LIFE Environment. Layman s Report SAPID. Strategy for Agricultural Products Identity Defence

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1 LIFE Environment Layman s Report SAPID Strategy for Agricultural Products Identity Defence Wide area protection of agriculture products identity from GMO pollution

2 THE CONTEXT GMOs are organisms whose DNA, the biological archive containing all the information necessary for life, has been modified in laboratory by inputting new information contained in DNA tracts from other organisms, also of different species. The new information allow the organism to acquire new features, such as resistance to herbicides, parasites, the production of particular substances, etc. The European Community specified that Member States cannot prohibit, limit or prevent the marketing of the GMOs that comply with community regulations. Thus, Coexistence was introduced in Europe, i.e. the presence at the same time of organic farming, conventional farming and agriculture with GMOs, in order to give farmers and consumers freedom of choice. Since it is related to living organisms, the DNA of GMOs may spread in space and time through pollen (as in the case of maize) and seeds (rapeseed), causing a contamination of non-gmo plants and the related products. Product contamination may also occur in processing facilities, due to the difficulties and related costs of separating GMO and non-gmo products. The coexistence policy, therefore, is difficult to implement in some contexts and it is at risk of compromising the identity of recognized quality productions (organic, PDO, PGI, typical). Furthermore coexistence, if it is not managed carefully, may affect the environment, reducing biodiversity, in particular in agriculture, causing an accumulation in the environment of the products of the synthesis of the new DNA input in plants (e.g. the Bt toxin produced by webworm-resistant maize), an accumulation in the environment and in cultivated products of the phytosanitary products the genetically modified plant has become resistant to, the selection of resistant parasites and invading weeds, etc., compromising the value of the territory and, as a consequence, penalizing the image of local agri-food productions. Therefore, coexistence strategies must be applied taking into account local peculiarities and different farming models in individual areas. Biodiversity represents the variability of life within a habitat and/or an individual species: the more abundant and differentiated the resources, the greater the potential of that habitat and/or species GMO: consumer protection and food labelling In order to protect consumers, in Europe the labelling of GMO or GMO-containing agri-food products has been made compulsory, unlike in other countries such as the USA. Nevertheless, there is the possibility that conventional, organic or certified quality products are contaminated by GMO material. In order to avoid potential legal controversies, a contamination threshold was set, below which no GMO content label is required, provided the producer can prove that the contamination was accidental or technically unavoidable. Such threshold is 0.9% and it applies to both conventional and organic products. Therefore, there is a substantial difference between the concepts of coexistence, as defined in the July, 23rd 2003 Recommendation of the Commission, which allows an 0.9% contamination as legal threshold for labelling, and of identity preservation (GMO-free) of productions, which aims at eliminating all forms of contamination. 1 Sapid Layman s Report

3 THE PROJECT The SAPID project was co-funded within the framework of the Reduction of the environmental consequences during the usage of products and services objective of the LIFE Environment European programme. Its main aim is to identify strategies and instruments at local, supply chain and farm level to guarantee the coexistence of the different farming models, avoiding GMO contaminations (including accidental ones) in the supply chains for feed and food. The SAPID demonstrative project, started in November 2005 and concluded in April 2009, included some work areas in Marche, a central Italy region characterized by a rich organic and typical production with an added value in the relation with a territory whose environmental, landscape and productive value is vastly acknowledged. In such a context, the GMO/non-GMO coexistence may cause the disappearance of one or more productive models and, in particular, organic farming and quality productions. The project activity consisted in 4 main stages, with the purpose of defining a strategy that may guarantee an actual coexistence of the various farming models and the identity of agri-food productions. LIFE Ambiente LIFE Environment is a financial instrument of the European Commission which, since 1992, has promoted demonstrative environmental projects Analysis and verification of the coexistence issue at the European, Italian and Marche level, through data collection and a technical and legal bibliography identification of coexistence management instruments Territory Coexistence plans Contamination hazard index Supply chain Certification specifications Farm Training Self-regulation manual Large scale coexistence management instrument experimentation and their adjustment Experimentation on the field Experimentation in processing facilities Definition of an identity preservation strategy for quality productions The Marche Agri-Food Sector Service Agency (ASSAM), beneficiary of the project, is a public agency of the Marche Region, providing direct and indirect services to the agri-food sector. The other project partners are: Marche Region, Agriculture Department; Experimental Veterinary Epidemiology Institute of Umbria and Marche, a public health agency operating within the framework of the national health service, in the specific field of public animal hygiene and health; Terra Bio, cooperative of organic farmers from Urbino; Ass. Terra dell Adriatico,, non-profit organization operating in the field of training and dissemination on organic and bio-dynamic farming. Urbino municipality, local, independent governing body in the Pesaro Urbino province; Asteria, incorporated consortium, Institute for Technology Development and Applied Research. Sapid Layman s Report 2

4 IDENTIFICATION OF COEXISTENCE MANAGEMENT INSTRUMENTS During the first project stage, a technical-legal biographical research on GMOs was carried out. The most interesting technical works, together with the relevant European, Italian and regional regulations are available at Furthermore, an analysis of Marche agriculture was carried out, in order to verify the presence of GMOs in the agri-food supply chains of the region and to study the potential effects on the environment and quality supply chains. The national regulations prohibit, until the coming into effect of regional Coexistence Plans, the cultivation of GM maize varieties (MON 810 maize is the only genetically modified plant having the requirements to be grown in Europe), while there is a widespread presence of imported GM products in agri-zootechnic supply chains, above all GM soy. The study on coexistence management instruments led to the definition of three action levels. INSTRUMENTS AT THE LOCAL LEVEL - Coexistence plans Technical-legal instruments drafted at the national or regional level, including the necessary measures to avoid the unintentional presence of GMOs in conventional crops and to reduce potential legal controversies between farmers. The adoption of coexistence management instruments at the local level is included in the July, 23rd 2003 Recommendation of the Commission, which nevertheless is restricted to the 'seed to silo' stage, i.e. only to the cultivation period. Within the SAPID project, a Plan was set up to manage coexistence throughout the agri-food supply chain, including obligations for all the operators willing to produce, process or use GMOs. - Gene contamination hazard index in maize The project elaborated a model to forecast the hazard of GMO diffusion in the environment through pollen (gene flow). Three categories of factors on which the contamination hazard may depend were identified: dangerousness; it is the category of parameters related to human intervention and it is affected by the presence of GMO crops, by the diffusion of maize cultivation, by the application of more or less restrictive Coexistence Plans; vulnerability; related to morphological and climatic parameters. It represents the 'environmental sensitivity' of the territory to the contamination hazard caused by the pollen produced by GMO maize plants inseminating non-gmo maize flowers; resource value; this parameter is related to the peculiar environmental and socioeconomic conditions determining the different value of a territory, in which a potential GMO diffusion would have a greater environmental and economic impact. Possible hazard index applications - definition of coexistence measures. The requirements of Coexistence Plans should be more stringent for the territories with greater hazard (requirement modulation); - rationalization of monitoring and control actions. Such actions should be intensified in the areas with greater hazard; - identification of areas for the promotion of voluntary 'no GMO cultivation' agreements. VULNERABILITY DANGEROUSNESS Morphology Climate Crop diffusion Vegetation INTRINSIC HAZARD Presence of GMO crops VALUE OF THE TERRITORY Organic farming SPAs and SCIs Application of coexistence plans Parks RISCHIO 3 Sapid Layman s Report

5 INSTRUMENTS AT THE SUPPLY CHAIN LEVEL SAPID certification specifications Open source Product Technical Specifications, that can be adopted by various subjects involved in the production, processing and/or use of raw materials at risk of contamination from GMOs and their by-products. The adoption of the activities described in the Specifications should lead, with reasonable certainty, to GMO-free products (HIGHER level in the Specifications) or to products containing an amount of GMOs below the level of accidental contamination defined by the law (BASIC level in the Specifications). Such an instrument is based on the adoption of hazard prevention and protection system, rather then on the recurrent use of laboratory analyses, which are effective but also expensive and not timely enough. The certification of a product, process or territory aims at protecting consumers, allowing the producers to obtain more market shares and a better bottom line. The value of the certification carried out based on the Specifications also lies in the fact that the measurements, tests and verifications are carried out by an independent third party, rather than by the producer with a conformity self-assessment, which is also a viable option. INSTRUMENTS AT THE FARM LEVEL Self-regulation manual for operators Basically, it is a check-list and it is an instrument for the operators who are willing to assess their compliance with the SAPID Specifications. This instrument may also be used not in combination with the Specifications: in such a case if an official control discovers GMO contamination (below 0.9%), it may be used to demonstrate that the operator followed all the procedures to avoid contamination, which can therefore be defined 'accidental' or 'technically unavoidable' and, according to European regulations, cannot be punished. The system was drafted by applying the HACCP method (Hazard Analysis and Critical Control Points) to a production process that begins with the cultivation of plants subject to GMO contamination hazard, includes the farming of livestock fed with the aforementioned produce and the storage of cereals at specific facilities and ends with the production of feed. The system was converted into the M.A.R.C.O. software (GMO contamination hazard self-evaluation manual). The software can be downloaded from the project website and it allows the operator to have a final evaluation on the procedures in place to reduce or avoid the GMO contamination hazard. Training Operators' training is a fundamental instrument in coexistence management, since the latter is a field with technical, legal and operational aspects which are not always easily understandable. Within the SAPID project, training was guaranteed with courses and guided tours in farms. One of the most complex topics tackled while setting up training was defining the meaning of accidental or technically unavoidable contamination. The feeling is that 0.9% is becoming an actual threshold for the purposes of labelling. Also to answer the operators' questions on this topic, a national convention was organized, with the participation, among others, of representatives of the DG Environment of the European Commission. Sapid Layman s Report 4

6 EXPERIMENTATION The aim of experimentation was to verify the effectiveness of the coexistence management systems devised in the previous stage on highly sensitive supply chains, such as those of cereal and animal feeding organic production, as well as to use a feedback mechanism to redesign those very systems, correcting and adapting them to the results of the experimentation. The experimentation was carried out with the collaboration of 30 Marche companies: 20 farms in which the Coexistence Plan was applied on the field and 10 storage, processing and animal feed production facilities, in which the application of the self-regulation manual and of the certification Specifications was simulated. Experimentation on the field The purpose of the experimentation on the field was to identify the probability and extent of crossfertilization at different distances between a marker variety (yellow dominant) and a receptor variety (white recessive) of maize, as well as to obtain data on the effectiveness of a number of agronomic instruments that can be used to contain cross-fertilization, such as crop separation, buffer zones, natural barriers, etc. The morphological features of the Marche territory, its climate and the way it is affected by wind determine greater maize pollen dispersion compared to flatland. The contamination was under the 0.9% threshold, but could not be eliminated. Concentrazione pollini (N /m³) Distanza dalla sorgente (metri) S1 S2 S3 S4 The model created by the Urbino University within the SAPID Project shows that maize pollen in complex topographies, such as the one of Marche coastal valleys and flatlands, at a given distance from the source is bigger than a flat area such as the Po valley. Experimentation in storage and processing facilities In this case as well, the effectiveness of the coexistence management instruments devised in the previous stage was tested. Perennial obstacles to the application of hazard prevention systems are the lack of operator training and the unwillingness to adopt measures that require expenses. IThe results of the experimentation The results of the experimentation show that it is possible to bring the GMO/non-GMO contamination under the coexistence threshold (0.9%), but it is impossible to eliminate it, on the field or in the remainder of the supply chain, because of the peculiarity of the Marche agri-food sector, which is characterized by: - farming land with a very low average usable surface: this implies greater difficulty in keeping seed and/or pollen-related gene dispersion in check; - structural inadequacy of agri-food supply chains (in particular, obsolete storage and animal feed plants); - inadequacy of services for farms, above all agricultural-mechanical ones; furthermore, the network of laboratories for GMO surveying does not allow a timely control on product batches; - lack of interest by the operators, who are not willing to highlight the issues of coexistence and contaminations (accidental and voluntary); this is definitely the biggest obstacle in the setup of IP systems since, as of now, they are not seen as a product enhancement and profit-making tool, but as further bureaucratic controls and limitations; In a storage facility, a simulated contamination test was carried out using yellow and white maize: despite the application of prevention measures, contamination could not be eliminated. - the operators are poorly trained and they are not yet able to come to terms with the complexities of the regulations, of analysis certificates for GMO research, of selfregulation manual procedures. 5 Sapid Layman s Report

7 CONCLUSION: GMO-FREE DISTRICTS The effectiveness of GMO contamination hazard prevention systems (coexistence plans, self-regulation manuals, certifications, operators' training, etc.) is affected by a wide range of variables: - local context (geography, morphology, climate, etc.); - presence of technically capable facilities to manage coexistence (e.g., storage facilities); - availability of non contaminated seeds (presence of local or national seed companies); - availability of adequate coexistence services supplied to farms (e.g., agri-mechanical companies, third party certification agencies, laboratories capable of promptly issuing analysis certificates); - presence of a network of public and private structures for monitoring activities (validation of analysis results, ring tests); - agri-food supply chain operators who understand the issues of identity preservation and know how to manage them; - capability to redistribute the cost of application of such systems throughout the sector, so that non-gmo producers are not forced to shoulder them entirely; Such ideal conditions are related above all to local contexts, where a concurrence of factors lays the foundations for an effective management of identity preservation or IP. For such reasons, an undifferentiated application of coexistence management instruments and systems at the local level would not completely eliminate GMO contamination, resulting in a loss of identity for typical and quality agri-food productions. Through the SAPID project, we have come to the conclusion that, in a co-existence regime, a possible strategy to try and prevent GMO contamination, including the accidental one, is the institution of GMO-free districts, based on voluntary agreements among all the supply chain operators, for the moratorium on the cultivation, processing and use of GMO plants and products. These districts should be promoted in areas of greater environmental integrity, where organic farming affects a relevant share of the usable surface and the operators are open to product enhancement and to linking products with a particularly valuable territory. Nevertheless, an agreement among all the operators is not enough to guarantee the complete safeguard of the environment and crops. In order to support their will, instrument and services should be supplied for the agreements to be complied with, to be effective and to really safeguard the environment and the consumers. In particular, an effective Identity Preservation strategy, to be applied in the areas in which voluntary agreements are implemented, can be obtained through: - training of all the operators; - farm self-regulation; - product certification, also in order to improve the communication with consumers; - monitoring plans by public authorities to support farms. A potential procedure for the institution of a GMO-free district, simulated during the project in the Urbino municipality, includes a local authority (e.g., the Municipality) initiative, with the support of farming sector representatives. The initiative should be then supported by all the stakeholders, also through the mechanism of unspoken agreement. The institution of GMO-free districts may lead to clear environmental (sustainability of production models, increase of local proteinic crops for animal feeding purposes, as soy replacement, enhancement of biodiversity), economic (short supply chain enhancement) and tourist (competitive advantage for territory marketing strategies) advantages. In order to concretely affect environmental management and the protection of quality productions, GMO-free districts should spread at the European level and their local image, in terms of territory and products, should be linked to a unique identification brand. Sapid Layman s Report 6

8 Beneficiary Marche Agro-Food Sector Service Agency Partners Associazione Terre dell Adriatico No profit Organic Farmers Private Association Istituto Zooprofilattico Sperimentale Marche Umbria Zooprophylaxis Institute for Marche and Umbria Regions REGIONE MARCHE Marche Region (Agriculture Sector) Muncipality of Urbino Terrabio Organic Producers Cooperative ASTERIA Soc.cons.p.a Technological Development and Applied Research Agency