Review of the moratorium on genetically modified organisms (GMOs) in Tasmania

Transcription

1 The Project Team Review of the moratorium on GMOs in Tasmania (2013) Department of Primary Industries, Parks, Water and Environment GPO Box 44 HOBART TAS 7001 Or by to: Review of the moratorium on genetically modified organisms (GMOs) in Tasmania The dairy industry is one of Australia s major rural industries. Based on farm gate value of production, it is ranked third behind the beef and wheat industries. There are approximately 6,900 farmers producing close to 9.5 billion litres of milk annually, for a farm gate value of just under $4 billion. An important characteristic of the Australian industry is the sharing of common safety and quality standards between the jurisdictions of states that support dairy farming. The industry recognises dairy farming in Tasmania as an integral part of Australian dairy supply, and the next largest producer of milk after Victoria and New South Wales. In addition, the Australian industry recognises the importance of evidence-based science to underwrite the advances and technologies essential to improve the sustainability of the industry on farm and in factory from the perspective of both domestic and international markets, whilst respecting the choice of farmers and producers alike over the use of such technology. The dairy industry welcomes the chance to present this submission in response to the Tasmanian Government s review of the moratorium on genetically modified organisms in Tasmania. This submission is made on behalf of the Australian dairy industry by the Australian Dairy Industry Council (ADIC). The ADIC is the national peak policy body for the Australian dairy industry and represents all sectors of the industry on issues of national and international importance. Its constituent organisations the Australian Dairy Farmers Limited (ADF) and the Australian Dairy Products Federation (ADPF) represent the interests of dairy farmers, manufacturers, processors and traders across Australia. The ADIC notes that whilst good science is based on the notion of disproving a null hypothesis it cannot prove that something cannot happen. In this regard it is of no practical purpose to demand proof that GMOs are safe, particularly in the absence of evidence to the contrary. This submission outlines the ADIC s response to the questions raised in DPIPWE s Review of the moratorium on genetically modified organisms (GMOs) in Tasmania: Issues paper and invitation to comment. Should you require any clarification of the comments contained herein, please contact the ADIC on (03) Yours sincerely, Noel Campbell Chairman Australian Dairy Industry Council Level 2, Swann House, 22 William Street, Melbourne, Victoria, 3000 AUSTRALIA Telephone: Facsimile: ABN:

2 ADIC RESPONSES TO QUESTIONS IN DPIPWE ISSUES PAPER ToR 1) Domestic and international gene technology policy relevant to primary industries Q 1.1 Are there any other examples of innovative GMO policy and regulation from other States or countries that Tasmania could learn from? Australia has a federal regulatory system that ensures that GM crops approved for commercial release are safe for humans and the environment. GM crops do not need their own policy or regulation, innovative or otherwise, over and above the science-based system provided by the Office of the Gene Technology Regulator. Market and trade aspects of crops have been managed by the agriculture sector for years. This raises the question as to why should GM crops which are now 17 years old and grown extensively around the world be treated differently to other crops and agriculture products? To provide one Australian example, the State of Victoria allows GM crops to be commercialised once the federal regulatory system, through the Office of the Gene Technology Regulator, has approved the crop. This system, while not innovative, delivers choice for all including those who wish to grow the new varieties and those who do not. This system has worked well since it was implemented in 2008 and GM canola was introduced. Such a system is mirrored around the world for example, in the US where GM crops are grown extensively at the same time that other production systems, such as organic, are also expanding. According to the USDA ( in 1995 (pre-gm crops) the area of certified organic farmland in the USA was 917,894 acres. In 2008 (the latest available information) after 12 years of GM crops, the area of certified organic farmland was 4,815,959 acres. During a similar time period the area planted to GM crops in the USA grew from 2.8 million hectares in 1996 to 62.5 million hectares in ( clearly demonstrates the ability of different farming systems to coexist and grow together. The DPIPWE Issues Paper lists Tasmania s 10 key trading partners. While there are variations between these country s regulatory approaches, it is important to note that (a) all 10 countries allow GM food (or ingredients from GM crops in food) and/or animal feed, and (b) many of the products under development in Australia would not trigger a specific GM approval or be identified as GM for example, in the future, a GM high energy pasture which increases milk production does not alter the end product, the milk. GM moratorium review Tasmania ADIC Submission 2

3 ToR 2) Research and development relevant to the use of gene technology in primary industries. Qs 2.1 & 2.2 Are there any new or emerging opportunities in gene technology or in non- GM biotechnology that could benefit Tasmania s primary industries, now or in the future? The Australian research projects focussed on barley, canola, ryegrass, wheat and white clover could all offer benefits to Tasmania. Gene technology in crops is now moving to include consumer/health-orientated traits in addition to more traditional agronomic traits. Such research may offer benefits to the Tasmanian community benefits which extend well beyond the primary industries sector. While a moratorium is in place, farmers will not be able to exploit the benefits of GM crops, however, should GM crops be permitted, this will not prevent the exploitation of non-gm ( non- GM biotechnology ) opportunities. Q 2.3 What impact has the moratorium had on research and development of new products or markets? This is hard to quantify, but a moratorium which essentially does not allow for a path-to-market provides (a) a disincentive to invest in research, and (b) a non-encouraging environment for young people considering a university degree or career in agriculture, science, food science etc. A ban on a product that has been proven safe and grown globally for 17 years does not create an environment of innovation, when a potential developer is unable to commercialise their end product. It should also be asked what impact a moratorium has on the community s perception of agriculture and food. Does a moratorium imply that certain R&D or crops are unsafe or that farmers are exploring unacceptable technology and innovation? GM moratorium review Tasmania ADIC Submission 3

4 ToR 3) The potential market advantages and disadvantages. Q 3.1 The use of GMOs in Australia is controlled by a dual system of national and State regulation.. Is having a moratorium appropriate for Tasmania? The Tasmanian moratorium allows for no choice, contradicts modern day agriculture that supports coexistence across many platforms, and has a maintenance cost of $250,000 per annum. It prevents the market from working by denying farmers, customers and consumers the GM option. Q 3.2 From a marketing perspective, we particularly want to hear from actual producers, retailers, wholesalers and exporters: a) What products do you sell in a domestic or international market as Tasmanian and/or GMOfree? b) What market opportunities have you gained or lost over the last 10 years as a result of Tasmania s GM moratorium? c) If Tasmania s GMO moratorium was to lapse what would be the impact on your business? d) If non-food GM crops were grown commercially in Tasmania would this impact on your food markets? e) Can you provide evidence of the financial benefits or costs to your business as a result of the current moratorium? While individual businesses will provide input to this, it is interesting to note that the Government s policy statement on Gene Technology and Tasmanian Primary Industries is to position Tasmania in the global marketplace as a producer of food that is genuinely GMO-free by striving to ensure that no GMOs are released to, or persist in the Tasmanian environment, and by encouraging investment in GMO-free business through brand development and pursuit of GMOfree opportunities in primary industries. Despite this position, a 2012 report commissioned by the Tasmanian Department of Economic Development, Tourism and the Arts, entitled Market Advantage of Tasmania s GMO-free Status (available at: data/assets/pdf_file/0011/67736/mf_tas_gmofree_marketing_advantage_2.pdf) reported that: A survey of 28 key stakeholders found that Tasmania s GMO-free status does not create a point of different but there were a range of views expressed in relation to the market advantage and disadvantage. The only tangible (quantifiable) benefits identified for specifically GMO-free product were for GMO-free canola seed, and some GMO-free canola oil meal being shipped to Japan. The combined farm gate value is estimated at around $1.9 million. On the other hand, there has been an annual loss of around $9 million farm gate over the past 10 years because the state s GMO moratorium closed down a potentially much larger GM canola seed industry. Many countries and regions have examined the potential for GMO-free marketing almost all have concluded that the potential benefits do not exceed the costs. At a general commercial level the Moratorium is anathema because it effectively represents Government interference in the legitimate marketing activities of lawful businesses. Further, it detracts from the ability of companies to differentiate and meet the needs and requirements of different market segments a prerogative and essential element of sustainable businesses, and artificially blocks market signals that enable both companies and dairy farmers responding to market signals which are essential for their on-going viability. GM moratorium review Tasmania ADIC Submission 4

5 Q 3.3 Should Tasmania s policy allow for exemptions to a moratorium? If so: a) How could any exemptions be determined and by whom? b) What other issues could arise and how could they be managed? Tasmania s policy should not extend beyond the existing Federal system, overseen by the Office of the Gene Technology Regulator, which ensures GM crops that are commercialised are safe for the environment and human health. The Tasmanian Government should utilise the current science-based system. Q 3.4 Is it possible for GM and non-gm crops to co-exist and not affect the marketing of Tasmania s products? GM canola was endorsed by 29 Australian organisations following the development of the market choice criteria that demonstrated the industry s ability to manage coexistence. In removing the moratoria in New South Wales and Victoria, the two State governments also recognised the grains industry s ability to manage coexistence. The grains industry approach to GM canola is available at: o Delivering market choice with GM canola - data/assets/pdf_file/0019/2935/delivering_market_choi ce_with_gm_canola_-_final_-_1mb.pdf o Principles for process management of grain within the Australian supply chain - data/assets/pdf_file/0020/2981/principles_for_process_ Management_Final.pdf Table: GM canola market choice model Step Action 1 Australian regulatory approval gained for GM varieties 2 Market requirements identified Need for segregation to meet the various requirements of domestic and international consumers 3 Threshold levels established Australian AP thresholds established for the presence of GM traits in canola at 0.5% for seed (Australian Seed Federation) and 0.9% for grain (NACMA CSO1 Canola standard) AP thresholds established in key trading partners, such as Japan (5%) and Europe (0.9%), for contractual or labelling purposes 4 Importing market approvals in place GM varieties have approvals in key importing countries 5 Supply chain processes to meet market requirements Protocols available to segregate throughout the supply chain Q 3.5 The current moratorium automatically expires in November If a decision is made to extend the moratorium beyond 2014, what would be an appropriate length of time for the new moratorium? An extension of the moratorium is not supported. GM moratorium review Tasmania ADIC Submission 5

6 Q 3.6 What would be the impact on the Tasmanian brand if the current GMO moratorium expired? A report commissioned by the Tasmanian Government ( data/assets/pdf_file/0011/67736/mf_tas_gmofree_marketing_advantage_2.pdf) surveyed 28 key stakeholders and found that Tasmania s GMOfree status does not create a point of difference but there were a range of views expressed in relation to the market advantage and disadvantage. Based on this, the removal of the moratorium is unlikely to have any impact. Q 3.7 What would be the impact of Tasmania s brand if non-food GM crops were grown commercially in the State? As above. GM moratorium review Tasmania ADIC Submission 6

7 ToR 4) Any other relevant matters. Question: Dairy industry competitiveness. The issues paper notes that if GM pasture varieties were introduced in other areas (e.g. Victoria or New Zealand) and Tasmania did not allow GM pasture, Tasmanian producers would have a point of difference, however, the paper questions if the Tasmanian dairy industry could turn this into a market advantage. Current research suggests that GM ryegrass has the potential to increase milk production by 10 per cent. If we use this as a base, the question needs to be asked if the Tasmanian industry were to be banned from accessing these new varieties, would any available market advantage be greater in value than this 10 per cent milk increase. It should also be noted that: Future GM pastures, beyond the first models could deliver greater benefits. If there was a market advantage to be gained from dairy products derived from cows not fed GM pasture this market advantage could still be delivered if GM pasture was grown in Tasmania GM pasture modelling research indicates that a GM high energy ryegrass that potentially delivered a 10 per cent milk increase, would also deliver strong commercial returns for all parts of the supply chain and strong benefits to regional communities. These benefits, beyond the immediate benefit to farmers, should not be overlooked. GM moratorium review Tasmania ADIC Submission 7

8 FOR FURTHER CONSIDERATION In addition to the questions posed in the DPIPWE issues paper, the following observations are made: 1. Opportunities that may be forgone in Tasmania There is considerable scope for the dairy industry to expand in Tasmania, which would involve renovating pastures to increase their productivity. New technology such as high-energy ryegrass is a valuable tool to extract the maximum value of milk production from each new hectare of dairy production. Ryegrass pasture is also relevant for high rainfall beef and lamb production that further increases its relevance for the Tasmanian economy. The high-energy ryegrass technology involves the use of GM technology to add an additional copy of two genes that exist in ryegrass plants. This GM plant generates additional energy from sunlight that is available as energy for greater plant growth as well as in stored energy that is consumed by animals. This increase in nutritive value is estimated to increase the productivity of dairy land by approx. $200 per hectare. Perennial and Italian types of ryegrass are the predominant pasture for Tasmanian dairy farmers. In addition there is a substantial industry located in Tasmania that produces ryegrass pasture seed for the entire Australian market. Therefore there are two distinct industries that have the ability to expand and meet the Tasmanian government s vision to substantially increase the State s food and agricultural production and become a major supplier of premium products. The on-farm impact of high-energy ryegrass has been modelled using multiple years of research data from a Tasmanian site (Elliot) and a western Victorian site (Terang). There is considerable evidence that the high-energy ryegrass will deliver greater economic value in a Tasmanian dairy environment compared to the western Victorian dairy environment. This regional difference may be as high as 40% and is attributable to higher rainfall during summer in Tasmania. 2. Proactive marketing Most of the examples of current day GM crops/products are those with agronomic traits. As a result, the marketing of these products have been directed at an agriculture rather than consumer audience. In reviewing the moratorium, the Tasmanian Government is encouraged to look beyond current, Australian research and explore the development of new emerging products. While these specific products may not be destined for Australian shores, the new products and the different marketing approach may present some food-for-thought. Two examples are as follows: a. GM apples A company has used gene technology to stop apples browning when cut and now they are out marketing and promoting their project in a positive way. Their website ( talks about the benefit this product will offer the entire supply chain and lists the consumer, the producer, the packer, the retailer, the foodservice operators, the fresh cut apple processors and the juice and sauce processors. The website reads: Welcome to Okanagan Specialty Fruits, home of nonbrowning Arctic apples. Our vision is to develop new commercial tree fruit varieties that offer exciting benefits to the entire supply chain, from growers to consumers. The company's first commercial product, nonbrowning Arctic apple varieties, is ideally suited to do just that. Modern science is revitalizing the commercial tree fruit industry, and Okanagan Specialty Fruits is at the forefront of this revolution. We are proud to deliver this science to our industry... We are committed to transparency and partnership. All our products must prove they add value to both consumers and the industry, and exceed all food safety standards before being commercially released. This product is currently being assessed by the relevant regulator. Further information is available via the Arctic Apples link referred to above. GM moratorium review Tasmania ADIC Submission 8

9 b. GM pineapple The Del Monte website reads, Del Monte Fresh Produce Company is one of the world's leading vertically integrated producers, marketers, and distributors of high-quality fresh and fresh-cut fruit and vegetables. Our long-range vision is to become the leading global supplier of healthful, wholesome, and nutritious fresh and prepared foods, and beverages to consumers of all ages. Del Monte has developed a GM pineapple with rose-coloured flesh. To create the colouring, the pineapple has over-expressed genes from a pineapple and tangerine and in addition, modifications have been made to alter the flowering of the plants to ensure more uniform growth and quality. Here GM has been used to create both novelty and address consistency of supply. This product was approved earlier in the year for import into the USA. 3. Australian market research/consumer attitudes The former Department of Industry, Innovation, Science, Research and Tertiary Education has conducted studies into public attitudes towards biotechnology since The latest study was conducted in late 2012 and surveyed 1000 adults across Australia on attitudes towards a range of biotechnologies including GM foods and crops, stem cells and using animals to produce human medical treatments. Findings relevant to agriculture/food include: People are more supportive of GM foods that have health outcomes or are cheaper, and find lasting longer or tasting better only of minor benefit. Support for GM foods and crops has remained fairly consistent over the past few years, with about 60 per cent of the population willing to eat most GM foods, and about 25% not willing. However this figure changes depending on the type of food being modified, whether there are benefits to the consumer and perception of effective regulation. Just over half (52%) of the population were in favour of growing GM crops in their state and a third (32%) were opposed but about six in ten of those opposed would change their mind if the crops could demonstrate positive outcomes for the environment, provide benefits to health or pass stringent regulations. Conversely, many of those who supported growing GM crops in their state would change their position if benefits were not proven or it diminished farmers competitiveness. GM moratorium review Tasmania ADIC Submission 9