OFA Concerns with the GTGC Strategic Framework for Co-existance
Sam Statham, Organic Federation of Australia
The Strategic Framework consists essentially of a set of principles. Each of these will be addressed.
1. Transparency and consultation
Whilst the GTGC argues "adopting a cooperative approach means clearly communicating production system and supply chain requirements, helping to resolve
debates on industry issues and assisting industry-wide communication", it is clear that the agenda is already set and the purpose of the consultation is to try to
convince organic producers and others in the farming community that they are wrong to continue their opposition to open release of GM crops. The OFA presented
more information and comment than any other committee member and yet very little of the issues have emerged in the final document.
For example, members of the GTGC have not been notified of concerns within the grains sector, even from within organisations that are represented on the
committee. For example:
1. "Rod Gribble from the Australian Grain Harvesters Association, says the prospect of having to clean down machinery from one farm to the next will be a nightmare. He says there's no guarantee that there won't be cross- contamination. "If we're going to do some sort of clean down protocol which I would presume is going to happen, now that's going to mean a major clean down. We go to the equivalent of a border crossing clean down, which can take from one and a half, to two days to clean down. Now if we have to do that between every farm or every crop on that farm who's going to pay.""[8]
2. "The NSW Farmers' Association has entered the debate over the introduction of genetically modified (GM) commercial crops to Australia by calling for a postponement of GM canola until identity preservation issues were resolved. The motion was reportedly passed after lengthy debate that showed that Australian farmers still have great misgivings about introducing GM canola.' Rueters said the motion replaced an even tougher action, which would have put a four-year moratorium on the general release of GM canola. [9]
3. In a recent letter to the Gene Technology Regulator Pulse Australia Limited stated that "In the case of pulses there has been advice in various forms from our markets that the commercial release of any GM broadacre crops MAY RESULT IN SOME OR ALL OF THOSE MARKETS BEING CLOSED ENTIRELY TO AUSTRALIA'S PULSES. Concern has been expressed that notwithstanding that there have been no GM pulse varieties commercially released, the release of other broadacre GE food crops, such as canola, will provide and opportunity for contamination by them, of conventional pulse crops during the harvesting, transport and handling processes." [10](original emphasis)
4. In a recent letter to the Corowa Shire Council, QAF Meat Industries stated that ""any contamination at our feed mill could see our entire Japanese business "put on the line", which currently stands at $30 million per annum and is rapidly growing.. Given we prepare 400,000 tonnes of stockfeed annually, our preference would be a 200km radius exclusion zone from Corowa for such trials, as we source most of our grain in that area..[11]
It would appear that the growing concerns of the grains industry are not being heard by the committee in the communications that issue from the Secretariat. Transparency is compromised by the use of the GTGC email and fax list as a pro-GM news and lobbying tool, continuing to present only one side of the debate about the feasibility of co-existence.
2. Freedom of choice
The Principle of division of the market into 3 separate supply chains of Non-discriminating markets, Non-GM markets, and identity preserved markets is arbitrary, costly and misleading.
This is mainly because consumer resistance to GM crops is growing in both affluent and developing countries. The whole Australian grain supply chain benefits from this resistance whilst it remains GM free. In a market where two products are offered at similar prices, the product with the lowest GM content wins.
For this reason, any attempt to create parallel supply chains based on contamination levels ("adventitious presence") is based on arbitrary thresholds. For example, whilst the Japanese regulators have set a threshold of 5%, the non-GM soy threshold is 1%. However, Japanese buyers are returning again and again to Australian soy producers so that they can satisfy consumer demand for even lower levels.
If adopted by conventional farmers, this Principle is costly because the starting point of market advantage in price sensitive crops such as canola is low production and distribution costs. The division of the bulk supply chain will increase costs and risks, thus narrowing producer options. For example, growers in the US and Canada who wish to access GM-free markets are having to change their crops to those where genetic modification has not been commercialised.
The Australian Competition and Consumer Commission oversees the Trade Practices Act. There are a number of sections that deal with misleading and deceptive conduct. Particular care needs to be taken with negative label claims such as GM free and Non GM. Advice received indicates that for such a label claim to stand up then a producer or processor must have a QM system that works to a Nil detectable residue specification. It is not good enough for a farmer to produce product contaminated with GM canola up to say 0.2% (below the trigger for GM labelling) and then expect to market the product as GM Free or Non GM. Thus the issue of GM contamination is just as large an issue for those farmers who are conventional and wanting to access premium markets for Non GM or GE free.
Lastly, the Principle is misleading because it assumes that there is such a thing as a non-discriminating market in the long run. At present we are at the early stage of the possible new era of GM cropping. However, as GM crops expand then the "non-discriminating" sector of the market can but shrink proportionally forcing commingled crops to be sold at lower prices. It will not be worth segregating the GM crop as its value will be lower, but if it is found in the GM-free supply chain, it will impose further physical and/or market opportunity costs. .
3. The role of standards
In their clear definition of customer requirements, Standards are seen by the GTGC as "in a sense, the basis on which other elements of delivering coexistence can be based. Standards will be established on a case by case basis and will be product specific." They will be supported by contracts and arbitration processes. However, such a Principle removes mainstream, presently non-GM suppliers, of their rights to remain GM free. Australian corn, soy and canola producers do not have standards in place to guarantee GM free status - they enjoy de facto GM free status. However, if they were to suffer losses due to GM releases they would have no recourse except if they have a standards system in place.
To secure contracts and legal recourse, mainstream suppliers will have to pay for a costly product standards system. The high cost of organic food may be largely attributed to its standards system, which is itself a process based and de facto product standard using risk assessment to achieve GMO levels below the level of detection.
4. Reasonable measures
The draft Principle states that "In order to preserve the competitiveness of different supply chains, measures implemented should minimise costs". However, control methods for high magnitude events and non-recallable technologies should not be limited on a simple cost basis. The targets for contamination should be set based on
market realities which include qualitative aspects such as consumer perceptions and public relations in export markets, then measures should be proposed, then costs should be quantified, last, to determine feasibility.
The Principle goes on to say that "scientific studies on pollen flow can provide information on measures required to manage adventitious levels of contamination in non-GM markets." However, measures to meet market requirements should be based on actual experience. This means, for example, that the Canadian experience should be studied in greater depth for its practical value, with farmers experiences valued as highly as "sound science" and reductionist experimentation. Agronomic factors such as selection pressure are equally important in the management of adventitious contamination. In fact very low rates of pollen flow may become very significant if there is a powerful selection factor such as herbicide tolerance.
5. Responsibility to act
This Principle states that "where a market demands 'GM-free', i.e. no detectable adventitious presence of a GM product in a non-GM product, this is likely to require a closed supply chain management system for the production and delivery of that product". However, where a market is currently accessed on the basis of current de facto GM-free status, the onus must be on the owner of the GM product to ensure that it does not affect the costs and opportunities of those who
currently benefit, or who may be able to benefit as GM free products are more sought after and less available worldwide. This applies to all products, and seeds in particular.
It is not reasonable or equitable to require GM-Free producers to form a closed supply chain. It is more reasonable to require GM producers to form a separate supply chain. If there was to be any sense of equity in parallel supply chains then the GM crops must be loaded into containers on farm and the expense borne by the farmer in getting the GM crop to market. It is simply not tolerable to expect all farmers both GM and Non GM to pay for parallel supply chains. And the definition of parallel supply chains if it is to expand beyond loading containers on farm is dedicated and separate infrastructure for grain handling from harvestor to truck, silo and train carriage where there is no throughput of Non GM in the GM infrastructure. And like the cost scenario for loading on farm into containers, the full cost of the separate parallel supply chain must be borne by the GM farmer and buyer.
6. Monitoring and review
This Principle says that "new measures are developed, or existing measures revised, in response to changed market, agronomic, environmental or technological circumstances." This is stating the obvious - but it is in the interests of some sectors of the industry to fail in this task so that rising background levels of contamination will force a rise in thresholds.
It states that "the industry will need to ensure that it constantly monitors, and periodically reviews, measures that are in place in order to ensure that the objectives of the strategy are being met". However, the industry has shown on many occasions that it is not willing or able to monitor trials, GM crop disposal, and non-GM seed purity.
7. Case-by-case planning
The principle that " specific strategies for managing the introduction of different GM crops will need to be developed on a case-by-case basis". Hover, on a case by case basis, canola is the highest risk crop that we could grow. European research and Canadian experience backs this view.
However, soy is widely seen as a low risk crop, but gene flow in the US soy crop is now forcing many farmers into lower value markets. The release of GM wheat has been postponed by Monsanto now. On a case by case basis, the only crops that could be released would be non-pollinating, with infertile seeds, such as bananas.
Canola is the worst crop that we could begin to develop co-existence as a real goal for Australian farmers and the community at large. This has been proven not only by the Canadian experience but also by the 145 page report, "Scenarios for co-existence of genetically modified, conventional and organic crops in European agriculture". To quote this report:
"Compliance with the 1 % threshold would result in additional costs (changing farming practices, monitoring system, insurance) of 1 % - 9 % of current product price for maize and potato. For OSR seed production, the equivalent costs would be 10 % - 41 % of current price. These costs include all identified costs, also those affecting the GM crop production. This reflects the present situation regarding legal obligations for commercial GM crop production."[12]
Discussion - Is Co-Existence Feasible?
In its letter to the OFA[13] , the GTGC argues that organic and conventional farmers are already demonstrating the feasibility of co-existence. However, there is a huge difference between the decertification of a single crop due to a spray drift event, and the permanent, self-reproducing "adventitious presence" of transgenic material.
In that letter, the GTGC argues that organic farming is of potentially equal risk to health and the environment as GM crops. This is an insult to the largest and most proven form of sustainable and natural agriculture, The concept of organic farming has been practiced in Australia for over 50 years, and elsewhere in the world for
centuries, considerably longer than GM crops.
As for the risks of GMOs as seen by independent scientists, the GTGC letter states that the effects of GM crops are to be monitored in one of the World's most stringent regulatory systems. However, so far the Gene Technology Regulator is yet to demonstrate this. It is unable to adequately examine these questions because there is very little research being done in the way of feeding and cropping trials which will stand up to careful scrutiny and peer review and still no long term feeding trials are being carried out.
The GTGC bases the concept of coexistence on a narrow definition of weeds, stating that GM varieties of crops have no greater ability to spread than any other crops. However, this definition excludes the issue of contamination of organic and GM free farmers, by whom a weed would be defined as "any plant in the wrong place at the wrong time".
The GTGC letter states throughout that many issues, such as the distribution of segregation costs, will be worked out in the detailed plans. However, the distribution of segregation costs is a basic principle that must be defined. Other issues that are deferred include management of buffer zones and physical seed movement into other areas.
The GTGC letter also shows contempt for the organic industry by stating that:
"In the case of organic production the system, not the product is accredited and certified. There is no regulated organic domestic standard and the industry itself decides on the structure of its own export standard. Therefore, if the organic industry imposes extra monitoring on itself, it should be responsible for paying it".
This confusion also came up at the last Melbourne meeting. The organic standard (export) and various international standards are indeed 'process' standards. However where process cannot guarantee a particular product quality, product standards are also in place. E.g. for pesticide residues and heavy metals. The product standards back up the primary process standards. So too with GM contamination. And yes, there is no single national domestic standard, but there are a number of nationally applied organic certification standards based on a national export standard. These all address GM contamination. The National Standard for Organic and Biodynamic Produce was first established in 1992, where it was agreed to by all parties, including NFF and the Federal Government.
The GTGC will not address the issue of liability. It has no answers on the issue of insurance. The GTGC is also trying to force the organic industry to accept thresholds for contamination. It states in its letter:
"The use of the term 'zero tolerance' or 'undetectable' is not permissible under Australian consumer and food laws. All Australian Food Standards are required to be set at measurable limits. Australian law must be enforceable. The Australian export standard for organic foods does not use the terms 'zero tolerance' or 'undetectable', it simply says GM crop varieties must not be used".
Again, there is a widespread misunderstanding of the tolerance for GM contamination in organic standards. The current situation is that detectable GM contamination renders the product uncertifiable. This is the policy as administered by AQIS which oversees the organic standards. The current level of detection is around 0.1%, so this is the current limit. The wheat industry works on a nil tolerance at point of export for insect infestation and can relate this to the current sampling regime. Once GMOs are released, Organic and GM-free producers will need to do the same.
It would appear that one of the primary aims of the GM proponents working through the GTGC is to get the organic industry to accept full responsibility for any GM-free standard "it imposes on itself" and maintaining a completely segregated production and supply system. This would get GM technology providers and producers off the hook with regard to liability in the event GM contamination of organic product.
Conclusion - What is the purpose of the GTGC?
The foreword to the GTGC Draft Strategic Framework states that "The GTGC is recognised by the State and Federal Government based Plant Industries Committee as the grains industry body reporting to Government on farming systems and marketing issues relating to genetically-modified grain crops."
However, this is contradicted in the letter from the GTGC chairman stating that "This is not a Committee where members are present to represent their constituents; people are invited to join for their knowledge of a segment of the industry.[14]"
The OFA is concerned that the GTGC is being controlled by players with vested interests in the technology, with mainly pro-GM material circulated to members.
It is clearly a committee whose goal is set in concrete, and in which the question on whether co-existence is actually feasible, is not asked. There is a lack of understanding of organic standards, and there is no participation by conventional, GM free farmers. The OFA feels that whilst the membership of the GTGC is skewed towards proponents and owners of the technology it is presenting a distorted view to the Plant Industries Committee and to farmers and the public generally.
It remains to be seen the response that is received to the Strategic Framework and the list of mail recipients. So many issues remain to be resolved that the OFA cannot be expected to continue to provide representation on this committee only to be falsely represented to the grains industry and the public.
References
[1] The document can be downloaded from the AFFA website www.affa.gov.au or through NFF and its state affiliates. Comments should be sent to Dr Fay Stenhouse at sracp@avcare.com.au or fax (02) 6230 6355
[2] OFA Position Statement on GMOs, August 2001, available at the OFA website www.ofa.org.au
[3] For example, June 20 2002 SMH http://www.smh.com.au/articles/2002/06/19/1023864457450.html">
http://www.smh.com.au/articles/2002/06/19/1023864457450.html
"The Organic Federation of Australia wrote to Mr. Amery two weeks ago with a warning that the decision could result in "significant financial losses and economic problems". The convenor of its genetic engineering committee, Sam Statham, said GM contamination would mean that organic farmers could lose their status. See also http://www.smh.com.au/articles/2002/06/28/1023864658181.html">
http://www.smh.com.au/articles/2002/06/28/1023864658181.html
" Sam Statham, of the Organic Federation of Australia, said the study showed a moratorium on commercial GM canola was necessary because it would be a "recipe for widespread low-level contamination". Organic farmers opposed a threshold-based system. "You're either GM-free or you're not," Mr. Statham said.
[4] Eastern Zone Gene Technology Grains Committee Meeting, 10.00 am, Tuesday 25 September 2001, Avcare Canberra
[5] Organic Federation of Australia Comments on the "Draft Code of Practice For the Supply Chain management of GM and non GM canola" prepared for the Eastern Zone Gene Technology Grains Committee, February 2002
[6] Eastern Zone Gene Technology Grains Committee Meeting, 10.00 am, Thursday 21 February2002, Industry Link Room, Discovery Centre, CSIRO, Canberra
[7] OFA Comments on Gene Technology Grains Committee's Draft Strategic Framework for Achieving Coexistence, May 2002
[8] Transcript from the ABC National Rural News that is broadcast daily to all states on ABC Regional Radio's Country Hour and in the city on ABC News Radio. From the ABC website, August 29, 2002
[9] Published:July 26, 2002, Farmwide news service, http://www.farmwide.com.au/viewarticle2.asp?artid=183
[10] Gavin Gibson, CEO, Pulse Australia Limited, 10/7/02, Ph 02 9232 6366 or ggibson@pulseaus.com.au
[11] Neil Smith, Managing Director, QAF Meat Industries Pty Ltd, Ph 02 6033 1200
[12] "Scenarios for co-existence of genetically modified, conventional and organic crops in European agriculture" Available on the Internet in PDF format at http://www.jrc.cec.eu.int/GECrops/">http://www.jrc.cec.eu.int/GECrops/
[13] GTGC letter of 02/08/02
[14] GTGC letter of 02/08/02
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