Issued by:

Dear Mr Kobina Lokko,

I write in reference to the review of the framework for overseeing developments in biotechnology and genetic modification that Mr Cunningham announced before Christmas. Views from members of the public on this issue are, I understand, welcome, and I would like to submit my views on some of the areas under review.

1) What gaps exist in coverage of biotechnology by the existing committees and how might these be remedied?

I do not know of all the committees that are looking at this issue. However my understanding of the membership of some of the committees advising government is that they may not be formed in such a way as to give a full and unbiased picture of potential problems arising from Genetic Modification. Not only this, but the questions committees are asked to consider may unduly influence the deliberations of these committees. For instance I attended two sessions of a Government backed Food Forum. A question to this forum was " Will organic food comprise 15% of food consumed by the year 2005". As the realistic answer was no, no further consideration of organic food was deemed appropriate. I hope therefor that this review will

a) Ensure there are no gaps in the views of those that make up the committees. i.e. their views cover the spectrum from very pro to very anti GMOs as well as unbiased views.

b) The questions the committees are asked to consider are also without gaps. i.e. not just questions such as " If there are lots of Hi-Tec biotechnology jobs at stake can we afford to be left behind", but also " How many extra jobs would be created if we followed a path of very actively supporting Organic farming and what is the export potential"

2) How could the system for providing advice to Government be made more transparent?

I am assuming that this is asking how advice to Government be made more transparent to the general public.

There cannot be any National Security implications at issue here so a Government backed Web Site giving the make up of the committees, where and when they sit; the questions that are deliberated, the answers that are given, to whom, and what action was taken, seems to be a reasonable first step to make this process more transparent. If this were done, and what was seen, was seen to be reasonable then this would start to allay genuine concerns.

3) Are ethical and other wider issues addressed fully and properly within the current system?

From what I have read so far there does not seem to be much consideration given to this issue from a fairly basic point of view. For instance; a reductionist view driving development has served us reasonably well up to now but with this being superseded by a systems view of the world will not a reductionist science such as genetic engineering generate unpredictable instabilities in life systems? As life is more than a machine, if we treat life like a machine, how will life bite us back? With genetic engineering how sharp will its teeth be when it bites?

4) Are stakeholders given the appropriate opportunities to make their views known? For example, would an environmental stakeholder forum be a valuable addition to the current framework.

Stakeholders should include in this case everyone who eats; By definition then everyone must be a stakeholder in this issue. If the government is genuinely trying to get views from everyone who wants to give one, why not, for a start, make a government announcement on this issue over the appropriate news groups and e-mail networks that are already in place. The feedback could then be made available to the committees and forums.

I am sure an environmental stakeholder forum would be a valuable addition to the current framework of forums, not just to consider genetic engineering, though this could have the most potent impact on the environment but also other factors determining the health of the environment in which we exist.

5) Is the framework flexible enough to cope with the rapid development of this technology which is likely in the future?

Here we have one of those biased questions as mentioned in section one. This presupposes the likely acceptance of this technology. I can only hope this is balanced with a question such as " Is the framework robust enough to cope with some interested parties dissatisfaction should it be found this technology inappropriate for introduction for at least the next five years."

6) Does the public have confidence in the system currently in place?

Questions such as, "Is the framework flexible enough to cope with the rapid development of this technology which is likely in the future?" when the public imagines that the " system " is now examining whether this technology should be introduced at all, tend to undermine confidence.

Other examples that could undermine confidence are things like:

a) The John Innes members having such prominent positions on a biotechnology appraisal committee yet belonging to an organisation receiving some 60 million pounds for genetic research from biotechnology companies.

b) Mr Cunningham`s previous personal private assistant at the Dept of Agriculture now being employed at such a salary by a biotechnology firm.

To avoid lack of public confidence in the system over issues such as these, the full transparency aspired to in section 3 must apply rigorously to these issues. Then, when these, and issues like them, are fully in the public view a realistic appraisal must be seen to be done to demonstrate that no preconceptions or undue bias has been brought to bare against the mass of stakeholder interests. This will, I am sure help boost confidence it the system.

I will be posting this letter on my web-site and await with interest your response, which I will enter there as well.

Yours sincerely

Alex Smith