FARMERS REFUSE TO ACCEPT CROP MANAGEMENT PLANS:

As farmers, we find it difficult to comprehend why our government could possibly accept the proposal by the Plant Industries Committee to allow the GM product provider to dictate crop management terms to the non-GM grower.

The Gene Technology Grains Committee (GTGC) was set up by the GM industry to have selected industry representatives endorse coexistence principles. (details of plans and public intentions here) The farmer representatives on this committee have been misled to believe all outstanding issues are to be managed by a different committee, the canola reference group. This committee has not yet met, has no intention to manage outstanding issues such as unfair liability etc and the coexistence for non-GM growers actually relies on the crop management plans prepared by the GM industry themselves, Monsanto and Bayer Cropscience. (see Senate questions here)

Although only in draft form, the proposal by the GM product provider for control of contamination is:

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The InVigor Hybrid Canola Crop Management Plan
Page 8, Draft 8, December 2002
Quote from Table 1 (4):
"Recommendations for growing InVigor hybrid canola near other canola in Australia, to minimised the occurrence of off-types.
Minimum distances for Managing Adventitious Presence of GM Grain to be less than 1%.
Between GM canola and:
Non-GM canola and all other canola - 5 metres
Foundation Seed Canola ( or farmer saved seed) - 400 metres
1. Based on extensive review of scientific studies, GM canola may be grown in the proximity of Non-GM canola, without the risk that the non-GM canola will exceed the 1% threshold level and therefore requires to be labelled as "GMO".
2. Where an alternate standard (ie. Lower threshold for non-GM canola) is required in response to market requirements and product specifications, appropriate management strategies applicable to the growing and processing of the crop should be incorporated as deemed and communicated by the supply
chain for the specified product.
3. If a GM and Non-GM canola crop are to be grown in adjacent paddocks, and there is a supply chain requirement to deliver and declare the product separately, it is recommended that a narrow width of the non-GM crop (approximately 5 metres or a header width) immediately adjacent to the GM
crop be harvested and processed as part of the GM crop or alternatively it can be slashed or cultivated as part of standard firebreak management. This area should be treated as per the GM field for subsequent volunteer control.
4. Where a farmer grows a GM canola crop along a boundary fence line that is adjacent to a neighbouring canola crop, it is recommended that the farmer notify the adjoining land owner. The area of approximately 5 metres or a header width, immediately adjacent to the Genetically Modified crop should be treated as per the GM field for subsequent volunteer control."

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Collins dictionary: Adjacent -  "being near or close, esp. having a common boundary"   

This indicates that a GM grower can grow their GM to the boundary fenceline and the non-GM grower is expected to provide the appropriate buffer zone. As yet, it has not been clarified as to what a buffer zone is, is it a crop that must reach flowering or is a firebreak sufficient? The above Crop Management Plan indicates that it is crop and the practicality of this proposal is unreasonable.

A non-GM grower will not be cooperative if he is asked by his neighbour to introduce a buffer strip that must be kept completely separate to the rest of the crop because his neighbour has decided to grow a crop that markets reject. At one of the busiest times of the year, this strip must be swathed and harvested separate, kept separate throughout the supply chain and each harvester, auger, chaser bin, storage bin and truck must be completely cleaned out and signed off as clean before completing the remainder of the crop. This may also involve subsequent contamination control, restriction on stock grazing and further tillage that may spread contamination. Cooperation must not be expected of neighbors to this level of inconvenience.

As a network group representing non-GM growers, we refuse the impositions implied where we either destroy or try to keep segregated a 5 metre or 400 metre (if growing crop for seed) buffer zone. We also refuse the liability for the contamination should it occur. The GM product provider must be legally responsible for their product.

It is expected that if we are to continue to grow uncontaminated produce for markets that are demanding uncontaminated produce, we are to supply a 3km buffer zone around our crop within our own boundary.
Contamination arising from the introduction of a GM product must be managed by the GM supply chain, not those of us that do not want the product.

And in case you missed it - from p 81 of the Office of the Gene Technology Regulators Risk Management Plans (RARMP)
The RARMP suggests that in order to prevent dissemination of GM canola seeds by sheep or other livestock, "restriction of livestock to a holding area for 7 to 10 days would ensure that all viable canola seeds would be passed before stock were moved away from the paddock."
Presumably, this would also need to apply to non-GM paddocks that are likely to be contaminated by adjacent or nearby GM canola or classified as "buffer zone" areas.

The question is... How many farmers have a holding paddock in every paddock that is capable of holding sheep from 7-10 days? How many will be prepared to handfeed sheep for this length of time? Will it be a requirement to remove the manure from this holding pen to prevent contamination, after all it will get into the wool and feet of stock and render the exercise useless? Will it be a requirement to restrain wildlife (kangaroos, birds etc) that will also be grazing on canola stubble?

Bayer Cropscience contacted the Network to arrange a meeting to clarify the crop management plans as they feel we have misinterpreted the plans. They indicated that the GM grower is to provide the buffer zone, not the non-GM grower as indicated.

Update 12th June, 2003: Bayer Cropscience have confirmed that they will amend the crop management plans to ensure that the buffer zone is clearly designated to the GM grower.

Update 21st August, 2003: The Gene Technology Grains Committee's latest Canola Stewardship Principle has removed buffer zone distances entirely. Will this also be removed from the Crop Management Plan? 

Update 30th October, 2003: Bayer Cropscience and Monsanto have both given their word that the 5 metre buffer zone is in the GM growers property but will not release their crop management plans until the crop is in the ground. The crop management plans are policed by the GM industry themselves with the only punishment proposed as industry sanctions, the question is, would the GM industry refuse to deal with their customers if they do not comply with management plans?

Update 15th February, 2004: Bayer Cropscience has maintained confidentiality and refuse to release their crop management plans.

Monsanto has released their crop management plans and resistance management plans (here)  While the GM grower does need a 5 metre buffer zone (a normal firebreak distance so will not affect normal cropping arrangements) the onus is clearly on the non-GM grower to provide the buffer zone required to prevent contamination. The intention of the crop management plans is to allow contamination up to 1% although markets do not accept any contamination. They are dealing with this zero tolerance by clearly stating that the non-GM grower is responsible for meeting contractual demands.

"Where an alternative standard (ie. lower threshold for non-GM canola) is required in response to market requirements and product specifications, or there is a plan to grow a specialty canola crop that requires specifice management to maintain product integrity (eg. high oleic, high urecic, gm-free or organic canola), appropriate management strategies applicable to the growing and processing of the crop should be incorporated as deemed and communicated by the supply chain for the specified product."  

The intention is also to deny the non-GM grower the right to save our own seeds:

"Farmers should not save seed from one season to the next unless it is produced under conditions of certified seed. This is important for both conventional seed and Roundup Ready canola seed."

These "coexistence plans" clearly have no intention to allow coexistence to be possible. It will be too difficult and too expensive to market as non-GM or GM-free (legally zero tolerance).

 Julie Newman (latest update 10th June, 2004)

Network of Concerned Farmers