20 February 2003
FSA SLAMMED! FSA MUST BE REMOVED AS INDEPENDENT SCIENTIFIC ADVISORS
for more on the FSA: http://ngin.tripod.com/pants1.htm
From: Doug Parr, Greenpeace
Sent: Wednesday, February 19, 2003 12:45 PM
To: Malcolm Grant, Chair of AEBC and Steering Committee for the Public
Subject: Role of Food Standards Agency
Sorry to give you something else to deal with when you will clearly have a lot on but I' m writing to you in connection with the role and activities of the Food Standards Agency in the GM debate. I raise them with you because it involves the components that are about the review interaction with the public, and which potentially undermine the work you are doing overall and on the main strand of the public debate.
You may be aware of their proposed work which is outlined in a press release of 15 February, and on the Food Standards Agency website. www.food.gov.uk/gmdebate (NB I've found that this jams on Netscape and better to use Internet Explorer for some reason)
1. First, my understanding of the role of the FSA was as independent advisers to the GM Science Review. This is apparently not a view shared by the FSA whose booklet states that their contribution is "to independently assess people's views on the acceptability of genetically modified food and how this relates to consumer choice". I have found no reference anywhere as to how this shift in role came about, and my understanding is that this has not been discussed at the Steering Board for the GM debate. The potential for confusion, overlap of roles and potential for contradictory messages in relation to the public debate itself is evident because of the FSA's standing as part of the official process.
2. Further if any attempt is being made by FSA to reference what it is doing to the main public debate strand it is pre-empting the research done by CorrWillburn to frame it. The FSA appears to have made its mind up about how the issues are to be framed in its proposed citizens jury in Slough. I would not claim to be an expert in deliberative processes but it looks to me like a narrow framing of the issues that people may wish to consider in relation to GM food. Work done by the National Consumers Council in their project with low-income and socially excluded people ( "Weekend Away for a Bigger Voice" ) shows that elite opinion framing of the concerns of low-income people can be highly misleading. It appears to me that the proposal by the FSA is at best contrary to the intended spirit of debate and at worst a simple spoiler exercise. Further advice on deliberative processes needs to be sought.
3. The materials produced by the FSA are clearly undermining of confidence in the GM public debate itself. As you will be aware the information to be provided to participants in the public debate is the subject of heated debate and the Science Museum has the difficult task of trying to condense a wide variety of views and perspectives into core information that could be considered acceptable to all. With lofty disdain the FSA has decided to by-pass that and produce its own 'official' literature, which has made no attempt to go through such a process or even attempt to give some semblance of balance. No doubt other organisations, including ourselves may be producing literature for the public debate. However the FSA is not Greenpeace or Monsanto but part of the regulatory apparatus for food/GMOs. They cannot and should not be producing literature which reflects what a few officials think in this sensitive time.
4. Such concerns may be more theoretical than actual were the actual information not so obviously one-sided and biased. Here are some examples from their booklet, a pdf version of which is downloadable off the website. The same text as is in the booklet is available on the FSA website in the GM debate section.
* In the first pages there are a variety of adjectives associated with genetic modification such as accurate, precise, specific which collectively convey an impression around GM which is highly contestable
* Genetic modification is discussed extensively as an extension of traditional breeding methods. As you'll be aware this is a way of formulating the issues that is controversial internationally, in respect of the differing risks associated with breeding methods and the specific unpredictable issues around GM. It also impacts on the validity of the concept of substantial equivalence.
* The section "What GM technology is being developed?" leads with Golden Rice and the Indian project for a protein-enhanced potato. This seems an odd choice for an Agency apparently concerned with consumer choice in the UK, where we're dealing with herbicide tolerant crops, and with virtually no prospect of food from these crops being sold in UK. It is difficult to avoid the conclusion that these have been picked as one of the few projects (to those who haven't studied the issues) which can show GM in a good light, irrespective of their relevance to the UK debate.
* The section on the ways GM is used in food production (p.9 of the booklet and beyond) seems obsessed with whether GM DNA is actually in the food on people's plates. The CorrWillburn questions on health (section D) did not mention this as a specific concern, nor did the PABE work. The FSA reportedly did some work with focus groups that flagged this issue up some years ago but is now clearly out of date, to be supplanted by a more sophisticated range of issues. Alternatively it may be because the FSA has well-known views about labelling and wants this (outdated, or just plain wrong) framing of food issues to be a major component of any debate about consumer choice.
* "Views of other scientific bodies" (p.12) includes a number of UK and international groups including the Royal Society and the Medical Research Council. Curiously it does not mention the British Medical Association whose concerns about GM food safety is well-known. Alternatively, having read this far, you won't find it curious at all.
* Countries growing GM crops (p.17) contains a large list, very flattering to GM crops when read like this. Less so when the unmentioned fact that the vast majority of the listed countries grow tiny amounts, in no small part to the highly controversial nature of the technology.
* The booklet is highly technocratic and offers no contextualisation of the role of companies, world trade, impact on the food chain, intellectual property rights etc.
* The booklet offers no space as to why people might think GM crops aren't wonderful. No mention of the Starlink incident, seed contamination occurrences, the cross-contamination of pharmaceutical crops with food crops even though pharmaceutical crops are discussed at the end of the text (p.19).
Above I suggested that the FSA is not Monsanto. A full reading of this booklet may suggest I've got that wrong. It is little better than a hard-sell for GM food. The FSA
* should be immediately removed as the 'independent' advisors to the GM science review because they are so obviously partial.
* Their materials should be removed and pulped because of the undermining effect that this will have on the potential public debate.
Certainly their continued involvement damages the credibility of the debate overall.
I am copying this to a few other members of the steering board as I gather you are meeting Thursday.
I will also send this to the GM science review, and to the Food Standards Agency itself.
It is obviously a matter for you to decide but I suggest that this is a very important issue to be discussed at the Steering Board meeting on Thursday.
Dr. Douglas Parr
Chief Scientific Adviser
Tel: +44 (0) 207 865 8240
Fax: +44 (0) 207 865 8200