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The Royal Commission on Genetic Modification - submissionsUNESCO's New Zealand National CommissionSTRATEGIC ISSUES & OPTIONSSubmission UNESCO's New Zealand National Commission (UNESCO) submitted that failure to be responsibly involved in the introduction of genetic modification (GM) technology would be economically disadvantageous. It may also, in UNESCO’s opinion, deny adequate nutrition to the hungry. People in developed nations with good incomes have choice, those in developing nations do not. Furthermore, if biodiversity is maintained, the environment enhanced, productivity increased and safety ensured as a result of field trials, monitoring and adherence to accepted regulatory norms then failure to use knowledge appropriately for the benefit of humankind is irresponsible. Exercising the choice has to be based on sound scientific evidence and accurate information.
However, they also submitted that it is important to distinguish between genetic modification (GM) technology applications with strong containment processes and large-scale introduction of genetically modified organisms (GMOs) into the environment. For the first category, it is already demonstrable that the benefits outweigh the risks. For the second category of large-scale genetic technologies that may be released into the environment or consumed by the public, then the risk/benefit balance seems less certain and progress towards these should be more cautious.
UNESCO then noted that New Zealand was in a relatively advantageous geographic position to manage the introduction of some forms of GM technology. Monitoring unauthorised introductions, however, itself requires sophisticated GM technology. Therefore, GM technology and concomitant understanding needs to be part of New Zealand’s core research competency. Furthermore, although caution in the introduction of large-scale genetic technology may give New Zealand market advantage for its agricultural products it would still be necessary to maintain high-level expertise at laboratory level to enable rapid re-assessment of the situation. In some areas, for example in timber development delay in accepting technology could have serious consequences.
LAW & LEGISLATIONSubmission Liability UNESCO noted that failure to use the beneficial technology available internationally could expose the Government or Health Providers to significant liability. For example, failure to introduce Hepatitis C testing when it was first available internationally has resulted in a significant claim. Denying New Zealanders access to the best available cholera vaccine when it was available for purchase in a significant number of countries could have resulted in liability claims. However, premature introduction of new technology could have similar consequences.
Intellectual property UNESCO stated that they support wider access to genetic. However, it was recognised that protection of intellectual property in relation to process development/application may be required for return on investment, particularly in an environment where the Government is limited in its support of research. They then noted that the IBC (1999) has observed that free access does not "exclude the possibility of patenting the results of genome research." UNESCO, however, draws the distinction between inventions, which may be patented, and discoveries which cannot. They acknowledged that has become increasingly difficult to establish such a clear dividing line between the two.
Regulation UNESCO submitted that while the existing legislation and regulations, as applied by the Environmental Risk Management Authority (ERMA) seems to be effective, the compliance costs may be inhibiting research. There may be a case, therefore, for a less stringent and less expensive regime in low-risk, contained situations. It is also UNESCO’s opinion that it is vital that any legislation which deals with GM humans or the use of embryos should be consistent with the principles of genetic research and other existing and ethical and safety requirements. They then outlined current ethical regulation in New Zealand. This review was concluded with the statement that some progress, in respect to the ethics of GM in humans, is being made with the review by the Ministry of Health of the National Standard for Ethics Committees. In their opinion, it is vital that this review be satisfactorily concluded so that the public can have confidence in the ethical review of genetic research involving human subjects.
RISKS & BENEFITSSubmission UNESCO's position is that if GM technology cannot be forgone if it can lead to:
At the same time investigation of any risk to biodiversity must be examined.
UNESCO then submitted that scientific research involves evaluating the risks and benefits. They then noted that the public would prefer guaranteed certainties or even zero-risk. This, however, is an unrealistic goal in biological systems. UNESCO then stated that at the level of large-scale release into the community, the application of this technology is still questionable. Accumulation of knowledge through further research in controlled conditions and open access to information should reduce the level of uncertainty and apprehension and lead to better decision making by politicians.
This submission noted that public confidence in field trials has been damaged by secrecy and inadequate safeguards which have led to reports of unforeseen consequences. Unauthorised or accidental introduction of GM material or organisms is a possibility even in New Zealand and the Government needs to plan and fund monitoring initiatives. Furthermore, the possibility, by inter-species transfer, of introducing new allergens into products previously considered non-allergenic must be carefully considered and is an important factor when detailed labelling of genetically modified foods is debated. The alternative that it is likely that some products known to contain allergens may be genetically altered to remove the allergen.
ETHICAL, CULTURAL & SOCIAL ISSUESSubmission UNESCO submitted that greater attention must be paid to ensuring the public are better informed through public education and inclusion of bioethics education in curricula. Consultation with both community groups and Maori should be open and respectful, acknowledging the importance of cultural diversity. However, they noted that failure to embrace GM technology might have a detrimental effect on the application of GM technology to health and well-being.
UNESCO then cited Article 1 of the Declaration on the Human Genome and Human Rights. This states that the human genome underlies the fundamental unity of all members of the human family, as well as their inherent dignity and diversity. In a symbolic sense, it is the heritage of humanity. This Article is interpreted by UNESCO as expressing the uniqueness and value of human life and that to condone or allow cloning or the selection of the human being that is to be born according to prior objectives is morally objectionable. Furthermore, it is probably important for a distinction to be made between therapies which affect somatic cells and those which affect germ cells where the former can have no effect on the common heritage of mankind while the latter may.
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