PO Box 155,

Kensington Park, SA, 5068

Australia

 

 

 

 

 

 

 

 

 

 

Submission

to

Biotechnology Australia

Working Group

on

Unintended Presence of GMOs

in Imported Seed

 

 

 

 

 

May, 2004

 

 

1         Introduction

 

The Institute of Health and Environmental Research Inc. (IHER) is a not-for-profit research institute with an interest in genetically modified (GM) organisms, particularly those destined for food.  Its directors hold the following degrees: ordinary degrees in Medicine, Science and Agriculture, Honours Degrees in Agricultural Science and Organic Chemistry, a Master of Public Health, and PhDs in Plant Genetics and Medicine. The Directors have training and expertise in plant science, agriculture, medicine, chemistry, biochemistry, nutrition, epidemiology and biostatistics. 

 

 

2         Submission

 

IHER wishes to make several key points in response to the call for consultation on this issue.

 

First, the consultation paper has been circulated amongst seed industry associations and related forums, and industry committees. We are concerned that this group may be too limited.  We believe that a more meaningful and prudent policy should obtain input from others directly impacted by the development of such a policy, such as farmers, exporters of food and grain, the organics industry, environmental scientists, health experts, food manufacturers and the general public.

 

Second, we believe that the discussion paper has correctly identified a number of key hazards of unintended presence of GMOs in seed, such as environmental risks, human health risks, and market loss. As we believe that food safety, environmental safety and the protection of Australia’s export markets are extremely important, we also believe that they need strong protection from the unintended presence of GMOs.

 

The Biotechnology Australia paper also discusses the risk of overseas-grown, commercial GM crops contaminating seed intended for Australian cultivation, where the GMO may not have been approved or assessed. While IHER regards such risks as valid and serious, there appears to be little consideration of the possibility that imported seeds may be contaminated with seeds, genetic material or proteins from crops that have been genetically modified to express industrial and pharmaceutical chemicals.  It is our understanding that GM crops have already been grown to express experimental pig vaccines, AIDS vaccines and blood thinners, amongst others. It is also our understanding that none of these crops have undergone any safety assessments on humans.  Furthermore, many are not intended for human use at all, eg a pig vaccine.  It is therefore of concern that they may enter the human food supply through contaminated seed, particularly as these chemicals are often genetically engineered into food crops, such as corn. In addition, most of these crops are grown in United States, one of our key trading partners.

 

While these crops currently tend to involve small-acreage field trials, they are still grown in the open in a manner that can permit the transfer of the modified gene(s) to nearby crops through pollen.  Furthermore, as these field trials are often conducted secretly, nearby farmers may have no warning of the potential contamination of their crop.  In addition, the field where the GM crop is grown may be contaminated for years afterwards via GM seed falling on the ground during harvest.  This seed may germinate over a period of several years after harvest, thereby contaminating all crops grown on that land for several years. 

 

There have already been cases of grain recalls due to inadvertent contamination with such GM crops.  There is therefore a documented history of food crops being contaminated by such GM crops.  There is also no guarantee that all incidents have been detected, or will be detected in the future.  It is expected that the risk would increase if these crops are commercially grown, as the number of acres and the number of farmers growing the crops would both increase, thereby increasing both the extent of any contamination as well as the number of opportunities for contamination.

 

If imported seed is contaminated with such GM seed, we consider that the following could occur:

·        There could be impacts on human health, animal health or the environment.

·        As each GM seed will grow into a plant that will set many further seeds, a small amount of imported contamination could progressively contaminate more of Australia’s crop with each ensuing season.

·        The level of contamination may make it almost impossible to remove the GM crop from the Australian environment or food chain.  This is of particular concern if one of these GM crops is later found to have adverse effects on health or the environment. 

·        The market dislikes GM crops and, according to Biotechnology Australia’s own surveys, this tendency is getting stronger over time.  In fact, many of Australia’s manufacturers and export markets require GMO-free produce.  Any documented adverse effect from eating a GMO may cause many more manufacturers and export markets to quickly demand absolute GMO-free status in their ingredients.  Australia could find it impossible to comply if its crops were contaminated from unintended GMOs present in imported seed stocks.

 

We therefore consider that the only acceptable option is Option 3.2: Introduce Active Enforcement and Surveillance of Imports, with a zero tolerance of unintended GMOs. We further consider that it is so important for Australia to import uncontaminated seed stocks that both of the following conditions should be met for each and every shipment of imported seed:

1.      A supplier guarantees that their seeds contain no GMOs whatsoever.

2.      The shipment passes a series of sensitive tests for the presence of all known GMOs.

If the shipment fails either test, then the shipment should be rejected.

 

Furthermore, in order to quell public and farmer concerns, the enforcement of these conditions should be done by people who are seen to be independent of vested interests.  Therefore, enforcement should be undertaken by Government-paid inspectors (eg AQIS), and all processes should be open and transparent. A data base of seed suppliers and/or countries supplying uncontaminated seeds could also be established and made available to seed and farming groups.

 

 

3    Summary

 

There are serious risks to health, the environment, food manufacturers and our long term export markets from unintended presence of GMOs in imported seeds.  Consequently, we contend that: