We will now hear oral evidence from Roger Kerr, chief executive, and Steven Jacobs, business development manager, both of Organic Farmers & Growers, and from Joanna Lewis, policy and strategy director, and Christopher Atkinson, head of standards, both of the Soil Association. All the witnesses are with us in person. We have until 3.50 pm for the session. Will each of you in turn introduce yourself for the record, and then we will come to questions?
My name is Roger Kerr. I am chief executive of Organic Famers & Growers. I am also a trustee of the Organic Research Centre, which is an independent organic research organisation. I am also a director of the Organic Trade Board.
Q Welcome, lady and gentlemen. The organic industry currently keeps supply chains separate between organic and non-organic. I wonder whether you could explain how that system works and what you view as the challenges in carrying on that system, given the current legislation.
Organic is a regulated activity, so the requirements for organic production, including separation and segregation, are laid out in law. In the UK, that is currently a retained European regulation, No. 834. That mandates an inspection and certification system based on international norms for product certification. The way in which producers who are under the control system specified in the regulation notify their activity and interaction with independent third-party certifiers, such as Organic Famers & Gowers and the Soil Association, is described in that regulation.
It is very much a farm-to-fork regulation: it covers all parts of the production process, from the farm, beyond the farm gate, right through to the point of sale. There is complete traceability, which is overseen by the certification bodies and maintained through record keeping and some elements of testing and checking, which are carried out both by those who are subject to the regulation and by the certification bodies that oversee their activity.
Yes. At the moment, there is prohibition of GMOs in organic production, and organic producers rely on the current labelling regime to verify and identify freedom from GM. There is also a testing regime based on detection thresholds for GM specified in the legislation, and there are duties both on the producers and on the certification bodies to apply those requirements.
Q With respect, we are not talking about GM products but about gene edited products and precision breeding. Therefore, I suppose I would like to tease out why it does not work for precision-bred crops that arguably are akin to traditional breeding. In the animal world, we already have scientists at Roslin and so on working on avian flu in our bird population, and we have porcine reproductive and respiratory syndrome devastating our pig population. Looking some 10 years hence, are you saying that advances to combat such diseases would not be compatible in your current system, given that those are arguably beneficial in stopping an animal dying in distress? I am trying to understand your world, if you see what I mean. It will be quite difficult to undo the potential benefits.
Your mention of PRRS offers a good way to explain why the global organic movement currently does not support the genetic engineering approach. That movement is very much founded on the principle that you harness natural processes to stop pest and disease problems arising in the first place. For instance, PRRS is widely accepted to be a disease that arises from industrial farming systems as a result of overcrowding. The crucial thing is to make sure that there is a public interest test at the heart of the Bill, and that is what we are calling for.
We noted that the Regulatory Policy Committee has raised a red flag about the impact assessment—I am sure that it has been discussed before. We found that the impact assessment had overlooked three crucial areas: first, clearly, the freedom of choice for citizens; secondly, the needs and interests of organic agroecological farmers and growers, who have a key role to play in the Government’s ambitions for a sustainable farming transition; and, thirdly, the impact on the Government’s ability to achieve their own really important legal biodiversity and climate targets, and to address their professed concern about animal welfare and their desire to improve those welfare standards.
One does not need to doubt the good intentions of the research institutions that are involved in the research, but there are strong commercial drivers at play here. It is no accident that current and recent developments on gene editing of crops relates overwhelmingly to herbicide resistance. When you have four companies controlling 60% of the global seed market and two of them, Bayer-Monsanto and ChemChina, which owns Syngenta, account for more than half the agrichemical market, it is no accident that there is that commercial bias.
When it comes to the interests of farm animals, the Nuffield Council on Bioethics held a public dialogue on gene editing and farmed animals. The concern expressed by the public, now backed by the support of the Biotechnology and Biological Sciences Research Council, and Sciencewise—I am on the oversight group for that dialogue—was clearly centred not so much on the distinctions between gene editing and conventional breeding, but on the fact that the direction of travel for conventional breeding had been to prioritise traits that came at the expense of animal welfare and which facilitated the keeping of animals in inhumane industrial farming systems. The concern was that gene editing might accelerate that trend.
That brings us back to the question of where the public interest test is that could allow the Government to do more than just presuppose and gamble on the benefits of this for climate, nature and health. Norway has developed a gene technology Act, which places that public interest test at its heart. I do not know if that has been discussed yet, but there is a test that requires evidence of community benefit and support for sustainable development, so we would like to see that considered in the deliberation of this Bill.
Just to pick up on where we stand as an organic control body, our role is to maintain integrity through the whole chain of custody, from farm to fork and from seed to shelf. You cannot necessarily tell that a bottle of milk is organic by testing it—actually, there could be tests for that. You can tell a bottle of milk is organic because we have inspected every stage of the process. According to our licensees—and we license more than half the organic land in this country—that is not onerous. They already do various certifications, such as Red Tractor. Our inspectors will be able to do two, three or four of those in one visit. Asking the same question can generate two, three or four certification requirements.
The situation we have is one where there is an established market. In this country, it is worth around £3 billion. Globally, it is worth around $100 billion. It has been going for 60 or 70 years. The regulatory regime has been in existence since the early ’90s. That integrity is accepted in the marketplace and is being bought by shoppers. In the consultation, something like 85% of respondents said it was not that they necessarily objected to gene editing, but they would like to see existing regulatory frameworks upheld. We work in a regulatory framework. We have ISO standards. We are audited by a Government-approved auditor every year. That is how we ensure that that integrity is maintained. For us, those customers have said they do not want GE or GM.
Right, okay. I am not sure that I entirely understand why you feel it would be any different with GE, which is a completely different technique—with all due respect—from GM. If I could tease out that animal welfare point, you are predicating your argument on the idea that everything is detrimental on a welfare front. Surely the eradication of avian flu—particularly as we have had the challenge in the last year—would be beneficial to free-range birds as well. I am keen that the rest of the Committee has its chance to contribute, though.
Q Good afternoon and welcome. I am glad that you raised the impact assessment because there is a lot of interesting stuff there. Some of it is a touch surprising, which we will probably explore in more detail when we go through the Bill line by line. You already touched on some of this, but what are the threats from these developments for your sector? What would you like to see in the Bill to deal with those challenges, as you see them?
From an organic regulatory basis, as Chris has already indicated, GE is still defined as GM. We need to be much clearer about what GE is being defined as, and we still do not have that clarity. As things stand, it is not allowed within the organic regulation, so the risk is where there is a lack of co-existence measures in place, which means that organic crops are contaminated. Organic consumers make these purchasing decisions because they believe they are avoiding GM, and that is a right they should have.
By not having robust co-existence measures in place, we are obviously putting our consumers at risk, because they are purchasing organic products on the basis that they do not believe they are consuming GM. It is a personal choice—I am not saying that you should not—and the organic sector is not saying per se that we should not have genetic editing. What we are saying is that it is incompatible with organic. Organic is out there, and there is a market for it, as Steve has clearly stated. There is a significant opportunity, both domestically and internationally, for the UK organic sector.
We should protect the organic sector, and there should be some visibility in terms of GE—where it is being grown, what is being grown and what the potential risks associated with that are for the organic sector—so we can ensure that the organic sector remains free from GM or GE, as it is at the moment. There is concern that if we are looking to provide consumers with the choice of having GE or not, we will end up with quite a significant cost within the supply chain to ensure co-existence, in terms of space and time, between GM and non-GM. This is not organic per se; it is just GM and non-GM. We will then have to have extra storage, more vehicle movements and a much higher level of testing. There are concerns that, without real clarity about what is going on and where the potential points of contamination arise, a significant cost will be borne by the food sector, which is already under significant pressure.
I understand that you are addressing us as the organic industry and the organic sector, but I just want to reiterate that the Soil Association is a charity of 70 years’ standing that represents all citizens, farmers, growers and scientists who want to see a mainstream transition to agroecological farming and regenerative farming for climate, nature and health.
The response to the consultation on the Bill—85% of people and businesses were opposed—reflects a deeper unease not just about the safety issues and technicalities around the distinction between gene editing and GMOs. That is what I was trying to bring through with reference to the Nuffield Council on Bioethics’s public dialogue. It is really important to emphasise the very legitimate public concerns about the fact that breeding as a whole—plant and animal breeding—has been on an unhelpful trajectory that is not up to the challenge of the Government’s goals on sustainable farming transition. We therefore need to ensure that we are not accelerating that trend through carte blanche deregulation.
There is an opportunity to put good governance at the heart of this Bill, set that public interest test, and ensure full supply chain traceability, transparency and labelling for citizens who want and deserve the right to choose whether this is the solution for them. I would not want it narrowed down to saying we are representing an economic sector. This is a broader movement, and it is very much one for mainstream transition.
I would really recommend that you look to Norway’s gene technology Act. I have not gone through it line by line, but it feels like a valuable precedent from a country that also sits outside the European Union and is looking at what governance can apply—to make sure we are not just presupposing the benefits. Commercial drivers are not given free rein, and if there is to be a relaxation of regulation, you can do it with the confidence that it is going in the direction of supporting more sustainable farming. I believe the test that it set is that something is of community benefit and supports sustainable development. I do not know whether that is fully adequate, but it is a precedent that is out there and merits some consideration.
Q Clause 3 sets out the conditions under which a person can release a precision bred organism in England. Do you think the measures within that are sufficient? Probably not. I would be interested to hear where you think they might be strengthened.
You are right in supposing that we feel the measures are insufficient. We need a high degree of traceability and the ability for organic producers in particular to understand where crops are being grown and the risk of contamination.
The other aspect is that, as we have heard from previous speakers, there is not going to be a significant amount of investment in producing this material unless there is sufficient visibility over where it is, because of the likelihood that it will disappear into the food system and the businesses that have developed the technology will not be able to recover the costs. There is an issue in understanding the full and public visibility over where these crops are being grown, who is growing them and where they are going, so that there is the opportunity to see where that product has gone, so that people can recover their investment.
The Bill says that the organism is
“a marketable precision bred organism” and
“the qualifying progeny of a marketable precision bred organism”.
One of the issues is what will happen if there are—and we are assuming there will be—many precision bred events put into one product, whether that is livestock or crops. In crops, for instance, you can have stacked traits. The issue is around that crop being bred with something else and some of those traits being passed over, perhaps unknowingly.
We have seen incidents where herbicide resistance has gone out into the wilder environment and that has caused problems. For instance, there was a case on the Swiss-Italian border where herbicide-resistant oilseed rape that was not grown in Switzerland was found on the railway. It had leaked out of the railway carriages. That is a problem because they spray herbicide to keep the railway sidings—all the ballast—stabilised. Now, they have a situation where there is a herbicide-resistant weed in a location that would normally be sprayed in order to keep the railway safe. There are incidents where one would need to see some measure of traceability in order to evaluate. It is not just our need; I would suggest that there is a public and commercial need.
On livestock, take a genetically edited bull, for argument’s sake—I have picked cows because I like cows. He will have sired innumerable daughters that will go on to be crossed back. They may be crossed back with a non-GE sire. At what point do they become non-GE? Obviously, going back through their parentage, there will be GE material in there. From our point of view—from an organic standpoint—the question is: at what point is it no longer a genetically edited animal, if its forebears were genetically edited? There is a lot of concern around how we manage this issue, how those things are defined and who, ultimately, owns the genetic material within that animal, albeit it is the great-great-great-great-granddaughter of something. There are concerns there.
It also feels that the solution in terms of implementing supply chain transparency, traceability and labelling is eminently achievable. It does not feel like a big barrier to bring that into the scope of the Bill in order to address those concerns and allow the legitimate needs of citizens who reserve the right to choose to reject this technology, and to preserve the integrity of organic systems. We are obviously at a point in time where the industry is buzzing with big data supply chain solutions and wanting a whole new resurgence in food labelling to show the citizen everything about the provenance, origin and production practices of their food. It should not be a big barrier to this Bill’s intent to include that requirement for full supply chain transparency and labelling.
Q So a real commitment to transparency and some effort to address the possibilities of unintended consequences on the back of this need to be tightened up in the Bill?
Going back to what was being said about animals, particularly what Joanna was saying, I want to try to unpick this. It has been mooted that one of the benefits of the Bill is that it could result in the breeding of more disease-resistant animals and in less use of antibiotics in livestock management. The downside is that that could pave the way for more intensive farming, because disease obviously spreads when lots of animals are herded together. That does not necessarily mean that making animals more disease resistant and not having to use antibiotics on them is a bad thingQ .
Some witnesses who gave evidence this morning said that it is not the Bill that is at fault. There is a completely separate argument, they said, about whether we want to increase the intensification and industrialisation of animal farming. Where do you sit on that argument? They said that the animal welfare codes deal with some of the concerns. I would say, however, that they are not operating in the right way at the moment, because we already allow a degree of intensification and, to my mind, animal welfare standards are not good.
On the separate issue of increasing yields from animals, cows produce an awful lot more milk than they would have done a few decades ago, and certainly a lot more milk than they need to feed their own calves. Where do you sit on the use of this technology for that purpose? Finally, do you think that the Bill’s provision for the Secretary of State to refer things to a welfare advisory body is a sufficient safeguard? Sorry, that was an awful lot of questions, and you do not have much time to answer.
You asked whether you can separate the intention of gene editing to solve animal welfare problems from the broader challenge of facilitating the perpetuation of systems that result in very poor animal welfare. I think it is important that we bring these together—as the public brought them together in the Nuffield Council on Bioethics public dialogue. We know that conventional animal breeding trends have been to prioritise greater yield, litter size and fast growth over the welfare of sentient animals, and we know that the argument for gene editing is partly that it speeds things up and is likely, therefore, to accelerate those trends. The public were saying, through that dialogue, that this is where they want to see governance. They want the Government to come in and say, “This is our vision for the future of animal farming. This is how it is going to become a higher welfare system that also delivers for climate, nature and health. This is the role we want to see gene editing play in that context.”
I know that you will be hearing evidence from Compassion in World Farming on Thursday, and I know that amendments will be proposed to try to make sure that there are additional tests—which could be linked to the Secretary of State’s powers, secondary regulation or the role of the welfare advisory body—on whether these traits are going to focus on yield, litter size and fast growth and cause lasting harm to the welfare of the animal. Also, are they going to perpetuate, facilitate or enable a farming system that is very detrimental to the welfare of animals? Those are the amendments that will be coming through from animal welfare bodies.
In terms of the disease-resistance issue, we have to be really careful about how we approach this. What we have seen, albeit through the use of antibiotics, is the reduction of disease. Again, unfortunately, I am referring back to the dairy industry. We have seen farmers driven to reduce cell counts in dairy cows to a point where the cow’s immune system has been suppressed to such a degree that the more virulent diseases come in, because there is not the natural, more benign flora around any more. Therefore, you have cows going down with E. coli and other things, which is killing them. We have seen this continual drive to reduce the immune system and reduce the cell count.
What we have found more recently is that allowing the cow to have a more natural immune system actually allows it to live a longer and healthier life. We have to be really careful when we start talking about disease that we do not start messing with something but then find that we end up with a whole lot of unintended consequences in terms of opening the animal up to other disease implications. Ultimately, we will just end up on the same old wheel of trying to continually firefight because the animal is going down with disease.
On the yield aspect, again, we can keep saying, “Oh, well, we can genetically breed them to produce high yield,” but what we find is that the longevity of the animals is massively impacted. These cows that can produce 12,000 or 15,000 litres of milk do not live very long because, unfortunately, cows are just not designed to do that. We have to be really careful about what we consider to be a farm animal and what it is there for. If we continue to drive it, we are effectively supercharging its physiology, and therefore it will ultimately not be able to live as long.
Using cows as an example, if you go into a collecting yard or a cubicle shed, you will see the cows breathing really quickly, even though they are lying down, because their physiology is going so fast. What we are effectively doing at the moment is turning what was a very low-input, low-output animal into a Formula 1 car. Unsurprisingly, they do not cope with it and they fall over. What we are doing now in terms of genetically editing is stepping that up a whole other gear. We have to be really careful about what it is that we are seeking to achieve here, and I think we have to look, in terms of welfare, not only at disease resistance but at longevity, quality of life and ability to withstand other disease impacts.
Q Is one of the concerns when it comes to the hormones of an animal—I am talking about animals that are being killed for meat; I know that this came up in the discussion about slaughterhouses —that if the animal is stressed throughout its life, that could affect the meat from a human health point of view?
Going back to what you said about what sort of tests should be applied to animals by any regulatory committee, the Farm Animal Welfare Committee introduced the concept of a good life for animals. Our view of animal health and welfare is based on positive aspects of an animal’s life. You have referred to the codes of practice; generally, they are based on absences of harm. For a long time in animal welfare science, absence of harm was equated with good welfare. We have moved significantly beyond that, so we would encourage you to look at the good life framework and ensure that those tests for a good life for animals are applied to any traits and outcomes.
On your point about slaughterhouses, we talk about a good life, but we also talk about a good death. It is important to recognise that a lot of stress is experienced when animals have to be moved a significant distance, or even away from the farm and environments that they are familiar with. The fundamental issue is how many abattoirs we have and how far animals have to move. To say, “Oh, well actually, what we’ll do is we’ll genetically manipulate their genes so that we can transport them hundreds of miles before we kill them,” seems to be a perverse and illogical approach.
Q I was more asking whether stress—you were talking about being able to increase yields, and about cows being put under stress—would affect the animal’s meat in the same way that—
I am not sure. We were talking about dairy cows, which, as you know, are not bred to be eaten. Beef animals would be different again. There is an issue around stress with killing an animal, but that is more about the environment that it is in. I think we should look at that in a holistic way in terms of the environment and not necessarily just say, “Let’s tweak something so that we can still treat—”