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The Royal Commission on Genetic Modification - submissions


The Safe Food Campaign

STRATEGIC ISSUES & OPTIONS

Submission

The Safe Food Campaign (SFC) believes that the utilisation of genetic modification (GM) does not provide the opportunity for a ‘no regrets’ approach due to the level of scientific uncertainty surrounding GM and potential for harm that may eventuate from it. They then state that in order to prevent harm from occurring, rather than manage the risks once harm has occurred, New Zealand should not utilise GM as a strategic option. As an alternative strategic option the SFC supports New Zealand becoming a GM-free zone and an organic nation.

The SFC states that the benefits of this approach are the following:

    • Very few problems eventuating from GM foods or the release of genetically modified organisms;
    • Enhanced economic gains from the premiums gained from organic markets;
    • Environmental benefits such as balanced soil micro-organisms and reduced chemical run-off;
    • Food free from chemical residues.

On the other hand if GM food leads to large-scale health problems, and GMO's to serious environmental problems, New Zealand will still have chosen the best option. New Zealand would have taken precaution and prevented these problems from developing here. In this way the 'no regrets' approach would mean that whether long-term detrimental problems from GM eventuate or not, New Zealand would reap benefits from becoming an organic nation.

Specifically, it is the SFC’s opinion that New Zealand should:

    • Not allow any releases of GMO's into the environment;
    • Cease participation in the development and testing of GMOs;
    • Cease importing GM foods, and products produced using GM technology;
    • Cease importing meat and (products that include meat) from animals fed GM foods;
    • Not produce foods which include GM ingredients and products produced using GM technology:
    • Oppose the patenting of life and life forms.

RISKS & BENEFITS

Submission

The SFC submitted that GM technology defies traditional risk estimates as both the probability of occurrence of harm and level of possible harm are unknown. Ulrich Beck is stated as proposing that the incalculableness and the globe threatening nature of genetic modification means that GM, like chemical and nuclear technologies, is a mega-hazard. These mega-hazards defy the risk management systems constructed with industrialisation, and demand a new system of management. The Safe Food Campaign therefore believes that in light of the 'scientific uncertainty' surrounding GM, NZ should refrain from utilising these technologies.

The idea that the current testing procedures carried out by ANZFA have the ability to prove these foods are safe was rejected by the SFC. In particular, they were concerned that ANZFA can allow the entry of these foodstuffs into New Zealand without the brief to consider the ramifications of the development of these products. They also highlighted the lack of independent testing, the limitations of allergen and toxicity tests and, question the merits of substantial equivalence as a method of testing GM foods.

In respect to possible environmental problems the SFC highlighted the following issues:

    • The increased use of herbicides due to the introduction of herbicide resistant crop varieties. Such wide spraying may have adverse effects of the flora and fauna of New Zealand;
    • The possibility of reduced diversity;
    • Adverse effects in repsect to ‘superweeds’ and horizontal gene transfer;
    • The difficulties in repsect to pollen transfer and the protection of conventional and organic crops;

LAW & LEGISLATION

Submission

It is the SFC’s contention that the imposition of insurance for the environmental threats posed by GM technology is impractical. No bond can be held, nor insurance policy taken out against such threats that retains any meaning. This is because insurance companies would be faced with calculating incalculable global risks, it is practically impossible to calculate the financial value of damage, and financial compensation would achieve very little in respect to the possible damage caused by GM technology.

The SFC then stated that it was opposed to the patenting of life forms. The then noted the possibility that through bio-prospecting and bio-piracy the intellectual property rights of our indigenous fauna and flora being held off-shore. They also submitted that signing the Trade Related Intellectual Property (TRIPs) agreement and General Agreement on Trade and Tariffs (GATT), is contrary to Te Tiriti O Waitangi. This is because the global flow of resource has the potential for the exploitation of Maori customary knowledge. For example, Bevan Tipene-Matua describes how despite indigenous peoples leading researchers to traditional medicines from which drugs are derived, less than 0.0001 percent of the profit from these products goes back to the indigenous peoples.

In respect to GM technology, they believed that this problem was exacerbated by the centralised control of GM technology products through a few powerful biotechnology companies. Furthermore, despite the establishment of Nga Kaihautu, and consultation with Maori, Maori perspectives continue to be marginalised in ERMA application decisions. Maori have not been granted their rights under Te Tiriti O Waitangi in being able to stop what Maori see as applications for inappropriate use of Maori intellectual and cultural property.

The SFC rejects the notion that the GM food labeling being introduced by ANZFA will provide 'consumer choice'. This is because the exemptions allowed under the proposed standards would mean, for example, that oil produced from GM soya beans will not be labelled as genetically engineered. Neither will meat and dairy products from animals fed GM crops, such as chicken fed GM corn, be labelled as genetically engineered. Also, the restriction of labelling to food only means that medicines, such as antibiotics raised in GM yeast and vaccines, will not be labelled as genetically engineered. Neither will vitamins, clothing and materials, or cosmetics, such as corn or soya in lipstick, be labelled GM even if genetically engineered. It will be difficult, therefore, for consumers to avoid genetically engineered products and ingredients, even if they purchase according to the new labelling system.

ECONOMIC ISSUES

Submission

The SFC believes that due to recent developments in the global food markets New Zealand would be wise not to utilise genetic modification in food production. Consumer aversion to GM food, and a growing demand for alternatives has led to lower returns for some GM crops and increased premiums being gained from some non-GE crops. In contrast to this movement some sectors are benefiting. For example, Australian farmers recently gained an extra $US 750 000 on 150 000 tons of Canola, because it was not genetically engineered (Reuters, 2000).

Part of this movement is the growing organic markets, and corresponding premiums being fetched for organic produce. It was submitted that this could lead to a price differentiation in foodstuffs. If this pricing trend continues we may have a situation in which organics achieve the highest premiums, followed by non-GE crops and the cheapest foodstuffs being genetically engineered. New Zealand should therefore attempt to produce for the affluent organic markets and consequently prevent the use of GMO’s.

SOCIAL & ETHICAL ISSUES

Submission

The SFC highlighted political and social difficulties in respect to GM technology. In their opinion , GM crop technology was not a revolutionary agriculture: it does not represent a new or bio(revolution) but merely extends the agro-chemical industrialised structural relationships set up by the green revolution. They viewed GM crop technology as a reductionist science that did not take a holistic approach to the issues surrounding current agriculture. The SFC stated, therefore, that they were ethically opposed to the reductionist science of GM.  Furthermore, they opposed to the expanded reliance of farmers on agro-chemical companies, and the continued domination of the industrialised world over the majority world, as embodied within GM of agriculture.  


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