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The Royal Commission on Genetic Modification - submissionsEnvironment and Conservation Organisations of New Zealand (Inc)STRATEGIC ISSUES & OPTIONSSubmission The Environment and Conservation Organisations of New Zealand (ECO) recommended a fully legislated moratorium on gene technology. This would enable time to take into consideration the cultural, ethical, health, environmental and financial issues associated with GM technology. They then highlighted that currently there is a world-wide demand for organic food and teachers of organic farming methods. Furthermore, New Zealand has thousands of threatened species that need study and little is known about soil micro-organisms and their role in sustaining fertility and decomposition. IPM (Integrated pest management Systems) systems are also in demand and could be developed more fully. In ECO’s opinion, there is much our scientists could do without embracing gene technology.
RISKS & BENEFITSSubmission ECO expressed cynicism and doubt over some of the claims that have been made in respect to GM technology. It was ECO’s opinion that the benefits of GM technologies mainly accrue to the companies who make and sell GM products. Furthermore, most innovations in agricultural biotechnology have been profit-driven rather than need-driven. As in other submissions, promises of increased yields and decreased herbicide and pesticide use were challenged. Concerns were also expressed in respect to the possible effects of GM technology on biodiversity, and the environment - especially in respect to increased use of herbicide and pesticide resistant plants and possible superweeds. The issues surrounding antibiotic resistance, cross-pollination, allergenicty, and increased toxicity were also discussed.
ECO’s submission also addressed DNA persistence in the environment. For example, it was contended that transformable plasmids have been shown to persist for sixty days after release1. It was also stated that the tobacco and potato transgenic plant marker gene nptII has persisted in soil for 77- 137 days2. It was then submitted that particles found in soil and sediment, such as quartz, feldspar and clay minerals, as well as those suspended in naturally occurring water, have the ability to bind both organic and inorganic material. When DNA is bound to some of these types of particles, it is protected from being broken down and must therefore be looked upon as a source for the transfer of genetic information3. It was also noted that the extent of horizontal gene transfer may be far greater than classical studies have succeeded in revealing4. Furthermore, despite strong barriers to horizontal transfer, it was submitted that there are indications that horizontal gene transfer takes place between eucaryotes across species, family and kingdom boundaries5. It is extremely important, therefore, to have these two issues investigated because even exceptionally rare cases may have far-reaching, unpredictable and serious ecological consequences6.
Craig Holdrege argued that without an awareness of an organism as a whole, the consequences of the most "innocent" genetic modification could hardly be guessed. Change one element of the complex balance in an ecological setting or within an organism and you change everything. Unexpected effects are therefore typical. Even when scientists try to change the narrowest trait of an organism, the organism itself responds and adapts as a whole. For example, when tomatoes were engineered for increased carotene production, some plants did make more carotene, but often in places where they wouldn't normally produce much of the substance for instance, in the seeds, the seed leaves, and the area where the tomato breaks off the stem7.
Other example of unintended effects were outlined by Terje Traavik. Tobacco plants were modified to produce gamma-linolenic acid. Instead the plants mainly produced the toxic product octadecatetraenic acid8. When yeast was genetically modified to obtain increased fermentation, it was unexpectedly discovered that the metabolite methyl-glyoxal accumulated in toxic and mutagenic concentrations9. When a gene from Brazil nut was inserted in soybean plants, unexpected, strong allergic reactions were recorded in nut-allergic persons who had never had any problems with soybean products. The inserted gene did not code for any known allergen10.
LAW & LEGISLATIONSubmission In ECO’s opinion, New Zealand needs to bring in legislation that requires full and complete labelling of all foods (human and animal) and products produced from gene technology. Regulatory bodies such as ERMA and ANZFA also need a more representative membership. ANZFA should also have the ability to investigate more fully safety submissions from applicants in respect to food approvals. Furthermore, when ANZFA's decisions are contrary to the New Zealand public’s wishes, then New Zealand should be free to make independent decisions based on public preferences.
SOCIAL, CULTURAL, & ETHICAL ISSUESSubmission It was highlighted that it is often heard that biotechnology is merely doing what high-yield breeding, industrial agriculture, and nutritional science have done all along but now much more efficiently. However, this is part of the problem - more of the same is not, in their opinion, required. ECO then submitted that there is considerable world-wide distrust over its use in agriculture and food crops. Because of this, markets for GM food and seed are not strong. They then gave a detailed outline of products that are being rejected by particular markets. In their opinion, Government and firms could get out of the current ‘mess’ with GM food if they switched from a narrow focus on scientific and technical issues to a wider focus that included the political, legal and ethical difficulties of handling the uncertain effects of new technologies. Therefore, ERMA needs to look at the issues involved from a wider perspective than risk analysis of a particular field trial. It was also submitted that the weightings given to the different scientific, ethical and cultural considerations should be made clear when any decision is reached.
ECO further submitted that the public are not stupid and ignorant about their approach to risk but have a sophisticated grasp of the main issues. Furthermore, they argued that science cannot provide definitive answers about the safety of new technologies, and a much more independent and participatory style of making decisions is needed if new technologies such as GM, where deep uncertainties about their effects are the norm, are to be accepted. Government and industry should greatly expand their initial experiments with new ways of making decisions on issues like GM food, for example by using consensus conferences, citizen juries, focus groups and deliberative polls.
ECONOMIC ISSUESSubmission They noted that at present the costs and risks associated with GM technology were being borne solely by the end user. This includes increased input, insurance, and segregation costs. Furthermore, land values are being affected by the technology. The Royal Institute of Chartered Surveyors (RICS) has called for the creation of a land register through which potential buyers, and banks, could find out if and when GM crops had been planted or grown on a particular holding. However, the RICS report, sent to the Government's Office of Science and Technology and other departments, warned that growing such crops might lower the value of the land. In the case of tenant farmers, a landlord could, in effect, sue for any shortfall in land value caused by the tenant growing GM crops.
They then submitted that GM crops are not a competitive advantage but a disadvantage, resulting in lower sales and lost markets. They then gave a detailed list of lower sales and lost markets due to GE contamination. For example, Canada was stated to have lost $300-400 million in canola sales to Europe in 1998 because authorities have followed the US model of co-mingling GM and non-GM grains. Another example was the Thai company Doi Khai that has conceded that a shipment of flour was rejected by a German importer who charged that the soybean was genetically modified.
ECO then noted that Currently about one third of our agricultural research budget or $35 million dollars is being spent on Biotech research. In their opinion, the Government of New Zealand seems keen to capitalise on the "knowledge" economy. However, with organics in such high demand, perhaps it was ECO’s contention that the Government should in fact be encouraging research into organics. Furthermore, organic agriculture and its economic benefits is just one example of the kind of economic activity that could result from a focus on more sustainable agriculture that is not mining or poisoning the soils of New Zealand. Another example of investment is that of Advanta wanting to produce GM free seeds in New Zealand. 1 Romanowski G. et al. (1993a). Use of a polymerase chain reaction and electroporation of Escherichia coli to monitor the persistence of extracellular plasmid DNA introduced into natural soils. Appl. Environ. Microbiol. 59: 3438-3446. 2 Widmer F. et al. (1997). Quantification of transgenic marker gene persistence in the field. Mol. Ecol. 6: 1-7. 3 Lorenz M.G. and Wackernagel W. (1994). Bacterial gene transfer by natural genetic transformation in the environment. Microbiol. Rev. 58: 563-602. Lorenz M.G. et al. (1991). Release of transforming plasmid and chromosomal DNA from two cultured soil bacteria. Arch. Microbiol. 156: 319-326. 4 Lorenz M.G. and Wackernagel W. (1994). Bacterial gene transfer by natural genetic transformation in the environment. Microbiol. Rev. 58: 563-602. Lorenz M.G. et al. (1991). Release of transforming plasmid and chromosomal DNA from two cultured soil bacteria. Arch. Microbiol. 156: 319-326. 5 Stachel S.E. and Zambryski P.C. (1989). Generic trans-kingdom sex? Nature 340: 190-191. 6 Syvänen M. (1987a). Cross-species gene transfer: a major factor in evolution? Trends Genet. 2: 63-66 Syvänen, M. (1987b). Molecular clocks and evolutionary relationships: possible distortion due to horizontal gene flow? J. Mol. Evol. 26: 16-23. Syvänen M. (1994). Horizontal gene transfer: evidence and possible consequences. Annu. Rev. Genet. 28: 237-261. 7 Fray, R. et al. (1995). Constitutive Expression of a Fruit Phytoene Synthase Gene, The Plant Journal 8:693-701. 8 Reddy S.A. and Thomas, T.L. (1996). Expression of a cyanobacterial delta 6-desaturase gene results in gamma-linolenic acid production in transgenic plants. Nature Biotechnol. 14: 639-42. 9 Inose T. and Murata K. (1995). Enhanced accumulation of toxic compound in yeast cells having high glycolytic activity: a case study on the safety of genetically engineered yeast. Int. J. Food Science Tech. 30: 141-146. 10 Nordlee J.A. et al. (1996). Identification of a Brazil-nut allergen in transgenic soybeans. New Engl. J. Med. 14: 688-728
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