Genetically Modified crops
External advice and advisory bodies
8.23 There is clearly a continuing need for expert bodies to advise the regulatory authorities on individual applications for approval of plantings or novel foods. The crucial requirement for such bodies is that they are expert and independent and have the means and authority to obtain thorough analysis of any question which they think needs deeper investigation. Some of our own members have been involved with the work of ACRE and Advisory Committee on Novel Foods and Processes (ACNFP) and we have also received consultation responses on the working of these bodies from a number of respondents. We believe that they have discharged their functions well, and ensured that safety and environmental considerations have been very thoroughly assessed.
8.24 It may be desirable to separate purely scientific assessment of issues about the safety and environmental impacts of GM planting and foods from some of the broader assessment suggested above. Such broader assessments are likely to involve judgements that are not purely scientific, and involve issues on which different people may legitimately take different views. The Working Party therefore also recommends that a more broadly based group of advisers representing a wider range of stakeholder interests should form part of the regulatory structure giving advice on the balance to be struck before decisions are taken. This group should report to the overarching body (paragraph 8.26) with its chair as a member of that body. From this perspective we regret the lack of consultation about the recent Government proposal to exclude industry and environmental group representatives from membership of ACRE when new appointments to it are made.
8.25 The difficulty of policy making with regard to GM food is greatly exacerbated by the current climate of public distrust. Our consultation brought home to us the interconnection between ethical unease and factual uncertainty. We believe that it is particularly important that the government advisory committees continue to have consumers and advisers on ethics as full members, involved in the scrutiny and evaluation of all applications. Any change to this well-proven procedure would, in our judgement, be a retrograde step and would be perceived adversely by the public. A public that does not know what to believe or whom to trust is even more likely to fear that 'unnatural' things are being done to food, that the results may be unsafe, and that the environment may suffer damage of an unspecified kind.
8.26 We therefore recommend as an over-arching body the creation of a biotechnology advisory committee that would report to the Cabinet Ministerial Group on Biotechnology and Genetic Modification, both upon request and on its own initiative. We propose that this body would provide a locus for the discussion of scientific, ethical and general policy issues, and would have as part of its remit the duty to consider the wide variety of moral concerns as well as the factual uncertainties surrounding the treatment of GM crops. It would determine the ethical desirability of particular types of genetic modification and their cumulative impact on the environment and society at large. Its advice would be published.
8.27 Such a committee would:
- be an independent advisory committee whose members would be appointed by Ministers in consultation with learned societies, industry, commercial, consumer and environmental organisations and other appropriate bodies, in such a way as to command public confidence;
- draw its members from a wide range of backgrounds, including the scientific, philosophical, religious, public policy, environmental and health communities;
- report directly to the Cabinet Ministerial Group on Biotechnology and Genetic Modification with a remit to anticipate potential issues as well as to make recommendations on the scientific, commercial, environmental, consumer and ethical issues arising from applications to the advisory committees;
- be responsible for the integration of advice from the relevant advisory committees, and operate under terms of reference similar to those recommended by the Royal Society in the summary of its Report entitled Genetically Modified Plants for Food Use.
8.28 We think it important that such a committee explore public attitudes and views in depth, and the way in which these are affected by different types of information and knowledge, perhaps through the medium of 'citizen juries' of the kind used in policy discussions in the US and the UK 'consensus conferences'. It would need to give careful consideration to the views of all groups that have strong opinions on the issues, including religious groups, consumer and environmental groups as well as the commercial and scientific community and the public at large.