The Royal Commission on Genetic Modification - submissions

Commonsense Organics Limited

STRATEGIC ISSUES AND OPTIONS — SECTIONS - A(1), B(i)

Submission

Commonsense Organics submitted that organic production standards preclude the use of organisms produced as a result of GM technology. Organic production was stated to be based on systems that are sustainable on environmental grounds. It is contrary to the purpose of organic farming to use GMOs where that environmental stability is put at risk. Contrary to previous submissions, Commonsense organics submitted that it is not possible or feasible to establish thresholds or tolerances in respect to the possible presence of GMOs. This means that the use of GM crops in New Zealand may compromise the certification of organic products as they are unable to claim ‘GM free’ status.

Commonsense Organics then recommended to the Commission that field trails be prohibited until there is more certainty as to the effects of GM technology. They also stated that the introduction of GMOs should be prohibited until it could be proven beyond a reasonable doubt that the technology was safe. However, research should be allowed to continue under strict containment.

Further Comment

The phrase ‘reasonable doubt’ is a difficult one. It is still grappled with in criminal law and is very difficult to define. Clarification is needed as to the level of scientific evidence required to reach this benchmark. From other comments in this submission it is likely that the benchmark is a positive proof of the absence of harm. However, proving a negative is a logical impossibility and ‘science’ cannot provide 100% certainty.

Furthermore, preventing field trails does not achieve the results Commonsense Organics would like to see. It is counterintuitive to require proof of safety and then recommend a moratorium on field trails that are used to ascertain the effects of GMOs on the environment.

RISKS & BENEFITS — SECTIONS A(1), A(2), B(b), B(c), B(j)

Submission

Commonsense Organics submitted that risks are a part of all scientific experiments in that if outcomes were certain there would be no need for experimentation. In the case of GM experimentation, not only are the outcomes unknown, but they are more or less random. What is worse, in their opinion, is that if there is an unwanted result the effects are likely to be irreversible. Moreover, the effects of GM technology would not be as easy to eradicate as nuclear waste. The introduction of GMOs was also equated with the introduction of possums and the use of CFCs.

James Kebbell submitted in behalf of Commonsense Organics that the aim of organic production systems was to work within the checks and balance of the environment. Everything is based on the premise of interconnectedness. In this context the use of GMOs is opposed as it is one thing to identify the composition and function of genes but it is another thing to assume that a gene transferred to an alien genome will have the same function and perform in the same way. Every insertion event is unique and every event is likely to yield different results.

They then stated that there was little argument for GM technology except that it was required to ‘keep up with the Jones’s’. They submitted that the three main claims in respect to GM technology are:

There will be increased yield in order to feed an increasing population on less arable land;

That it is the same as traditional breeding only faster;

That pest resistant and herbicide resistant plants will decrease the use of pesticides and herbicides respectively.

Commonsense Organics stated that these claims are not supportable for the following reasons:

That the lack of food in the world was due to distribution problems not to a lack of food and that it as not clear that GM crops would produce a higher yield;

That herbicide resistant plants have been developed to allow the application of sufficient herbicide to suppress weeds without damaging the soya. The net result of this is an increased use of herbicide, not a decrease;

That if the plant is not genetically modified, insecticide is only applied when needed. In a GM plant, however, the toxin is produced whether it is needed or not. This results in an increase of toxins in the environment.

That GM technology was qualitatively different to traditional breeding techniques. It is not possible to breed across species let alone biological families.

They then claimed that the evidence is such that it currently must be assumed that GM crops will result in contamination of organic and conventional crops. Later in the submission they made a similar statement to the effect that the risk of cross contamination in respect to field trials or the commercial release of GM crops or animals is real to the point of inevitability. Commonsense Organics also used the term ‘genetic pollution’ to describe this contamination.

Further Comment

The statement that if outcomes were known there would be no need for experimentation is problematic. It seems to equate the scientific process with risk assessment and ignore the concept of science as a search for basic knowledge. This distinction needs to be further emphasised. The term ‘genetic pollution’ is also dangerous as it emotive and inexact. What exactly does ‘genetic pollution’ mean?

There is also a difficulty with the statement that the outcomes of experiments are random. The scientific method is designed to decrease ‘randomness’ by requiring rigour in the form of replication of results. A similar problem exists in respect to the statement that each insertion event is unique and that the results are different every time. This either ignores or misunderstands the fact that every insertion must be shown to be stable. However, previous submissions have only stated that the trait must be shown to be stable without explanation as to how this is done. This may require further explanation. Furthermore, the statement that it is another thing to assume that a gene transferred to an alien genome will have the same function and perform in the same way highlights another problem. The scientific method does not ‘assume’ anything.

Difficulties also reside in the claim that herbicide resistant plants actually increase the use of herbicides. This seems to misunderstand the fact that herbicide can applied less often and in smaller doses when a crop plant is resistant. It also ignores the fact that glyphosate is more benign in comparison to herbicides currently used to control weeds in non-GM crops. Comparative evidence of weed control methods in respect to GM and non-GM plants may be required. The same misunderstanding seems to apply in respect to insect resistance.

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