Please find my comments attached.

Thank you.

Emma Overton

General Comments on GM Science Review

I would like to emphasise that I am a private individual with no scientific background. I am commenting on this report because I think it's extremely important that the public have a say in the future of food production and consumption because of its tremendous impact on human health and the environment. In general I found the report's bias towards GMOs extremely alarming; the assurances given of GMO's safety and benefits are multiple, whilst the arguments against it are infrequently acknowledged and given little voice. The report reads as if the government has already made its decision in favour of GM. However, since I have not yet completely lost my faith in democracy, I would like to exercise my right as a citizen to participate in what I hope against hope, is still a debate, and not a fete a compli.

The report's bias is immediately evident in its attempt to portray genetic engineering as an extension of traditional breading methods; for example, on page 56, it is claimed that the 'widely accepted view within the biological research and plant breeding community is that there are many parallels in the properties of plants produced by GM and non-GM plant breeding methods'. Firstly, I would like to challenge the assumption that this is a widely held view, other than within the biotechnology industry. Secondly, the report underplays the difference between traditional and genetic engineering breading techniques when in fact genetic engineering is significantly different from traditional breeding methods. The report seeks to equate GM and non-GM products by emphasizing that there are uncertainties with both, and by making little mention of the wealth of scientific opinion which has severe reservations about GM technologies, sometimes appearing to have added more cautious attitudes as an after thought.

The report glosses over the fact that the outcome of genetic engineering is inherently random, disruptive and unpredictable and that testing procedures do not take into account the multifunction of genes, failing to recognise that a gene may be safe in its original organism but not within a GMO. Genes can and do move out of GMOs and enter other organisms, including the human gut. The report claims that risks are the same between GM and non-GM products (see for example page 72), but this is simply not true; genetic engineering crosses boundaries that would otherwise never be crossed. Further, side effects are not always obvious or identifiable, and not always eliminated before growth or sale. In the US, there have been many examples of unexpected effects being found in plants after they have been approved. The report glosses over the wildly unpredictable effects of GM, and focuses instead on GM's alleged positive effects, citing for example the 'second generation' GM crops under development which claim to have improved characteristics, in terms of safety or enhanced nutritional properties (page 62). The report emphasises the supposed 'increased levels of health promoting factors' in some GM crops, intimating that the report's writers see GM products very much as the way forward (page 62). But what about organics which already have health benefits and which the public have demonstrated that they are keen to buy? By contrast, the public has clearly indicated its distrust of, and lack of desire to purchase GMOs. Again, insufficient weight was given to consumer feeling, or to scientific opinion outside the biotechnology community.

The report notes that 'many millions of tonnes of GM crops have been produced and consumed internationally over the past eight years without any substantiated evidence of harm when compared with non-GM crops' (page 53). It further states that 'the extent of production and consumption of GM food over the last seven years and the lack of any convincing evidence of verifiable untoward toxic or nutritional effects resulting from its consumption, provides a measure of confidence in its safety when compared with the safety of other novel or non-GM foods' (page 62). If there is a lack of convincing evidence for harm, this is because there is a lack of research into the effects of GM. Firstly, the report fails to note that routine trialing for unexpected effects is not required before GMOs are sold/grown. There is a major shortage of independent and peer reviewed research on health effects, and the government has mainly relied on company data which is not peer reviewed or published. There is a clear lack of transparency and accountability here and a willingness to accept and utilise 'evidence' provided by biotechs which would not be acceptable to the wider academic community. Unsurprisingly the biotechs themselves often find that their products have no negative effects, yet when other scientists look more closely, negative effects are often to be found. Secondly, there have been no epidemiological studies to support the fact that there have been no negative effects from years of GM consumption. Thus to claim that there is no substantial evidence of harm without mentioning that there has been a lack of independent research is, in itself, misleading. The grudging admissions that are made regarding the lack of thorough study in this area e.g. on page 73 it is mentioned that 'at present there are no post-marketing surveillance systems for GM foods in place in any country' are not enough, when compared with the amount of space given over to the claims that GM is 'at least as safe as conventional food' (page 72). As for 'a measure of confidence', the public have clearly demonstrated that they have no confidence in GMOs or in the government's and biotech's assurances of safety.

In summary, genetic engineering introduces many random hazards, and the limited level of scientific knowledge means that risk assessment and control measures cannot be reliably designed. Currently, it seems that decisions on the safety of GMOs and the necessary control measures are often not being made on the basis of science, but on assumptions and industry opinion. Many scientists are concerned that GM crops could cause unpredictable and possibly serious impacts on health and the environment. The way in which genetic engineering is being introduced into food production is unnecessary and unsound. There are many good solutions to the problems of agriculture which involve far less risk and uncertainty, and offer clear and substantial benefits. Investment should be preferentially directed at these solutions, and in particular towards greater support for organic and small-scale food production. The report does nothing to address any of the issues.