Agenda Item 1 - Opening Remarks
1. The ACRE Chairman, Professor Gray, welcomed everyone, particularly ACAF members, to the meeting. Introductions were made and apologies for absence given.
2. Professor Gray gave a brief introduction to the relevant legislation - EC Directive 90/220 on deliberate releases of genetically modified organisms (GMOs) into the environment. Members were informed that there was no specific EU legislation on GM animal feed and that before the establishment of ACAF, ACRE had, in part, consulted with MAFF experts in forming its views on the animal feed aspects of applications under Directive 90/220. Professor Thomas briefly outlined the background to the establishment of ACAF. He explained that such a committee was originally recommended by the Expert Group on Animal Feedingstuffs back in 1992 but that Government commitment to setting it up was only finally given in the Food Standards Agency White Paper published in 1998.
Agenda Item 2 - The Roles of ACAF and ACRE
3. Professor Gray presented a background paper on the Legal Framework for Decision Making on the Release and Marketing of GMOs in the EU. He explained that ACRE was concerned with the human health and environmental aspects of a deliberate release. It was emphasised that ACRE dealt only with the environmental risks rather than any potential benefits of GMOs.
4. Professor Thomas presented a paper giving background information on ACAF. He explained that ACAF had a broad based membership and a wider ranging remit than ACRE. The lack of specific legislation on novel and genetically-modified (GM) animal feeds made ACAF's work difficult. EU-wide legislation on novel feeds had been promised by the European Commission since 1994 but was taking a long time to come forward because of changes to the related legislation on novel foods and to Directive 90/220. Proposals on novel feeds were now expected by November this year.
5. It was explained that in order to advise ACRE on the animal feed aspects of applications under 90/220, ACAF also had to examine the same detailed dossiers as ACRE. This was undertaken with a more limited scientific base than ACRE and the Advisory Committee on Novel Foods and Processes (ACNFP). Currently the detailed dossiers are considered by a sub-group consisting usually of ACAF's scientific members who report back to the main Committee. These dossiers do not always contain the sort of information e.g. animal feeding studies, that ACAF would like to see in order to give a view on a product. It was suggested that ACAF inform ACRE if they thought there was anything missing from a dossier and this would get fed into the regulatory loop.
6. Dossiers contain extensive molecular analysis of the GM crop and it was suggested that this could be where the ACAF sub-group may wish to consult with ACRE members, particularly if there were any problems identified with the data provided. ACRE members agreed that it was a good idea for closer links with ACAF, and the meeting was informed that an ACRE member, Chris Pollock (a plant biochemist) had offered to help the ACAF sub-group. This move was welcomed by ACAF members.
Agenda Item 3 - Risk Assessment of Genetically-modified crops
7. Members were presented with two papers on risk assessment, one from the ACRE perspective, "Risk Assessment for Releases and Marketing of GMOs in the EU", and one on the "ACAF Role in Assessing GM Material". Within ACAF's role the importance of thresholds or tolerances for GM materials was emphasised and the need to take into account relevant factors in setting them e.g. the type of processing, dilutions and the level of feeding to animals. An important part of ACRE's assessment of new GM plants is to compare their similarity to the conventional variety. If differences were identified the Committee then needed to know how these will impact on the animals fed on the plants. This was where ACAF advice would be appreciated.
8. It was pointed out that the UK was a large importer of feedstuffs and therefore a significant proportion was likely to come from GM sources. This made traceability an important issue for ACAF. It was emphasised that ACAF had a wider remit than ACRE and its interest went beyond safety issues to embrace such concerns as consumer choice. Members were informed that a new body, the Agriculture and Environment Biotechnology Commission, had been set up to consider the wider issues of biotechnology. It was agreed that there was a need to look beyond strict safety issues and that communicating both the risks and benefits of GM technology to the public was important. It was thought that ACAF had a better opportunity to do this given its wider remit.
9. It was agreed that there was a need for both Committees to concur on the molecular data submitted with applications even if they then went on to hold different views based on the same data given their different remits. There was also agreement about the desirability of post marketing monitoring for GM animal feeds and it was thought that this requirement would be contained within the proposed novel feeds legislation.
10. It was pointed out that ACAF had limited practical experience of assessing applications as it had only looked at three dossiers to date. However, ACAF members thought that they would look at things on a case by case basis using the concept of Substantial Equivalence and/or feeding studies depending on individual circumstances. It was suggested that the concept of Substantial Equivalence was less important for animal feed than for food because of the possibility of carrying out feeding trials. It was also suggested that ACAF might favour more in the way of close post market monitoring of on-farm situations.
Adventitious presence of GM oilseed in commercial seed stocks
This incident had been discussed at ACAF's last meeting and its members had wanted clarification from ACRE on the sterility or otherwise of the GM hybrid that had contaminated commercial seed stocks. They were informed that the company had indicated that the plants were sterile but further investigation was taking place, including on how the contamination had occurred.
Agenda Item 4 - Molecular Data Requirements
12. It was explained that ACRE was proposing to set up a sub-group on molecular data analysis with the aim of providing guidance for applicants. This was agreed to be a good opportunity for further co-operation between the two committees and John Heritage, an ACAF member, agreed to join the sub-group. He explained that he was already working on this area in connection with his membership of the Scientific Committee on Plants (SCP) and had written a paper. He would make available to the sub-group after the next SCP meeting on 4 October.
Action: John Heritage to forward his paper on molecular requirements to the ACRE Secretariat.
Agenda Item 5 - Any other Business
13. The ACAF Secretariat raised the problem of the tight deadlines for advice under the timetable for handling applications laid down in Directive 90/220. The ACRE Secretariat indicated that there were two or three dossiers currently in the system on which ACAF's advice would be required. The ACRE Secretariat agreed to forward these dossiers to ACAF as soon as possible to enable a reasonable period for evaluation.
Action: ACRE Secretariat
Food Standards Agency