The Royal Society of Edinburgh (RSE) is pleased to respond to the Scottish Executive Rural Affairs Department consultation on the revised European Commission proposals on the Adventitious Presence of Genetically Modified (GM) Seeds in Seed of Conventional Varieties. 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 in crop science and agriculture.

The changes made by the Commission are minor, except for the proposals for Isolation Distances and therefore most of the points made in the RSE’s response to the first working document remain valid. Nevertheless, some additional comment on specific issues identified in the new consultation paper are addressed below:

Maximum thresholds for the presence of GM material

As noted in our original submission, if a GM product has not been approved by the relevant European Union (EU) Committee, the 0% tolerance is the only approach that will satisfy requirements and the demands of those who have concerns about GM technology. However, it is the adventitious, non-intentional andunavoidable presence of GM seed in conventional seed lots, which is to be regulated. Given the supply chain through elevators and silos, and barges, ships, lorries and holding bins, the likelihood of adventitious presence is sufficiently high that a 0% threshold will not be practicable. There are also problems in developing suitably sensitive methods of measurement.

If, as is noted in the consultation paper, the possibility of establishing thresholds for technically unavoidable or adventitious presence of minute amounts is envisaged, then some distinction may need to be made between Non-GM seed for organic production and Non-GM seed for conventional production. As noted before, the proposed threshold values of 0.3% and 0.5% for authorised GM seed will be very difficult to test against, with the likelihood of picking up contaminants depending upon the methods used to sample, with practical difficulties in particular for crops such as soya, maize and rape. It should be remembered that contamination of any sort is not spread uniformly within a large mass; it tends to ‘pocket’ in small areas which can only be detected when the number of samples is large.

Breaks in crop production
As noted before, the separation period between GM and non-GM plants of similar varieties should be based on scientific understanding and checked against existing information on the cross-contamination experienced in the production of certified seed of different varieties of non-GM crops.

Isolation distances
The opinion of the European Commission Scientific Committee on Plants concerning the adventitious presence of GM seeds in conventional seeds, on 7 March, noted that there was evidence that oilseed rape pollen could be detected at low levels at considerable distances from sources, especially if the sources of pollen were large. It is, however, critical to distinguish between pollen flow (the distance that pollen can travel from its source) and successful pollination of a recipient plant. The National Institute of Agricultural Botany (NIAB) determined that 0.1% contamination of different lines of oil seed rape required no more than a 100-metre separation, following experience of plant breeders maintaining discrete lines of rape at breeding stations. (J Ingram. Report on the separation distances required to ensure cross pollination is below specified limits in non-seed crops of sugar beet, maize and oil seed rape. MAFF Research Report RG0123. MAFF London August 2000).

The EU Committee on Plants did note that, in North America, crops had been pollinated by GM crops growing at several kilometres distance, and that some samples of imported hybrid rape seed contained levels in excess of 0.3% GM presence. There was no information, however, to determine whether that imported seed had been grown several kilometres from a GM crop, or in fact much closer. The possibility of the GM presence resulting from contamination in the supply chain through elevators and silos, and barges, ships, lorries and holding bins could also not be ruled out.

Labelling requirements for seeds of genetically modified plant varieties
Under the section on labelling of GM seeds the proposal is that the harmonised labelling will say 'genetically modified variety' together with the name of the organism (e.g. maize, rapeseed). However, under the proposals on GM labelling and traceability accepted by the European Commission on the 25 July, any GM product entering the feed or food chain must be labelled with a unique EU identification number. Clearly, unless the product registration number of the seed was labelled, it would not be possible to know the product registration number of the crop.

Additional Information
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:

Review of the Framework for Overseeing Developments in Biotechnology (February 1999); The Scientific Advisory System-Genetically Modified Foods Inquiry (March 1999); The OECD Edinburgh Conference on the Scientific and Health Aspects of Genetically Modified Foods (February 2000); The Assessment of Risk to Biodiversity from GM Crop Management (December 2000) and The Adventitious Presence of GM Seeds in Seed of Conventional Varieties (April 2001)
August 2001
Further information is available from the Research Officer, Dr Marc Rands

Further information is available from the Research Officer, Dr Marc Rands