ngin - Norfolk Genetic Information Network

4 August 2002


1. RIGGED DEFRA CONFERENCE - how to respond
3. say no to contamination of conventional seed


1. Subject: BBKA email address

Date: Sun, 4 Aug 2002 12:31:40 +0100
From: "Robert Vint" <>
I understand that the general email address of the BBKA is
Individuals there are presumably [ ]

The other contact details, as noted earlier, are: The British Beekeepers Association, National Beekeeping Centre, Royal Agricultural Showground, Stoneleigh, Warwicks, UK  CV8 2LG   Tel:  02476 696679   Fax:  02476 690682

A friend in Devon tells me that the conference is being organised for the BBKA by: Glyn Davies (BBKA Executive Chairman) of Ashburton, Devon 01364 652640

Jean Saunders, in an earlier email giving info about this conference said:

"Thanks to John Salt for providing the following information.  It is pretty clear that this is a done deal - no nasty environmental organisations invited.  The covering letter from the BBKA executive chairman (Glyn Davies) says that the event has been "given objective and open support by the GM Industry".  As such, they have been invited to give a position statement twice (SCIMAC and ABC).  No doubt they will wish to remove the 6 mile exclusion zone for hives."




"John Salt" <>

From John Salt, President: Moray Beekeepers:

"Honey produced in the UK has remained GM-Free because beekeepers who wish to sell their  honey to the British Honey Importers and Packers Association have been required to move their hives at least 6 miles from any GM crops.The normal flying distance of a honeybee is three miles,  doubling this distance should ensure all honey will therefore remain GM free. 27 GM test sites thus prevent beekeepers from using just under 8,000 sq miles of the UK!  Many beekeeping associations including numerous individual beekeepers have been highly critical of GM crops, have asked many embarrassing questions of government and have been major contributors to the anti-GM movement.

The Government sees this as an obstacle to the commercialisation of GM crops and wants the GM-Free honey standards scrapped.

The Department for the Environment, Transport and the Regions (DEFRA), as part of a nationwide 'PR offensive' to remove resistance to GM crop commercialisation, has arranged for the British Beekeepers Association (BBKA) to organise a conference to discuss the standards. Only pro-GM  government advisers and pro-GM or uncommitted representatives of the larger and more commercial beekeepers associations are invited. Invitees have been limited to approx 80 and a maximum of 2 per Association/Organisation.  Key critics who in the past have expressed serious concerns on behalf of UK and Scottish Beekeepers, have been excluded from the conference. The National Pollen Research Council - who provided the data showing that pollen can be spread far further than Government estimates - are not represented. Small beekeepers, the large majority of whom oppose GM crops, will not have an opportunity to express their views at this meeting. Also unrepresented are consumers organisations, the health food / wholefood trade and organic farmers associations.

Participants have been carefully selected and the conference is clearly designed to reach the conclusion that the 6 mile hive exclusion zone should be abandoned - the Government has stated that the amount of GM material in honey is so small it should be dismissed - totally contradicting the views of the majority of beekeepers and their customers.

A major concern is that the Government may repeat this strategy of setting up rigged conferences and committees throughout the whole national debate about GM crops - and thus silence the voices of sceptical scientists and experts. The most important national decisions on GM crops will not be made by the Public Debate but by the carefully managed Science and Economics Committees that the Government is setting up in parallel with the debate. An unnamed Government minister has already told the media that this debate is just a "PR offensive" and said: "They're calling it a consultation, but don't be in any doubt, the decision is already taken."(2) The Government knows that it would lose a genuinely open debate on GM crops and that rigging the debate is the only way they can win. This could be their biggest ever spin operation."


John Salt
President, Moray Beekeepers
Sunningdale, Forres, Moray, IV36 2RU  Scotland.
Tel/Fax...+44(0)1309 673703

1. John Salt, President of Moray Beekeepers, is available for interviews on 01309 673703
2. Financial Times-July8,2002'Public consultation on GM crops 'just PR''; Daily Telegraph-July9,2002: 'Blair to head GM campaign'.
3. The full programme of the DEFRA/BBKA conference is given below

The British Beekeepers Association
National Beekeeping Centre
Royal Agricultural Showground

Tel:  02476 696679
Fax:  02476 690682


Fri 20 Sep 2002 at the National Beekeeping Centre
10am to 4pm.

To share opinions and concerns across the sectors of the Industry
To debate the definition and acceptability of "GM free" and "non-GM" honey
To consider the merits and future of the 6 mile hive exclusion zone.

By invitation from the BBKA

80 approx.  max 2 per Association/Organisation

BBKA Member Associations (61)
Bee Farmers Association
First Honey Co-op
Scottish, Welsh and Ulster BKA
National Bee Unit
Honey association (importers)
IACR Rothamstead
Agricultural Biotechnology Council
Agricultural and Environment Biotechnology Commission
British retail Consortium
Local Authorities Co-ordinating Body on Trading Standards
International Bee Research Association
Food Standards Agency
QP Services


Coffee and Registration from 10am

Start 10.30 - Chairman:  Glyn Davies BBKA

Position statements (10-15 mins) from possibly:
The Beekeepers dilemma - BBKA
The public debate - AEBC
The scientists - IACR Rothamsted
The retailers - BRC
The importers and packers - Honey association
GM Industry - ABC
The government position - DEFRA
UK Honey producers - BFA
GM supply perspective - SCIMAC

Lunch 1-2pm

The Debates:
1 is there an acceptable definition for GM free honey?  If so what is it?
2 Is the 6 mile exclusion zone meaningful and necessary?

4pm conclusion and close.
Subject: GM-ACT: say no to any GMO contamination of conventional seed
Date: Sun, 04 Aug 2002 11:01:05 +0000
From: "Jean Saunders" <>

Hi All

I have pasted in below the DEFRA letter that outlines the main points up for consultation about what level of GMO contamination will be allowed in  conventional seed before labelling is required.   The EC have already opted for zero contamination of unapproved GMOs (ie those that have not gained an EU marketing consent) in conventional seed and this is welcome.

The proposals allow for between 0.3 to 0.7 percent contamination of seed  before labelling is required.  Industry is bound to call for higher  acceptable levels to be introduced and for the consumer/farmer to pay for  GMO free seed.

At the end of the DEFRA letter (which only applies to consultation in  England so I guess that Scotland, Wales and N.Ireland have a different  address to write to), I have pasted in a short sample response that you  might send to DEFRA before 12 September 2002.



Plant Variety Rights Office and Seeds Division
White House Lane, Huntingdon Road, Cambridge CB3 0LF
Telephone: 01223 342380 FAX: 01223 342386

Commission proposals on thresholds for the adventitious presence of approved GMOs in seeds

To all interested parties in England
August 2002


I am writing to consult you about EU Commission proposals relating to  thresholds for the adventitious presence of approved GMOs in non-genetically modified seeds. A copy of these proposals is enclosed in document SANCO/1542/02July2002 [can be downloaded at following URL].

The main elements of the proposals are summarised below and would: &#61623; Introduce maximum thresholds for the adventitious presence of  approved GMOs in non-GM seeds. The thresholds would be set at levels such  that crops produced from these seeds should not contain GMOs in excess of  the 1% labelling threshold for food and feed. The proposed thresholds are:

*0.3% for seeds of oilseed rape
*0.5% for seeds of beet, maize, cotton, tomato and chicory
*0.7% for seeds of soya bean

*Allow the marketing of seeds above these thresholds, providing the  seeds have been labelled as exceeding the thresholds and that the label  indicates the original transformation event(s) of any genetically modified seeds;
*Require good practice for seed production to minimise admixtures
and undesirable gene flow through the whole seed production chain; *Require seed producers to supply evidence to satisfy national  authorities that they have taken appropriate steps to avoid the presence of  GMOs, since the threshold is only applicable where GM presence is  adventitious;
*Require seed to be tested in accordance with a Commission  Regulation (not yet available) on a protocol for the sampling and testing of  seed lots of non-genetically modified varieties for the presence of  genetically modified seed;
*Require national authorities to carry out these tests in all cases where there is reason to believe the requirements may not have been satisfied. The tests need not be carried out where the authorities determine that routine testing need not apply (e.g. in areas where GM crops are not  grown) provided that checks are carried out on a targeted basis; *Require genetically modified varieties (i.e. varieties that have  been deliberately genetically modified) to be labelled with the words  'genetically modified variety' together with information that specifies the  original transformation event.

The Commission had considered placing an upper limit on the marketing of  seeds (appropriately labelled) that exceeded the thresholds of 0.3%, 0.5%  and 0.7% for individual species and tentatively suggested that this should  be set at 5%. Some Member States could accept an upper limit no higher than  1% but the Commission maintained that an upper limit of 1% itself would be too close statistically to the thresholds of 0.7% and 0.5%.

The expert statistical advice was that for seeds with a true adventitious  presence between 0.7% and 1%, the decision on whether or not to label or to prohibit marketing would be inaccurate in 50% of the cases. The comparable position for the 0.5% threshold was a decision error rate of 24%. Consequently, the Commission has made no proposals for an upper limit in its  proposals. As yet, the Commission has provided no indication of the estimated cost of its proposals so a regulatory impact assessment (RIA) has not been produced. However, we should be interested to receive your views on any anticipated compliance costs.

We would normally allow you 12 weeks to comment but because the Commission intends to hold an indicative vote on these proposals during September, we shall need to shorten the consultation period to 6 weeks.

If you wish to comment on the Commission's proposals, would you please do so in writing, by fax or by e-mail, to Mr Michael Miller at the following  address by no later than 12 September 2002.
Mr Michael Miller
Department for Environment, Food & Rural Affairs
PVRO and Seeds Division
Room 22
White House Lane
Huntingdon Road
Cambridge CB3 OLF
Fax: 01223 342386

Your comments, together with any others we receive, will be made publicly  available at the main DEFRA library at 3 Whitehall Place (West), London SW1A 2HH (Tel: 08459 335577). The library will supply copies on request to personal callers or telephone enquirers. Your reply will be made available in this way unless you expressly ask us to exclude all or part of your response from this arrangement. Organisations and persons who are interested in the elements of the  Commission's proposals that concern seed potatoes are being consulted  separately by the Plant Health Division of DEFRA.
Yours sincerely

Heather Hamilton
Controller of Plant Variety Rights and Head of Seeds Division
Sample letter to send to:

Michael Miller
Department for Environment, Food & Rural Affairs
PVRO and Seeds Division
Room 22
White House Lane
Huntingdon Road
Cambridge CB3 OLF

Fax: 01223 342386

Dear Mr Miller

Re:  Commission proposals on thresholds for the adventitious presence of approved GMOs in seeds

It is not acceptable that the proposed European Commission directive would allow conventional seeds to be contaminated with approved genetically modified organisms (GMO) by 0.3 to 0.7 percent dependent on the seed variety. I fully support EC moves to introduce zero-tolerance of non-approved GMOs in seed and would ask that the same obligation is placed on approved GMOs.

In order to take a precautionary approach to transgenic biotechnology, that is still in its early stages of development and in recognition of the „polluter pays‰ principle,  I believe that this would be the fairest and most equitable approach.  It would simplify matters in that the industry supply chain would have to introduce strict separation controls at all stages of seed production, transport and use and, as such, the costs would fall on the industry chain and on farmers who elect to grow GM varieties.  It is vital to ensure that costs arising from any obligation is not borne by consumers nor farmers who do not wish to consume or grow GMOs.

Zero-tolerance of GMO contamination in conventional seed would also remove any requirement for Member States to set different upper limits before labelling is required.  If the industry believe that they are unable to meet these strict obligations, then GMOs should be banned.

Yours sincerely


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