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The Royal Commission on Genetic Modification - submissionsGreen Party New ZealandSTRATEGIC ISSUES & OPTIONSSubmission It was submitted by the Green Party New Zealand (Green Party) that given the uncontainable nature of GMOs once they are released into the environment, their unpredictable and unknown impact on the environment, it would be wise for New Zealand to maintain its GMO-free status. Hence, only contained-use applications of GM technology, which do not result in the release of viable GMOs capable of reproduction and spreading into the environment, should be permitted. These applications include developments of genetic based therapies (e.g. somatic gene therapy) for inherited diseases (e.g. cystic fibrosis) and plant genome studies that can significantly expedite the selection of new plant food varieties resulting from natural breeding programmes.
It was further submitted that research and extension funding has become disproportionately biased toward proprietary technologies, and towards GM in particular. It was then noted that the organic sector in New Zealand is small but growing and that the demand for organic is growing in preference to chemical- and biotech-based produce. In their opinion, New Zealand should capitalize on its isolation as an island, and its clean and green reputation, through a major push toward organic production systems. To allow production of GM crops in NZ would be to waste these inherent advantages.
Furthermore, science in a ‘GM Free’ NZ would take a different direction. In their opinion New Zealand could become world leaders in a field much less dominated by big players. Historically New Zealand has done excellent work in soils and grasslands. Instead of burying New Zealand’s expertise in soil and grasslands in the rush to develop patents on new organisms New Zealand could expand this expertise to develop valuable intellectual capital in sustainable management. They then stated that there is a valuable role for genetic science in the lab to better understand inheritance, to provide diagnostic tools and to support natural selective breeding of plants and animals which are particularly successful in organic systems. Medical work using GM micro-organisms could grow, without being brought into disrepute by association with GM higher organisms and food, against which there is such a strong public reaction.
The Green Party then went onto state that there is no place for nutriceuticals in New Zealand. Alongside the risks of GM plants, the required dose would be very difficult to administer accurately and the risk of confusion between such crops and their natural counterparts even more risky. It also opens the door to mass medication, through engineered food, of a population without consent which breaches the most basic democratic rights. LAW & LEGISLATIONSubmission
The Green Party then recommended the following changes to the regulatory structure of GM technology:
The Green Part also noted that 157 unauthorised experiments had been discovered in New Zealand research institutions. This was stated to demonstrate that the scientific community as a whole has not fully bought into the regulatory process. In their opinion, to weaken the assessment process, in order to exempt applications from low risk experimentation, would send the wrong signals both to scientists and the public.
RISKS & BENEFITSSubmission In her witness brief Dr. Ann Clark submitted that resource-intensive agriculture, as supported by conventional plant breeding, exposes both biodiversity and hence, human health to risk. However, GM crops pose unique, additional risks, because they were conceptualized and developed largely in isolation from applied scientists. While conventional plant breeders work closely with applied scientists and farmers to improve crops, molecular geneticists have worked independently, to maintain control over the technology.
She then gave examples of how this disciplinary isolation has lead to problems. For example, she stated that researchers assumed that horizontal gene transfer occurred in the lab but not in the harsher field environment microbial ecology, virology, and pathology. However, other researchers such as Hoffmann et al. (1994) and Ho (1998) discussed evidence of horizontal gene transfer. Furthermore, Ochman et al. (2000) reviewed evidence of horizontal gene movement via plasmids, transposons, and other mobile genetic elements, with emphasis on antibiotic resistance, virulence attributes, and metabolic properties. This was then stated to show that lateral (horizontal) movement among unrelated organisms is another means by which transgenes can spread into the wider ecological community.
It was then submitted that the process of inserting transgenes is not precise. Transgene packet insertion is random, both within and among chromosomes, and order matters not simply to the reliability and stability of transgene expression but also to inadvertent expression of unintended traits. Dr. Clark then stated that commercialized transgenic crops may be unstable in expression across a range of environments representative of that in which it will be grown. Coghlan (1999) reported a study conducted by Bill Vencill of the University of Georgia, where farmers had reported unusual behavior in Roundup Ready (RR)(glyphosate tolerant) soybeans. In two successive springs, soils were particularly hot, causing RR soybeans -but not the original parental cultivar or other transgenic soybeans - to be stunted. Stem splitting occurred, exposing the plants to pathogen infection. In a normal year, this didn’t happen. RR cotton has also exhibited a range of adverse side effects and instability problems relating to floral abortion and pod retention (Edmisten and Stewart, 2000).
Dr Clark then gave a list of examples of the unintended side effects of gene insertion. For example, Klebsiella planticola, a common soil bacteria, was genetically modified to transform plant residues into ethanol. However, it not only competed well with parental strains, but also with a beneficial soil fungus (mycorrhizae) and actually killed the test wheat plants (Holmes et al., 1998). Unmodified parental strains did not have these effects. The side effects of increased use of glyphosate, a known mutagen (Kale et al., 1995), were also listed. This increased use was stated to be enabled by the use of RoundUp Ready (RR) crop plants. Furthermore, it was considered noteworthy that the allowable level of glyphosate residue on soybeans was increased by 200X (from 0.1 to 20 ppm) in several countries coincident with the approval of RR crops.
The risk of invasiveness of GM crops was also discussed. Dr Clark stated that it was not possible to predict potential weediness of a GM crop from a few simple measurements. It was further submitted that at present, a largely assumptions-based process is used to infer that GM offerings will not be invasive in both the US (Purrington and Bergelson, 1995) and Canadian risk assessment processes (Clark, 1998). In her opinion, remarkably little empirical information is requested or provided with GM submissions, and much of what is provided has little apparent relevance to actual risk of invasiveness. Particularly with increasing evidence of unintended side-effects attributable to transgene insertion per se, some of which could influence invasiveness, the evidence is not compelling that GM crops or crop: weed hybrids, or recipients of genes via horizontal transfer, will not be invasive.
Overall, it was Dr. Clark’s contention that GM technology has been released prematurely into the marketplace, based on an understanding of gene action and plant physiology which is rudimentary at best (Brown, 2000). Couple this with the at least equal level of uncertainty about how biodiversity actually functions in natural systems, and you have a situation conducive to invasion, displacement, destabilization, and dysfunction.
Dr Elaine R. Ingham called for full and complete biosafety testing before any engineered organisms is allowed to be released, in line with the Precautionary Principle. She then set out a range of methods by which this could be done. She then went on to discuss how GM crops may affect soil ecology. Overall, she submitted that soil organisms are extremely sensitive to the use of genetically engineered organisms, and in those few cases where impacts have been assessed, it is quite likely that nearly every engineered plant will have unpredicted and unexpected effects on beneficial organisms in the soil. The Green Party also warned that overseas based research may not be relevant to our indigenous biodiversity and soils. For example, outcrossing of GM crops through cross pollination with native plants is less of a risk in NZ because the wild relatives of common food crops are not part of our indigenous ecosystems. Just as this risk is reduced in our environment, there will be others that are enhanced.
Dr Michael Antoniou refuted the claim that GM technology was analogous to traditional breeding. He stated that GM is a no holds barred technology that allows the isolation, cutting, joining and transfer of single or multiple genes between totally unrelated organisms. This circumvents natural species barriers and as a result, combinations of genes are produced that would never occur naturally. In addition, the newly introduced gene units are composed of artificial mixtures of genetic material. He then went onto note the tight interdependency of control mechanisms in the genome. In his opinion the GM of animals and especially plants, always results in a loss, to a lesser or greater degree, of this tight control and balanced functioning which is retained through conventional cross breeding. This divorce from control and balance produces a totally unpredictable disturbance in host genetic function as well as in that of the introduced gene. The resulting disturbance in biochemical function can unexpectedly produce novel toxins, allergens and reduced nutritional value.
As in other submission the Green Party outlined concerns in respect the heath risks of consuming GM food products. These included allergenicity, antibiotic resistance, the possibility of novel toxins, and the possibility of new viral diseases through the process of recombination. As with Nelson GE Free the increased incidence of soy allergies was noted. They then noted a possible correlation between this increase and the infiltration of RR soy into the market. The Green party was concerned that no-one could guarantee whether or not the soy that caused the increase in allergies was GM free. In their opinion, this means that so it cannot be established whether there is a casual link between the consumption of GM soy and an increase in allergic reactions to soy.
ETHICAL, CULTURAL & SOCIAL ISSUESSubmission The Green Party submitted that ethical issues are particularly relevant to the genetic engineering debate. In their opinion, the distinctive nature of genetic modification requires urgent ethical reflection. They noted that a number of commentators have suggested that recent industrial, agricultural, medical and military advances and applications of science, especially in the realms of information technology, robotics, genetic engineering and nanotechnology have been proceeding largely in an ethical vacuum. Hence, there is an urgent need to make ethics an integral part of the scientific method in order to properly address risks and benefits, and to be publicly accountable.
The Green Party then stated that it was committed to Te Tiriti o Waitangi as a living document and recognises its partnership relationship with Maori. The Green Party further recognised the obligation to take full account of Maori cultural and spiritual views in Crown decision-making. It was the submission of the Green Party, therefore, that the Crown, through its agent, the Commission, must give substantial weight to Maori views on genetic engineering. GM poses serious irreversible risks to matters at the heart of Maori cultural and spiritual values. The issues are of such significance that that a strong case exists for the Crown being obliged to act on the Maori views. For the Crown, through its agent this Commission, to do anything less is to undermine Te Tiriti and to fail to meet its obligations under it.
ECONOMIC ISSUESSubmission As in other submissions the Green Party noted adverse opinions in overseas markets in respect of GM food products. They submitted that agriculture and trade policy-makers need to factor in the possibility that money and effort may be being wasted if the majority of New Zealand producers don’t want to use GM technology, and consumers don’t want to buy it. Furthermore, there is a real risk that the introduction of GMOs will damage the market for certified organic produce. They were also concerned that New Zealand’s tourism image may also be damaged by the release of GMOs.
In their opinion, organics was a flourishing and vital industry. It was then stated that the kiwifruit industry is a good illustrative example of organic market demand. The seasonal demand for certified organic kiwifruit in Japan alone can exceed New Zealand’s total (organic and conventional) kiwifruit production. They then argued that not only would a GM Free New Zealand benefit the organics industry, it would also benefit the conventional agriculture sector. For example, in respect to the production of guaranteed GM free seed stock. |