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The Royal Commission on Genetic Modification - submissions


New Zealand Cooperative Dairy Company

The New Zealand Cooperative Dairy Company (NZDG) supported the submission of the New Zealand Dairy Board (NZDB). The following is a synopsis of additional points made by the NZDG in their submission.

Law & Legislation – SECTIONS B(a), B(b), B(c)

Submission

The NZDG submitted that opponents of GM technology frequently make the point that the people that gather and submit evidence to regulatory authorities have a vested interest in the outcome. The NZDG expects that the Commission will recommend to Government that the regulatory framework that assess applications for the use of GM or products derived from the use of GM technology are:

  • Seen to be fair and independent;
  • Science based;
  • Part of a wider framework considering food and environmental safety;
  • Do not disadvantage New Zealand in relation to its competitors;
  • Do not deprive New Zealand consumers of the benefits of new products.

RISKS & BENEFITS – SECTIONS B(b), B(c), B(h), B(i), B(j)(i)

Submission

Improving productivity

The NZDG noted that phosphate fertilisation and the requirement for magnesium in lactating dairy herds are major costs to dairy farmers. Some of the genes determining phosphate requirement and magnesium uptake by plants are known and GM could be used to manipulate them in pasture plants. Furthermore, GM plants could contribute to increased productivity through genes that:

  • Allow plants to grow more in winter, or to grow with less water in summer; or that
  • Delay the time of flowering so that plants retain their digestibility characteristics.

This would allow milk production at full capacity year round. These modifications would also contribute directly to animal health and welfare.

Improved efficiency in milk production

This could be achieved through the reduction of the water content of milk and the increase of proteins such as casein. Cows milk is nearly 90% water and removing this water is currently a large energy cost for the NZDG. Increasing the casein composition in milk would enhance the efficiency of producing cheese and increase the value of the product. For example, K-casein has a substantial influence on the quality of cheese produced. Increasing the proportion of K-casein would improve the texture and flavour of cheese.

Human health

The NZDG provided the example of altering the types of fatty acids in milk fat to achieve a nutritional/health claim. This would probably be done through the alteration of the plants the animals eat. A second example is the alteration of milk constituents for infant formula so that they are more like human milk proteins. One example is the addition of the iron-binding protein lactoferrin, which is much higher in concentration in human milk as compared to cows’ milk. Furthermore, PPL Therapeutics have already produced transgenic cows in which bovine α-lactalbumin was replaced by the human variant. No adverse effect on animal health was apparent.

It was observed that to date, the proteins from the milk of transgenic animals has only been used to limited extent in clinical trials. The two examples supplied were the phase I and II trails by PPL with α-1 antitrypsin and by Pharming with glucosidase for Pompe’s disease.. This means that there is no conclusive evidence for humans as yet.

NZDG then outlined the following points in respect to the uncertainty of possible future use of GM technology in protein biochemistry:

  • If the protein structure at the time of translation is aberrant, then it is degraded by the ubiquitin system;
  • Many, if not most proteins will partially unfold into aberrant forms and form amyloid fibrils. The incidence of these structures acting as prions (acting as a template to deform other proteins and behaving like infective agents) is extremely rare in natural situations and there is no reason to think that this will occur more often when GM technology is used;
  • Of more than forty proteins that have been expressed in the milk of transgenic animals there is no evidence of unusual protein structures;
  • As the expression of proteins in the milk of transgenic animals has now been carried out for more than 15 years, there is a substantial body of evidence in this field.

Environmental

The NZDG stated that the environmental impact of GM in the dairy industry would depend on the particular application. In general, it was noted that GM technology could match plants to the environment so that they require fewer inputs such as herbicides and pesticides. They provided evidence that actual pesticide use has been reduced. Moreover, GM modified plants have facilitated the replacement other synthetic herbicides for glyphosphate. The previous herbicides were least three times as toxic and persisted in the environment nearly twice as long as glyphosphate.

Animal Health and welfare

In relation to uncertainty of use of GM technology to animal health the NZDG noted that all major corporations are strictly regulated. They must show that the transgenic animals used for biopharmaceutical production are normal and healthy, especially where they are expressing a biologically active human protein.

Uncertainties

The NZDG cited a number of articles, which are generally supportive of GM technology. The NZDG noted that a consistent theme across these reports is that in both food and environmental risk there was a need for an open, and transparent and inclusive debate and for openness and transparency in the policy debate.

TREATY OF WAITANGI – SECTIONS B(g)

Submission

The NZDG noted that the fundamental principle, which underlies the Treaty, is that of partnership. They then submitted that, as a partnership, the relationship between the Crown and Maori must operate on the basis of respect for the views of the other partner. The principle of partnership does not permit the views of one partner being given primacy over those of the other. The NZDG noted that within the group there is a substantial Maori presence and that their view would have to be carefully and sensitively considered. However, there are clearly different views within Maori, and that iwi, hapu and whanau may have a range of views, which could influence the activities of the NZDG. It was then noted that some of its largest suppliers are Maori Incorporations and that if the New Zealand industry is disadvantaged in comparison with overseas because GM is banned or unduly restricted, then that will effect the viability of Maori dairy farmers as much as other farmers.


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