The Royal Commission on Genetic Modification - submissions

New Zealand Game Industry Board (NZGIB)

STRATEGIC ISSUES & OPTIONS – SECTIONS A(1), A(2), B(c)(ii)

Submission

The NZGIB highlighted that it was important for New Zealand to maintain its strong ‘natural’ position and as a consequence advocated a conservative approach to the introduction of GM technology. They further stated that they did not support the introduction of GM products into the food chain. However, this was due to current consumer preference and not due to any health or safety issues. It was also observed that if GM products are avoided in the food chain, a ‘clean green’ or ‘GM free’ New Zealand was a realistic and defensible marketing ploy. They equated this as similar to the pragmatic ‘nuclear free’ label attributed to New Zealand. It did, however, support the option of being able to adopt a broad range of gene technologies in the future and acknowledged that consumer preferences can change.

LAW & LEGISLATION – SECTIONS A(2), B(d), B(h), B(k), B(n)

Submission

Regulation

The NZGIB supported a prudent and independent regulatory system. The current legislation was stated to require revision however. It stated that any regulatory system should have its scope limited to health, safety and environmental issues. In general it supported the AgResearch submission in respect to legislative change. NZGIB also submitted, like many others, that ethical, cultural, and other value based issues should be part of the overall regulatory framework at a generic or policy level, rather than at the level of the approval process. They then called for a greater emphasis to be placed on responsible self-regulation and internal (audited) risk management programmes. See also the New Zealand Dairy Board summary under the regulations subheading.

International obligations

the NZGIB noted that New Zealand’s membership in the WTO restricted its ability to impose import restrictions. Under WTO rules, restrictions that are necessary to protect human, animal, and plant life or health can be placed on imports. As per the Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement) these restrictions can only be imposed to the extent necessary, must be based on scientific principles, and cannot be maintained without sufficient scientific evidence. The SPS Agreement, therefore, affirms the supremacy of scientific evidence. The NZGIB also noted that although the precautionary approach may be followed, these measure may only be temporary and the body imposing these measures must actively be seeking evidence. Furthermore, the NZGIB observed that the WTO has recently ruled that labelling may be considered a restrictive trade practice.

BENEFITS & RISKS – SECTIONS B(a), B(b), B(c),

Submission

Risks

It was submitted by the NZGIB that the technology and its application is sound and safe provided that due regard placed on potential risks and comprehensive testing procedures are followed. It then highlighted the conclusions of the OECD conference on GM Foods. These are:

There is no credible evidence for any health risks associated with GM foods:

There is no reason to consider GM foods as more likely to produce allergens. Furthermore, the GM technology involved is more appropriate to detect them than is a conventional approach;

Antibiotic resistance genes are unlikely to present a threat; these can and should be removed, however, as a precautionary measure.

The preliminary result (11 July 2000) of the ANZFA study was also submitted. This stated that GM foods had all the benefits of conventional foods with no additional risks. In respect to risk management it recommended the witness brief of Dr Derek Woodfield on behalf of AgResearch.

Benefits

In general, this submission outlined the same benefits as have already been mentioned in previous submissions. In particular it noted the possibility that the use of GM technology could remove or reduce the problem of internal parasites in herd animals. This is important as the residue from chemical drenches can be used as a reason to impose trade barriers, and because of the development of chemical drench resistance in ruminant parasites. The NZGIB also highlighted the importance of Market Assisted Selection (MAS) for the deer industry and noted that some anti-GMO proponents supported MAS approaches.

ECONOMIC ISSUES – SECTIONS B(h), B(k),

Submission

It was submitted that innovation drives competitiveness. The NZGIB noted that it is faced with an increasingly discerning consumer market in Europe and North America. People in these affluent markets were stated to require new knowledge based products that offer value, health and nutrition benefits.

The NZGIB submitted that productivity gains in the deer industry are insufficient to sustain long run earnings. They then observed that knowledge applied to natural resources could be used for product development and be the basis for new add-on industries to emerge. The use of GM technology would allow the deer industry to reposition itself and develop a platform for future revenue growth, resulting in innovative improvements, new products and more efficient production and processing systems. Exclusion of GM technology would reduce New Zealand to an economic backwater. New Zealand, therefore, needs to maintain research options in order to capitalise on new knowledge produced from this research

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