(PIRSA)

From: Sent: Monday, 30 September 2019 5:00 PM To: PIRSA:GM Review Subject: SA enquiry GM-Free Moratorium Attachments: gmo SA.docx

Attention: GM Secretariat Support Primary Industries and Regions South Australia

Please accept my submission into this inquiry.

Please keep this above confirmation confidential and private (not for public view), initials are okay.

Regards, M. H

1

GM Secretariat Support Primary Industries and Regions SA - F'IRSA Government o f South Australia PIRSA.GMReview@sa.gov.au

n nth G7 September 2019

Dear Reviewers, I would like you to consider my submission for the enquiry into SA GM free Moratorium. My contribution is from the position of a humble consumer.

The effect that keeping the moratorium will have on consumers (local and global), and subsequent income opportunites. We are all consumers of food, and everyday w e make choices about wha t to eat and drink. With food-related health issues on the rise over pas t decades, selecting which food to buy and consume has become more complex than ever before. Depending on individual circumstances, consumers need to include the following things in their considerations when choosing which foods to purchase: nu t free, gluten free, egg free, meat free, soya free, dairy free, low in sugar/salts/fats, palm oil free, hepatitis/salmonella/listeria free, and now also GM free. It's get- ting very complicated.

A poll conducted by Choice about Australian's attitudes to consuming GM food revealed that 84% o f Australians are concerned about eating foods with GM ingredients) I have read through some other comments for this enquiry, and there has been mention made about how Australian's are already eating GM foods so SA should grow them. As a conscious consumer, I would like to put forward tha t the main reason for this is tha t many Australians are simply not aware that they are eating GM food. Australian food labelling laws in relation to GM derived ingredients are weak. As a consumer, i t is difficult to know if a food product has genetically modified ingredients used in it, added to it, fed by it, or not. Listed on the Choice website2, the following foods which may contain GM ingredients are exempt from labelling: • G M oils, sugars and starches — Highly refined foods no longer contain the GM protein, according to

FS'ANZ. This includes corn syrup, cottonseed and canola oil. • G M food additives or processing aids. • Meat, daily and eggs from animals f e d G M feedstock • Food bought .from cafes, restaurants, takeaway shops and vending machines. • G M flavourings 'flavourings in a concentration q f no more than 0.1%. • Unintentionally present G M ingredients o f no more than 1%.

GM derived oils - not labelled. A small amount of GM indredients present, such as a small amount of soya flour commonly added to processed foods - not labelled. Animals fed with GM foods - not labelled. Take away chips etc - no t labelled. Australian consumers should have access to infor- mation about wha t their food includes, however due to the obvious shortcomings, conscienscious

'Potter, A (2016). Are you eating genetically modified food? - CHOICE. https://www.choice.com.audood-and-drink/food- warnings-and-safety/food-safety/articles/are-you-cating-gm-food [Accessed 29 Sep. 20191.

2 Potter, A (2016) op cit

consumers in Australia often turn to organic food choices, not neccesarily because they are fans of organic-only food, bu t because the lack of information on labels is confusing and can only be over- come by purchasing organic food instead. It's no t a case of GM-food vs organic, it is more about offering consumers food that they actually want to eat, and there is definitely room for GM-free food that is not necessarily organic. Studies done with GM free labelling will not be truly re- vealing until food products containing or fed with any GM ingredient are properly labelled in Aus- tralia. When a consumer can choose between foods labelled with "contains GM" and "GM free", based on current consumer sentiment, the choice will be for the GM free option. If Australia had better labelling laws for GM ingredients, it is highly unlikely we would even need GM free labels in the first place. That would be preferable. Consumers require a variety of choice which reflects dif- ferences in opinions about percieved risks, conflicting information, and contentious ethical, cu- tural and social isues. SA will be in a good position if it stays GM crop free.

It is worth looking a t what is happening overseas to explore this further: the US, which is a mas- sive grower of GM crops, and has better food labelling regulations, has a large market for consum- ers seeking GM free food. Headlines reveal that China is seeking GM free options. These are huge markets. In the US, sales of foods labelled as non-GMO went from $12.9 billion in 2012 to $21.2 billion in 2016.3 A study by the University of Adelaide in 2016 revealed that the Global Food Mar- ket for non GMO food in 2014 was $550 billion, and was expected to double by 2019. It also acknowledged tha t there are very real opportunites for marketing non GM food'. South Australia is already in a good position to connect with these markets due to our existing pure GM free sta- tus. In coming times, keeping this status will benefit consumers, resulting in a viable commodity free of genetically modified ingredients and the myriad of associated problems caused by their inclusion. Put simply, if Australia had thorough labelling laws for food containing GM ingredients, consumers would likely make different choices, and associated with this, if GM crops were to be grown in SA, conscientious consumers may no longer be willing to purchase food containing in- gredients grown in SA.

The effect that lifting the moratorium with GM crops will have on SA's environment. GM crops have also been reported to create a lot of problems in the environments in which they are grown. There are 2 main issues which have come to my attention, discussed below: 1. What Round Up Resistance actually means: We've read about "Round up resistant" crops, and I can't help bu t be worried about what tha t means. We have already created a situation where herbicides are causing health problems with people who are exposed, and many readers may al- ready know about the recent compensation cases, yet increasingly these same herbicides are de- tected in our food and our ecosystem, where they can also make their way into our drinking wa- ter. To create a plant that is resistent to this herbicide seems synonymous with being able to use more of tha t herbicide. Considering the current state of the environment, this sounds like an envi- ronmental catastrophe. South Australia currently has comparitively low amounts of these toxins

3 Malcolm, H. (2016). Non-GMO demand growing despite report that says GMOs are safe. [online] USA today. Available at: https://vvww.0 satoday.com/story/moncy/2016/05/18/gmo-report-not-likely-to-change-mind s-over-gmo-con- cern/84501686/ [Accessed 29 Sep. 2019]. 4 Centre for Global Food and Resources. Identification and Assessment o f Added-Value Export Market Opportunities for Non-GMO Labeled Food Products from South Australia." PIRSA, The University o f Adelaide Centre for Global Food and Resources, June 2016, https://www.pir.sa.gov.au/ data/assets/pdf file/0005/282173/Full_Report_Adelaide_Univer- sity_GM_Report.pdf

in our waterways compared to other countries, and w e should avoid making any choices which will lead to an increase in the amount used. The use of Roundup has been increasing over the years, and recent scientific studies have been looking into its effects on our health and in the envi- ronment. While reading through several of these studies, it has become obvious to me that Roundup is no t as harmless as it was once previously claimed to be, tha t it has a negative accumu- lative effect on health, and that glyphosate (and AMPA, aminomethylphosphonic acid, which are usually detected together) have accumulated in environmental systems of soil, sediment and wa- terways5 6.

Some o f the scientists conducting these studies have commented on the difficulty o f being able to test the individual components o f Roundup thoroughly due to the owning company's lack o f willngness to disclose its full list o f ingredients. This is further confirmation about the lack o f transparency about the products owned by some large corporations, and should be o f concern to us because it is easy to see how that could have problematic repercussions for any decisions we do make for food-related business with them. Meanwhile, before allowing crops which enable an increase in the use o f glyphosate, lets first update ourselves to at least consider the findings o f recent scientific studies, and the long term un- certainties involved. In addition, there are also articles which discuss the pests who form re- sistance to pest-resistant GM crops and reports tha t even more pesticides and herbicides are re- quired to deal with this new kind of pest. If we go down this road, where does it end?

With South Australia now declaring a status of Climate Emergency, it is important to make choices which continue to preserve our clean environment, and minimise the potential harm cre- ated by increasing the use of accumulating toxins, such as Roundup. By continuting to ban the growing of GM crops in SA, no t only can w e profit by preserving an important pa r t of the food market, and keeping ownership and control of our crops, we will be avoiding the far reaching ef- fects of increased herbicides (and other) in our ecosystem, including in our drinking water.

2. Contamination: When we first heard of GM food crops many years ago, we learned that they may infest neighbouring non-GM fields, and were told not to worry. When GM crops started to be grown in Australia, we were told that if any infestation occured, and it wouldn't, there are laws in place to protect the victims. Then we learned about the farmer in WA who lost his organic status and so his livelihood because his neighbour decided to t ry GM crops (canola). Mr Marsh was an organic farmer, a certfication which takes many years to accomplish, bu t the hard-earned organic status of his farm and therefore his existing market income was lost when GM crop seeds blew in from the neighbouring farm. Facing financial ruin, his only available choice was to take his neigh- bour, a former friend, to court. The ruling was made AGAINST the organic farmer. The system has no t provided any example of security for existing farms who have been, or will be, negatively im- pacted by a neighbour's choice to plant GM crops. Organic status - lost. Income - lost. Court costs, high. Re-gaining of organic status - a t least 3 years. Likelyhood of keeping organic status amongst neighbouring farms growing GM crops - close to zero. The ramifications of this example go well beyond only the farms with organic status, as there will be similar implications for existing non-

5 Battaglin, W. etal (2014). Glyphosate and Its Degradation Product AMPA Occur Frequently and Widely in U.S. Soils, Sur- facc Watet; Grounchvater, and Precipitation. [online] Wiley Online Library. Available at: https://onlineli- brary.wiley.com/doi/full/10.1111/jawr.12159 [Accessed 29 Sep. 2019]. 6 Bruggen, V. et al (2018). Environmental and health effects o f the herbicide glyphosate. [online] Science Direct. Available at: https://www.sciencedirect.com/science/article/pii/S0048969717330279 [Accessed 29 Sep. 2019].

GM farmers who wish to keep growing traditional crops and for whom there will be a similar lack of recourse for protection or adequate compensation when things go wrong.

In conclusion, South Australia is currently in a good position by not growing genetically modified crops, and should continue with the moratorium to utilise the growing global markets for GM-free food, and to hold an established position in a country which currently has unthorough GM food labelling laws so consumers can be reassured tha t "grown in SA" and "made with SA ingredients" means it does not contain GM ingredients. In addition, holding-off on these GMcrop varieties will also minimise the accumulating environmental impact of increased Roundup use, a higher poten- tial for the spread of GM crops into non GM farms, and the damaging repercussions of this to our economy and farming communities. If South Australia is to continue with this inquiry, it is manda- tory that further and deeper investigation is made into the available research about the rising GM free economy, the effects that GM-crops will have on surrounding non GM farms and how this will impact on their livelihoods, the accumulative effects of products like Roundup on human health and the environment, and independent studies (i.e. studies not funded by GM seed companies) about the longer term effectiveness of GM crops doing what they claim to be able to do. Doubt about their effectiveness does exist 7. At the very least, it will provide insight into the fact that there is conflicting information, tha t important studies are ongoing, and that we should hold off until we know more. Finally, if after all this, a decision is made to trial this idea, there must be acknlowledgement of the fact that the neighbouring farms and communities are going to be ef- fected and impacted. There needs to be thorough consultation, informed consent, agreement on methods, and absolute assurity of options for damage control and compensation when things go wrong. Those farmers who have organic status, or who wish to continute growing conventional non GM crops, have the right to continue with their choices without being negatively affected by the choices of others, this will also preserve significant areas of non-affected land. In addition, any farmer increasing their use of glyphosate-containing products must adhere to strict health and environment standards, and unbiased studies which monitor our soils, sediments and water- ways, insects and microbiome, must b e conducted over time, and any changes must be docu- mented and acted on accordingly.

My hope is that South Autralia, for the health of our whole environment and the living systems within it, does no t start growing GM crops.

Thank you.

7 Prof Zsuzsanna Bardocz. (2018). Genetically Modified Crops: Seeds o f Hope or Deception?. Committee on World Food Security. Available at: http://www.fao.org/cfs/home/blogiblog-articles/article/en/c/1104228/ [Accessed 29 Sep. 2019].