» WELCOME
» AN INTRODUCTION
» PROFILES
» LM WATCH
» CONTACT
» LOBBYWATCH LINKS
»


Soil Association response to ACRE consultation (3/7/2006)

some excellent material here - worth reading right through to the annexed material at the end
---

Dear all,

For information, please find attached our submission to ACRE [the UK's GM regulatory body, the Advisory Committee on Releases to the Environment] on its draft report on proposals for 'comparative risk assessment' for GM crops and other novel agricultural processes.

We have taken a strong line - I hope you find it a useful contribution to the GM debate. We considered the report to be very poor and, if followed through, would be very helpful indeed to the GM companies. We are completely rejecting ACRE's proposal and indeed rejecting the continued use of 'case-by-case assessment' (much loved by the pro-GM camp) as the main policy approach for GM crops. Below is a some background and a summary of our response.

Background

The draft report was written by a sub-group of ACRE (Advisory Committee on Releases to the Environment). The sub-group was established in 2004 and is chaired by Jules Pretty. Others on the sub-group are Chris Pollock (Chair of ACRE and of the Scientific Steering Committee of the Farm-scale trials) and Phil Dale (John Innes Centre) the AEBC had supported the concept of a wider assessment of the impacts of GM crops. But it is clear from ACRE's report that the pro-GM constituent have seen this as an opportunity to secure assessment of the benefits of GM crops and enable these to counter any concerns about negative effects. The current system only allows for assessment of negative health or safety effects

Summary of ACRE proposals

The proposals are for a wider 'sustainability' case-by-case assessment of the impacts of GM crops, including positive impacts and economic impacts the proposals are thin, little more than a set of principles and criteria which are reasonable but do not seem to give enough emphasis to the basic safety of the products compared to other issues and would allow for biased assessment some case studies are presented which are really very poor and pro-GM (eg. quoting only pro-GM evidence; omitting obvious negative impacts) worryingly, ACRE concludes that "strict regulatory constraints" should be abandoned, in favour of a more flexible approach that allows innovation. However, EU legislation would need to be changed to allow this.

Summary of Soil Association response

We consider ACRE's paper to be very poor, biased, lacking rigour and coherency, and totally inappropriate as a basis for taking the subject further. We disagree with many of the statements. ACRE recognises that comparative risk assessment (CSA) poses fundamental problems, then ignores them.

Recent developments in scientific understanding of the biological impacts of genetic engineering have proven that case-by-case assessment is totally unreliable as the principal decision-making basis for novel processes these problems mean that case-by-case assessment of novel technologies and products cannot in practice be comprehensive, cost-effective, evidence-based, proportional or reliable, contrary to what ACRE tries to suggest we completely reject ACRE's recommendation against 'strict regulatory constraint', which would be a disaster for public safety and confidence we agree with the conservation agencies that case-by-case safety assessment should address the 'bottom-line'. However, there should be an initial generic safety assessment of the novel process/product and a general decision if the general decision is negative, approval should be considered only in specific cases where there is an important and unique need. There should then be a programme of research and precautionary case-by-case assessment public opinion must play an important role in the decision-making, to ensure that the decision will take agriculture in direction wanted by the public important omissions in ACRE's paper include the health and food quality impacts, socio-economic impacts and impacts on other crops. The novel approach should also be considered against alternatives, in particular organic farming system, a proven 'win-win' system with strong public support

Regards
Gundula Azeez
Policy manager
Soil Association
---

"Managing the Footprint of Agriculture: Towards a Comparative Assessment of Risks and Benefits for Novel Agricultural Systems"

Soil Association response to ACRE consultation June 2006

Executive Summary

· we consider ACRE's paper to be very poor, biased, lacking rigour and coherency, and totally inappropriate as a basis for taking the subject further

· we disagree with many of the statements. ACRE recognises that comparative risk assessment (CSA) poses fundamental problems, then ignores them.

· recent developments in scientific understanding of the biological impacts of genetic engineering have proven that case-by-case assessment is totally unreliable as the principal decision-making basis for novel processes (Annex I)

· these problems mean that case-by-case assessment of novel technologies and products cannot in practice be comprehensive, cost-effective, evidence-based, proportional or reliable, contrary to what ACRE tries to suggest

· we completely reject ACRE's recommendation against "strict regulatory constraint", which would be a disaster for public safety and confidence

· we agree with the conservation agencies that case-by-case safety assessment should address the "bottom-line". However, there should be an initial generic safety assessment of the novel process/product and a general decision

· if the general decision is negative, approval should be considered only in specific cases where there is an important and unique need. There should then be a programme of research and precautionary case-by-case assessment

· public opinion must play an important role in the decision-making, to ensure that the decision will take agriculture in direction wanted by the public

· important omissions in ACRE’s paper include the health and food quality impacts, socio-economic impacts and impacts on other crops

· the novel approach should also be considered against alternatives, in particular organic farming system, a proven ‘win-win’ system with strong public support.

1. Introduction

The Soil Association was founded in 1946 to achieve sustainable and healthy agriculture. It is now the main organisation of the organic movement in the UK and certifies about 56% of organic farmers and 70% of the organic food sold in the UK.

Organic farming is a management-based system which harnesses natural ecological and biological processes, rather than using of synthetic chemical inputs. Organic farming now accounts for about 4% of UK farmland. Sales of organic food are worth over £1.2 billion and increasing by over £2.3 million each week. 33% of farmers have said they would consider organic farming and 38% consider organic farming as "the future" (Farmers’ Weekly on-line polls, August 2005 and May 2006 respectively).

The Sustainable Development Commission has called organic farming the "gold standard" for agricultural sustainability. Research shows that it has significant environmental advantages over non-organic farming. It supports higher levels of wildlife, whilst reducing agrochemical pollution, waste, and halving the amount of fossil fuels needed to produce food. Because of these benefits the Government wishes to expand organic farming. Defra adopted an action plan for organic food and farming in 2002, with a target of 70% of the UK organic food market to be supplied by UK farmers by 2010, and public procurement to include organic food.

The use of GMOs is prohibited in organic farming as they contradict the basic organic principles of using natural processes and a precautionary approach to safety issues. The organic movement is also completely opposed to the introduction of GM crops in non-organic farming for health, environmental, and ethical reasons and because of the inevitable contamination of non-GM food which will prevent a choice of GM-free food including organic food. We believe our stance on GMOs is increasingly supported by the developing scientific evidence.

2. Response to ACRE's draft paper on comparative risk assessment

Overall we consider ACRE's paper to be very poor and totally inappropriate as a basis for taking the subject further. The report should be abandoned, and replaced with a summary of the criticisms and proposals for who should take over. The report mentions here and there, but does not begin to address, several fundamental weaknesses and conflicts in the proposed CSA approach. Moreover, the draft is not honest about the nature of the decision-making that will result, presenting the approach as evidence based but admitting that (because of the weaknesses that it does not address), decisions will in reality be largely the personal judgements of 'experts'. The report also portrays an unacceptable bias in ACRE on this subject.

Suitability of 'case-by-case' assessment for novel technologies and products

· We disagree with many of the statements in the report. We believe novel technologies and products should be dealt with differently from new farming practices. We disagree with using energy crops as analogy. We disagree with the Canadian approach, which ACRE holds up as an example, that only the unique characteristics of the final product should be assessed and not the process. This omits any safety assessment of the common characteristics of the process and disregards the basic problem of the immature state of scientific knowledge and lack of practical experience with novel processes, which is the critical flaw in the current regulatory approach to GM. We totally disagree with the clear view of ACRE that GM crops have been ‘hard done by’ under the current system, as the current approval system works consistently in favour of the GM products whenever there is doubt. We agree with the conservation agencies view that case-by-case risk assessment should focus on the "bottom-line" and products prohibited if they fail this the impacts of intensive farming have gone far enough. Thus any wider sustainability assessment should only apply to novel processes and products passing this stage. However, we not think this alone is adequate. For novel technologies and products, we believe that there should be an initial generic safety assessment stage.

· Recent developments in scientific understanding of the biological impacts of genetic engineering have proven that case-by-case assessment is totally unreliable as the principal decision-making basis for novel processes. Case-by-case assessment of GMOs was based on assumptions about general impacts of the process and scientific certainty, which the new evidence has proven were inadequate and wrong in many critical ways. The case-by-case assessments have not been addressing many of the problems now revealed by the generic research. Basic assumptions about genetic engineering which informed the safety assessments, have been found to be incorrect, in particular the reductionist belief that genes operate without interaction by the rest of the organism. See Annex I

· The proposed principles are totally inadequate for the nature of the problem. Fundamental conflicts remain unresolved. ACRE admits that comparative risk assessment poses fundamental problems of user bias, limitations in the availability of scientific data, the large cost and time in gathering new evidence (for even just one impact as shown with the FSEs). Yet ACRE’s proposals completely ignore these problems and assume they do not exist. However, these problems mean that case-by-case assessment of novel processes and products cannot be comprehensive, cost-effective, evidence-based, proportional or reliable. We therefore consider the proposals totally unrealistic and unreliable.

· ACRE needs to bite the bullet and recognise that these issues are the basis of the failure of the current ‘science-based’ approach with GM and the public distrust that is behind the endless controversy and market rejection. Simply proposing a broader case-by-case assessment will not resolve these issues. A completely different approach is needed that is specifically tailored for these challenges.

· We instead propose that the first (and in effect dominant) stage must be a generic assessment of the novel agricultural process or product (whether GM crops or, say, pesticides). This should comprise (i) a review of whether there is an adequate and reasonably robust body of scientific understanding to enable case-by-case assessment and possible approval; (ii) an assessment of whether the current understanding and evidence suggests there could be inherent risks; (ii) and an assessment of the viability and cost-effectiveness of generating the required range of data to enable comprehensive reliable case-by-case assessment.

· There should then be a general decision for or against the novel process or product. In our view, because of the inevitable negative outcome of this generic review (the lack of a body of scientific understanding and that it would be unrealistic and disproportional to generate all the required data), this should result in a general presumption against the use of artificial processes and products in agriculture and the food chain. This should not be considered a lost opportunity, as clearly ACRE would believe to be the case.

· Compared to natural biological processes or new farming practices, which can only affect the balance of existing natural processes, unnatural processes and products introduce new chemical and biological interactions. They therefore have a higher likelihood of disrupting natural processes with negative effects. They also have a high likelihood of displacing as yet unidentified benefits of existing natural processes, and of being unethical. Artificial products also generally involve a high level of embodied energy in their production, compared to management approaches and natural processes. Moreover, there is already an effective and proven environmentally beneficial agricultural alternative that does not generally use artificial processes or products organic farming. This already delivers most of the supposed current and potential benefits of GM crops (such as reduced herbicide use and better soil protection). There is great potential for further research and development with natural, management-based processes.

· Only where there is a good case for a specific novel technology or product, based on an important and unique need, should approval be considered. There should then be a programme of research and rigorous precautionary case-by-case assessment of the evidence, including of the level of uncertainty, followed by a comprehensive policy assessment, taking a strong steer from public opinion

· In contrast to ACRE’s proposals, the policy approach used by the organic movement is genuinely comprehensive, holistic (ie. also accounting for interactions between factors and any unknowns), reliable, practical, established, proven to be effective (having produced a range of scientifically-proven benefits), efficient, proportional and objective-led. We recommend ACRE study the organic approach and recommend that those who develop this subject further, do so. We attach a summary of the organic decision-making principles.

Objective-led

· We agree that agricultural policy decision-making should be "objective-led". However, the objectives must include orientating agriculture to promote health and the quality of food. This aspect is almost totally neglected in this draft.

· A second objective that must be central to the assessment, is implementing the key conclusion of the Curry Commission, ie. that agriculture must reconnect with market. In our view, this means that public opinion of any novel technology or products must play an important role in the decision-making, to ensure that the decision will take agriculture in direction wanted by the public. This omission should be readdressed in the next stage of work.

Comprehensive assessment major omissions in the draft CSA

· We agree that the final assessment prior to a policy decision on whether to allow novel technologies and products, should be broad in scope. Unfortunately, the scope of discussion in ACRE’s report is frequently too narrow. As well as including the health and food quality impacts, there should be assessment of the social and socio-economic impacts (such as impacts on consumer choice and on the balance of power in the food chain), and indirect impacts on other crops and the consequences of this (eg. widescale bioenergy crops would replace food production, causing more imports and thus greater energy used in transport).

· The draft report betrays a clear interest in enabling the consideration of the benefits of GM crops including ‘potential benefits’, ie. speculation. ACRE must therefore agree that the potential disbenefits must be fully assessed as well, even where there is little evidence or proof. Our concern is that, until now, assessment of this critically important area has in practice been opposed by many 'experts' and industry stakeholders (such as through the opposition to generic assessment), on the grounds that decisions should be 'evidence-based'. ACRE's must address the reluctance of 'experts' to assess the disbenefits.

Comparative assessment

· We agree that there is a need to consider the impact of the novel technology or product against the practice and/crop that it would immediately replace, but there is also a need to consider the novel approach against alternative practices and systems, in particular organic farming, which is an established and proven ‘win-win’ agricultural system with strong public support.

· The statement in Annex F that "LCA … has rarely been applied in agriculture" is incorrect - several Life Cycle Assessments of organic and non-organic farming have been carried out.

Evidence-based

· "ACRE ... argues for a system … based on … a comprehensive evidence-base". Yet, there is a clear shortage of evidence from suitable controlled studies for assessing novel technologies and products. The huge cost and time for an FSE-type evidence gathering exercise for just one impact makes it clear that it would not be remotely viable to gather evidence for all the impacts as part of an approval process. We therefore believe that the proposed CSA approach will simply in practice not be evidence-based, but mostly based on assumptions and opinions. ACRE acknowledges this problem (commenting about the FSEs, "but was very expensive", p.68), but does not deal with the problem.

· We are very disappointed that ACRE tries to present their approach as evidence-based; we consider this irresponsible and deceptive. Having argued that the CSA will "form part of a trend towards … evidence-based… policy", it admits that "the difficulty in quantifying and valuing environmental" impacts, means it "is therefore unavoidable that expert judgement plays an important part in the proposed CSA". This is the actual result of ACRE’s approach and the centre of their recommendations, but is obscured and contradicted throughout the paper.

· We agree that large-scale studies, not small plots, are needed to assess environmental risk. Case-by-case assessment and approval should not be considered without such basic information. However, large-scale, long-term studies are equally needed for investigating the health impacts, which are not currently happening with GMOs. The next report should clearly state this.

· The independency of the data used will be all important for making the right decisions and securing public support. ACRE should recommend that official assessments always prioritise the findings of independent research over industry studies, where there are differences in the conclusions.

· We are concerned that ACRE is focussing too narrowly on only scientific evidence. Defra policy decisions are meant to based on evidence, but this is meant to include non-scientific evidence, including the experience of practitioners and the views of stakeholders. We are not confident that ACRE is aware of this. To help address the inevitable shortage of scientific evidence and long-term experience, it is very important that anecdotal evidence from independent sources is included in the evidence base. This must be stated.

· The taxpayer should not bear costs of generating the evidence base for technologies or products where there is continuing strong public opposition.

'Expert' judgement final recommendations

· We are concerned that ACRE does not appreciate that the final recommendations and decisions must be taken by experienced policy-makers and elected politicians, not scientists or non-Government technical experts. The complexity of the real-life issues, inevitable assumptions that need to be made about the actual impacts, the limits in using evidence-based approaches for assessing social and socio-economic issues, the need to consider values and ethics, the weighing up of alternatives, these are all policy-level subjects. Scientists should stick to assessing and advising on the level of basic generic scientific understanding and case-by-case evidence, and level of uncertainty/extent of gaps.

· Decision-making criteria will need to be used by policy-makers to ensure a reliable and consistent approach we propose those of organic movement which are designed and proven to deal with all these real-life challenges. See Annex II.

Proposed deregulation of GM

· We completely reject ACRE's recommendation against "strict regulatory constraint". Public and environmental safety must be prioritised over commercial opportunities for industry. Strict, precautionary regulatory control should exist for all artificial compounds and organisms.

· Deregulation would be a disaster for public confidence and completely counter to the conclusions now reached in rest of Europe and the European Commission that the weaknesses in the current controls are partially to blame for the lack of public confidence and that GMOs remain a source of political controversy.

· ACRE should instead be acknowledging the severe weaknesses in current system which work in favour of GM approvals, for example that it is not precautionary in practice as need proof of a negative effect is needed, instead of proof of absence of risk, which means decisions have always been made in favour of the safety of the product whenever there has been a difference of scientific views

· ACRE should publicly support the current European Commission proposals to improve the GM assessment procedures. These would help resolve diverging scientific opinions in a way that rebalances the process in the public interest.

Transparency

· ACRE says it wants "transparent evaluation" but we are concerned that in practice the CSA would be very untransparent. It is not enough that the notes of the sub-panel meetings are made public. A basic requirement for transparency is that all evidence used in the assessments should be freely accessible to the public over the internet - this is a major criticism of the current GM assessment process.

· With the assessment being far broader in scope than now, we are concerned that the process would be accessible to monitoring and influence from only those with very large resources to follow the work of all the sub-panels or those with a commercial interest to justify doing so. The Soil Association, for example, would wish to monitor the objectivity of the assessment processes, but would not have the resources to do so with the system proposed.

Specific case studies

· We found the proposed matrix to be very poor, unbalanced, biased, selective and restrictive. It lends itself to inappropriate evaluation.

· We found the case studies to be completely inadequate, and confirm that ACRE’s proposals and expertise are totally adequate for addressing this subject.

Role of ACRE & taking the CSA forward

· based on the clear bias in this draft report, the intrinsic conflicts in ACREs proposals and presentation, and the very poor case studies, we have to conclude that ACRE is out of its depth and too deeply directed by an objective of gaining faster, wider approval of GMOs. Therefore, we do not trust ACRE to take this forward and have to advise the Government and public likewise

· ACRE should abandon its attempt to develop this further and concentrate on protecting the environment and public health, in a way that better supports public preferences and win-win policy solutions

· This subject should be passed to the civil service for development with politicians, health and environmental stakeholders and the organic movement.

GA, 29.6.2006, GMregul060

Annex I

New Research on the Impact of GMOs on Health

Although some GMOs have been approved and marketed for several years, there was no body of scientific research on their impact on the biology of living organisms. This is partly because animal feeding trials are not required in the current safety approval process for GMOs in the EU or USA. Only now is a body of evidence starting to emerge from a small number of animal feeding trials into the health effects and progress in the new science of epigenetics. This indicates that genetic engineering is much more unpredictable and risky than traditional breeding.

Animal feeding trials

Recent studies have found a range of serious, unexplained effects from GM consumption:

· an Australian study of GM peas revealed immunological effects of genetic engineering with the transfer of a ‘safe’ gene to a different plant species producing allergic reactions in mice. A trial by Monsanto also indicated immunological effects with higher white blood cell levels in GM maize fed rats.

· the only long-term feeding trial (24 months, by an Italian team) found GMOs can affect key body organs, changing the cell structure and cell functioning of the liver, pancreas and testes of mice fed Roundup Ready soya. Similarly, a Monsanto trial found rats fed its GM maize Mon863 developed smaller kidneys.

· a Monsanto trial found GM consumption affects the development of the blood with fewer immature red blood cells and changes in blood chemistry in rats fed its GM maize Mon863.

· a Russian rat study found apparent generational effects of GMOs with very high death rates in the young of rats fed GM Roundup Ready soya (56% died) and stunted growth in the surviving progeny.

· a programme of UK studies funded by the Food Standards Agency found that genetic engineering routinely causes a large number of random genetic and chemical changes in GM plants, the health impacts of which are unknown.

· two UK trials, one with humans and one with sheep, found that when GMOs are eaten some of the inserted genes move out and transfer into the gut bacteria.

Additionally, past studies found GM consumption damages the gut wall and is associated with unexplained deaths of test animals:

· studies by three scientific teams of two different GM plants found GMOs have the potential to cause haemorrhage. Feeding trials by two teams found that GM potatoes cause lesions in the gut wall of rats and mice, and two US feeding trials found that GM tomatoes cause lesions in the gut wall of rats.

· at least two trials of different GMOs found unexplained deaths among the test animals, with 7 of 40 rats (17.5%) in a feeding study of GM tomatoes dying within two weeks ; and a 7% mortality rate for chickens fed GM glufosinate-tolerant Chardon LL maize (twice the rate of the non-GM fed chickens).

(It should be noted that these studies were designed to identify health impacts and include toxicological studies involving tissue analysis. These are different to the various non-toxicological feeding studies frequently referred to by the biotechnology industry, which are primarily carried out to test commercial aspects of GM feed).

The study of Epigenetics

The actual causes of these effects are not known, but many possible factors could account for them. It has long been known by scientists that the artificial insertion of the genes physically disrupts other genes through the damage caused by the uncontrolled insertion process ('positional effects'). In addition, the chemical functioning of the new gene interacts with the activity of the plants' existing genes and biochemical pathways, and so disrupts the metabolism in unpredictable ways. However, research into the new science of "epigenetics" (meaning 'above genetics') is also now showing that genes account for only a part of the control of the biochemistry of organisms, and organisms have a level of control above genes that interact with genes. The exact details of this interaction between the rest of the organism and its genes are still far from known. However, this more complete understanding explains why genetic engineering is so unpredictable, with different results produced by each attempt and why the products are often unstable.

Annex II

Decision-making principles of the organic movement

(N.B. this is an informal description of organic principles to assist understanding)

1. Holistic or systems approach - the different factors in a farming system do not act in isolation. A holistic approach means accounting for unknown factors, and for the interactions between different factors including between unknown factors. It is the opposite to reductionist, and not the same as comprehensive. Holistic relates to ‘whole’ and derives from an old German word for health.

2. Use of natural biological and ecological processes - nature already has the answer to most of agriculture’s problems. Using natural processes means that on balance, we are more likely to avoid negative health/ecological effects, have positive side-effects, avoid ethical problems, and we get nature to do the work for ‘free’ rather than using external energy sources (eg. using soil biological activity to feed and protect plants rather than applying artificial chemicals).

3. Prevention, not cure - we seek to prevent problems from arising to begin with, rather than just having the means to cure (unlike today’s NHS). So, we study the chain of causality and ask ‘why did the plant/animal/person succumb?’

4. Treat the causes, not the symptoms similar to above. We do not let ourselves be distracted by symptoms of a deeper problem. We seek to identify the ultimate, not the proximate causes or side effects.

5. Positive health, not hygiene - our focus is not the conventional focus on the pathogens (eg. controlling pathogens and controlling exposure to pathogens - hygiene) but the plant/animal/person and their health (positive ability to resist disease). We use illness as an indicator of poor health of the organism and address that problem, not so much worry about the presence of pathogens. So, we are always looking at the cause of health, not at the cause of ill health.

6. Nurture, not exploitation - unlike non-organic farming, we seek to positively nurture the basic resources of farming (eg. soil, livestock), not exploit them. This keeps the supply renewable and optimises their ability to function positively for agriculture. This is also ethical.

7. Management based rather than product based solutions - this is more holistic and efficient in the use of resources. Organic management is more of a ‘conversation’ between the farmer and the farm (he observes the response to his management and adjusts his practices accordingly), rather than a ‘lecture’ (use of external products is one way/one size fits all, more about control/dictation and less amenable to subtle adjustment according to the needs of the farm).

8. Law of return recycle nutrients removed from the system at harvest. Emulates natural cycles. Helps ensure sustainability of the system

9. Diversity, not specialised diversity is a feature at all levels (soil biological diversity, genetic diversity, farm product diversity etc.). Makes the system more robust to external challenges, so more stable. Also allows for more sophisticated and specialist processes to act within the whole (eg. niche soil organisms controlling specific pests), providing for major and minor needs of the system.

Approach to science:

10. Biology and ecology, rather than chemistry our interest is more in the biological and ecological processes working in agriculture, than chemical processes which are the focus more in non-organic farming. Ie. a higher level of organisation. Eg. this is why conventional farming believes that as N,P,K are major constituents of plants, plant nutrition can be addressed by simply supplying these in the form of artificial chemicals, while the organic movement recognises the importance of the biological and ecological processes involved in nutrition and has designed its system around that (eg. soil biological health).

11. Everyday, rather than unusual - our interest is more in understanding the scientific processes at play in everyday phenomena for life on earth, than in explaining the unusual. So, we want to understand the processes of nutrition, the biology of the soil beneath our feet, good health etc., not so much what happens once a pathogen succeeds in causing illness, how to treat illness, how to process food, how to produce crops on the moon etc. It is shocking how little is still known about everyday processes, when such great scientific progress has been made in the ‘unusual’ (eg. the origin of the universe).

12. Recognise limits of scientific approach - although science can in theory explain everything, this is very different from actual scientific knowledge and the scientific methodology which are useful but are limited and biased. Scientific methods, and therefore the knowledge derived, are biased towards what can be determined through experiments ie. short-term, immediate, direct influences and impacts which are statistically significant in experiments. It thus is poor at identifying long-term, complex, indirect, low frequency and low magnitude effects, though these are probably more significant when it comes to health and environmental impacts and achieving our policy aims for the real world (eg. science is currently unable to address the cocktail effect, optimal nutrition etc.).

13. Decisions based on a combination of observation, experience, traditional /indigenous knowledge, science, common sense, intuition and ethics, not just scientific evidence - because of the limits of science, we use a range of approaches to make decisions in line with our aims and principles. We use all the science available, but do not rely on science solely and use all these approaches (though they each have biases of their own) to ensure a more holistic, reliable response. (Eg. as understanding of the relationships in nature take time to build up, we recognise the value of traditional knowledge and farmers’ own experiences.)

14. Led by the real world, not the laboratory ideas for new developments in organic farming come from knowledge of the natural world or practical farming experience, rather than being derived as a result of laboratory experimentation out of context off the natural environment. (Eg. using natural predation, clean grazing systems etc., rather than agrochemical and GM solutions).

Go to a Print friendly Page


Email this Article to a Friend


Back to the Archive