From arguments to awareness raising: GM Freeze’s Leonie Nimmo reflects on a busy week
Last week was a whirlwind: I argued at a Food Standards Agency Board meeting, presented at a Civil Society conference and spoke at a Q&A after the screening of the film Six Inches of Soil. It was… more mixed than my veg bag! Meeting some inspiring people and speaking alongside some luminaries in the regenerative farming and legal sectors provided a perfect antidote to the brick wall of a government agency failing to listen.
Football at the Food Standards Agency
The Food Standards Agency’s Board meeting in Leeds on the 20th March was a surreal affair.
It was the first time they had met since the FSA analysed the responses to its consultation on the way it intends to deregulate (in England) so-called Precision Bred Organisms (PBOs) – new-style GMOs to many of the rest of us. The public and others (81%) are overwhelmingly against these plans, and there remain major unresolved issues around safety, labelling, traceability, threats to organic standards and trade with Europe and the rest of the United Kingdom.
Nevertheless, the Board did not find anything that meant it would reconsider its approach and will blithely press on regardless. Much of the meeting was spent kicking responsibilities over the net to the Department for Environment, Food and Rural Affairs or up into the higher echelons of Government that passed the Genetic Technology (Precision Breeding) Act last year. Despite a couple of members of the Board clearly uncomfortable with the direction of travel, overall it was presented as a reasonable conclusion. Remarkable.
FSA Board meeting, Leeds, 20th March 2024
Trade uncertainty
It was also the first FSA Board meeting since the European Parliament voted to require traceability and labelling of what in Europe are described as products from New Genomic Techniques (NGTs). This could have a huge impact on a swathe of our trade with Europe which is estimated by DEFRA to be worth £8.5 billion, though the effect on the wider economy and workers that depend on this trade will be far greater. As pointed out in a Government Impact Assessment, divergent regulatory systems could result in checks and certification requirements on UK food exports entering the EU’s single market. These non-tariff barriers “would not only affect products exported to the EU which contain PB [Precision Bred] plant material, but also those in the same product categories which do not.” Presumably that could ultimately mean all agricultural produce.
Despite the enormous impact that this change would have on British producers, the FSA Board did not even mention it until I asked a question at the end of the meeting. Even then, it failed to respond as to whether any risk modelling has been conducted on this eventuality.
Quizzing the FSA Board
Steven Jacobs from Organic Farmers and Growers also pointed out the obligation for the government agencies to create a framework that will enable organic suppliers and those that distribute and sell organic produce to fulfil their legal duty to maintain segregated supply chains. Steven highlighted the fact that the proposals as they stand will not do this.
When traceability does not mean traceability
One encouraging aspect of the meeting was the willingness of some of the FSA Board and staff to speak to GM Freeze and our allies in the audience outside of the formal meeting. In particular, I received some clarity from Dr. James Cooper, Deputy Director Food Policy and the person who has responsibility for this area, on a couple of issues.
Cooper had explained to the Board that the traceability mechanisms available to businesses that want to trace whether products have ‘PBOs’ in them involve asking up the supply line, and “if somebody doesn’t want to tell you then don’t do business with them.” Which is not traceability as far as myself or anyone in the organic sector would understand it.
Cooper acknowledged that he was describing traceability to all potential sources. This he helpfully described to me as like a tree: there could be multiple potential sources depending on the product and whether it was traded on commodity markets. Likewise, it wouldn’t be possible to trace the exact products that contained a ‘PBO’, only those that potentially contained it, and in the event of a product recall all products potentially containing it would need to be removed. Cooper’s boss Rebecca Sudworth described this system as “robust”. The mind boggles.
When risk assessment does not mean safety testing
With regard to safety testing, I was keen to discover what if any testing would be conducted or commissioned by the FSA in its process of authorising the riskier (Tie r 2) ‘PBOs’, because the FSA’s proposals are unclear on this point. The answer, stated Cooper, was none: it will all be conducted by the developers. It may include animal testing or anything else they deem necessary to establish that their products are safe. The FSA will analyse the data provided, but there will be no independent testing.
This reminded me of the GM developer-turned-whistleblower Caius Rommens’ remarks in the US context: “It is amazing that the USDA and FDA approved the GM potatoes by only evaluating our own data. How can the regulatory agencies assume there is no bias?… We test our GM crops to confirm their safety, not to question their safety.”
When safety can mean different things
Cooper was keen to point out that – as with any other product – it is the manufacturers’ legal responsibility to ensure that food is safe. When I questioned this with regard to ultra-processed, high sugar and high fat foods, or indeed smoking, Cooper’s response was that “it depends on your definition of safe.” I didn’t find this entirely reassuring. He later clarified that ultra processed foods are the Department of Health and Social Care’s policy responsibility.[1]
When labelling does not mean labelling
In trying to untangle the details of the FSA’s proposed framework when face to face with the person responsible, I found that perhaps the most sneaky issue was around that of labelling for particular population groups. The FSA’s consultation pack states: “As with any food, if there is a need to provide safety information for a particular population group, (for example, hypersensitive consumers or people with certain health conditions) this can be required as appropriate.”
The implication is that ‘PBOs’ will be labelled if required. But I pointed out to Cooper that labels don’t only appear on the products that are being sold to a particular population group, they would need to appear on all products containing the ‘PBOs’ in question. How then, could this be compatible with the FSA’s determination not to label? The response was a little chilling. Cooper asserted that ‘PBOs’ are the same as conventionally bred organisms, so if there was a requirement to label a novel allergen – for example, if cabbages were identified as an allergen – then all cabbages would need to be labelled.
So – to clarify – under the proposed framework, there will never be labelling of ‘PBOs’ for particular population groups. This is worrying given increasing concern about novel allergens. An expert opinion on the risks of new GM plants published by the French National Agency for Food, Environmental and Occupational Health Safety (ANSES) states that potential risks include those “linked to unexpected changes in the composition of the plant, which could give rise to nutritional, allergenicity or toxicity problems.”
A video of the Board meeting and questions can be watched here, and the written questions put to the board – which they have until 18th April to respond to – can be viewed here.
Strengthening Civil Society Impact on Westminster – a Four Nations event
Moving swiftly on from Leeds… to Cardiff, and a two day conference organised by the Civil Society Alliance, Wales Council for Voluntary Action, Wales Governance Centre and Human Rights Consortia from Northern Ireland and Scotland. The event bought together people from civil society across the UK’s four nations to discuss how to maximise our collective impact on Westminster in the years ahead. It was great to hear such a diverse range of voices and learn about the different challenges we face, as well as think about how we can work together in the future.
I shared GM Freeze’s experience of working on the Genetic Technology (Precision Breeding) Bill – now Act. I was speaking alongside Suhan Rajkumar, a Senior Associate at Bates Wells, who provided insights and advice for NGOs, charities and the voluntary sector that are working to influence the political landscape.
Civil Society discusses influencing Westminster, voco St. David’s, Cardiff, 21st March
What I took away from the conference was a deepening understanding of how different areas of the United Kingdom are impacted differently by Westminster. In the case of new-style GMOs, the aforementioned Act means that these will be forced onto people across the UK despite Wales and Scotland withholding legislative consent (with Scotland evidently furious with how the process was managed), and there being major issues regarding trade with Northern Ireland.
The Internal Markets Act will mean that despite new-style GMOs being regarded as old-style GMOs in Wales and Scotland, they will be sold there without the regulations (labelling for example) applying. It will not be possible to produce in, or import them into, Wales and Scotland without the GMO regulations applying, but they could be imported or produced in England and then sold in Wales or Scotland without the regulations applying. If they undergo a ‘significant production step’ they would need to be labelled, however, they won’t be labelled or identifiable going in, so it is hard to understand how this could be possible. This trade and logistical nightmare waiting to happen is an example of Westminster’s cavalier post-Brexit deregulation drive being implemented in the rest of the UK without regard for the democratic processes there.
Do get in touch if you think the lessons we learnt working on a parliamentary Bill could be of interest to your organisation – we’d be very happy to share.
And so to Hebden Bridge, where the wonderful Pennine Cropshare had organised a film screening of Six Inches of Soil. I was invited to speak on the panel discussion afterwards alongside Mike Smith from Incredible Farm, Aine Douglas from Calderdale Food Network, Geoff Tansey from the Food Ethics Council, local livestock farmer Anne Jones and soil scientist Charlie Clutterbuck.
It was brilliant see the venue packed out with people interested in how we create food systems that work with nature rather than against it. The film followed three start-up producers on their journey to create thriving and regenerative production systems – key to which, of course, is soil.
I took the opportunity to flag the threat to such systems posed by the current push for GM deregulation. I was also keen to situate what GM Freeze does within the wider movement for Food Sovereignty and in relation to La Via Campesina, the movement of peasant producers who “work the land and feed the world”. La Via Campesina categorically rejects genetic modification in all forms, as it poses a serious threat to seeds and genetic resources, and undermines producers’ right to determine their food systems. GM Freeze is a member of the Landworkers’ Alliance, the UK arm of La Via Campesina.
The film provided a perfect backdrop to my response to a question as to whether some GMOs might be beneficial in adapting to climate change or reducing chemical use. We already know what we need to do. Technofixes in the form of altering genes will not solve the problem of degraded and destructive farming methods. We need better farming with regenerative and sustainable practises, and soil.
Six Inches of Soil Q&A, Hebden Bridge Picture House, 24th March 2024
[1] By email, 27th March 2024.
