal Society of Edinburgh publications which are of relevance to this subject: The Scientific Advisory System (June 1998); Review of the Framework for Overseeing Developments in Biotechnology (February 1999) and The Food Standards Agency: Draft Legislation (March 1999).
Professor P N Wilson CBE FRSE
Royal Society of Edinburgh
22-26 George Street
Edinburgh EH2 2PQ
Further information is available from the Research Officer, Dr Marc Rands