Submission to Agriculture and Food Policy Reference Group

By Dr David Tribe, Senior Lecturer, University of Melbourne and Dr Roger Kalla, Director Korn Technologies.

The issues paper on ‘Ensuring a profitable and sustainable agriculture and food sector in Australia’ presents a number of challenges facing Australian governments’ agricultural producers, marketers, scientists and consumers now and in the future.

We have focussed our submission on the benefits arising from the continued adoption of Biotechnology to Australian agriculture and food sector and a way forward for the testing of parallel GM and non- GM grains supply chains.

In a recent paper presented to the 9th Conference on Agricultural Biotechnology hosted by the International Consortium on Agricultural Biotechnology Research (www. economia.uniroma2.it/conferenze/icabr2005/papers/Tribe_Davi_Kalla_Roger.pdf) we described the results of an analysis of the economic and environmental impact of genetically modified insect resistant cotton in Australia.

The paper outlines the factors that have contributed to the rapid adoption of GM cotton in the well integrated cotton supply chain. The conversion to insect resistant GM cotton in Australia has provided direct economic benefits while at the same time reduced use of pesticide with concomitant reduction in yield losses in yield. Put in another way the land sown to cotton in Australia is now more productive giving a raised output while requiring less input. The adoption of GM cotton has also ensured the competitiveness of Australian cotton growers against GM cotton producers in India, China, Mexico and USA as evidenced in a recent report from ABARE on Market issues for GM crops where Australia’s share of cotton exports over the five years from 1999 to 2003 represented 37 % of world export while Australia produced less than 3% of world cotton seed (Market Access Issues for Genetically Modified Products: Implications for Australia, abareonlineshop.com/product.asp?prodid=12559).

Innovation in Australia’s first fibre, food and feed crop continues unabated and in addition to input traits now output traits with direct health benefits to the consumer are being evaluated in small scale field trials (DIR 039/2003 - Field Evaluation of Genetically Modified High Oleic (HO) Cotton, www.ogtr.gov.au).

The main concern raised by participants in the canola and cereal grains supply chain against full scale commercial production of GM canola the second GM food and feed crop that has received federal regulatory approval (DIR 021/2002 - Commercial release of InVigor® hybrid canola (Brassica napus) for use in the Australian cropping system and DIR 020/2002 - General release of Roundup Ready® canola in Australia, www.ogtr.gov.au) has been the perceived threat against the international marketing advantage of the projected default ‘GM free’ status for Australian grain producers.

The notion that Australia could protect the image of its agriculture and food export sector as being 100 % GM free (in spite of rapidly having converted to GM cotton which constituted 80% of last year cotton harvest) by delaying the introduction of GM canola has been challenged by the recent finding of minuscule amounts of a strain of GM canola mixed up in an export consignment of conventional canola and detected by sensitive forensic DNA analysis technology. The origin of this approved, but obsolete, GM strain is under investigation by the Victorian Department of Primary Industries.

The most likely explanation is that this particular strain of GM canola got mixed up in a batch of conventional canola seed imported into Australia from North America.

The modern breeding of novel types of canola and cereal grains is a global pursuit with novel genes ( derived using GM or non GM technologies in molecular breeding research centres all over the world ) being crossed into plants that are well adapted to the local growth conditions in collaborative research programs between private and publicly funded agricultural R & D organisations. Often these programs take advantage of the counter seasons with seeds being multiplicated and evaluated on both sides of the globe and frequently exchanged before commercialisation in any one country.

There are previous examples of human error creeping into this interconnected system. A GM canola strain, mislabelled as of non-GM origin, was delivered by an overseas private seed company for evaluation in the field to the Victorian Department of Primary Industries in 2003. However, this case of mistaken identity was detected before the GM canola plants had flowered and the plants were destroyed. The incident was investigated by OGTR without any action and reported on its web site (www.ogtr.gov.au/rtf/public/sept2003qrpt.rtf).

We would argue that the benefits to Australian agriculture and food industries and the consumers of Australian research organisation continuing to take part in global technology diffusion far outweighs the perceived risks to our export markets by the tarnishing of a projected ‘GM free’ image due to such mix ups.

It is in the interest of private and public research organisations to carefully manage these risks due to real issues with IP management. Such incidences, if carefully monitored, certainly doesn’t warrant that we pull out of all work with overseas research organisations nor that Australia unilaterally ban all imports of any grains from North America due to the perceived risk of ‘contamination’ of the Australian ‘GM free’ image as has been suggested by some groups ideologically opposed to GM crops.

Likewise it is unreasonable to expect that parallel GM and non- GM canola and cereal grains supply chains could guarantee 100 % purity of any type of canola in our export grain.

We see a role for the Australian Government in partnership with companies involved in the providing services in the grains supply chain and State Governments to determine what are tolerable levels of admixture of GM canola in any type of exported grain. The Australian position needs to be underpinned by scientific and economic analysis of cost vs. benefit of the testing regimes that are required to adequately address the cut –off criteria.

It is worth noting that forensic DNA testing is technically challenging and costly (in the order of $ 100 -250 per sample analysed). There are also issues with standardisation of sampling protocols of bulk consignments seed for presence of GM canola seed along the supply chain.

If it was decided that Australia required to DNA test some or all of its export grains to meet internal or external market requirements there would be a potential role for Government in advising and accrediting research organisations involved in such analysis.

The EC Directorate General Joint Research Centre, within the Institute for Health and Consumer Protection, has got a dedicated Community Reference Laboratory (CRL) for GM food and Feed. The CRL develops tests for GM crops and evaluates their efficacy. A recent example is the standardised test it developed for the Bt 10 maize strain (http://gmo-crl.jrc.it/detectionmethods/Bt10%20Detection%20Protocol.pdf).

We believe that a thorough test of the capability of the grains supply chain to keep GM canola apart from non-GM canola is required. An approach to a trial of coexistence using the GM canola strains that had received regulatory approval was originally suggested by the Australian Oilseeds Federation in submissions to a number of State Governments in the beginning of 2003. We would suggest that the original proposal could be augmented by the establishment of independent testing authority modelled on the EC Community reference laboratory for GM food and feed.

There are companies involved in DNA testing of food and feed in Australia (www.agriquality.co.nz/horticulture/agriquality_gmo_services.cfm). Other major grain marketing organisation, including AWB, has decided to join groupings such as the Global Laboratory Alliance (GLA) which is supported by large US DNA testing companies such as Genetic ID. Genetic ID has recently also developed a test to Bt10 maize that is legally recognized by the EU (www.genetic-id.com/pr/bt10_test.pdf) and aligned with the CRL protocol.

Incidences such as the discovery of the non-approved Bt10 maize mixed in shipments of approved GM maize from US to Europe and the recent minor incidence with the approved GM canola strain being detected in Australian non-GM canola destined for export to Japan provides ample proof that the moratoria on GM canola and other GM novel crops are only a holding pattern and that proactive leadership from the Federal Government is required in order for Australia to continue to benefit from the world leading research being undertaken in agricultural biotechnology by Australian public and private research organizations. Australia’s agriculture and food sector and the Australian Government needs to take a pro active role in the development and ordered conversion of these technologies into solutions for the agricultural and food sectors.

Best wishes,

Yours sincerely,

Roger Kalla

PhD, Director Korn Technologies

David Tribe

Reader, University Of Melbourne, Department of Immunology and Microbiology

SUMMARY OF COMMENTS AND RECOMMENDATIONS:


1) BENEFITS OF GM COTTON TO AGRICULTURE AND END CONSUMERS NOW AND IN THE FUTURE

§ Our paper outlines the large economic and environmental benefits that insect resistant BT cotton, the first Australian GM fibre, food and feed crop, has provided until know.

§ The direct benefits to end consumers of GM cottonseed with modified oil content will be realised with High Oleic GM cotton strains being evaluated in the field.

2) GM CANOLA AND THE BLOCKAGE TO ITS COMMERCIALISATION

§ The present blockage to the commercialization of GM canola, the second Australian GM food and feed crop is unsustainable.

§ The projected ‘GM free’ image of Australian agriculture and food export sector based on the State moratoria on GM canola is misleading and doesn’t acknowledge the realities of the globally integrated efforts in the development of novel strains of major food and feed crops such as cotton and canola.


3) FEDERAL GOVERNMENT NEEDS TO TAKE A LEADERSHIP ROLE IN DEVELOPING A ROAD MAP PAST THE MORATORIA SPEED HUMPS

§ Revamped Coexistence trials to evaluate the capacity for segregation along the grains supply chain needs to be undertaken by agriculture and food industry sector organizations and facilitated by Federal Government.

§ Standardized DNA testing protocols based on scientific and economically sound cut-off levels for admixture of GM crops in non-GM canola and grain bulk consignments overseen by independent national authority like the EU Community Reference Laboratory (CRL) for GM food and Feed.

§ In order for Australian agriculture and food sector to continue to be competitive in overseas markets Federal government needs to take a more proactive role in ensuring that Australian world class research and development efforts in these sectors converts good ideas and smart work to solutions that will benefit Australian rural communities, economy and end consumers.

Attached: Abstract to paper by Tribe and Kalla submitted and published by ICABR July 2005.