1.
The goal of governmental policy should be to set ZERO contamination of the food and feed supply by GM Pharm and industrial crops. To ensure GM Pharm and industrial crops achieve this they should:
a)
Not be grown in food or feed crops: GM medicine and industrial crops should not be grown in food or feed crops to minimise the chances of them entering the animal and human food supply.
b)
Not be grown outdoors: GM medicine and industrial crops should not be grown in the open environment, but in enclosed systems which would guarantee containment.
c)
Establish entirely safe separation distances: To prevent pollen flow GM medicine and industrial crops should be grown away from all other food and feed crops – either in completely different areas or regions or with absolutely safe distances between them. In addition, ‘temporal separation’ methods can be employed – growing GM crops which flower at different times to other crops nearby would minimise pollen flow.
d)
Dedicate machinery and infrastructure solely to GM production: Dedicating farm machinery (planters, combines, trucks) and grain-handling infrastructure solely to GM Pharm and industrial crops would help contain the spread of GM seeds and crop residues.
e)
Genetically modify crops with sterile pollen, chloroplasts or suicide genes: GM medicine and industrial crops might be genetically engineered to have sterile pollen, or to have their drug genes spliced into choloroplasts (which would limit cross pollination) or contain suicide genes which would reduce the viability of the seeds.
2.
The government should establish a public scientific advisory committee to advise government agencies on measures, which could be implemented to achieve zero contamination of the environment and food supply by GM Pharm and industrial crops.
3.
The government should use the advisory committee’s report to devise regulatory requirements to be imposed on growers, handlers, and transporters of GM Pharm and industrial crops.
4.
The government should impose a moratorium on field tests and commercial production of GM Pharm and industrial crops until they have convened the scientific advisory committee and established a regime that the scientific community believes will assure the goal of zero contamination of the food supply.
The National Academies Recommendations
The National Academies report mentions many of the above as measures which could be implemented to ensure containment of GM Pharm and industrial crops, but goes on to suggest two additional safeguards:
1.
The establishment of an ‘Integrated Confinement System’ to control GM Pharm and industrial crop production, which is based on risk assessment for ‘worst case’ scenarios, including human error. The system should be designed with written confinement measures, include training of employees, ensure that permanent employees are kept to maintain continuity of the system, implement standard operating procedures, carry out periodic audits by an independent entity to ensure transparency, and conduct periodic reviews and adjustments to the management system. The report states, “For the Integrated Confinement System to be effective, it is essential that it is supported by a rigorous and comprehensive regulatory regime that is empowered with inspection and enforcement.”
2.
The report emphasises the importance of enforcement and notes that monitoring the environment for escaped GM material could be made easier if GM Pharm and industrial crops were genetically engineered to allow escaped GM material to be detected with special equipment. This would enable regulatory bodies to carry out effective and efficient monitoring and inspections.
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Drugs in Our Breakfast Cereals?
The need to contain GM pharm crops is summarised by Jean Halloran of the Consumers´ Union (USA):
“Drugs have side effects - they should not turn up in our cornflakes.”
(TIME magazine, May the 19th 2003)
