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The Royal Commission on Genetic Modification - submissionsSoil and Health Association of New Zealand Inc.STRATEGIC ISSUES & OPTIONSSubmission The Soil and Health Association of New Zealand Inc (S&HA) submitted that the use of GM crops and foods is contrary to sound science and the laws of New Zealand. In their opinion, it relies on the systematic deception of the public and their political representatives. It also poses unacceptable hazards to consumers, the organic movement, and the environment while draining financial resources. It is their contention, therefore, that only a complete and permanent ban of GM foods will adequately curtail the inherent hazards. The nation’s precious resources could then be redirected from a high-risk, low-benefit technology to organic technologies that are safe, sustainable and life supporting on all levels.
LAW & LEGISLATIONSubmission Regulation It was the contention of the S&HA that tests for known toxins and animal toxicity tests have proven inadequate to identify potential harmful side effects of GM foods. Current tests include 90 day toxicity tests using rodents. This form of testing is inadequate to assess the effect of novel foods on human health. Additionally current testing regimes, including those relied on by ANZFA and ERMA, look for specific known toxins. Completely new toxins, allergens, and carcinogens, not previously encountered, are likely to be produced by novel foods, so testing for known toxins, will not be adequate to detect all possible harmful side effects. It was their submission, therefore, that to protect public health, full spectrum toxicity testing and long term human trials should be required. Food should be proved safe before it is released for sale.
The S&HA also noted that ANZFA regulations do not contain provisions for independent testing of the safety of novel foods. ANZFA relies on the assessments and submissions provided by the manufacturers and regulators in the country of origin of the novel foods. In their opinion, this process is open to abuse. For example, manufacturers have commercial reasons for hurrying their products to market and may cut corners with safety testing and assessment. In the S&HA’s opinion, demonstrably independent testing procedures should be a required element of the approval process.
Labelling It was also highlighted that current labelling regulations allow many food ingredients, additives, processing aids, and chemicals derived from genetic technology and used in human and animal foods to be exempted from labelling. However, it is their contention that in order to promote confidence, consumer choice and safety all foods should be labelled with complete information on all ingredients, processing agents, and methods whether they are genetically modified or not. Traceability would, therefore, be an absolute requirement. Furthermore, it should be a requirement for the relevant New Zealand government departments to publicise the ANZFA deliberations and seek public submissions before formulating a position on this issue. The S&HA also recommended that ERMA, ANZFA, the Codex, and other regulatory bodies are made responsive to consumer wishes by mechanisms such as referenda on acceptability of biotechnology, consumer surveys, and genuine consumer representation on its committees.
Liability Limited liability laws should also be extended to make the product inventors, employees, and directors of such companies personally liable for health-damaging effects of products where they are suspected or already known. This is because currently, limited liability statutes make it possible for companies to continue to manufacture of products that they know to be unhealthy or risky. Often, when side-effects of foods or other products come to light, years have elapsed. The original companies selling the products are no longer operating and therefore no one can be held responsible.
RISKS & BENEFITSSubmission Dr. John Clearwater described the proposition of controlling leaf roller in apples through the introduction of the avidin gene. Avidin is an extremely effective inhibitor of biotin- requiring-reactions. Leaf-rollers that eat tissue expressing the avidin gene would eat a dose of avidin that would bind biotin and prevent the leaf-roller from carrying out normal metabolic function. The metabolically impaired leaf-roller would then die. Avidin is also toxic to humans and therefore the avidin gene would need to be modified so that it was only expressed in the leaves. However, it was then noted that leaf-rollers will migrate to the crevices between the apples and eat apple flesh. Because of this, and the threat of toxicity to humans, the project was rejected by the New Zealand Apple and Pear Marketing Board. In the opinion of Dr. Clearwater this project showed a profound lack of knowledge of the toxicity of the new component that could have been found in any biochemistry text. GM crops already commercialised were stated to have been associated with increased use of herbicides rather than less. Crops that produce their own pesticides were seen by the S&HA as posing an additional health risk. They should be banned immediately. It was also submitted that Bt genes in plants will expose humans to higher concentrations of Bt and more frequently than before. This may generate health hazards including allergic reactions or other more serious illness. In support of this contention S&HA cited the purported effects of Bt spraying in the Auckland area in response to the white spotted tussock moth. Residents reported a variety of allergic reactions including headaches, nausea, skin rashes, itching, breathing difficulties, and burning soreness of the throat and lungs.
As in other submissions the argument that GM technology would ‘feed the world’ was challenged. In the opinion of the S&HA there are many avenues for research into sustainable development that should be funded by government as an alternative to funding research into biotechnology in agriculture. The issues surrounding allergenicity, novel toxins, and cross-pollination were also discussed.
Further comment The avidin project was only a suggestion. There is a proposition, that proposition is discussed by scientists and other stakeholders, the risks and benefits are examined, and the project is either approved or discarded. In the case of avidin it was simply that the risks outweighed any possible benefits and the project was therefore rejected. This is not, therefore, and example of why GM technology should be banned. It is in fact an example of a participatory and responsive regulatory system actually working.
ECONOMIC ISSUESSubmission The resistance to GM crop plants in certain markets and the increased sales of organic produce were also outlined in this submission. This has been extensively dealt with in previous submissions and will not be revisited in this summary. Of particular note, however, was Dr. Clearwaters’ submission that organic apples are currently fetching substantial premiums on the international market place. In Dr. Clearwaters’ opinion, these returns are threatened by the field release of GM apples. The value organic apples has been demonstrated and it is unacceptable, in his opinion, that unproven promises in respect to GM technology will be allowed to threaten this.
ETHICAL, CULTURAL & SOCIAL ISSUESSubmission Dr Klaus Bosselmann, an Associate Professor of Law, submitted that science is neither objective, nor value-free. It is shaped by the humanist tradition of modernity which separated science from arts/humanities and focused on the pursuit of material benefit for humanity. This anthropocentric approach has profound ramifications for the research and development of GM. One aspect is, in his opinion, the almost complete absence of an overall ethical code that respects human life and the environment. He then stated that scientists believe that the findings of science are ethically neutral, but the practice of science is not. The practice of science should therefore be regulated. However, society has not been very effective in providing such governance for new technologies. Its responses have been reactive rather than proactive. The desire for quick review, quick implementation, and quick reward has led to an exaggeration of the benefits and a denial of risks.
He then went onto discuss a change in focus from the above mentioned anthropocentric approach to one that is evident in documents such as the Biodiversity Convention. The trend is now towards the recognition of the intrinsic value of nature and respect for life in all its diversity. However, as the new ethic fundamentally challenges the prevailing tradition, governments are reluctant to review and revise regulations, statutory controls, intellectual property law, property rights and consent procedures. Furthermore, the enormous pressure of industry and industry-driven GM research is a further factor explaining this reluctance. There are no indications, at present, that governments are committed to an ethically informed legal framework to guide GM.
In his opinion, for such a framework to emerge much more is necessary than, for example, an investigation by the Royal Commission listening to the various groups and then concluding who is right and who is wrong. As New Zealand with its key stakeholders in science, business and agriculture stand in the tradition noted above the weaker voices of the new ethic - environmental groups, organic movement, environmental philosophers, environmental lawyers, Maori, churches - are bound to be drowned by the professional chorus convinced that ethical problems can be sorted out within the existing paradigm of progress and anthropocentrism.
Dr. Bosselmann also argued that the precautionary principle requires a shift of the burden of proof onto those who argue that a proposed activity will not cause significant harm. Furthermore, the responsible parties should be held liable for environmental harm. He then suggested consideration of the formula "respect for life" as a starting-point for political debate. The three elements of this formula could be expressed as follows:
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