Home > Resource > Briefing > The SCIMAC Code of Practice and Guidelines for Growing Genetically Modified Crops: A Critique by Friends of the Earth
Home > Resource > Briefing > The SCIMAC Code of Practice and Guidelines for Growing Genetically Modified Crops: A Critique by Friends of the Earth
This critique is based on five discussion papers which set down the proposed code of practice prepared by the Supply Chain Initiative on Modified Agricultural Crops (SCIMAC) dated March 1999. These documents have not been published at the time of writing.
The guidelines, as they stand, would completely fail to ensure the safe introduction and use of genetically modified herbicide-tolerant (GM HT) crops, nor do they address the dangers posed by these crops. Friends of the Earth has identified the following areas where the SCIMAC guidelines are fundamentally flawed:
In the past, voluntary regulation in farming has proved to be a failure. In the 1980s the voluntary agreement on the approval of pesticides failed to ensure that dangerous pesticides were removed from the market. The voluntary scheme was replaced by statutory provision under the Food and Environmental Protection Act 1985. Similarly, a code of practice on the burning of straw and stubble failed to assuage public fear and concern or to control air pollution. In the end straw and stubble burning was banned by legislation in 1993 except for specific cases (Crop Residues Burning Regulations SI 1366/93).
Friends of the Earth recommends that the Government should not agree to the current SCIMAC draft. We believe that any such code should be on a statutory basis as suggested by the House of Lords European Affairs Committee Report (EC Regulation of Genetic Modification in Agriculture - para 181).
Friends of the Earth is calling for a minimum five year freeze on:
During the Five Year Freeze the following must be developed:
This critique examines the proposals for a voluntary code of practice to manage the commercial growth of genetically modified (GM) crops. Government ministers Jeff Rooker (Food Safety) and Michael Meacher (Environment) made statements before the House of Lords Committee on European Affairs on Agriculture, Fisheries and Food on 21 October 1998 referring to a potential agreement with the biotechnology industry to produce guidelines and a voluntary code of practice for farmers. At no stage has there been any indication that these will be put a statutory footing.
The Ministers were optimistic about the ability of the code of practice to ensure that the environment would be safeguarded:
Mr Rooker said:
“Herbicide tolerance, which is one of the main traits being engineered
into crops for use in the UK, may cause serious problems as a result of their
spreading to neighbouring crops and related wild plants... MAFF has therefore
urged the proponents of GM crops to draw up guidelines on their correct use.”
Mr Meacher said:
“We have reached agreement in principle with the plant breeding industry
for a programme of managed development of herbicide tolerant GM crops, whereby
the first farm-scale plantings are strictly limited and monitored for ecological
effects... This process will be underpinned by the strict guidelines for best
practice in using GM crops referred to by Jeff Rooker”
The group which has produced the guidelines and code of practice is known as Supply Chain Initiative on Modified Agricultural Crops (SCIMAC), a consortium of UK companies set up to promote the development of GM crops in the UK. They have presented proposals to deal with the first generation of GM crops, which are all herbicide-tolerant. These crops have been engineered to be tolerant to a particular herbicide enabling farmers to spray the growing crop without damaging it but destroying all weeds. At present crops tolerant to glyphosate, manufactured by Monsanto, and glufosinate ammonium, manufactured by AgrEvo, are the closest to being commercialised in the UK.
Herbicide-tolerant crops are a cause of serious concern, with consequences for wildlife, the environment and the future of UK farming. They represent a further intensification of UK arable farming, a sector which is already causing serious damage to the UK countryside. The threats which they pose include:
SCIMAC's Code of Practice contains no measures to protect biodiversity.
The main threat to UK wildlife from herbicide-tolerant crops comes from the switch to using the broad spectrum herbicides glufosinate and glyphosate. Their use is likely to eliminate weeds from broad leaved crops which have been a haven for wild plants in the arable rotation. The SCIMAC guidelines completely fail to deal with this issue, despite the fact that it was this which prompted English Nature to call for a moratorium on GM crops(1). These guidelines will provide absolutely no protection for wildlife on farms where herbicide-tolerant crops are grown. They contain a list of organisations which are involved in farm land biodiversity conservation, but there is no requirement for farmers to make contact with these organisations or put in place conservation measures.
“The environmentally-untested introduction of GMOs could be the final blow for such species as the skylark, corn bunting and the linnet, as seeds and insects on which they feed disappear”. English Nature Press Release 8 July 1998
“In field conditions, rape does not readily cross with any other species” - Guidelines for Growing Newly Developed Herbicide Tolerant Crops (p.2).
This is not true. Natural hybrids between oilseed rape and wild turnip (Brassica rapa) occur and they have been listed as part of UK flora(2). Hybrids have been found growing in Denmark(3), and at a recent conference it was announced that hybrids had been found growing in oilseed rape fields in Yorkshire. Therefore SCIMAC's statement seriously downplays the risk of growing GM crops.
“Ensure that cross-breeding with non-herbicide tolerant varieties or those tolerant to a different herbicide is minimised by maintaining an appropriate distance between the crops” Guidelines for Growing Newly Developed Herbicide Tolerant Crops (section 5).
The current guidelines provide separation distances between GM and non-GM crops which will be totally inadequate to prevent contamination. The recommended isolation distances for GM oilseed rape are 200 metres to certified seed and organic crops and only 50 metres to conventional oilseed crops. Recent monitoring work by DETR found outcrossing rates of 0.11% at 50 metres distance from small GM test sites(4). In their monitoring of large size test sites, researchers concluded that “detection of herbicide tolerance in seed of male sterile oilseed rape plants at distances of up to 400m show that there is potential for oilseed rape pollen to be dispersed by wind and remain viable over considerable distances”(5). Work conducted by the Scottish Crop Research Institute detected viable pollen up to 4 kilometres from oilseed rape fields. Not only are the maximum separation distances wholly inadequate but it is unclear why conventional oilseed rape is given so little protection when it is quite possible that farmers will be under contractual obligations to produce GM-free oilseed rape crops.
The separation distances to non-GM maize crops are only 200 metres despite the fact that recent evidence presented by the Soil Association showed that large amounts of maize pollen have been found to travel distances exceeding 500 metres(6).
The maximum separation distance provided for GM sugar and fodder beet crops is 600 metres. Recent work examining wild beet populations in the UK found gene flow occurring between populations at a distance of 14 kilometres(7). Not only do the current guidelines fail to protect non-GM crops from contamination, but there is no provision for the separation of GM beet crops from wild plant populations despite the fact that the guidelines acknowledge that cross-breeding between cultivated and wild beet is certain to happen. There should also be provision for separating GM crops from weed beet populations in order to prevent the rapid development of herbicide resistance in these troublesome weeds.
Sugar beet and fodder beet are able to cross-breed with other crops, including beetroot and spinach beets, as well as with wild sea beet (Beta vulgaris spp maritima). Beet crops are biennial, but there can be flowering in the first year, known as bolting. The pollen of sugar beet and fodder beet can travel at least 3km(8)and so there is unlikely to be any satisfactory isolation distance which would prevent the bolters of the GM crop cross-breeding with other crops and wild plants. In the SCIMAC guidelines, it is suggested that farmers should "destroy all bolters before flowering to prevent pollen release or seed production" (section 5, para 8). But this is extremely tedious and labour-intensive work, as it often has to be done by hand. In any case, labour is in short supply on arable farms. If this policy were effectively policed, farmers might carry out this extra work, but enforcement would be extremely difficult as every field would have to be monitored.
"Few farms have a labour surplus and this will make any extra work entailed in meeting the requirements difficult to complete reliably" - East Anglian arable farmer, November 1998
"As part of the rotational strategy for any field, growers must not plant any two GM/HT crops in immediate succession. The only exception is GM/HT maize which can be grown in continuous maize rotations" Guidelines for Growing Newly Developed Herbicide Tolerant Crops (Section 2, para 3).
This advice will not prevent genetically modified volunteers becoming a problem for farmers in following crops. In a recent monitoring study conducted by the DETR it was found that volunteers tended "to be more prevalent in the second crop post GM release"(9). The current advice will lead to a situation in which farmers will be growing GM crops with a high likelihood of GM volunteers appearing in them. In addition, allowing GM/HT maize to be grown in continuous rotation will encourage natural herbicide resistance to develop amongst weed species.
"Volunteers of the HT [Herbicide-tolerant] crops continue to be as susceptible to other herbicides and control methods as conventional varieties". Guidelines for Growing Newly Developed Herbicide Tolerant Crops (Background Issues p.2).
This statement, although accurate, fails to account for the problem which these volunteers could pose to farmers. Oilseed rape and sugar beet volunteers are already a problem on many farms. It has been estimated that over 750,000 hectares of cereal rotations in the UK are infested with oilseed rape(10), which gives an indication of how ineffective conventional methods actually are. In addition, oilseed rape seeds can become dormant in the soil, emerging several years after the crop was originally planted. This can add further complications to controlling oilseed volunteers. In the SCIMAC guidelines it is recommended that farmers "do not use deep soil inversion ... for at least three weeks post-harvest" (section 7, para 2), which could go some way to reducing dormancy and to increasing the likelihood that seeds shed in the field will germinate soon after harvest - but this will not eliminate the problem.
GM sugar beet volunteers could pose a serious problem to farmers. At harvest, bits of sugar beet root are inevitably left in the ground and continue to grow. These can be very difficult to control, because of the large root. GM sugar beet volunteers will flower in the following crop, increasing the risk of outcrossing to weed and wild beet.
"No matter how well the combine is set, shedding will occur. Oilseed rape will be transferred by tractor wheels, people's shoes, leaks from trailers, to other areas, especially in damp conditions" - agronomist, South Wales, November 1998.
"To preserve the management of herbicide tolerance on farm, it is strongly recommended that seed of crops of the same species from adjacent fields should not be saved" Guidelines for Growing Newly Developed Herbicide Tolerant Crops (section 7, para 5).
This may protect the farmer who grows GM crops, but fails to address the problem of contamination of other farmers' fields. In a recent report from North America, a farmer found large amounts of glyphosate-resistant oilseed rape appearing in a field where it had never been grown previously. This appears to have been due to cross pollination(11). The current guidelines will do nothing to protect farmers near to GM crop farmers. Section 3 details the distances which oilseed rape and sugar beet pollen can be transported by wind and insects; it is unlikely that any code of practice could guarantee that there was no cross pollination between neighbouring crops. The growing demand for food ingredients free of GMOs makes statutory safeguards essential if farmers' interests are to be protected.
"Failure to reach agreement between neighbouring growers must be notified to SCIMAC at the latest within seven days of the specified notification date for consultation with the appropriate representative body (eg UKROFS). Any failure at this stage will be resolved through normal legal channels". Guidelines for Growing Newly Developed Herbicide Tolerant Crops (Section 2. para 5)
The strategy for dealing with disputes is unclear and there is no indication of how neighbouring farmers will be persuaded to undertake what could be financially damaging actions. The implication in the guidelines is that disputes will eventually be resolved in court. Although this provision will be of benefit to lawyers it does not provide much comfort to farmers who wish to grow non-GM crops. Even the minimal isolation distances proposed could impose severe restraints on farmer planting decisions. As it stands, this suggestion raises several questions: Who is liable if cross pollination financially damages either or both farmers' crops? Will farmers be required to take out insurance against such an event? Will insurance companies provide such cover? What will be the consequences if they don't?
"In this situation the onus lies with the GM grower to notify neighbouring farms in writing of his planting intentions-as soon as possible and at the latest by 1st August for autumn-sown crops and by 1st March for spring-sown crops. There is a responsibility on both parties to act in good faith in reaching agreement on planting strategies." Guidelines for Growing Newly Developed Herbicide Tolerant Crops (Section 2, para 5)
Protection of organic farmers is left to voluntary agreements between GM growers and organic farmers. There appears to be no requirement for farmers to identify organic farms in their area. The implication is that organic farmers may be expected to alter their crop planting in order to accommodate the GM crop. The organic farmer potentially faces a highly unjust situation in which their crop could be compromised due to the actions of another. Small farmers may not be able to move their crop outside the pollination zone, perhaps forcing them to stop growing a particular crop. In addition, it is substantially more difficult (and may even be impossible) for an organic farmer using a complex rotation to simply move crops around the farm, and could even result in loss of organic certification. This was illustrated in 1998 when Guy Watson, an organic farmer near Dartington, Devon, was faced with GM fodder maize growing near his planned sweetcorn crop. Mr Watson was advised by the Soil Association that his crop could lose its organic status:
"As you are aware, genetically-engineered organisms and their derivatives are excluded from the Soil Association's organic standards. Cross pollination between the two crops at this distance is a significant risk and in these circumstances the harvested crop from your sweetcorn would be contaminated, since cobs consist largely of seed material.
"We have now consulted with an official of UKROFS, our Competent Authority under Regulation 2092/91, who shares our view that in these circumstances the certification status of your crop could be placed in jeopardy." - letter to Guy Watson from Francis Blake, Certification Director of the Soil Association, 5 May 1998.
In the end, Mr Watson decided to move his crop as far from the GM maize as was possible to minimise the chance of cross pollination.
As the proposal from SCIMAC stands, every organic farmer would have to take the same action as Mr Watson if faced with a GM crop in a neighbouring farm. Many would not be able to because their land holding would be too small to escape the risk of cross pollination. The requirement to remove a crop if necessary must rest firmly with the GM crop farmer.
"Establishing a co-ordinated and robust framework of information, advice and rigorous control will promote best practice along the primary supply chain, and ensure the safe and effective introduction of this new technology onto UK farms" - Guidelines for Growing Newly Developed Herbicide Tolerant Crops (page 1, para 3).
These are worthy aims, but in their own code of practice for the introduction of GM crops, SCIMAC show how their proposals would completely fail to deliver such a system. Under the SCIMAC proposals, almost all the information provided to farmers will come from "the licenser of the GM technology and/or the developer of the variety" (Code of Practice - Information Requirements). This information will take the form of marketing literature, and an explanatory leaflet which will provide details of where to get further information about the crop, such as a telephone help line - run by the "licenser of the GM technology and, where applicable, the variety owner". The only source of independent information to farmers will be existing seed variety guides, but these only deal with the performance of the crop - they do not provide any environmental or practical information.
As the guidelines stand, farmers will not receive any independent literature, nor any information detailing the risk to the environment of growing GM crops. This is completely unacceptable, and fails to protect farmers from commercial exploitation by the promoters of GM crops.
"I have seen lots of materials presented to me by various companies. The problem is that they tend to show information that suits their case. These leaflets should be produced by independent people with no commercial gain and with all the information at their disposal" - agronomist, South Wales, November 1998.
"Notify any problems or unexpected occurrences...through the appropriate reporting channels" - Guidelines for Growing Newly Developed Herbicide Tolerant Crops (section 1, para 7) .
An integral part of protecting the environment must be the monitoring of the impacts of GM crops and effective reporting of problems as they arise.
But later in the above-quoted section, SCIMAC state that "monitoring and reporting systems will be operated by individual companies" and a "summary of feedback received" will be published annually. It is totally unacceptable for the system of monitoring and reporting of GM crops to be controlled by the organisations that promote and sell them. As it stands, the only reports to government agencies will be summary reports prepared by the industry. This cannot constitute an independent and effective monitoring system. Any monitoring and feedback system must be independent of commercial interests.
Self monitoring and regulation in farming has a sorry history. The NFU's voluntary code of practice on the burning of straw and stubble was widely recognised to have failed long before it was finally banned in 1993 (See section 13 below).
The guidelines require that farmers implement extensive new record keeping and working practices. These requirements would impose extra labour and cost demands on farmers, including extra training for staff, extra record keeping, monitoring for and mapping volunteers, negotiation with neighbouring farmers, maintenance of separation distances, extra cleaning of machinery and extra control of sugar beet bolters and volunteers.
Guidelines such as these, which will impose significant costs on farmers, will require rigorous enforcement to ensure that they are adhered to. It is questionable whether the current proposals will provide this.
The responsibility for the majority of the enforcement and monitoring of farmers will fall to the licensed agricultural supplier. Increasingly, strong links are developing between the agricultural supply industry and biotechnology companies. For example the recently announced SCATS Agriseeds Ltd is a joint venture between a UK agricultural co-operative and a US agrochemical and seed supplier. In a letter to its customers, the UK co-operative justified the deal by saying that "technological changes in seed production are being driven by the agrochemical manufacturers who now own many of the plant breeders." So it is likely that agricultural suppliers will increasingly have a financial interest in the promotion of GM technology. It also seems highly unlikely that suppliers will want to impose severe penalties on their own customers when there is no benefit in it to them and when it will ultimately result in a loss of trade. Agricultural supply companies who wish to maintain good relations with their customers will be under severe pressure to turn a blind eye to infringements.
In theory, the third party auditor will prevent this kind of conflict of interest. However, under the SCIMAC guidelines the auditor will operate under contract to SCIMAC whose stated aim is the promotion of GM technology. In addition, it is proposed that by the third year of the scheme only one in ten farmers will be independently examined. Thus, as adoption by farmers increases the level of monitoring will fall. In contrast, one in two of the variety owners and seed merchants will be examined. This may well reflect a desire to cut costs - on-farm inspection is very expensive - but continued independent inspection of farms is essential if enforcement of the code of practice is to be effective.
The only real censure that this system proposes will be the withdrawal of access to GM crop technology, but even this is unlikely to be imposed upon growers. The system of penalty points that is suggested by SCIMAC concentrates on administration and industry protection instead of environmental protection. For example, saving seed without the variety owners permission will result in immediate withdrawal of the GM technology, whilst actions such as failure to prevent cross-contamination or to manage GM volunteers are less severely penalised and do not result in removal of access to GM crops.
"Penalty points will be automatically deleted after three years on a rolling basis". Measures to ensure compliance with the SCIMAC code of practice (Penalties for non-compliance)
Considering the low level of penalties to growers for actions which could cause harm to the environment, this proposal would allow growers who repeatedly mismanage their GM crops to avoid the only real censure that is available.
As the proposals are only for "the initial years of the technology's introduction" there will not be any long term system to ensure the safe management of GM crops. This is in spite of the fact that the variety and range of GM crops will increase in the future, vastly increasing the possibility of damage to the environment.
The point system is:
One visit a year will make it impossible to track what is happening on a farm. For a point system to work each farm would require year-round inspection.
It is not unreasonable to assume that significant extra resources would be required to ensure that the code of practice is effectively followed. Very few farms have any surplus labour, and so there will be severe temptations for farmers to cut corners. In the absence of rigorous enforcement these guidelines will count for very little. The guidelines propose that enforcement will be by existing government bodies such as the Health and Safety Executive (HSE) and by the companies promoting GM crops. HSE inspectors are already extremely busy and without further resources they will be unable to provide anything beyond minimal and infrequent inspections. In 1997, the number of agricultural holdings in the UK was 211,868 (MAFF annual farm census 1997). HSE have less than 100 farm inspectors employed at any one time. HSE also inspect GMO test sites to ensure compliance with the release consent. Between April and October 1998 only one in ten sites was inspected by the two staff responsible. Unless there is a massive increase in staffing at HSE the suggestion that HSE will be able to make a meaningful contribution to the enforcement of the SCIMAC code of practice is fanciful.
"Requirements of the agricultural supplier to: refuse to sell seed of GM/HT varieties to growers....who cannot demonstrate the required levels of training/competence" (Terms of Interprofessional Agreements (i)1).
Exactly how a seed merchant is expected to assess the competence of one of their customers is left unclear. There are no specific requirements for farmers wanting to grow GM crops although there is suggestion that farmers will have to prove that they can meet the requirements of the SCIMAC guidelines. The only control is that GM technology could be withdrawn from farmers after they have failed to use it safely. This will do nothing to ease public concern about GM crops. There are no provisions to ensure that a farmer who is turned down as incompetent by one supplier cannot simply go elsewhere. An industry sponsored and regulated scheme for growing GM crops, whose entry is apparently dictated by the seed suppliers, could face serious opposition from many farmers.
As farmers are already concerned with the amount of paperwork, these guidelines will substantially increase the amount of red tape. Schemes such as the Assured Combinable Crop Scheme are already unpopular with farmers, particularly smaller ones. Recently, a county branch of the National Farmers Union called on the NFU president not to introduce any more assurance schemes without a referendum of all members(12). Small farmers feel that these schemes unfairly penalise them while giving cost savings to large producers. A statutory obligation would at least apply to all.
The extra paperwork includes:
"The code of practice appears to us to put farmers in a strait jacket, increasing the already heavy burden of paperwork".The Farm and Food Society, letter to Michael Meacher 26 November 1998.
"Do not rely entirely on the same herbicide for weed control and subsequent stubble clear-up. Consider an alternative herbicide or mixture, or combination of herbicides and cultivations" Guidelines for Growing Newly Developed Herbicide Tolerant Crops (section 5 paragraph 4)
The current guidelines recommend using multiple herbicides, and acknowledge the likely development of multiple tolerant volunteers. Management of such problems would inevitably be dependent upon increased herbicide use.
In March 1998, MAFF published a Code of Practice for the Safe Use of Pesticides on Farms and Holdings. This included the following advice to farmers:
"Unnecessary use of pesticides can involve risks to the health of humans, both as users and consumers, other creatures (including beneficial insects), plants and the environment. It can also be uneconomic and could increase the possibility of pesticide resistance. In some cases unnecessary use might also damage the crop.
"The 1990 White Paper, The Common Inheritance, established Government policy that the use of pesticides should be minimised to that necessary for the effective control of pests, compatible with the protection of human health and the environment. Farmers and growers are encouraged not to use pesticides unless it is necessary for the protection of their crops from pests, weeds and diseases."
The SCIMAC advice is not in line with this Code of Practice. SCIMAC is advising use of herbicides to control volunteer crops; MAFF is advising against pesticides. SCIMAC's advice would lead to an increase the amount of herbicide used on herbicide-resistant crops. The advice is also inconsistent with the Government's sustainable development policy. Claims by the biotech industry that herbicide-resistant crops will reduce the amount of herbicide used need to be closely examined.
The record of voluntary codes of practice in agriculture is not impressive. Agriculture is a widely dispersed industry where inspection is not easy.
The SCIMAC guidelines would require a high level of enforcement on-farm, for instance to ensure volunteers were being controlled correctly and to ensure buffer zones around growing crops were sufficient. The SCIMAC proposals would mean that by the third year only one in ten farms would be independently examined, and for the remaining 90 per cent, environmental protection would rely on farmers acting in good faith.
Below are details of three voluntary schemes which were operated by the agro- chemical industry and farmers. All three have failed and been replaced by statutory provision.
"It is plain that many farmers are ignoring the National Farmer's Union's voluntary code of practice on straw burning, which in itself is now shown to be too restricted" - Jack Boddy, Farmworkers Section of the T&GWU and Ken Cameron, General Secretary of the Fire Brigades Union, joint statement, 19 September 1983.
The control of genetically modified crops is no easy task either by voluntary
agreement or statute - pollen and the wind are no respecters of the law.
3.Summary and conclusions
The guidelines, as they stand, would completely fail to ensure the safe introduction and use of herbicide-tolerant crops, nor do they address the dangers posed by these crops. Friends of the Earth has identified the following areas where the SCIMAC guidelines are fundamentally flawed:
In the past, voluntary regulation in farming has proved to be a failure. In the 1980s the voluntary agreement on the approval of pesticides failed to ensure that dangerous pesticides were removed from the market. The voluntary scheme was replaced by statutory provision under the Food and Environmental Protection Act 1985. Similarly, a code of practice on the burning of straw and stubble failed to assuage public fear and concern or to control air pollution. In the end straw and stubble burning was banned by legislation in 1993 except for specific cases (Crop Residues Burning Regulations SI 1366/93).
Friends of the Earth recommends that the Government should not agree to the
current SCIMAC draft. We believe that any such code should be on a statutory
basis as suggested by the House of Lords European Affairs Committee Report (EC
Regulation of Genetic Modification in Agriculture - para 181).
1. English Nature. 1998, "Position statement on Genetically Modified Organisms", English Nature, Peterborough, July 1998.
2. Stace, C.A. 1975. "Hybridization and the Flora of the British Isles" Academic Press, London.
3. Jorgensen, RB. 1999. "Gene flow from oilseed rape (Brassica napus) to related species" in Gene Flow and Agriculture: relevance for transgenic crops. BCPC Symposium Proceedings No.72.
4. Simpson EC., Norris CE., Law JR., Thomas JE., Sweet JB. 1999. "Gene flow in genetically modified herbicide tolerant oilseed rape (Brassica napus) in the UK." in Gene Flow and Agriculture: relevance for transgenic crops. BCPC Symposium Proceedings No.72.
5. Op Cit 4.
6. Emberlin J. 1999. The Dispersal of Maize Pollen.
7. Raybould AF., Clarke RT. 1999. "Defining and measuring gene flow" in Gene Flow and Agriculture: relevance for transgenic crops. BCPC Symposium Proceedings No.72.
8. Department of the Environment. 1994. "Genetically Modified Crops and Their Wild Relatives - A UK Perspective." Research Report No 1. DOE , London 1994.
9. Norris CE., Simpson EC., Sweet JB., Thomas JE. "Monitoring weediness and persistence of genetically modified oilseed rape (Brassica napus) in the UK" in Gene Flow and Agriculture: relevance for transgenic crops. BCPC Symposium Proceedings No.72.
10. Gene Watch, 1998. "Genetically engineered oilseed rape: agricultural saviour or new form of pollution?" Gene Watch, Buxton, Derbyshire.
11. MacArthur, M. 1998. "Canola crossbreeds create tough weed problem" The Western Producer 15 October 1998.
12. "Whole-farm rebels withhold NFU subs." Farmers Weekly 16 October 1998, p 15.
13. British Agrochemicals Association, 1977. "Pesticides in Agriculture" Submission of evidence to the Royal Commission on Environmental Pollution November 1977.
14. House of Commons Agriculture Committee, Session 1985-1986. "The effects of pesticides on human health." Minutes of Evidence presented on 15 May 1986.
15. Cited in Sheail, J. 1985. "Pesticides and Nature Conservation: The British Experience 1950-1975" Clarendon Press, Oxford.
16. House of Commons Agriculture Committee Session 1985-86. The Effects of pesticides on Human Health. Minutes of Evidence 15 May 1986.
17. British Agrochemicals Association, 1977. "Pesticides in Agriculture" Submission of evidence to the Royal Commission on Environmental Pollution, November 1977 para 45.
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Real Food Team
Last modified: June 2001
