Open letter to the Food Standards Agency on the timing of its consultation on ‘precision bred’ organisms
15th November 2023
For the attention of: Chief Executive Emily Miles and Chair of the FSA Board, Professor Susan Jebb.
Dear Ms. Miles and Professor Jebb,
I am writing to you from GM Freeze, a membership organisation that campaigns for adequate safety regimes, transparency and regulation in relation to the development and commercial release of genetically modified and gene edited plants and animals.
I would like to lodge a complaint in relation to the timing of the consultation on “proposals for a new framework in England for the regulation of precision bred organisms used for food and animal feed”. In order to rectify the prohibitive timeframe of the consultation, I request that you extend the deadline for responses to be submitted.
As you will be aware, the consultation was launched on the 8th of November and the deadline for responses is the 8th January 2024. This is a month – or one third – less than government guidelines for public consultations, which state: “Consultations should normally last for at least 12 weeks with consideration given to longer timescales where feasible and sensible”. I am not aware that any explanation has been provided by the FSA for the contracted timeline, however, please do point me towards one should it exist.
Furthermore, the consultation period coincides exactly with the Christmas period, which will undoubtably have a significant impact on the quality and quantity of the responses you receive. GM Freeze is particularly concerned by the chilling impact that the timing will have on participation by consumer-facing or supplying businesses during their busiest time of year.
The consultation document is 29 pages long and contains technical, scientific and legal details. A substantial amount of time will be required by respondents in order to make their responses as meaningful as possible; time which is simply not available to many potential respondents over the Christmas period.
Consumers and consumer-focussed businesses are key stakeholder groups, particularly for the consultation in question. The lack of traceability and point-of-sale labelling that are fundamental aspects of the proposed regulatory framework may result in profound changes to the relationships and trust between businesses and their customers.
It may be that distributors such as supermarkets would want to take legal advice on their obligations under the proposed new regime, including on issues such as product recalls. However, there is no way that such a business could do this and formulate a formal response to the consultation in a matter of weeks.
I am sure that you appreciate the necessity for full and active participation on this issue by as broad a section of businesses and civil society as possible. I therefore very much hope that you will reconsider the deadline of the consultation, in line with government guidelines and in order for the timing to not be prohibitive – and therefore discriminate against – any particular stakeholder group.
 HM Government Code of Practice on Consultation, available from: https://assets.publishing.service.gov.uk/media/5a7ae75540f0b66a2fc039f8/file47158.pdf