The Royal Commission on Genetic Modification - submissions

The Royal Society of New Zealand

Submission to the Royal Commission on Genetic Modification

Witness brief Part B: Social science

Presenter:

Rosemary Du Plessis, Social Science Representative on the Council of the RSNZ

24 January 2001

A. Introduction

1. I am a senior lecturer in Sociology at the University of Canterbury and have a long-term interest in the politics of knowledge, public policy and cross-disciplinary gender-focused research. In July 2000 I took up an elected position as the social sciences representative on the Council of the Royal Society and coordinated Part B of the Society's submission to this Commission. I appear, not as an expert in the social issues relating to genetic modification, but to represent the group of social scientists with expertise in this field who contributed to this submission. (A list of those who participated in this group, and of those who acted as referees, is appended to this witness brief)

2. The submission prepared by social scientists raises questions about the circulation of knowledge about GM technologies and about opportunities for people to make choices with respect to health care, food consumption and their physical environment. It explores the relevance of the Treaty of Waitangi for decisions about the use of genetic modification technologies in Aotearoa/New Zealand. The economic interests of different sets of food producers and the potential economic consequences of the commercial release of land based GMOs are considered. The submission looks at how citizens might have a more effective and informed voice in decision-making with respect to GM technologies and their application in Aotearoa/New Zealand.

This witness brief highlights aspects of our submission and attempts to be more specific in its recommendations with respect to action on certain matters. It focuses in particular on:

Tikanga Maori and genetic modification
Health applications of GM technologies and nutriceuticals
GMOs and land-based production of food, fibre and nutriceuticals
Research and decision-making
Community participation
Information transfers

The text of this witness brief is available for your records.

B. Tikanga Maori and Genetic Modification Technologies

4. Basic principles vital to Maoritanga are challenged by the practices associated with GM technologies - these are mauri (life essence or unique life force), whakapapa (the connections between all living things) and kaitiakitanga (the guardianship of natural and physical resources). GM technologies change the genealogy of living organisms, disrupting existing intergenerational connections. The submission argues for continuing attention to Maori involvement in decision-making relating to GM technologies and their application. (RSNZ Submission, Part B, paragraphs 49 - 51, 80 - 91)

5. The Treaty of Waitangi has been defined as offering protection, participation and partnership. (RSNZ Submission, Part B, paragraph 83) This raises the issue of how ‘partnership’ should affect the weight given to Maori views on the use of GM technologies.

6. In particular we would like to highlight the following:

The conditions under which Maori objections to the use of GM technologies could lead to the decline of an application to import, develop or field trial GMOs must be clearly defined. (RSNZ Submission, Part B, paragraphs 80, 83, 88)

Maori involved in processes of consultation with respect to the import, development or release of GMOs should be appointed on the basis of their expertise in tikanga Maori and their connections with local hapu and iwi. (RSNZ Submission, Part B, paragraphs 88 — 9)

Health researchers must recognise that some Maori assert that human genetic information is owned by whanau, hapu and iwi. Research using such information should therefore not proceed without appropriate consultation with Maori and their participation in decision-making. (RSNZ Submission, Part B, paragraph 79). Pending the outcome of the Wai 262 claim the same recommendation is made with respect to flora and fauna.

Local hapu and iwi should be actively consulted about the use of GM technologies in field trials associated with their ancestral land. (RSNZ Submission, Part B, paragraph 89)

Decisions made by particular whanau, hapu or iwi cannot be taken as precedents for decisions involving other whanau, hapu or iwi. (RSNZ Submission, Part B, paragraph 89)

We support the recognition in law and regulation that assessment of the 'risks' associated with the use of GMOs should not be confined to technical risk, but include attention to other types of risk. (RSNZ Submission, Part B, paragraph 38) All decisions with respect to GM experimentation involving indigenous flora and fauna should take into account Maori culture and taonga. Maori must be involved in such decisions (RSNZ Submission, Part B, paragraph 91)

Resources should be available for research and transmission of information in Maori communities about customary knowledge that is relevant to decision-making relating to GM technologies. Consultation depends on informed publics, the circulation of knowledge within communities and critical debate informed by that knowledge. (RSNZ Submission, Part B, paragraph 77)

C. Health applications of GM technologies and nutriceuticals

7. There is evidence that citizens in Aotearoa/New Zealand and elsewhere are more positive about the health applications of GM technologies than they are about GM crops and foods. There are concerns about the environmental impact of GM crops (which may be produced for export rather than local consumption) and about the health impacts of GM food produced in Aotearoa/New Zealand and elsewhere. (RSNZ Submission, Part B, paragraphs 110, 111(a))

8. The higher acceptance of health applications of GM technologies is linked to perceived levels of control with respect to food, diagnostic and treatment regimes. Consumers may accept pharmaceuticals derived from GMOs (e.g. hepatitis vaccine and insulin), but avoid GM foods. (RSNZ Submission, Part B, paragraph 110) (RSNZ Submission, Part B, paragraphs 101, 111)

9. The submission argues that the positive and negative effects of GM foods on human health cannot be ascertained for many years. Currently food producers submit documented evidence of their food testing procedures to the Australia and New Zealand Food Authority (ANZFA) for assessment. There is a need to go beyond assessing submitted supportive evidence. (RSNZ Submission, Part B, paragraph 113)

10. Nutriceuticals are foods produced for therapeutic purposes using GM technologies. For example, attempts have been made to use GM technologies to modify certain fruits so that they act as vaccines. Nutriceuticals should therefore be treated as both pharmaceuticals and foods. (RSNZ Submission, Part B, paragraphs 115 -116, 155)

11. In particular we would like to highlight the following:

ANZFA should have the investigative capacity to check on the adequacy of evidence submitted by food producers relating to their testing procedures. (RSNZ Submission, Part B, paragraph 113)

Nutriceuticals should be covered by the Medicines Act 1981, particularly Section 4 of the Medicines Act that defines the concept of ‘therapeutic purpose’ and prescribed so that contraindications can be identified.

Nutriceuticals should be clearly labelled and their distribution regulated.

Nutriceuticals, like medicines, should be subject to the scrutiny applied to products for which therapeutic benefits are claimed. (RSNZ Submission, Part B, paragraph 116)

D. GMOs and land based production of food, fibre and nutriceuticals

12. Consumer resistance to genetically modified foods is most evident in markets with high numbers of well-educated consumers who can exercise choice with respect to what they eat. Consumers increasingly require information about the content of food and how it has been produced. For this reason we support the labelling of all GM foods, whether they originate in New Zealand or elsewhere. (RSNZ Submission, Part B, paragraphs 101, 110, 132 - 134)

13. Genetically modified organisms and their commercial promotion by global producers could intensify the trend towards the loss of genetic diversity. This trend is not solely a consequence of GM technologies. However, these technologies are part of a focus on technological solutions rather than good management of food production. (RSNZ Submission, Part B, paragraphs 118 - 121)

14. Consumer resistance to GM foods in certain markets could lead to diminished markets for NZ crops. A variety of economic models has been used to assess the likely impact of the introduction of GM technologies in land-based production. This submission draws on a trade model developed at Lincoln University that examines the implications for New Zealand's strategies in overseas markets. Preliminary findings from this model indicate that economic returns from GM technologies in this field might not be favourable to Aotearoa/New Zealand. (RSNZ Submission, Part B, paragraphs 122 - 123)

15. Some food producers in Aotearoa/New Zealand could find that their foods are rejected in international 'green' markets if producers cannot guarantee that they are GM free. Pollen pollution, reduced effectiveness of pest control strategies and increased compliance and testing costs could also lead to reduced economic performance of enterprises involved in crop production using organic and integrated pest management. (RSNZ Submission, Part B, paragraphs 52 - 55, 158)

16. In particular we would like to highlight the following:

We support recent efforts to label GM food and provide consumers with opportunities to choose their own food supplies. (RSNZ Submission, Part B, paragraphs 101, 110, 132 - 133)

The potential negative impact on other food producers should lead to caution with respect to the commercial release of GMOs for in the land-based production. As an island nation, Aotearoa/New Zealand has the capacity to maintain a GM-free status and take advantage of international preferences for GM-free food in high-value developed markets. (RSNZ Submission, Part B, paragraphs 52 - 55, 158)

The HSNO Act (1996) should be strengthened to require ERMA to take account of the social, economic and cultural effects of importing, developing, testing and releasing GMOs. This should involve adding the phrase ‘the social, economic and cultural effects of new organisms’ as Section 6 (g) of Part 11 of the Act.

If GMOs are approved for use in commercial production, the corporations using these technologies should meet the costs of responding to any negative effects of the release of GMOs. The relationship between ACC and any other compensation agreements should be clearly articulated. (RSNZ Submission, Part B, paragraphs 64, 68, 70)

A system for controlling the release of GMOs should be developed before approval is given for the commercial release of any GMOs for land-based production This should include the regulation of the method of release, strategies used to diminish gene transfer and assessment of the impact of these processes at different stages of the implementation of these technologies. (RSNZ Submission, Part B, paragraphs 64 - 71) This will require a review of the HSNO legislation.

Monitoring of the impact of the release of GMOs should be done by independent researchers and facilitated by ERMA.

E. Research and decision-making

17. Public good funding for GM biological research should be complemented by funding for research into the social, cultural and economic issues relating to these technologies. This involves using the expertise of social scientists generally, and Maori researchers in particular. (RSNZ Submission, Part B, paragraphs 24 — 26, 73 - 91, 97 — 99, 104 —109, 122 — 134, 151)

18. A component of such research should involve attention to public attitudes to GM technologies and how different sections of the population respond to information about these technologies and their applications. Decisions by ERMA, ANZFA and the Genetic Technology Advisory Committee of the Health Research Council should be informed by knowledge about community acceptance of different applications of GM technologies and their perception of the risks of such applications. (RSNZ Submission, Part B, paragraph 105)

19. Recent decisions by the Foundation for Research, Science and Technology to invite and accept tenders for research into the potential key effects of genetically modified organisms are welcomed. The composition of committees making decisions about such tenders, and the processes involved in selection, should be open to public scrutiny.

20. As a small nation, Aotearoa/New Zealand can do little to influence world events on its own, and biotechnology development is an international phenomenon. In the light of this, Aotearoa/New Zealand should be involved in a variety of international initiatives directed at addressing issues associated with science generally, and genetic modification in particular. (See for example, the UNESCO International Bioethics Committee and international conferences on the social, economic and political issues associated with scientific research and its applications such as the World Conference on Science) Biological scientists, government officials, politicians, social scientists and those with expertise in tikanga Maori should be a significant presence at international gatherings when the cultural, economic and political dimensions of science are being discussed. Those attending such gatherings could contribute to further discussion and debate in Aotearoa/New Zealand through forums facilitated by New Zealand science agencies. (RSNZ Submission, Part B, paragraphs 21, 159)

21. In particular we would like to highlight the following:

Public good research funding should be increased to meet the costs of more extensive research into the effects of GM technologies. This should include research into the development of better procedures for participation by Maori and non-Maori in decision-making about GM research and GM technologies. (RSNZ Submission, Part B, paragraph 19, Recommendation 4)

Decisions on public good funded research applications that have implications for the community should include experts in the field, government officials, Maori representatives, and representatives of other community-based stakeholders. The decision-making processes should be open to public scrutiny.

New Zealand biological scientists, officials, politicians, social scientists and those with expertise in tikanga Maori should be a significant presence at international gatherings where the cultural, economic and political dimensions of science are discussed and contribute to public forums on these issues when they return. New Zealand has taken a leading role on the international stage with respect to climate change. It could also take this role with respect to genetic modification technologies.

New Zealand science agencies should facilitate a range of forums for people in the social sciences, Maori studies and the biological sciences to consider national and international issues relating to genetic modification technology and its applications. (RSNZ Submission, Part B, paragraphs 21, 159)

F. Community Participation

22. There is public concern about GM research, the effects of field trials and the commercial release of GMOs. Improving mechanisms for public participation in decision-making about the use of GM technologies would be one way of improving people’s sense of control over the risks involved in this field. (RSNZ Submission, Part B, paragraph 156)

23. More emphasis on consultation and decision-making at a local level could provide communities with a better sense of control over the use of GM technologies in their environment. (RSNZ Submission, Part B, paragraph 157)

There are also benefits to be gained from universities and Crown Research Institutes formalising relationships with members of their local communities who have an interest in genetic modification or are concerned about the actions of biological scientists. The community advisory councils used by Land Grant Universities in the USA could provide a model for similar strategies in Aotearoa/New Zealand. (RSNZ Submission, Part B, paragraphs 19, 144, 148)

25. In particular we would like to highlight the following:

Consultation and decision-making at a local level could provide communities with a better sense of control over the use of new technologies in their environment. This should include consultation with local hapu and iwi. (RSNZ Submission, Part B, paragraph 157)

Community advisory councils used by Land Grant Universities could be the basis for similar strategies for public participation in Aotearoa/New Zealand (RSNZ Submission, Part B, paragraphs 144, 148)

The ERMA regulatory framework should be strengthened to include aspects of their current consultation policy. This consultation policy and its implementation in particular contexts should be regularly reviewed by an external body co-ordinated by the Ministry of Research, Science and Technology.

G. Information transfers

26. Change with respect to application of GM technologies is occurring very rapidly. It is difficult for citizens to access and understand the implications of these scientific developments. The government has a responsibility to see that citizens are informed about debates in this field if it wants to facilitate processes of consultation and ensure that decisions by publicly funded committees, agencies and authorities are acceptable to citizens. (RSNZ Submission, Part B, paragraph 149, 153 Media)

27. It is important that any process of information transfer or public education about GM technologies and their commercial application should not assume an 'ignorant' public whose 'hysteria' is to be countered by compelling scientific evidence. (RSNZ Submission, Part B, paragraphs 24, 104 - 106) Exposure to the complexity of the GM debate, and opportunities for people to consider the principles for determining risk, is better strategy for presenting information and arguments than bland reassurance.

28. In particular we would like to highlight the following:

Scientists should use mass media outlets more frequently to communicate what they are doing as simply and directly as possible.

Forums should be established for sharing information on genetic modification technologies and their application. They should include government agencies and authorities, research institutions and media organisations.

The current web-site of the Royal Commission on Genetic Modification should continue to present information about gene technologies, their applications and the regulatory regimes associated with these technologies after the Commission has presented its findings. This initiative should be properly resourced and administered by an appropriate science agency.

Publicly funded hard copy sources of information about GM technologies, the variety of ways in which these technologies are applied, and cultural, economic and political issues in this field should be widely distributed. This should be implemented by the agency responsible for the web-site on Genetic Modification. (RSNZ Submission, Part B, paragraph 153 Media)

H. Conclusion

29. We argue that Maori have particular concerns about GM technologies since they involve the modification of the whakapapa of living organisms. These concerns are particularly strong with respect of indigenous flora and fauna. Commitments under the Treaty of Waitangi require that Maori have a particular role in decision-making with respect to decisions about GM research and the applications of GM technologies. (RSNZ Submission, Part B, paragraphs 80-91)

The ethical and political concerns of individuals and communities and their perception of risk must be a component of decision-making relating to the application of these new technologies.

31. There is a need for caution with respect to the commercial release of GMOs for land-based production of food, fibre and nutriceuticals. Overall a more investigative approach to the testing and monitoring of the social/psychological, physical environmental and economic impacts of GM technologies is recommended.

32. Resources should be made available for the continuing distribution of web-based and hard copy information about GM technologies.

Health applications of GM technologies can be distinguished from their applications in the production of foods and require different forms of regulation.

Nutriceuticals using GM technologies should be regulated as medicines through the Medicines Act 1981.

35. Aotearoa/New Zealand should be involved in a variety of international initiatives directed at addressing issues associated with science generally and genetic modification in particular.

36. Finally, it is important that 'science' and 'cultural values' should not be seen as mutually exclusive systems of thought. The process of producing science and advancing knowledge involves values and assumptions about what counts as knowledge, as well as social relationships and economic transactions. Claims about both 'science' and 'culture' should be the subject of critical scrutiny by physical, biological and social scientists as well as health, food and environmental activists, governments, politicians and those with expertise in tikanga Maori. This is particularly important when we are involved in discussions about life changing technologies such as genetic modification.

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