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The Royal Commission on Genetic Modification - submissions


Pesticide Action Network New Zealand

STRATEGIC ISSUES & OPTIONS

Submission

The Pesticide Action Network (PAN) submitted that New Zealand should become GE-free, not allowing any outdoor GE technology or commercial developments, and that we should channel our energies instead towards becoming an organic nation. In their opinion, if our country goes down the organic path as opposed to the polluting one provided by pesticides and genetic modification (GM) technology, we will have the opportunity to exploit our comparative geographical isolation by providing organic, GE-free products to the rest of the world.

In particular PAN recommends that:

  • New Zealand government put the international community on notice that it is considering declaring itself genetically engineered-free (GE) to fulfil its international legal obligations;
  • More stringent testing for GE food and crops be put into place by the Government;
  • Section 44(b) of the Hazardous Substances and New Organisms Act 1996, and consequent monitoring and compliance sections of the Act, are amended;
  • A referendum on the issue of GE is held;
  • The labelling of GE food is more stringent than that proposed by ANZFA;
  • Consideration be given to the adoption of a five-year moratorium on all outside GE applications, if the Commission decides not to recommend a GE-free policy for New Zealand.

LAW & LEGISLATION

Submission

In order that New Zealand remain ‘GM — free’ PAN recommended that:

  • NZ adherence to FDA and WTO rulings must be conditional on priority of local ecologies (and cultures), and that NZ therefore put the ICJ and UN "on notice" of this intention for GM restriction in order to allow international rules of "notice" to take effect;

  • To allow the more rigorous testing and encourage surveillance, the HSNO Act 1996 should be changed to require that GM workers be required to:

    1. prevent the escape of DNA from GM organisms via parasites, predators and other vectors, as well as the escape of "organisms (by amending section 44(b)); and
    2. monitor for the escape of DNA to the environment by using DNA technologies such as the polymerase chain reaction (PCR) routinely with respect to preventing and detecting such escapes. 

  • That a specific change should be made to section 44(b) of the HSNO Act 1996. The section should now read as follows. "The Authority, when making a decision under section 45 of this Act, on an application made under section 40(1)(a) or (c) of this Act, shall have regard to:

(b) The ability of the organism or its DNA to escape from containment, as assisted by humans, parasites, predators, or any other organism whatsoever.

  • Related sections concerning "genetic monitoring" - monitoring and detection for such escape of GM DNA (for example by PCR of parasite DNA from sheep) should likewise be altered.  

PAN then stated that they, along with the Public Health Association of Australia (PHAA) are concerned about flaws in both the process and science of GM food safety assessments in Australia and New Zealand. The ANZFA process was submitted to be flawed because it does not use the precautionary principle, does not allow easy access to the underlying scientific data, and allows inadequate time for public consideration of individual assessments. In their opinion, ANZFA has  adopted the approach that GM food is safe until proven unsafe.

They also stated that the process used by ANZFA to determine safety, lacks independent scientific safety assessments. Essentially all of the safety evidence has been obtained from the applicant company. The evidence provided by the applicants is rarely peer-reviewed and published in scientific journals. Consequently, the accuracy and veracity of the findings and the methods employed have rarely been scrutinised by outside scientists and other scientists have not been able to repeat the experiments to check the findings. Furthermore, it was contended that the science used in assessments is flawed because it fails to address potential impacts on human health adequately, relies on an untested assumption that only the genetically engineered change will occur, uses inadequate sample sizes, misdirects blame for adverse results, and fails to address cumulative issues which arise for humans through eating animals fed on genetically modified foods. 

RISKS & BENEFITS

Submission

PAN stated that testing of GE food and crops needs to be much more stringent, on similar lines to pharmaceuticals, testing for at least six years on a range of organisms including humans, as well as tracking of the movement of altered genes into other organisms. They were specifically concerned that each case or plant is considered in isolation, without taking into account the impact of several plants or toxins eaten together.

The same concerns that have been expressed in previous submissions were also highlighted. For example, superweeds, allergenicity, antibiotic resistance, increased pesticide use, and increased resistance to herbicides and pesticides. They also noted possible adverse effects such as diminished biodiversity. In particular, they highlioghted that  insecticide or herbicide-resistant GE crops may accelerate the already massive extinction of plant and animal species. In their opinion, the Sudden Death syndrome, a fungal disease that hit GE soybeans in the US in 1998, may be a foretaste of things to come.

They also submitted that GE crops may damage beneficial organisms such as ladybirds. They cited a Scottish study that is purported to show that GM crops may poison ladybirds, which flourish in healthy environments. Where ladybirds were fed on aphids which themselves had a diet of GE potato plants, they tended to die much earlier and lay fewer eggs. They also cited studies that were stated to show that in Thailand 30% of the bees around GE cotton field tests died. Another study was stated to show that the mortality rate of lacewing larvae increased after eating a Bt toxin similar to that found in Novartis maize. Then there is the well-publicised study of the Bt toxin killing monarch butterflies. Furthermore, a study published in Nature detailed how Bt toxins are crossing root membranes into the soil, causing worms to die.

In the PAN submission, Dr. Robin Ord disputed the professed need for GM to accomplish many genetic changes. Based on the knowledge derived from these different aspects of genetics Dr. Ord believed that classical genetics can achieve almost every trait conceivable using ‘organic genetics’, which was defined as spontaneous mutation, strong selective pressure and ‘founder effect’ (back-crossing or cloning the mutant type). This witness also outlined possible problems in respect to the ‘scale-up’ of laboratory techniques. It was noted that there are no facilities to handle ‘scale-up’ production testing in New Zealand. Dr. Ord estimated that the time taken to provide such facilities and to test products in containment for safe release to take up to fifty years, depending on the species generation time.

Further Comment

It should be noted that some submissions have been critical of the findings of some of these studies. (See especially, Crop and Food Research Submission).


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