The Royal Commission on Genetic Modification - submissions

The New Zealand Arable Food Industry Council (AFIC)

STRATEGIC ISSUES & OPTIONS — SECTIONS A(1), B(l), B(m)

Submission

AFIC submitted that there were opportunities for the arable food industry in both GM and non-GM products. They further submitted that a GM free approach was not viable because it is not achievable, it would be expensive, and result in lost opportunities for New Zealand. In their opinion, allowing scientific research and development in the GM technology field was fundamental to the viability of the arable food industry. Furthermore, efforts must be made to maintain and enhance the science infrastructure and workforce.

LAW & LEGISLATION — SECTIONS A(2), B(d), B(f), B(n)

Submission

Regulation

The AFIC stated that it was against political considerations being involved in the assessment of GM food products. They supported the scientific consensus that risk management should focus on probable not hypothetical risks but requested a more transparent assessment process. They further stated that there is no scientific justification for the labelling of foods based on the method by which the product is produced. They accepted, however, that consumer pressure has resulted in a need for labelling legislation.

The AFIC then outlined the current seed certification procedure in respect to the regulation of seed purity. This voluntary procedure currently covers all cereals, peas, beans, lupins, forage brassicas, linseed, and herbage plants and is monitored by MAF. AFIC stated that powerful biochemical techniques exist in respect to hybrid purity assessment, distinctiveness testing, cultivar regulation, seed testing and certification, documentation of genetic resources, and quality control. They are confident that traceability, in respect to GMOs, can be maintained and that tolerance levels can be met without the need for further legislation.

Intellectual property

The AFIC outlined what it considered to be flaws in the current Plant Variety Rights (PVR) Act 1987. To be protected under this Act a cultivar needs to be distinct, uniform and stable (DUS). To date, morphological characteristics have been used almost exclusively in DUS testing. Cultivars produced through the use of GM technology, however, are often morphologically indistinguishable from other cultivars. The use of molecular methods for DUS testing needs, therefore, to be encouraged. The ability to gain patent protection of new GM technology based plant cultivars is also in doubt and needs to be clarified. In the AFIC’s opinion this uncertainty, combined with the Governments failure to ratify the international agreement in respect to the protection of plant varieties, puts intellectual property in this area at risk.

ECONOMIC ISSUES — SECTIONS B(h), B(i), B(j)(iii), B(l), B(m), B(n)

Submission

As in other submissions, the AFIC observed that New Zealand’s economy is based on primary production. Improvements in production have resulted from the application of scientific innovations. GM technology has the ability to continue this trend as well as increase add-on industries and the production of new products.

AFIC noted that all New Zealand’s major trading partners have differing requirements relating to the manufacture, importation and sale of GM products. The rest of the world does not, therefore, share the European risk averse approach. They then submitted that fears in respect to GM technology will reduce and that New Zealand must maintain the ability to compete in this changing market.

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

Submission

Benefits

Many of the benefits outlined in this submission have been covered by the submissions from HortResearch and Crop & Food Research. Briefly the AFIC observed the following benefits in respect to GM technology:

Increase in food quality and nutritive value. For example, potatoes with less starch that absorb less fat during frying, peanuts with improved protein balance, and tomatoes with increased antioxidant content;

Improved food safety. For example, Bt maize has been shown to contain lower concentrations of fumonisin, a mycotoxin produced by Fusarium moniliforme and linked with oesophageal cancer. This is because the incidence of F. moniliforme is greater in plants that are attacked by corn earworm and the expression of the Bt toxin in plants reduces corn earworm attack;

Environmental goals such as decreased chemical use, bioremediation, and the replacement of currently non-renewable resources;

Improvement in agronomic traits such as resistance to freezing, drought tolerance and increased water use efficiency;

Human health benefits such as the use of plant ‘factories’ to produce vaccines and pharmaceutical products. For example, the use of lucerne modified to produce interferon-β, which is used in the treatment of a form of pneumonia.

Risks

The arguments and counterarguments in respect to the risks posed by GM technology have already been thoroughly outlined and analysed in previous submissions, especially in the HortResearch and Crop & Food Research submissions. Briefly this submission covered:

Substantial equivalence:

Allergenic and toxic factors;

Pollen dispersal and outcrossing;

Antibiotic resistance;

The development of superweeds and insecticide resistant insects.

Organic production

In the AFIC opinion, GM technology and organic systems can and should co-exist. They stated that despite claims to the contrary, organic production systems might themselves pose dangers. For example, there may be a higher incidence of mycotoxins and/or Escherichia coli in organic food products. They did acknowledge that the claim as to the levels of E. coli in organic foodstuffs has not yet been confirmed. Furthermore, sprays that are currently allowed in organic production may also be dangerous. For, example copper based sprays may result in a toxic copper build up in the soil. Rejection of GM technology by the organic industry may restrict, therefore, the reduction of chemical use in farming.

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