GMP Management: Not Transparent Enough
In the European Union, GMPs are the object of an authorization procedure and monitoring governed by a directive and a European regulation. This has been put in place by the European Commission, the Council, and the governments of member states. A great deal of information is required throughout this procedure concerning both experimental GMPs (field tests) and commercial GMPs. This includes: scientific information for evaluation before authorization; commercial information for the purpose of labeling to better inform consumers; agricultural information to allow professionals in the field to know which products are being used and to allow local elected officials to follow the field tests of GMPs in their territory; and further scientific information to allow national authorities to follow the possible negative impacts on the local environment.
Missing Information at all Levels
And yet there is still a significant amount of information which is not demanded or made public. The lively debate taking place within civil society about GMPs is therefore cut short by a lack of the most complete and up-to-date information available – this limits its effectiveness. Schematically, the observed information gaps are as follows:
Experimental dossiers: The field tests of GMPs taking place prior to marketing requests need to be the object of a citizens’ consultation initiated by national authorities where the GMPs are being introduced. In France, these consultations currently take place over the internet, usually over the summer, in short time frames and at a technical level which demands specialized scientific or professional knowledge. Such a consultation procedure has already been deemed undemocratic by civil society actors since it does not put in place the optimal conditions to allow everyone to give their opinion or assure that it has been taken into account.
Scientific Data: Studies furnished by the petitioner after requests for commercial authorization for GMPs contain data interpreted according to analysis taken on the plant itself and not the raw data. The analyses allow the petitioner to biologically characterize their GMP, to compare it to a non-GM variety, and to evaluate its toxicity as it affects humans and animals. Today the raw results are therefore not made accessible to experts or the public. Moreover the interpreted data presented in the files are not made public beyond the circle of experts taking part in the evaluation of the authorization request. This situation has already been denounced as contrary to the basic scientific principle that all studies should be published in such a way that they can be reproduced by a third party. In addition, the analysis is conducted by the petitioners themselves and/or by the laboratories paid by the petitioner. No analysis is therefore undertaken by a public laboratory working independently.
Labeling: The European regulation imposes labeling of all crops containing GMPs or deriving from GMPs. The objective of this labeling is to provide information to professionals working in the GMP field and consumers at the end of the chain. One class of products remains unaffected by this mandatory labeling: products of animals which were fed with GMPs.
Locating Crops: Information concerning the location of commercial GMP crops is demanded by current European regulation. Member state authorities therefore need to inform citizens about the locations of these crops. But the European regulation does not stipulate the degree of precision for this information, leaving the choice to national authorities whether to indicate the region, department, commune or precise plot of land where the GMPs are located. This allowance for open interpretation on the precision of geographic information leaves the door open to the provision of useless information (eg. if the member state only indicates the region or department). In France, the law states that information must be made public indicating the exact plot of land with GM crops.
Tracking Bio-vigilance: Monitoring of experimental and commercial GMP crops – call it bio-vigilance – is required by current regulation in order to detect all negative effects on the environment. This monitoring is the responsibility of national authorities. Publication of bio-vigilance reports as well as reports of meetings of national bio-vigilance committees, however, are not systematic. This situation does not therefore allow citizens or non-governmental actors with vested interests in the debate to follow the work of national authorities in this domain.
“GMO free”: Professionals involved in quality assurance labels or certain crop systems wanted to put in place a “GMO free” label due to the risk of contamination by GMPs and in the interest of best informing consumers. This labeling scheme has not received much political support at either the European or national level.
The Association Inf’OGM (GM infO Association) was created in 1999 with the objective of creating a citizens’ debate on the subject of whether or not to adopt GMPs and in order to permit all of society to take informed decisions. Its ten years of existence and its daily monitoring of affairs bring Inf’OGM to present the following proposals today with an eye toward greater transparency in the GMP file:
- Put in place citizens conferences at the European level, where the final recommendations must be examined by political decision-makers so that public opinion and debate can be incorporated into final decisions
- Make the publication of all scientific studies furnished by petitioners who file requests for commercial authorization mandatory, along with the publication of the raw data from analyses that were conducted. This publication will in no way undermine the protection of industrial secrets because the studies only concern the results of analysis of the effects of GMPs.
- Create a real structure of independent scientific analysis, financed by industry.
- Make the precise location of plots of land used for commercial GMP crops available as it is in France in order to allow local agricultural professionals, elected officials and citizens to protect themselves accordingly
- Make the publication of bio-vigilance reports and the reports of national bio-vigilance committee meetings mandatory and make it mandatory for national authorities to take their conclusions into account
- Make the GMO community bear the costs of these measures.