GM Free Cymru

Science, Politics and Ethics in the approval of GM Crop Varieties

Brian John
GM Free Cymru (Wales)

Barcelona Conference
Som lo que Sembrem
6th March 2009
Residencia d'Investigadors (Hospital, 64. Barcelona; http://www.residencia-investigadors.es)

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I am grateful for the opportunity to speak to this conference, and pleased to be able to bring with me the greetings of my colleagues in GM Free Cymru. We are working in Wales to keep our GM Free status, with cross-party support in the Welsh Assembly and across the country -- and with an Assembly Government that sees a real competitive advantage in keeping GM crops out of Wales, with the use of all legal means possible (1).

I have been asked to examine the GM approvals process in Europe, with particular regard to science, politics and ethics. These three are closely entwined, as we shall see. Perhaps I should have entitled this talk "Malpractice and Corruption in the GM approvals process" -- in some ways that might have been more appropriate, given the powerful evidence that we have assembled over the past eight years (2).

Science

How should GM science be conducted? Well, it should be like all other science, based upon a rational process of observation, data collection and recording, working hypothesis formulation, experimental work and hypothesis testing. According to the guidelines drawn up by the philosopher Karl Popper, science cannot advance through work designed to confirm hypotheses -- since those hypotheses then become ruling hypotheses, and science quickly becomes corrupt. The ideal should always be to strive for hypothesis falsification and refinement -- and in this way the scientist will retain his integrity and will make gradual progress towards the truth. Sadly, in the fields of GM science related to health and safety, scientists are for the most part signed up to the affirmation of one ruling and commercially-driven hypothesis -- namely that GM crops are entirely safe for consumers and for the environment. In other words, they are no more harmful than the isolines or conventional varieties from which they are bred.

But GM crops and foods ARE different -- that is the whole basis of the EU regulatory framework (3). To get onto the common seeds register GM crops have to be distinctive, uniform and stable. That is hardly ever demonstrated in reality, and while GM varieties are generally agreed to be distinctive, they are also known to be non- uniform and unstable. On that basis they should not be allowed a place on the Seeds Register. The approvals process has become distorted to suit the GM applicants, who are powerful, wealthy and adept at political manipulation and lobbying. So the EU has allowed itself to be bullied by the US in particular into accepting science that is frequently corrupt.

Because GM crops are unique, they should be treated as drugs in the approvals process. In fact, their regulatory control should be even stricter. Drugs are intended for sick people, to help them get better, but GM foods will be fed to everybody without discrimination. There will be no way of escaping them -- they will be everywhere. The strategy of the biotechnology corporations (both American and European) is to contaminate by stealth, until we arrive at a situation where there is no longer any genuine GM-free soya or canola (for example) available on the world market. A similar strategy is being employed with Golden Rice.

But instead of a tight and unique regulatory regime for GM crops and foods, in the US there is effectively no regulation. Somehow or other, the scientific community has allowed itself to be fooled by an extraordinary piece of public relations and political / economic manipulation. Central to this conspiracy is the absurd concept of "Substantial Equivalence" (4). Essentially, it has been used by the GM corporations (with the connivance of the US administration) to minimise scrutiny of GM crops and foods and to facilitate approval and commercialisation. Then there is another absurd concept. The term "Generally Recognized as Safe" (GRAS) is used often by the GM industry to describe its new GM varieties; and the usual reaction of USDA and EPA is to say "Well, if you say it's GRAS, then it probably is." That reaction is scientifically and ethically indefensible, as well as being intellectually lazy. We have every reason to be thankful that this phrase is not much used in Europe. Then there is another concept which is creeping into the literature -- namely the "Concept of Familiarity." This concept is being used in the promotion of Golden Rice -- an unauthorised and untested GM variety which is being touted as a means of solving the medical problems associated with Vitamin A deficiency in the poorer nations (5). Quite cynically, Golden Rice is promoted under the slogan "It's just rice!" In other words, "there is nothing at all unusual about it, and it should be allowed to enter the food chain without any regulation whatsoever".

All of these three concepts are totally nonsensical from a scientific point of view -- and they are designed to encourage complacency and to avoid rigorous scientific testing and appraisal. To their eternal shame, the European regulators do appear to have been influenced by them. But why has not the scientific community risen in protest across the world? To its shame it has (apart from a brave few) gone along with this uniquely dangerous conspiracy -- putting the safety of the whole planet at risk.

There is another profoundly dangerous tendency within the approvals process, and that is the gradual abandonment of the precautionary principle and its replacement by something we can call the "anti- precautionary principle." In both American and European law, any new additive to the food supply (such as a new GM food crop) must be presumed to be unsafe until it is demonstrated through scientific procedures that it is safe (6). There must be a reasonable certainty of no harm to those who consume it, and a burden of proof should be placed on the manufacturer. In Europe, the Precautionary Principle is used in Directive 2001/18/EC relating to GM crops, and it should also be used in all national or subsidiary legislation. In reality, the Americans have abandoned that principle with respect to GM crops and foods, and have replaced it with a principle that says, in effect: "All GM crops and foods will be presumed safe until somebody comes along and proves otherwise." In Europe things are moving in the same direction; and in the UK one of our Government Ministers recently stated that the onus is now placed on the opponents of GM to provide him with evidence that GM crops and foods are harmful, in spite of the fact that he is already in possession of such evidence.

Now I want to turn to the conduct of GM science within the EU. Within the EU countries, a great deal of GM research is carried out within biotechnology laboratories and university departments; much of it is honest "pure research", and much of it is published in peer- reviewed journals. But most of this academic work is not related to toxicity or safety issues. Where research is conducted on the actual GM varieties intended for commercialization, honest academic research quickly becomes impossible, because the owners of the GM patents insist that they must "own" every aspect of research based upon their patented seeds and plants (7). Normally they fund the research. In English we have a proverb that says "He who pays the piper calls the tune." So honesty and integrity disappear from the laboratory and the field trial site.

The science that comes before EFSA and the national regulators for assessment and opinions comes in the form of dossiers and supporting papers and annexes. The dossiers are carefully assembled, and everybody knows that the applicants simply do not include any information or experimental results that might damage the case being made for approval. In English we call it "cherry picking." So the science is always "advocacy science" and not empirical science; and on those grounds alone it should be ruled as inadmissable. But it gets worse, for the science is also NON-REPLICABLE, since the GM patent holders simply will not allow the use of their GM reference materials, seeds or plants to be used for genuinely independent research which seeks to verify, test or improve upon the results reported in their dossiers. This contravenes the most important of all scientific principles -- namely that any scientific experiment, if it is to be accepted as valid, MUST be adequately described and replicable (8).

On both counts the science brought before the national regulatory committees and before the GMO Panel of EFSA should be disallowed, since scientific fraud is almost inevitable.

From our investigations, we have discovered that these are some of the common tricks used by applicants for GMO consents (9):

1. Experimental designs calculated to mask undesirable effects 2. Very short experiments -- inadequate to show up real physiological changes 3. Use of surrogate proteins rather than the actual proteins contained in GM crops and foods 4. Data aggregation in order to mask significant effects 5. Stratification of samples to mask out undesirable effects 6. Statistical manipulation of results 7. All science conducted in house or with "friendly" laboratories 8. Use of identical feed for all groups in feeding experiments 9. Use of "nutritional studies" instead of acute toxicology studies. 10. Feed preparation in animal feeding experiments which destroys potentially toxic material 11. Use of unrealistically small percentages of GM material in feed 12. Suppression of studies that do show undesirable effects

While these practices are universally condemned by NGOs and consumer groups, EFSA tends to turn a blind eye to them. Very occasionally, the GMO Panel will highlight deficiencies in dossier research results -- but instead of suspecting scientific fraud it generally communicates concerns about minor defects in the research process. Only very rarely does it ask for complementary studies to be undertaken; it NEVER insists on truly independent work, and NEVER commissions work itself, except for rather abstract reports on methodology. Sometimes, it will ask for an outside "opinion", but if it does not like the opinion it will commission another, and another, until it gets one that it does like!

Politics

Politics has a powerful role to play in the GM approvals process, largely because most of the applicants for GM approvals are powerful corporations (including Monsanto, Syngenta, Pioneer, Bayer, and BASF) and because the United States and Canada need to promote their own trading activities by placing GM products (mostly GM soy, maize and canola) into the European marketplace. At an international level, there is huge US and Canadian diplomatic pressure -- including diplomatic blackmail -- designed to open up the European market and to break down the relatively tough GM regulatory system that we have in Europe. On a continuing basis, the US makes cynical use of the WTO to exert pressure on the EU Parliament and on the Commission. The Parliament is not too concerned, but the Commission is easily swayed -- with a majority of pro-GM Commissioners and a pro-GM President Barroso. For political reasons (to maintain good relations with the USA and the WTO) the Commission want to "give" GM approvals on a regular basis. The WTO case a few years ago (10) was political bullying on a massive scale, which resulted in a political fudge and no clear victory. But the Commission does not want another WTO case, and is prepared to go a long way to appease the Americans by showing that in Europe the scene is being set for GM crops and non-GM crops to grow side by side without any problems. That aspiration is fanciful and even dishonest -- since the Commission already knows from a multitude of scientific studies that cross-contamination is inevitable and that coexistence is impossible (11).

Within Europe, some governments are more well-disposed to GM technology than others (12). The voting patterns of the Environment Council and other committees reveal where the power lies. Under the EU's complex weighted voting system, countries have varying degrees of influence in a decision and must try to reach a consensus or "qualified" majority. The largest countries have the most votes, and if there is deadlock (as usually happens) then the decision goes back to the Commission, which always follows the advice of EFSA. Quite often France, Greece, Austria, Luxemburg, Hungary and Germany vote against GM approvals and oppose the Commission, whereas the UK, Spain, Ireland, Poland, Finland, and Netherlands often hollow the Commission's line. Many countries side with one group or the other depending upon which GM crop is being considered or which country has a strong vested interest; ancient political alliances and rivalries are often more important in the voting process than careful assessments of scientific evidence. In the UK there is currently a great deal of anger in Wales, Scotland and Northern Ireland (the devolved administrations) because their views are simply dismissed by the London Government when it comes to GM votes in the EU. The wishes of these 3 "competent authorities" are for a GM moratorium, and for support for the MON810 bans in Austria, Greece and France -- but the UK Government will, as usual, betray the majority wishes of its partners in the GM "Concordat" and vote with the Commission on all of these matters (13).

Now I turn to EFSA and the National Regulatory Committees. The GMO Panel of EFSA contains "experts" from many of the member states. They are hand-picked individuals with GM academic interests with established industry links -- and since they all have jobs in the biotechnology / GM industry, they clearly have a vested interest in seeing it develop and flourish. Those personal interests have been allowed to override what should be their priority -- to protect the European population (and the environment) from harm. So the EFSA GMO Panel sees itself as a body whose purpose is to facilitate GM approvals (14). It has been heavily criticized over the last eight years for failing to incorporate representatives from NGOs and consumer groups on its GMO panel, and for failing to take account of the views of the public on scientific, ethical and social matters. In the coded language of diplomacy, even the Commission has been highly critical of the working methods of EFSA, and there have been many calls for it to be reformed. A German group is currently investigating the prospects for a legal challenge to EFSA on the basis that its assessments of GM crops are corrupt, and I have personally taken a Petition to the European Parliament (15) in which I claim that through its behaviour (ie through its GM approvals and its denial of evidence of harm in the scientific literature) EFSA has denied me my citizen's rights to safe food and good health.

In the UK the main GM Regulators are two supposedly independent advisory committees -- the Advisory Committee on Releases into the Environment (ACRE) and the Advisory Committee on Novel Foods and Processes (ACNFP). Then we have the Food Standards Agency (FSA) which is supposedly "an independent Government department set up by an Act of Parliament in 2000 to protect the public's health and consumer interests in relation to food". There is no such thing as an independent Government department. The FSA has, ever since its establishment, supported GM crops and food at every opportunity, while minimizing the risks and overplaying the benefits. Partly, this promotion of the interests of the GM industry relates to the appointment of a great GM supporter in the person of Sir John Krebs as FSA Chairman. He also had strong links with the Royal Society and other organizations known to be active in promoting GM crops and foods. The FSA's complacency relating to GM food led to a judicial challenge (16) from FoE in 2007, when FSA failed to take decisive action to keep contaminated rice out of the UK food chain following the LL601 scandal in the United States, and actually seemed to encourage retail outlets to turn a blind eye to the presence of contaminated products on supermarket shelves. The Department for Environment, Food and Rural Affairs (DEFRA) orchestrates everything in all three of these supposedly independent bodies, as a result of which they slavishly follow the UK government line of "finding no fault with GM crops and foods." The members of the committees are hand-picked to ensure that nobody rocks the boat; DEFRA provides the secretariats, writes the agendas and the minutes of meetings; DEFRA conducts off-the-record briefings of Chairmen and other key personnel; and DEFRA personnel sit in on meetings and provide "advice" to committee members as to how they should behave, what they should think, and what decisions they should come to. To any independent observer, this would be seen as corruption at the heart of the decision-making process. I suspect that in many EU countries there is not such a carefully-orchestrated and supposedly independent GM assessment system in place; but in those countries which do have similar committees, they are probably just as corrupt.

Ethics

The word "Ethics" encompasses proper conduct and "good" or worthy living. It is essentially about behaviour, and ethical behaviour is normally assumed to be moral in that it incorporates care for others and the environment, moderation, responsibility and sensitivity. There have been many attempts to define scientific ethics. When Professor Sir David King was Government Chief Scientist in 2007 he attempted to define seven principles of scientific ethics (17), as follows:

1. Act with skill and care, and keep skills up to date. 2. Prevent corrupt practice and declare conflicts of interest. 3. Respect and acknowledge the work of other scientists. 4. Ensure that research is justified and lawful. 5. Minimise impacts on people, animals and the environment. 6. Discuss issues science raises for society. 7. Do not mislead; present evidence honestly.

When we apply these principles to "the conduct of GM science" we see that they are systematically broken or abused (18). For example, a good deal of the science in the GM dossiers is incompetent and corrupt, to the great delight of companies like Monsanto and Syngenta. It has been suggested that they sometimes deliberately employ gullible or incompetent technicians to do work that should be done by experienced scientists. Deliberate falsification of results happens all the time, as confirmed by many who have worked within the GM industry. Scientists who discover inconvenient facts about GM are routinely vilified; here we can name (for example) Arpad Pusztai, Irina Ermakova, Manuela Malatesta, Ignacio Chapela, and Angelika Hilbeck as people who have dared to find problems with GM crops and foods and who have had their careers all but destroyed by the GM industry and its hit men. The principle seems to be "shoot the messenger" -- but the industry is apparently not smart enough to realize that messengers, when they are shot, become martys and heroes, and cause people to develop a profound mistrust and even hatred towards the bullies and thugs who work for the GM cause. The concept of justified and lawful research has been twisted so as to argue, as often as possible, that there is no need for research because GM varieties are substantially equivalent, or that hybrid varieties with stacked GM traits are no more harmful that the varieties they are bred from. Whereas GM scientists are supposed to minimise their impacts on people and the environment, the GM industry as a whole is associated with large- scale industrial or agrochemical farming systems that maximise social and environmental damage across the board. Scientists involved in GM research and development do occasionally engage in the discussion of social issues, especially with respect to global hunger and food security; but almost always in my experience the points they make are driven by the commercial imperative and are directed by the GM industry spin machine. When it comes to the requirement for honesty, we find that papers purporting to show that GM is harmless consistently mislead, through the range of familiar techniques mentioned above.

Maybe there should be an eighth principle on the above list: "Publish honestly, and do not cite data selectively." All authors who are seeking to argue a case or prove an hypothesis tend to cite references selectively, with a preference for those published sources that show similar effects or draw similar conclusions. But DATA should always be reported honestly, and there should certainly be no place in the literature for so-called "learned papers" which hide or obscure observed effects simply in order to satisfy the requirements of employers or patent holders. This happens all the time with respect to publications in the GM field -- whether or not they are peer-reviewed. Where GM science is funded by the biotechnology corporations, they mainain a power of veto over publication. Many studies have never seen the light of day, since they have thrown up "inconvenient" results. We have been in contact with many scientists who have been "leaned on" by their employers or institutions, and who have had to rewrite their papers over and again to the point where they become "acceptable" and in line with GM orthodox opinion. Recently a group of 26 scientists in the US (19) complained that they were being prevented from conducting honest and open research by the GM seed owners and by their technology use agreements -- often through shutting off a supply of the raw materials needed for field or laboratory research. Interestingly, the scientists were too frightened to give their names. That says a lot about the "climate of fear" which surrounds the research operations of the GM companies.

This case emphasizes the fact (see above) that the most unethical aspect of the experiments associated with GM (under the control of the industry) is the point blank refusal by the industry to allow reference GM materials or GM seed, foliage or feed to be used in truly independent studies. As a consequence, studies conducted by or for GM corporations are are NON-REPLICABLE. And truly independent studies are simply blocked. This is not simply a matter of bad science -- the practice is utterly unethical and indefensible. As indicated above, any scientific experiment which cannot be repeated or duplicated should immediately be thrown into the rubbish bin.

I will conclude with a few examples of the manner in which GM science has been corrupted in the last few years.

(1) The case of the Ermakova set-up (20). When Russian scientist Dr Irina Ermakova revealed the results of her studies of rats which had been fed on a diet of GM soy in 2005, there was immediate and widespread press coverage, since her findings indicated that the fertility of animals fed on the GM material was compromised, and that the survival rates of offspring were dramatically reduced (1). The GM industry and the regulatory bodies in Europe and elsewhere were not best pleased, and they tried to marginalise and vilify Dr Ermakova, to demonstrate that her research methods were fundamentally flawed, and to spread the message that her findings were anomalous and untrustworthy. In the summer of 2007 a group of four scientists (Bruce Chassy, Val Giddings, Alan McHughen and Vivian Moses) contacted the Editor of Nature Biotechnology and asked him if he would facilitate an opportunity for them to attack the research methods and findings of Dr Ermakova. He went along with this request, and invited her to answer a set of agreed questions about her research for publication in the journal. She agreed, and was given the impression that this would be her paper, with her name on it. She was not told that the four GM industry advocates would be given the opportunity to dissect her answers by liaising with one another, and that their comments would be given prominence in the article. She was even sent a "dummy proof" with her name beneath the title. The dummy proof did not contain the aggressive and dismissive comments of the "group of four." When the article was finally published, Ermakova was amazed to see the critical comments for the first time, to discover that authorship was attributed to the Editor, Andrew Marshall, and to find that her "assassins" had even been allowed space for citations and additional references while her own citations had been reduced. This is the worst case of editorial and publishing malpractice that I have ever encountered, and the fact that the Editor was not sacked shows that the editorial board of Nature Publications was broadly supportive of his behaviour. Nature Biotechnology is no longer a responsible journal publishing impartial peer-reviewed papers -- it has become a "trade journal" promoting the interests of the GM industry.

(2) The case of the fraudulent survey of farmers' attitudes to GM crops (21). In February 2008 a press statement was widely disseminated in the UK, beginning with these words: "Farmers are upbeat about genetically modified crops, according to new research funded by the Economic and Social Research Council (ESRC)." The lead author of the research report, Prof Andy Lane, was quoted as saying “New technology such as GM is attractive to farmers". The wording of the press release was manufactured to give the impression that the findings of the study referred to the UK farming community as a whole -- and it was clearly the intention that the first sentence of the piece would be widely quoted by the media. It turned out, on investigation, that the views of only 30 carefully-selected large- scale commodity farmers had been canvassed, and that a group of bodies involved in the promotion of GM technology were involved in setting up the research and in supervising its conduct and reporting. The sample of farmers questioned was not just statistically insignificant; it was blatantly biased. The study was, in reality, nothing more than a cheap pro-GM propaganda stunt. The real scandal is that £131,000 of public money was spent on it, and that the corrupt research was done by a team from one of the leading UK universities.

(3) The case of the "fixed" farm-scale trials of GM maize (22). In 1999-2003 the UK Government funded a series of "farm-scale evaluations" designed to discover whether GM crops (maize, oilseed rape and sugar beet) were harmful to the environment when compared with their non-GM counterparts. About 300 fields were due to be planted with GM crops, in many different parts of the UK. From the beginning there were not only protests and direct actions against the sites where GM crops were planted (causing many trials to be abandoned), but also concerns in the science community about the design of the experiments, which appeared to have the objective of maximising wildlife and minimising yields. In other words, the trials would not be replicating real farming conditions. In the event, the trials of oilseed rape and sugar beet showed without doubt that the GM crops did damage the environment, with the result that the experimental methods were not heavily scrutinized by critics. In the case of the GM maize, the researchers found that it was less damaging to the environment than conventional maize. However, investigations showed that the GM maize trials were fixed to minimise the environmental effects. The conventional maize plots were sprayed with Atrazine, a dangerous herbicide which is highly toxic to insects. On the other hand, the GM maize plots were sprayed with the herbicide Liberty - glufosinate ammonium - just once between planting and harvest. Bayer, which had developed the maize variety, effectively conducted the trials itself. It stopped farmers from spraying more than once with the result that weeds - and insects - proliferated in the GM crop, so that in some cases it yielded only half the tonnage of the non-GM maize. There were no studies of horizontal gene flow, or of soil microbiology, or of the unique effects of using specific proprietary insecticides and herbicides with specific GM crops. There were no extensive studies of cross- pollination, pollen drift or adventitious occurrences of GM varieties or GM hybrids. In addition, the seed owners were allowed, within the FSE programme, to vary the densities of seeds planted and to carry out their own "off the record" trials on germination rates, ground coverage and so forth. This interference in the farm management of the crop was unscientific and unethical. In the analysis of results, the null hypothesis ("that there was no difference between the management of GMHT varieties and that of comparable conventional varieties in their effects on wildlife abundance and diversity") was not tested properly; the GM plots were managed in order to achieve cost-effective weed control, and the non-GM plots were managed in order to maximise yields. The overall conclusion of the trials was that GM crops do indeed damage the environment; and for that reason the UK government now appears to have forgotten that the experiments ever took place!

(4) The case of Golden Rice (23). For the last few years the Syngenta Foundation and the Golden Rice Humanitarian Board have been promoting a GM rice variety called Golden Rice as part of a grand humanitarian gesture which will solve the apparently intractable problem of Vitamin A deficiency in many of the poorer nations. It contains enhanced quantities of beta-carotene, designed in turn to enhance the Vitamin A content of the plant. Syngenta boasts that it has donated the patents for Golden Rice to the world, whereas it has done nothing of the sort. Golden Rice is promoted as "just rice" -- and in most of the literature there is no admission that this is an untested and unapproved GM variety which may well harm health rather than improving it. The leading figures in the Golden Rice Project are using the variety to exert emotional or moral pressure on NGOs, and as a vehicle for dismantling regulatory controls in those countries which have them. They also intend to ensure that such controls are not introduced in other poorer states. The Golden Rice Humanitarian Board argues, with a snake's tear in its eye, that regulatory barriers are causing great delays in bringing their wonder product onto the market, resulting in ongoing suffering in Vitamin A deficient populations. The Bill and Melinda Gates Foundation is heavily implicated in this despicable campaign, and it has recently given $5.4 million to be used for political and lobbying activites (and probably diplomatic and economic blackmail as well) designed to break down regulatory resistance to GM crops in Africa. One of the most disturbing aspects of the Golden Rice Project is the use of sick children in China in Golden Rice feeding studies -- in effect using them as "laboratory rats." No animal studies measuring Vitamin A uptake from Golden Rice have ever been done. This is a deliberate tactic, justified on the grounds that "there is nothing different about Golden Rice" apart from the enhanced vitamin content. These tests in children are in clear breach of the Nuremberg Code; we are sure that neither the children nor their parents have been told that the rice is untested, unauthorized, and genetically modified. We are not talking here about experiments as sinister as those of Dr Josef Mengele in Nazi Germany, but we are talking about a profound and very dangerous lapse of scientific ethics, which has caused 32 scientists from all over the world to enter a formal protest with the Tufts University Medical School in Boston, USA, where the experiments have been organized.

Conclusion

It is my considered view that an examination of the science, politics and ethics of the GM approvals process in Europe reveals something that is rotten to the core. GM Free Cymru and many other organizations have called for the process to be reformed, and for the EFSA GMO Panel to be disbanded and recreated with a more truly representative group of individuals within it who can articulate the concerns of the people of Europe. That will probably not happen, since evolution rather than revolution is nowadays preferred within the EU. But public pressure for change must be maintained, and national governments can also assist by questioning EFSA and criticising the workings of the GMO Panel -- and also by pressing for a GM moratorium until health and safety issues are carefully and independently worked out. The national bans on GM crops in France, Greece and Austria must be supported.

And there are signs of change already. On 4th December the Environment Ministers of the nation states sent an unequivocal message (24) to the Commission and to EFSA, its advisory body: there must be a dramatic improvement in the way in which GMO risks to health and the environment are assessed. They unanimously agreed to a whole series of measures, opinions and recommendations which will have the effect of reducing the power of EFSA, pulling in independent scientific opinion into the approvals process, and enhancing the power of nations and even regions to declare GM Free zones. Now we must simply ensure that these "intentions" are not caught up in a bureaucratic tangle created by the Commission, and that they are translated into action on the ground.

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REFERENCES

(1) http://www.gmfreecymru.org/pivotal_papers/mathry.htm MATHRY'S SUCCESSFUL CAMPAIGN IN 2001 AGAINST GM CROP TRIALS
Ministerial Statement on GM Crops, 24th February 2009
http://www.gmfreecymru.org/news_introduction.htm
http://www.assemblywales.org/bus-home/bus-chamber/bus-chamber-third- assembly-rop/rop20090224qv.doc
http://tinyurl.com/cgn35y

(2) http://www.gmfreecymru.org/pivotal_papers/ gm_health_effects_part1.htm
http://www.gmfreecymru.org/pivotal_papers/harvestoffear.htm
http://www.gmfreecymru.org/pivotal_papers/rottweiler.htm
http://www.gmfreecymru.org/open_letters/Open_letter10Dec2007.htm
http://www.gmfreecymru.org/news/Press_Notice9March2007.htm

(3) http://ec.europa.eu/food/food/biotechnology/index_en.htm

(4) Substantial Equivalence:
http://www.gmsciencedebate.org.uk/topics/forum/0028.htm
http://www.gmfreecymru.org/pivotal_papers/sustantial.html

(5) The "concept of familiarity" and Golden Rice: http://www.goldenrice.org/Content2-How/how3_biosafety.html

(6) The law is unambiguous in the USA, and is enshrined in an amendment to the Food, Drug and Cosmetic Act passed by Congress in 1958. See: http://www.gmfreecymru.org/documents.htm The Precautionary Principle for GMOs: rational and needed, by Steven M.Druker European Voice 17 June 2004 (vol. 10 number 22)

(7) http://www.gmfreecymru.org/pivotal_papers/syngenta.htm The Syngenta Dodgy Dossier http://www.gmfreecymru.org/pivotal_papers/manipulation.htm PERVERTED SCIENCE -- THE MANIPULATION OF GM RESEARCH How "inconvenient" GM research is stifled, starved, marginalized and patronized Brian John GM Free Cymru

(8) http://www.gmfreecymru.org/open_letters/Open_letter12Nov2007.htm

(9) GM health effects -- a tale of institutionalised corruption (Part 1) by Jeffrey Smith STATE-OF-THE-SCIENCE ON THE HEALTH RISKS OF GM FOODS http://www.gmfreecymru.org/pivotal_papers/gm_health_effects_part1.htm

(10) http://www.foodnavigator.com/Legislation/WTO-GM-ruling-will- change-nothing-say-campaigners WTO GM ruling will change nothing, say campaigners By Anthony Fletcher, 13-Feb-2006
http://www.gmfreecymru.org/pivotal_papers/enforcers.htm GM Enforcers in dark suits: How US diplomatic thugs force other nations to lower biosafety standards and accept GM imports

(11) http://www.gmfreecymru.org.uk/documents/impossible.htm Coexistence is impossible, say GM opponents www.gmfreeze.org/uploads/4B5_coexistence_legal_opinion.pdf

(12) Below is a list of the different member states' number of votes:
AT Austria 10, BE Belgium 12, BG Bulgaria 10, CY Cyprus 4, CZ Czech Republic 12, DK Denmark 7, EE Estonia 4, FI Finland 7, FR France 29, DE Germany 29, EL Greece 12, HU Hungary 12, IE Ireland 7, IT Italy 29, LV Latvia 4, LT Lithuania 7, LU Luxembourg 4, MT Malta 3, NL Netherlands 13, PL Poland 27, PT Portugal 12, RO Romania 14, SK Slovakia 7, SI Slovenia 4, ES Spain 27, SE Sweden 10, UK United Kingdom 29,
TOTAL VOTES 345, Qualified majority: 255, Blocking minority: 91

(13) The Concordat which is supposed to guide GM matters and represent agreed positions between the four UK "competent authorities is here: http://www.scotland.gov.uk/Publications/2007/04/GMConcordat

(14) OPEN LETTER "EFSA is not fit for purpose " http://www.gmfreecymru.org/open_letters/Open_letter10Dec2007.htm
PUBLIC CONSULTATION ON THE INDEPENDENT EFSA EVALUATION REPORT http://www.gmfreecymru.org/open_letters/Open_letter27Feb2006.htm
http://www.gmfreecymru.org/news/Press_Notice21Sept2006.htm

(15) EFSA Petition currently being considered by the Commission: Title of Petition: The importance of impartiality within EFSA & the food safety rights of EU citizens Text of Petition (No. 0813/2008): http://www.gmfreecymru.org/pivotal_papers/petition.htm

(16) http://www.foodqualitynews.com/Legislation/Judicial-Review- favours-FSA-in-GM-contamination-case

(17) http://news.bbc.co.uk/1/hi/sci/tech/6990868.stm

(18) http://www.gmfreecymru.org/news/Press_Notice24May2005.htm
http://www.gmfreecymru.org/news/Press_Notice16Feb2007.htm
http://www.gmfreecymru.org/news/Press_Notice10Mar2008.html
http://www.gmfreecymru.org/pivotal_papers/manipulation.htm
http://www.gmfreecymru.org/pivotal_papers/syngenta.htm
Company Research on GM Foods is Systematically Rigged http://www.gmfreecymru.org/pivotal_papers/company.htm

(19) Crop Scientists Say Biotechnology Seed Companies Are Thwarting Research By ANDREW POLLACK Published: February 19, 2009 http://www.nytimes.com/2009/02/20/business/20crop.html?_r=2

(20) NATURE BIOTECHNOLOGY FACILITATES PREMEDITATED GM ROTTWEILER ATTACK How a well-known scientific journal "set up" an honest scientist through a conspiracy of lies and deception http://www.gmfreecymru.org/pivotal_papers/rottweiler.htm
The Excommunication of a Heretic by Roland Fischer http://www.gmfreecymru.org/pivotal_papers/excommunication.htm
For some insight into the perpetrators of this scam, see here: http://www.gmfreecymru.org/open_letters/ support_Open_letter28Sept2007.htm

(21) Farmers and GM Crops: new report slammed as "propaganda dressed up as science" http://www.gmfreecymru.org/news/Press_Notice22Feb2008.htm ESRC is criticised for 'biased' study http://www.timeshighereducation.co.uk/story.asp? sectioncode=26&storycode=401048&c=1

(22) The Farm Scale Evaluations in the UK http://www.defra.gov.uk/environment/gm/fse/
GM Maize Trials involved "cynical scientific fraud" http://www.gmfreecymru.org.uk/documents/trials.htm
http://www.greenpeace.org.uk/taxonomy/term/421

(23) The Golden Rice Project
http://www.goldenrice.org/
The 'Golden Rice' - An Exercise in How Not to Do Science
http://www.i-sis.org.uk/rice.php
http://www.loe.org/shows/segments.htm?programID=09-P13-00005&segmentID=3
http:// www.foodwatch.de/foodwatch/content/e6380/e23456/e23458/GoldenRice_english_final_ger.pdf
The campaign for genetically modified rice is at the crossroads http://www.sciencemag.org/cgi/content/short/320/5875/468
Tough Lessons From Golden Rice by Martin Enserink Golden Scare: A new genetically modified rice strain is breeding controversy Noemie Bisserbe, 22 Aug 2008
http://www.businessworld.in/index.php/Economy-and-Banking/Golden-Scare.html
Golden rice feeding trials breach medical ethics code GM Experiments involved sick Chinese children http://www.gmfreecymru.org/pivotal_papers/feedingrice.html

(24) EU MINISTERS AGREE TO MUCH TIGHTER GM CONTROLS ** More devolution of decision-making ** Curtailment of EFSA powers http://www.gmfreecymru.org/news/Press_Notice05Dec2008.htm
http://www.euractiv.com/en/cap/eu-ministers-back-gmo-free-zones/ article-177557