The Royal Commission on Genetic Modification

Read our GM overviewfrom Professor George Petersen FRSNZ
The Structure of DNA was discovered fifty years ago. See DNA50 50 years of the double helix
The UK Science Review Panel on Genetic Modification published its first report in July 2003.
The Royal Society of New Zealand's Submissionto the Education & Science Select Committee on the New Organisms and Other Matters Bill
Organise your thoughts on genetic modification. See Critical thinking - a resource for schools 11 June 2003
New Zealand's plans for biotechnology. See Government announcement 12 Feb 2003

October 2003: GM precautions in place

In 2001, the Royal Society of New Zealand, this country's science and technology society, took a long hard look at the science and social science of Genetic Modification. The results of what the Society thought then, and summaries of what other groups said to the Royal Commission on Genetic Modification, can be found at www.rsnz.org/news/gene. At that time we said that more safeguards were needed before any release of a genetically modified organism should be contemplated. We didn't give any time frame to put them in place, but subsequently the government announced a two-year moratorium, due to finish at the end of October.

New Zealand's Hazardous Substances and New Organisms (HSNO) Act requires the Environmental Risk Management Authority (ERMA) to take the need for caution into account. When it comes to questions on risk and uncertainty, there is no doubt we need to be careful, but HOW careful? Views expressed around the country seem to imply that caution lies anywhere from the emergency brake to second gear. A review of the conditions laid down by the Royal Society and what has been done to date is given below.

Overall, the Royal Society wanted to see a stronger consultation, control and administrative framework. What we see now is that the changes coming through the New Organisms Bill (now going through parliament), combined with the recent review of ERMA, do provide a stronger process of consultation, control and administration. In particular ERMA can impose a wide range of conditions on release into the environment, including post-release monitoring.
We asked that legislation and/or regulations should include not just scientific risk assessment, but also include cultural, ethical and social issues and concerns at both the research and field trial levels. We do now find that the requirements on both ERMA and the Minister to consider such issues have been strengthened. In particular the Government established the Bioethics Council specifically to advise the Minister on spiritual, cultural and ethical issues. The degree to which that advisory role has an impact on decisions by ERMA and the Government is of course yet to be tested.
We wanted to reduce red tape on the construction and importation into containment of low-risk GMOs, more clearly prescribe the steps needed for research and field trials, and establish a science panel to advise ERMA and research institutions on questions of containment. The red tape is being reduced, and a science panel now turns out not to be needed, as containment conditions are already in line with internationally agreed standards.
We wanted a good monitoring system in place before any GMOs were released. With the changes in legislation, the New Organisms and Other Matters Bill ensures that ERMA will be able to require effective monitoring and reporting of results to the appropriate authorities.
We thought that those benefiting from the use of GM technologies should have to meet the costs of any adverse consequences of commercial release. The Law Commission was asked to look at this, and concluded that current laws are adequate. In fact, ERMA's penalty provisions also ensure that there is an incentive to comply with release conditions.
We noted that, inherent in the concerns expressed by Maori is the question of who decides on GM matters. Where non-negotiable beliefs were held, we wanted them to be heard. We are satisfied that the ERMA process now provides opportunities for all views to be taken into account, however, no one group should have the power to either veto or force the release of GMOs into the environment.
We noted a sense of disenfranchisement in respect to intellectual property rights. In particular, Maori are concerned that rights (both spiritual and financial) to customary knowledge about native flora and fauna could be lost through the use of intellectual property law. We also noted that, where ownership of the genetic resource is asserted, ownership must be resolved. Two years later we do see some progress on the Wai262 claim on Maori ownership of indigenous flora and fauna, and accept that this complex issue will take time to resolve.
Lastly, we asked that, where risks are apparent, both the probabilities and the individual/group perceptions of risk must be weighed. It is important that in making its decisions ERMA should use comprehensive understandings of risk and take account of a diversity of cultural and ethical understandings among New Zealanders. This remains a subjective area, however, where statistical assessments of risk must be supplemented by methods for dealing low probability catastrophic events. Risk must also include the dimension of public trust in the system and institutions entrusted with the decisions. Assessment of economic risk will entail the development of transparent and defendable criteria by which ERMA can assess the economic costs and benefits.

One last thing we suggested was that the Act at some stage be split into two parts, to deal separately with Hazardous Substances and New Organisms. That wasn't done, and wouldn't affect the conditions we set, but over the longer term it would make administration of this complex area simpler to understand and operate. As it stands, the revised Act contains a number of patches which make it difficult to follow.

Overall, the Royal Society welcomes the improvements in the conditions it wanted to see met before release of GMOs. Many scientists do not see any significant science problems yet with GMOs, but that doesn't mean that there won't be any. The Society sees no scientific need to continue with a blanket ban of release, but we continue to see a need for careful case-by-case assessment. We welcome the increased attention to safeguards against adverse effects and we recognise the need to attend, not just to the science issues in this field, but also the social, economic, cultural and ethical aspects of the use of GMOs.

October 2003: On Trial? GM or Weedkiller?

On October 16, the Royal Society of London published in its "Philosophical Transactions B" some useful papers on farm trials of GM crops. "A massive blow" thundered one British journalist. "None of the studies ... supports the banning of any GM crops," said Dr Paul Rylott, of the UK Agricultural Biotechnology Council. To help make up our own minds, letís look at what the trials actually found. Certainly they were the biggest trials to have been done to date, but even so they dealt with only one aspect of GM. They are useful as much for what they did not cover, as well as what they did. Read on.

It's possible to put one of several types of gene into crops like maize and beet - for instance, a gene for resistance to a herbicide, or a gene which helps the plant itself to kill bugs that eat it, or a gene to increase nutrient content in some way. Some companies chose the first (and to my mind, not necessarily the best) option by making GM varieties of crops such as cotton, maize, beets, soybean, wheat and oilseed rape which could withstand herbicides such as Liberty (active ingredient: glufosinate) or Roundup (glyphosate). Liberty is a 'contact herbicide' which just kills the tissue upon which the spray lands, while Roundup is a 'systemic herbicide' that moves throughout the plant to kill all tissues. The reason that companies chose this option is likely because they were the easiest to commercialise and to recoup the millions of dollars spent on the basic research.

The UK farm trials dealt with only three crops of this sort: maize, oilseed rape and beet, for all of which a Genetically Modified Herbicide Tolerant (GMHT) variety has been made. Specifically, the GM beet variety is Roundup-tolerant, while the maize and oilseed rape are Liberty-tolerant. The GMHT beet trial plots were sprayed only with Roundup (widely used as a general herbicide), while the GMHT maize and oilseed rape were sprayed only with Liberty. For control, plots of the non-GM varieties were sprayed as they usually are in UK commercial practice.

The trials showed that GMHT beet and oilseed rape needed fewer herbicide applications than the non-GM versions. Roundup and Liberty don't persist in the soil for long, but their 'broad-spectrum' nature kills most plants they fall on, and non-GM crops can't survive them - so, for example, the non-GM beet received up to six sprays of other herbicides over the growing season, while the GMHT beet was sprayed twice with Roundup. The numbers of sprays used for GMHT maize were about the same as for non-GM maize. However, one of the sprays sometimes used for non-GM maize in the UK is Atrazine (a very persistent herbicide which is banned in some parts of the US), and this is avoided in GMHT maize.

Farmers apply weedkiller to kill weeds, and it works! The trouble is that, over time, this could kill too many 'weeds' which, if they had no opportunity to grow elsewhere, might eventually reduce biodiversity in the landscape . In addition, bugs which feed on the weeds could also die away. The UK trials found that, because the herbicides applied to GMHT beet and oilseed rape were broad-spectrum, they killed weeds more effectively. While they produced a cleaner crop, they also reduced the 'seedbank' available for next year's weed growth, both in the crop itself and in the surrounding hedgerows. The reduced seedbank in turn reduced the number of insects in the neighbourhood.

Conversely, the Liberty used on GMHT maize was less effective than the weedkillers used on non-GM maize. Liberty killed fewer weeds in the maize and resulted in generally higher insect populations than those that came from the weedkillers used on non-GM maize. This surprising result implies that use of GMHT maize could actually increase biodiversity - the opposite of the results from oilseed rape and beet.

In New Zealand, many weeds in farmersí fields have been introduced and very few are part of our natural flora. They are not strictly essential to the biodiversity of our landscape.

Now, what are we to make of this? It seems that some GMHT crops can save on the number of weedkiller sprays we use by allowing use of a broad-spectrum weedkiller, but in doing so they reduce biodiversity in the neighbourhood. Spray practices in other GMHT crops may actually increase biodiversity. A number of proponents of release of GM crops have said that developing crops that are resistant to herbicides like Roundup is a benefit of GM, as it means that one can use less herbicide in controlling pests, which is better for the environment. What this research shows is that the benefits of GM in this aspect are not clear cut, either one way or the other, and that the benefits of the technology in this instance must be carefully evaluated on a case-by-case basis. The UK trials show conflicting evidence, but there could still be a useful place for GM herbicide-resistant crops, for example as gene markers in research, and in specialised seed production.

Perhaps we should listen to Dr Les Firbank, coordinator of the project, who said "One of the key points to remember is that the results are only applicable to the three crops studied, and only under the regimes of herbicide usage which were employed. Each new application of GM crop technology must be looked at on a case-by-case basis, using rational evidence-based approach."

A case-by-case approach is what the Royal Society of New Zealand also advocates, and is the way in which the Environmental Risk Management Authority (ERMA) is required to proceed. ERMA are required to take into account on a case-by-case basis the predicted risks, costs and benefits of release of GM crops in their deliberations. The UK trials did not, and were never designed to, deliver a complete answer to all our questions. Yes, we still need to be cautious as we proceed. The UK studies have added one more piece to the jig-saw puzzle, but give no carte blanche to proceed without limit, nor to halt in alarm. New Zealand's Hazardous Substances and New Organisms Act requires ERMA to take into account the need for caution. Overall, we haven't yet seen insurmountable problems with GM crops, but that doesn't mean there won't be any. I'm encouraged to see that stringent safeguards are being put in place in New Zealand to be ready to respond if things threaten to go wrong. For full details of the trials, see www.pubs.royalsoc.ac.uk/FSEresults.

Useful reading

As part of our task of "advancing and promoting science and technology" we have sourced articles that the Royal Society considers to demonstrate quality science. The list below is by no means exhaustive but may provide a starting point to learn about this very complex issue.

GM Foods: Facts, Worries Policies and Public Confidence. Robert May, currently president of the Royal Society of London, speaks out on genetic modification . Here is another paper on the topic.
The Nuffield Council on Bioethics: Genetically modified crops: the ethical and social issues
The Royal Society: Genetically modified plants for food use | Transgenic plants and world agriculture | Genetically modified plants for food use (NB: these are PDF docs: require Adobe Acrobat)
Beatrix Tappeser, Manuela Jäger, Claudia Eckelkamp: Survival, Persistence, Transfer - An Update on Current Knowledge on GMOs and the Fate of their Recombinant DNA
E. Ann Clark, Plant Agriculture, University of Guelph: Environmental Risks of Genetic Engineering in Field Crops
31 Critical Questions in Agricultural Biotechnology
ISIS: Use And Abuse Of The Precautionary Principle

The Royal Society Submission to the Royal Commission

The submission is in two parts because the writing teams came up with two distinct threads, and to try to edit it into one would have meant a loss of clarity. However, it is one rather than two submissions. The Society would like to thank the authors (Part A) (Part B) for their considerable efforts.

Part A (Biological Sciences) | Part B (Social Sciences) | Witness statement by George Petersen | Witness statement by Rosemary du Plessis

We also have a list of "interested persons" accepted by the Commission.
Our January 2001 update on our submission
Our summary of our submission we made just before the Commission was due to report

The Royal Society assembled teams of experts from many areas of specialisation to contribute to its submission below. This work has been edited into a submission that focuses on excellent science, rather than taking any particular point of view.

Weekly reports from the Commission

Reports by Deborah Kessell-Haak.

Week 12

ANZFA

Week 11

Week 10

Week 9

Week 8 (2001)

Week 7

Week 6

Summary | Golden Bay Organic Employment and Education Trust | Commonsense Organics | BioGro | ComVita

Week 5

Week 4

Week 3

Week 2

Week 1