What is 'gene flow'?
What's coexistence about?
National strategy to ensure coexistence
GM crops, and food and feed that is derived from GM crops, can only be marketed within the member states of the European Union when they meet stringent food safety and environmental standards. To achieve this, each GM crop must undergo a comprehensive risk evaluation assessment to ensure that it poses no risk to human and animal health or to the environment. As such, a GM crop may only be planted in the EU after authorisation has been granted.
As an additional guarantee, the crop is subject to monitoring during the production phase and the land is also inspected for a period post-harvest to ensure that the appropriate guidelines have been complied with. Following on from this, to enable the consumer to make an informed choice any food/feed that is produced from the GM crop must be labelled prior to marketing.
What is 'gene flow'?
All plants have the ability to spread their genetic material (genes) through a natural phenomenon termed 'gene flow'. Without this system, plants would not have evolved through time and we would not be witness to the enormous diversity that exists within the plant kingdom today.
Plants achieve gene flow by spreading their pollen and/or their seed. When pollen is dispersed it can spread (or 'flow') by the wind or with the help of an insect (e.g. honey or bumble bee). This typically starts in late spring and signals the beginnning of the 'hay fever' season for allergy sufferers.
Irrespective of how the pollen is spread, the desired result is for the pollen to be transfered to a fertile flower. If this is achieved, fertilisation will occur and a seed will be produced.
This seed in turn can then be dispersed by an animal, wind or water. When it germinates it has the chance to establish itself into a new plant, which will then flower, produce pollen and continue the cycle of gene flow.
What's coexistence about?
The cultivation of GM crops in Europe has implications for the organisation of agricultural practices, both on-farm and between neighbouring farms. As described above gene flow between adjacent fields is a natural phenomenon and as a result some pollen and seed from GM crops will be dispersed into conventional or organic crops.
Similarly, pollen and seed from conventional or organic crops will be dispersed into GM crops. While such a circumstance will create no health/environmental risk because the GM crop will have undergone regulatory evaluation, it may become an economic issue because of the EU requirements for the labelling of GM food and feed. Quite simply, if a product contains GM derived material above a set threshold of 0.9%. the label must state that it contains GM material.
So for example. if a batch of non-GM wheat is inadvertently mixed with seed that was harvested from a GM wheat field, it must be labelled as a GM crop if the GM content exceeds 0.9%. It is at this stage that this now becomes an economic issue because the non-GM farmer may otherwise receive a premium for maintaining his non-GM status.
To overcome this issue the Department of Agriculture has developed a set of guidelines to enable the effective 'coexistence' of GM, conventional and organic crops. This implies the efficient segragation of GM and non-GM crops all through the production and supply chain, from seed to store. In order to achieve this task, the European Commission has established guidelines (European Commission, 2003/556/EC), which summarised state that:
approaches to coexistence need to be developed in a transparent way, based on scientific evidence and in co-operation with all stakeholders concerned. These guidelines should be based on experiences with existing segregation practices (e.g. in certified seed production) and at the same time should ensure an equitable balance between the interests of farmers of all production types.
- measures to ensure coexistence should be efficient and cost-effective and should be specific to different types of crop as the probability of gene flow is high for certain crops (e.g. oilseed rape and ryegrass) while nominal for others (e.g. wheat, potato, barley).
- farmers should be able to choose the production type they prefer and farmers who introduce the new production type should bear the responsibilty of implementing the actions necessary to limit any mixture of their produce with that of a non-GM neighbour.
Coexistence guidelines are intended to address the measures a farmer must adopt to minimise the mixing of GM and non-GM crops and any subsequent economic loss a non-GM farmer may incur if mixing does occur. It is important to note that if mixing does happen, the level of GM materical in the conventional/organic crop must exceed the threshold of 0.9%; otherwise it is considered non-GM and can be labelled accordingly.
National strategy to ensure coexistence
In order to develop national coexistence guidelines appropriate to Ireland, the Department of Agriculture, Fisheries and Food (DAFF) established and inter-department/inter-agency Working Group to draw up a report and recommendations to develop co-existence guidelines for Ireland. This report was published in September 2005 and the entire report can be viewed on the DAFF website. The 21 Key Recommendations by the Working Group are as follows:
- A combined mandatory and voluntary arrangement best meets the objective of implementing coexistence measures. Mandatory measures should be specified in a Code of Good Farming Practice.
- Growers must obtain prior approval from the DAF to grow GM crops and applications shoud be lodged a minimun of 60 days prior to the planned date of sowing.
- Growers of GM crops must attend prescribed education training courses. All other interested parties, e.g. neighbouring non-GM crop growers, seed suppliers, machinery and transport operations, contractors, advisers/extension workers etc., should attend education and training courses on GM crop production and coexistence.
- The crop separation distances between GM crops and non-GM crops as set down in this Report must be observed.
- A GM crop grower must obtain signed written agreement with his/her neighbour, where part of the neighbour's farm is required to satisfy as part of the application for approval to grow a GM crop.
- Growers must keep records on all aspects of the GM crop grown for a minimin period of five years. Such records must be made available for inspection to the relevant authority.
- Non-adherence to madatory coexistence measures should incur sanctions.
- A mechanism should be established to allow for appeals on decisions taken by the DAF with respect to approval for GM crop cultivation and sanctions imposed.
- All those intending to grow GM crops should be encouraged to consult with their contiguous farming neighbours and to give them written notification of their intention prior to sowing of the GM crop.
- Growers should observe the required crop required rotation internvals and control volunteer plants, bolters and related weed species in order to reduce the risk of admixture to non-GM crops.
- GM crop growers, contractors and all operatives involved in the production of GM crops should adhere to a Code of Good Farming Practice with respect to the cleaning of farm machinery and equipment, and the secure transport and storage of GM produce.
- A register of those approved to grow GM crops, showing the GM corp species, area and the location (using the Land Parcel Identification System - LPIS), should be accessible to the public through a dedicated website.
- Crop management and procedural measures should be subject to compliance inspection. This should be carried out by, or under the supervision of, the DAF.
- Where a non-GM crop grower incurs a verifiable and quantifiable economic loss as a result of the maximum labelling threshold in his/her crop being exceeded through admixture by the actions of a third party, the affected grower should be compensated.
- Where the party liable for admixture can be identified, evey effort should be made by the affected parties to reach a private settlement.
- A fund should be established for the redress of economic loss if and when the necessity arises. Such a fund should be established initially by the State, but on a cost recovery basis. The recovery of costs should be from contributions from the main beneficiaries i.e. the GM crop grower, biotech companies and other industry beneficiaries. (Notwithstanding the establishment of a redress fund, National law on liability would still apply and non-GM crop growers are entitled to pursue a civil action through the Courts).
- An Independent Body should be established to adjudicate on the nature and extent of the economic loss and to carry out the administration of the fund. The conditions of payment from the fund shold be clearly defined and strictly controlled.
- The coexistence measures recommended in this Report sholuld be subject to on-going monitoring and evaluation by the DAF, or under its supervision, to vertify their effectiveness. The measures should be reviewed initially after 2 years and as deemed appropriate thereafter.
- A database should be established by the DAF with respect to all applicants to grow GM crops, wherein, all necessary details of the applicant, the crop and the management of the crop should be recorded for analysis and coexistence management purposes.
- Research should be commissioned in relation to the: (i) economic impact for Ireland from GM crop cultivation; (ii) costs of coexistence measures; (iii) coexistence of GM and non-GM oilseed rape; and (iv) impact of GM crop management regimes on biodiversity.
- Where independent scientific analysis suggests that a GM crop could not coexist with its non-GM equivalent, within the thresholds pertaining under normal coexistence management measures, the State should consider an application to the EU Commission to establish a GM free Zone on such a specific crop at regional level.