109.  In the public's eyes, concern at environmental safety is only half of the GMO problem. References to "Frankenstein foods" have created doubts as to whether a pizza containing GM soya, tomato and cheese is as safe to eat as conventionally produced foods (Greenpeace, Q 115). It should however be noted that "many products from GM plants, such as sugar prepared from GM sugar beet, are absolutely identical to conventional products."[148] Additionally, the majority of GM foods will not contain viable genes or DNA[149], although the issue of whether these might be transferred to humans has vexed the public. It is acknowledged that DNA can survive in human saliva for up to twenty minutes and in the stomach for up to eight seconds. Similarly, there is evidence for uptake of DNA by micro-organisms and human cells. Indeed, Dr Chesson argued that this was a "perfectly natural event which has been occurring throughout human kind". There was no evidence however for the incorporation of such DNA into human cells' genetic material (Q 639). In the Royal Society's words, "it is worth remembering that the medical profession have been trying to develop ways to insert genes into the body cells of humans for some time, with so far rather limited success. We are not aware of any evidence for transfer of intact genes to humans, either from bacteria in the gut, or from foodstuffs such as potatoes, wheat or chickens, despite daily consumption of DNA in the diet."[150] The transfer of genes between higher organisms depends on the probability of sexual crossing. Natural sexual barriers mean that it would be extremely rare for any gene (including transgenes) to be transferred between non-sexually compatible plants let alone between plants and animals. The fear that transgenes may be transferred to humans by eating GM foods seems to be unfounded.

110.  In any event, generic statements about the safety or otherwise of GM foods cannot be made: each novel food has to be assessed on a case by case basis (Professor Bainbridge, Q 677; Dr Chesson, Q 645; also Professor James, Q 637). Additionally, it is not so much the source of the gene which is important, but its behaviour in the new organism and the characteristics which result (Professor Bainbridge, Q 681). The emphasis should not thus be on "genetically modified" but on the new characteristics of any individual product.

111.  All GM foods[151], whether grown in the EC or imported, are subject to an assessment (additional to and completely separate from the assessment for environmental safety) under the EC's Novel Food Regulation (and accompanying documents[152]) which meet World Health Organisation standards (Mr Rooker, Q 603). In the United Kingdom, the Advisory Committee on Novel Foods and Processes (ACNFP) assesses such applications (see paragraph 37) and can refer issues to other committees[153]. ACNFP has not been subject to the same criticisms as ACRE (see paragraphs 148-153) and its practice is generally commended (Professor James, QQ 648-9). There is cross membership between ACNFP and the other food advisory committees such as the committee on toxicology and the committee on medical aspects of food policy[154]. An ethicist sits on ACNFP and there is consumer representation on each committee (Mr Rooker, Q 607; Professor James, Q 648). ACNFP will eventually be responsible to the Food Standards Agency.

112.  The food is rigorously assessed for safety before it is approved or rejected. The level of surety and safety required was illustrated by ACNFP's chairman, Professor Bainbridge, who said that if the common (unmodified) potato were to come before the committee, it would not today be approved (Q 676). She argued that we know far more about novel foods than many of the staples of our diet and that novel foods which have been approved are at least as safe as their non-GM counterparts (Q 675). Intentional and unintentional changes are examined, as are the levels of key nutrients. The nature of the transgene is examined as is its level and expression. The food is tested for, amongst other things, stability, toxicity, allergenicity and mutagenicity (Zeneca Q 85; DETR Q 448; Professor Bainbridge, QQ 674-5, 685-7). Additional questions must be satisfactorily answered which are specific to each application (Dr Chesson, Q670).

113.  Any risk to human health may usually be attributed to known properties of the parent organism and of the transgene. The behaviour and track record of the gene in the donor organism can be studied and compared with the new organism. In relation to allergenicity, for example, assessment is based on the allergenic potential of the donor[155] and comparison of the transgene with genes known to produce allergic reactions[156]. Should the transgene not have a previous history of food use[157], while assessment would similarly be based on comparison and prediction, the appropriate outstanding information would also need to be gathered through testing (Professor Bainbridge, Q 685). The Royal Society is of the opinion that this approach may not be adequate in the future, should the use of genes without a history of food use become commonplace. Their statement considered that: "the current system of relying on identification of known allergens in the GM plant, coupled with the reliance on 'substantial equivalence'[158] may result in potential allergenicity problems being impossible to predict if there are no data available on the substances in question, particularly since the mechanisms of allergenicity are often poorly understood.". This was however put into context by Dr Chesson, who noted that, because the tests do not operate in isolation, if an allergic reaction was not predicted, any problem would surface during, for example, toxicity testing (Q 647). Professor Bainbridge argued that the system worked as well as it could in relation to assessing allergenicity[159] (Q 689). She recommended however that regulators should prepare for the situation identified by the Royal Society by establishing databases to compile pertinent information and allow it to be shared world-wide, so that regulators had access to the widest possible range of data (Q 685).

114.  There has also been disquiet over furthering the spread of antibiotic resistance through the use of antibiotic resistant marker genes[160] (GeneWatch, p 335) and we considered this issue in paragraph 0. Antibiotic-resistance marker genes should be phased out as swiftly as possible. Those developing GM crops have, in any event, now successfully developed alternative marker genes (Dr Chesson, Q 669).

115.  General concerns relating to unforeseen longer term effects have also been raised, especially in relation to the ability of scientists to predict the effects of the technology (Greenpeace UK, p 33, Q 101; CWS, p 311) and indirect effects of GM foods which may not manifest themselves for a very long period of time. These indirect effects would not be due to the safety of the technology, but the changes to diet and nutrition which may result from it. For example, if the quantity or type of fat in the diet is much reduced by means of GM food or otherwise, there may be long term health consequences. Foods which have long been available are not (and have never been) subject to the same care relating to their short or long-term safety as novel foods, whether genetically modified or not.

116.  We consider the regulatory process for assessing the safety of novel foods to be thorough and proper and we see no reason to doubt the safety of foods which have been approved by the regulatory process. All genetically modified foods on sale in the United Kingdom have been approved by this process and, as the FDF noted, by approvals processes around the world (Q 543). We consider that research needs to be conducted into how best to consider applications involving genes without proven track records of food use. We support the call for the accumulation and sharing of national data to assist regulators[161]. Any long term effects of GM foods are likely to be the result of changes in the nutritional content of those foods rather than the GM method by which the foods are produced.

TRACEABILITY

117.  Mandatory traceability must not be confused with "identity preservation" which is discussed in paragraph 131. Traceability is when the lineage of a finished product can be traced back to source. Were it to be required, it would primarily facilitate long-term monitoring for health effects of GM foods and product recall in the event of any adverse health effects. For this reason it was advocated by some witnesses (CEG, p 308; CWS, p 311; Safeway Q 250; NFU Q 311). ACNFP has yet to decide how GM foods ought to be monitored in the food chain[162], but Professor Bainbridge suggested that a lot could be learnt from analysing existing data (such as that possessed by supermarkets) rather than requiring new information to be gathered (Q 724). Mr Rooker indicated that the supermarkets were willing to share their data on consumption habits, collected through the use of loyalty cards (QQ 607, 611). Genetic modification does not concern a single product or variety but will soon affect the whole spectrum of agriculture. To require traceability for all agricultural commodities would be an exceedingly costly exercise[163] for little benefit, especially when there is no anticipated risk to human health. Furthermore, GM is but one technology applied to agriculture. It would be irrational to require the traceability of GM products but not those treated with novel fertilisers, preservatives or pesticides. Product recall is already possible without traceability[164] and in the remote event of there being a detrimental effect on human health an immediate and total recall would be necessary. A partial recall would only work if the system was precise and perfect and this could never be ensured. Traceability, though a theoretical asset, should not thus be required. Moreover, it is difficult to see how traceability could be achieved in the light of the quantity of imports likely to enter the Community from third countries, especially when those countries have deregulated GM crops (USDA, p 169).