The Royal Commission on Genetic Modification - submissions

New Zealand Biotechnology Association

STRATEGIC ISSUES AND OPTIONS — SECTIONS A(1), B(h), B(j), B(k), B(m)

Submission

The New Zealand Biotechnology Association (NZBA) stated that it was inconceivable that New Zealand should reject genetic modification (GM), a technology that could substantially improve New Zealand’s welfare. In their opinion, if New Zealand does not adopt genetic technologies it is likely to lose its international competitiveness for agricultural related exports. For example, a company that employed the witness for the NZBA lost its original business of producing a natural product sourced from the meat industry (100% sales reducing to approximately 5%) to a product produced more cheaply using a micro-organism and modern biotechnology. It was then noted that even countries that speak out against American GM food imports are themselves heavily investing in modern biotechnology. It is essential, therefore, that New Zealand continues research and development in both agricultural and medical fields if this country is to grow in the international market place.

They then stated that the NZBA supports an environment in which issues can be rationally discussed and informed decisions can be made. They considered their role to be to help New Zealanders gain an improved understanding of the basis of gene technology. This could lead to many undecided people and others who base their value judgements on ethical, cultural, and environmental issues to be more accepting of the technology. Furthermore, it is important that a reasonable level of transparency regarding the science and business of genetic technologies is available. This is so that public opinion can be balanced through wise assessment rather than rejection through fear of the unknown.

LAW & LEGISLATION — SECTIONS A(2), B(b), B(k)

Submission

The NZBA highlighted the same problems with the Hazardous Substances and New Organisms (HSNO) Act 1996 as have been noted in previous submissions. It was stated that risk management regimes should focus on identifying and managing actual risk with potential serious harm to human health or the environment. A distinction needs to be made between GM research that is contained versus that which is to be released. The following proposed revisions were outlined:

Applications to develop genetically modified organisms (GMOs) in containment to be assessed on a project not experimental basis. Methodological or material changes should be notified to an IBSC;
Projects that qualify as requiring PC1 containment should be exempt from prior approval provided the facilities available met at least PC1 containment standards and procedures. IBSCs should be notified and maintain a record of all such projects. These records should be available to ERMA for auditing purposes;
The assessment of all projects involving GMOs in containment should be delegated to IBSCs with recourse to ERMA where specified expertise or interpretation is required;
Approval for the development of a GMO should be sufficient for importation of a GMO subject to obtaining a MAF importation permit and the GMO being imported into an appropriate level MAF registered facility;
Animal cell culture line genetic modifications should be exempt from approval unless they are agents of significant toxicity that affect risk to laboratory researchers are involved. This is because animal cell culture lines do not survive outside of laboratories and do not regenerate to whole organisms.

The NZBA also noted that the rate of change of development in biotechnology is very rapid. The regulatory environment, therefore, will need to change just as rapidly to ensure public safety as well as allowing flexibility in research and development.

RISKS & BENEFITS — SECTIONS B(a), B(b), B(c), B(j), B(k, B(h)

Submission

It was submitted that accumulated knowledge means that questions about safety in respect to GM technology can be answered with a certainty not possible with regard to traditionally bred crops. The NZBA highlighted that Crop and Food Research alone have carried out 27 contained field trials demonstrating the ability to successfully and safely introduce new traits into crops. They then stated that the key assessment for GM is to determine to what extent the technology ameliorates existing risks and introduces new ones. Concerns in respect to modern agricultural systems are related to the use of the product not the technology that produced it.

The NZBA stated that much of the public uncertainty is due to the lack of a credible and independent voice. In their opinion, the role of IBAC has been weakly executed due to limited resources. This means that the publicity associated with gene technologies has not been presented to the public in an effective manner. Furthermore, any information that is released is sensationalised by the media. Negative results are widely publicised but if the research proved to be incomplete or the conclusions were inaccurate, this information is difficult to find through normal media routes. It is IBAC’s role to provide balance in reporting to the community.

The NZBA then outlined benefits that have and could be derived from the use of GM technology. These have been well covered in previous submissions and will not be repeated here. They did, however, emphatically state that they did not wish to see GM technology used for cosmetic purposes or as a tool for discrimination. For example, if a person is unwell then knowledge of that person’s genes may lead to individualised health care. On the other hand, similar genetic information could lead to a ‘non-employable’ status or rejection of a health insurance application. In other words, it is the end use of science and technology that may require regulation, not the science or technology itself.

Our Royal Commission homepage