GM Free Cymru

(7) Verbal Presentation by BSJ 26 April 2010

Name: Brian John Postal Address: Trefelin, Cilgwyn, Newport, Pembrokeshire SA42 0QN, Wales, UK Nationality: Welsh Title of Petition 0813-08: The importance of impartiality within EFSA & the food safety rights of EU citizens


Thank you for the opportunity to speak to you about my Petition. My concerns arise out of the fact that EFSA's GMO Panel routinely makes decisions which might damage the health of millions of EU citizens, without any effective intervention from any other body. It is an unelected panel which undertakes risk assessments; but it carries no responsibility for risk management and it evades all legal liability for its decisions. I therefore protest in my Petition about the defective manner in which EFSA processes and assesses scientific evidence, and forms its "opinions" on GM products. I also wish to state that I am dissatisfied with the Commission responses to my Petition.

These are my main concerns, elaborated (with references) in my Petition and following submissions:

1. EFSA regularly issues positive "opinions" on GMOs which are based on selected data provided by the applicants. These studies are not replicable (because the GM patent holders will not allow independent scientists to have access to their GM products). This is unacceptable. Scientific trials MUST be repeatable if they are to be trusted. Moreover, EFSA sometimes disregards "independent" studies or declares them "unreliable" without a clear justification.

2. The composition of EFSA's GMO Panel of scientists is inadequate to deal with the demands placed upon it. It does not have good representation from agronomists and environmental biologists, or from experts in toxicology and health effects. There should also be scientific representatives from European NGOs and consumer groups. The Panel has a history of close links with the GM industry, and some of the Panel experts are also involved in national advisory committees, who then have two opportunities to influence decisions.

3. The biggest problem with EFSA is that the requirements for GMO applications are not concrete enough to allow for proper risk assessments. (Also, the Commission's "Draft Implementing Regulation" sent to the WTO makes matters worse, introducing far too much discretion into the application and approval process). Clear research standards must be set. First the parameters must be defined, then the research must be carried out strictly as required. (For example, it is unacceptable to test isolated or surrogate proteins instead of whole plants, to assume that "stacked events" are as safe as their individual components, to allow the results from very short-term animal feeding studies to be taken as valid, or to omit effects on non target-organisms.) The Draft Implementing Regulation could solve these problems (at least to some extent), but in its present form it waters down the existing EFSA guidelines and seems to pave the way for "fast-track" approvals.

4. EFSA does not make full and early release of the data contained in GMO application dossiers. Independent testing can only be done post- release (if at all) because of excessive use of "Commercial in Confidence" claims. (For example, the full data on MON863 was impossible to obtain, until EFSA was forced by a court ruling to release it.)


In spite of the many serious problems I have identified, I consider that it is not too late for the Parliament to take action to increase its own authority in the matter of GM policy and to enhance the protection of EU citizens. The Commission and EFSA appear to have done remarkably little to implement the recommendations of the Environment Council of 4th December 2008. I therefore respectfully ask the Committee to bring forward the following suggestions to the Parliament:

1. Place it on the record that the Parliament will insist that EFSA's GMO Panel must be reformed to include a much broader base of representation.

2. Place it on record that all research contained in application dossiers MUST be replicable, and that applicants will henceforth be required to confirm in writing, in advance, that they will provide their genuine GM products, comparator isolines and reference materials to independent researchers -- if necessary, prior to approval being given.

3. I ask Parliament to condemn, by resolution, the following: (a) over-dependence upon scientific evidence produced entirely under the control of the applicant; (b) the use of any results from scientific experiments that are, for whatever reason, non-replicable; (c) the blocking of independent research through "non-cooperation" by GM corporations and patent holders. (d) any actions by EFSA to prevent full release of research dossiers for peer review BEFORE the formulation of opinions; (e) any attempts by EFSA to water down or speed up application / assessment procedures for future GM products; (f) any attempts to "simplify" the safety study requirements for "stacked" GM events; (g) the vilification and intimidation of independent scientists who happen to discover GM-related health and safety effects.

4. I ask Parliament to insist that truly independent studies relating to the safety of GM products are ALWAYS brought into the risk assessment process and given due respect.

5. I ask Parliament to encourage greater involvement by the Member States in risk assessments, and to remind both EFSA and the Commission that where there is disagreement and uncertainty, the Precautionary Principle should always come into play, with a view to providing maximum protection for the health of European citizens.

I am very grateful to the Committee for allowing me to bring this Petition forward, and I respectfully ask for careful consideration of the points I have raised.

Dr Brian John GM-Free Wales