OPEN LETTER 1st February 2010
For the personal attention of: Rt Hon Andy Burnham MP Secretary of State for Health
cc: Gillian Merron, Minister responsible for FSA matters
1st February 2010
Dear Secretary of State,
Formal Complaint: ACNFP is not fit for purpose
As the Minister responsible for safeguarding the public from any possible harmful effects associated with the consumption of GM crops and foods, it is essential that you should have full confidence in the ability of the Food Standards Agency and its advisory committee ACNFP to deliver to you up-to-date and reliable advice on safety issues. Sadly, we have come to the view that both bodies have now become so partisan and complacent on GM issues that they have become criminally negligent. It follows that they are no longer fit for purpose, and we therefore ask you to take this as a formal complaint about their behaviour, and to commit your Department to a full investigation into where the responsibility for this state of affairs might lie.
Specifically, our complaint relates to the following:
1. When Renessen Monsanto submitted applications for consent for the high-lysine maize varieties referred to as LY038 and LY038 x MON810, around a dozen regulatory committees from around Europe raised such fundamental concerns about the quality of the data contained in the dossiers (and indeed suggested that the research was probably fraudulent) that EFSA was forced to request clarifications and additional feeding trials. At that point Renessen recognized that the "game was up", and pulled both applications. ACNFP should have inspected these dossiers and should have recognized their shortcomings. In its defence, Sandy Lawrie told us that FSA had not asked for any advice on the high-lysine GM varieties, and that the Committee had therefore not looked at the dossiers. In our view, and the view of many others, that smacks not just of complacency but of incompetence, and on this issue alone ACNFP and FSA both deserve very severe reprimands, on the record.
2. As you will be aware, ACNFP occasionally considers the contents of scientific papers relating to GM feeding experiments, when invited to do so by FSA or by MPs or members of the public who are concerned about apparent signs of harm. When these papers are considered, the automatic response from the Committee is as follows: " ........ it was not possible to draw any conclusions about cause and effect or to assess the significance of this report for human health". What is interesting about these responses (and there have been several of them) is that ACNFP does not dispute the findings of the researchers, or deny that signs of physiological harm have been observed, but simply expresses doubt that there is any SIGNIFICANCE in the damage recorded. The Committee also seems incapable of doing what hundreds of other scientists have done across the world -- which is to synthesise the results from scores of different feeding studies and to conclude, as the American Academy of Environmental Sciences has done, that “several animal studies indicate serious health risks associated with GM food consumption including infertility, immune dysregulation, accelerated aging, dysregulation of genes associated with cholesterol synthesis, insulin regulation, cell signalling, and protein formation,and changes in the liver, kidney, spleen and gastrointestinal system”. The Academy Report concluded that: “There is more than a casual association between GM foods and adverse health effects. There is causation …........” We are not alone in concluding that in circumstances such as these, there is only one response that a competent scientific advisory committee can make -- and that is to say "Negative health effects HAVE been observed, and we must have further long-term feeding studies in order to assess whether they are truly significant." If neither FSA nor ACNFP is prepared to take this obvious step, again we have to say that both bodies are incompetent -- and do not deserve either your confidence, or that of the public.
3. In response to a recent PQ (301230) from Alan Simpson MP, your colleague Gillian Merron admitted that there had been no review of the science relating to the health and safety effects of GM foods since 2003. She implied that the Government's GM policy was in effect based upon science that is at least seven years old, and that it remains unmodified. That is a quite incredible, given the very impressive number of scientific papers that have appeared since then which point towards a range of toxic effects which must at the very least be investigated further, if not actually taken on board with a view to GM policy revision. Again, this points to incompetence on the part of both FSA and ACNFP.
We will be grateful if you will give this matter your personal attention, and do us the honour of a personal response. We are copying this letter to FSA and to ACNFP as a matter of courtesy, but we want to be assured that YOU are in charge, and that you accept personal responsibility for keeping our food supply free of dangerous substances. We have corresponded enough with FSA and ACNFP, and we are fully briefed as to their position with regard to their functions and duties; that position is exactly what we are complaining about, and that is why we want -- at this very late stage -- ministerial leadership from you.
In conclusion, may we remind you that it is not FSA or ACNFP that gives consent for the use of GMOs in the food supply. It is their role to advise you on the potential risks, and it is down to you personally to decide whether or not to vote for consents at the EU level. You are not obliged to take FSA's advice nor is the ACNFP assessment the only consideration for Ministers when coming to decisions. We contend that the two bodies concerned have become so complacent and incompetent that their advice relating to the science of GM is now essentially worthless; and you are coming dangerously close to supporting the introduction of GM components into the food supply in the full knowledge that they are unsafe. That is a very serious matter indeed.
The evidence of harm associated with the consumption of GM materials is there, in abundance, in the peer-reviewed scientific literature. If you are unaware of it, please ask, and we will provide the full references for you. Or are you, like certain other politicians, fully signed up to the policy of "don't look, don't find"?
We look forward to receiving your personal reply.
Dr Brian John GM-Free Cymru
PS. Copied: recent correspondence with Sandy Lawrie of the FSA, who provides services to ACNFP. This material is available on request.