Environmental
and health issues
4.
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4.
Environmental and
health issues
1.
This chapter discusses some of the issues of environmental and health
safety that were raised in the evidence before us. The Commission responds to
these issues in more detail in subsequent chapters of the Report.
2.
Those who thought the ongoing development of genetic modification was
of benefit to New Zealand largely based their arguments on the economic
benefits or disadvantages inherent in a decision either to permit or limit the use of
the technology. Issues of the safety of the technology could not be ignored,
however, and many of the proponents of genetic modification sought to provide
information that would allay public concerns about the risk of releasing genetic
modification, genetically modified organisms and products from laboratory
confinement.
Key questions:
* What are the scientific hazards of gene technology?
* What are the possible impacts on the environment and human health
of uses outside laboratory containment?
* Can gene technology be managed safely?
Concern about the risks
3.
During the course of our consultation, many concerns were expressed
about the risks of gene technology. Some people were so opposed to the
technology for cultural, ethical and spiritual reasons they did not wish it to be
used in any circumstances. The main issue discussed, however, was whether
genetic modification could be used safely in the wider environment or whether
such use should be confined to the laboratory, either for research or for some
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health purposes. Many people said the risks of genetic modification could be
contained within the laboratory where, within reason, its safe use could be
assured. But they submitted the technology was inherently unsafe outside the
laboratory and there was an unacceptably high level of risk associated with its use,
even under field trial conditions.
4.
The belief that risks were unacceptably high reflected submitters'
underlying concerns that negative impacts of uncontained genetic modification
L-Tryptophan
1
L-Tryptophan is an amino acid, one of the building blocks of proteins. Tryptophan is
important for brain function and is normally obtained from dietary protein. In the 1980s
tryptophan became popular as a dietary supplement for such conditions as insomnia and
depression. Tryptophan can be purified from plant and animal proteins, but is obtained more
economically by vat fermentation. In this process, tryptophan-producing bacteria are
fermented in tanks with sugars and a nitrogen source. When the tryptophan levels in the vat
are high enough, the solution is purified by filtration. The bacteria used may be genetically
modified. At the time, several companies, including Showa Denko KK, used vat fermenters
and genetically modified bacteria to produce tryptophan.
Late in 1989, people consuming high doses of L-tryptophan began showing up with
eosinophilia-myalgia syndrome (EMS), a new illness characterised by painful and swollen
muscles, rashes, gastro-intestinal problems and large numbers of white blood cells in the
body. In the United States 37 people died, 1500 were disabled and around 5000 were
affected. These patients were all taking tryptophan from a single Showa Denko KK batch
that used not only a new genetically modified organism producing a more concentrated
product but also a different filtration system using less charcoal, which bypassed a membrane
filtering step to purify the product.
The batch was found to contain 60 contaminants of which six were responsible for causing
EMS. Three toxins (a dimer of tryptophan, along with two others) were identified by 1993,
but it was not until 1999 that the remaining three toxins were identified accurately.
The United States courts decided that the manufacturing process rather than genetic
modification was at fault. It is unclear whether the high concentration of tryptophan made
by the genetically modified bacteria or the changes in the filtering system were responsible
for the build up of contaminants. Attempts were made without success to reproduce possible
faults in the filtration system. At the time, other tryptophan products made using genetically
modified organisms were available on the market, but no problems were reported with them,
suggesting that the use of genetically modified organisms alone was not to blame.
Although the first cases of EMS were not notified until late 1989, by early 1990 the Food
and Drug Administration had recalled all dietary supplements containing manufactured
L-tryptophan.
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may be irreversible and rapidly get beyond control. These concerns are addressed
throughout this Report: for example, discussion on the invasiveness of genetically
modified organisms (paragraphs 51­57 of this chapter), xenotransplantation
(paragraphs 61­72, chapter 9: Medicine), possum control (paragraphs 104­114,
chapter 7: Crops and other field uses) and genetically modified forests (paragraphs
70­77, chapter 7).
5.
For many who opposed the use of genetic modification outside the
laboratory, especially in relation to food and food supplements, the events
surrounding L-tryptophan (see page 43) illustrated the dangers of the technology.
6.
The L-tryptophan disaster was used frequently by submitters to illustrate
many of the aspects of genetic modification that caused public concern: the
inherent unpredictability of gene technology; the potential for widespread and
significant harm; the difficulty of implementing regulatory controls and standards;
the lack of integrity by the companies that use gene technology; the need for
dietary supplements to undergo the same vigorous testing as medicines; and
problems associated with establishing liability for harm. Mere McGarvey (Tuhoe),
speaking at the hui at Poho-o-Rawiri, Gisborne, said:
We want to say that we do not oppose genetic modification in general, but wish to remind
everyone here and the Royal Commission that technology out of control is potentially
intolerable and dangerous and could lead to calamitous consequences.
2
7.
Since no direct link was established between using genetic modification in
the production of the dietary supplement and eosinophilia-myalgia syndrome
(EMS), the incident cannot be taken as clear evidence of the inherent risks of
genetic modification or the need to prohibit the use of genetic modification
outside laboratory containment. There are, however, some useful lessons. For
example, the short time it took the United States authorities to withdraw the
product in question illustrates the need for such authorities to maintain the ability
to respond rapidly to indications of harmful effects. The length of time it took to
identify accurately all the toxins responsible for the harm, however, highlights the
need for ongoing research into the hazards of the technology.
Scientific risks
8.
Many submitters spoke at length about their concerns regarding the risks
of genetically modified organisms escaping into the environment. They were
concerned that such escapes could lead to the production of new pests and
pathogens, to "super weeds" or to disturbance of the natural ecology. The risk of
escape, however, depends on factors such as the nature of the organism and its use.
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For example, there are different risks associated with a weakened bacterial strain
used within a containment laboratory, a caged transgenic mouse, a transgenic
sheep or cow in a secure enclosure and a genetically modified crop capable of
producing fertile genetically modified pollen and seeds.
9.
Humans have traditionally developed crops and animals with improved or
desired characteristics by methods of systematic selection and breeding which
ensure that strains displaying the desired characteristics are retained. Those that
do not are discarded. This deliberate engineering of crops and animals has been
seen as benefiting human society and has therefore been accepted. Occasionally
natural mutations of genes or chromosomes have occurred that have been
deemed desirable and these too have been retained.
10. More recently, radiation mutagenesis has been used to create new plant
varieties. Radiation mutagenesis causes chromosome breaks and rearrangements,
or deletions. We were told by Dr Johannes Wirz, a senior scientist at the research
institute at the Goetheanum in Dornach, Switzerland, and a witness for Bio
Dynamic Farming and Gardening Association in New Zealand [IP61], that the
dose of radiation given is usually enough to cause between one to three breaks per
chromosome. Other evidence, however, suggested that the genome could be
completely rearranged as a result of gamma irradiation.
3
Extensive outcrossing
of variants created by this technology has occurred, but there was no evidence that
concerns about radiation mutagenesis were equal to the level of concern over the
use of genetic modification. The development of desired characteristics through
the application of genetic technology was not, we were told, so readily acceptable
because of the nature and extent of the risks associated with the technology.
11. If manipulation of genetic characteristics by traditional means has never
been perceived by the public as having the same level of risk as genetic
modification, and if there is not the same concern about radiation technology, the
public perception of risk from transgenic crops and animals must arise from the
nature of the artificial genetic changes.
Risks associated with the gene construct
12. Each genetically modified organism contains a "gene construct", which
confers the required characteristic. A construct consists of some or all of the
following DNA sequences, each of which may carry different risks:
*
vector sequences (from viruses, bacteria or plasmids), to aid incorporation
of the new genes into the organism's genome
*
promoter sequences (such as the 35S promoter from cauliflower mosaic
virus), to switch on the transgene in the genetically modified organism
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*
selection marker genes (such as antibiotic resistance genes), to enable the
transgenic organisms to be identified
*
the new gene that confers the desired characteristic to the genetically
modified organism.
Vector sequences
13. The major perceived risk arising from the use of DNA from viruses or
other microorganisms as transgenic vectors is the possibility of the generation of
new diseases through recombination of the vector sequences with DNA from
known pathogens. Dr Robert Anderson, a retired scientist with the Physicians
and Scientists for Responsible Genetics New Zealand [IP107], wrote:
Genes, like viruses, can infect the body, which should warn of the potential risks of
transgenic organisms serving as a reservoir for new diseases and as a medium for the
evolution of new pathogens because of their altered physiology and biochemistry.
4
14. Dr Mae-wan Ho, Visiting Reader at the Open University in the United
Kingdom, speaking by video link as a witness for GE Free New Zealand (RAGE)
in Food and Environment [IP63], described the creation of a new mouse pox virus
by Australian researchers who were trying to make a vaccine for fertility control.
The issue was raised by other submitters as an example of the lack of safety of
genetic modification.
What they did was supply a gene from the protein interleukin 4 into the vaccine, and this
succeeded. It was made from the relatively harmless mouse pox virus, which was used just
as a vehicle to carry egg proteins into the mice. The hope was that the interleukin 4 would
induce the immune system to make more antibodies against the mouse egg, thereby
killing it. When the researchers injected the vaccine into the mice, however, all the mice
died. In fact, this synthetic virus was so lethal that it also killed half of all the mice that
had been vaccinated against mouse pox.
5
15. It is clear that such experimental work requires rigorous containment and
careful controls, but the Commission received no evidence suggesting that the
new virus had escaped from containment or had infected any mice not involved in
the experiment. Unexpected results such as these are a part of and, to some extent,
the purpose of research.
Promoter sequences
16. Another perceived risk was the activation or suppression of other genes by
strong promoters in the modified gene construct, especially when the construct
was inserted randomly into the genome.
17. Some submitters had particular concerns about the use of the cauliflower
mosaic virus promoter (CaMV 35S) to drive the expression of new genes in plants
and animals because of the risk of activation of previously dormant genes. They
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suggested that new diseases might arise, through gene activation or from the
new transgenes with strong promoters jumping within the genome. Dr Mae-wan
Ho said:
CaMV is closely related to human hepatitis B virus, and less closely, to retroviruses such as
the AIDS virus. Although the intact CaMV specifically infects plants of the cabbage
family, its isolated 35S promoter is promiscuous across domains and kingdoms, and is
active in all plants, algae, yeast, bacteria as well as animal and human systems. It can
substitute in part or in whole for promoters of other viruses to give infectious viruses.
It is known to have a `recombination hotspot' where it is prone to break and join up with
other genetic material, hence increasing the likelihood for horizontal gene transfer and
recombination. It has the potential to reactivate dormant viruses, which have now been
found in all genomes, plants and animals included, and to recombine with other viruses,
dormant or otherwise, to create new viruses.
In addition, the fact that it is active in animal and human cells means that, if transferred
into their genomes, it may result in over-expression of certain genes that are associated
with cancer.
6
18. Dr E. Ann Clark, Associate Professor of Plant Agriculture at the University
of Guelph in Canada, speaking as a witness for the Green Party of Aotearoa/New
Zealand [IP83], said:
In GM crops, genes coding for chitinase activity [are] stimulated to overproduce at very
high levels (hyperexpress), typically using the CaMV S35 promoter. The result is the
presence of [a] very high level of chitinase not normally seen in nature. What will happen
to non-target fungi, including mycorrhizae, when residues of a GM crop designed to
hyperexpress chitinase activity is soil-incorporated?
7
19. Dr Robin Ord, genetics consultant and law student appearing for Pesticide
Action Network New Zealand [IP87], saw a political aspect to the debate:
As regards the much discussed cauliflower mosaic virus 35S (CaMV) promoter patented by
Monsanto ­ I believe that the patent for the worldwide use of the enhancer gene that
goes with it is or was owned (at least in part) by Lord Sainsbury, who also happens to be
or have been the UK Minister of Science, and has sat on committees promoting GM foods
... Lord Sainsbury has decided me against GM for the immediate future.
8
20. Dr Daniel Cohen, a plant scientist in the Plant Health and Development
group of HortResearch [IP5], also discussed the concerns about the CaMV 35S
promoter in his witness brief:
Most of the experimental data cited by Ho et al ... is not disputed. It is well known that
viral sequences recombine and on very rare occasions new strains of virus evolve. ...
Horizontal transfer is common among bacteria and transfer of viral and prokaryotic
sequences has occurred during the evolution of plants and animals. What is disputed is
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the extrapolation of data from laboratory experiments under controlled, highly selective
conditions to making claims that under field conditions major environmental and public
health problems will occur.
9
21. Dr Cohen told the Commission that CaMV was present in New Zealand
brassicas and infection rates of up to 50% had been reported. He argued that the
virus had clearly been part of the human diet in Europe, Asia and Australasia for
a considerable period of time and that:
... if ... this virus has a tremendous power to recombine with other viruses and cause
disease in other plants and animals, we might expect some evidence of remnants of the
virus in other organisms. Extremely sensitive PCR tests have been developed to detect
traces of the 35S in foods as evidence of GE ingredients. Such tests would be impossible
if horizontal transfer had taken place.
10
22. In this last sentence, we understand Dr Cohen to be saying that if the 35S
promoter had jumped to other plants and organisms, the test for genetically
modified ingredients would lack reliability. In a letter to the Commission, the
Ministry of Health confirmed that, until recently, New Zealand relied on such
tests for the 35S promoter and the nos terminator sequence to indicate the
presence of genetically modified ingredients from 17 of the currently permitted
genetically modified foods.
Selection marker sequences
23. We noted the concern from some submitters about the use of antibiotic
resistance genes as markers for selection of transgenic organisms. It was suggested
that the use of these markers might increase the spread of antibiotic and drug
resistance genes, leading to new diseases. This fear was summarised on a
workshop summary card from the Whangarei Public Meeting:
The use of antibiotic marker genes (tool of GE) may prove to be dangerous ­ creating
super bugs. GE food plants containing antibiotic resistant marker genes can transfer to
bacteria in the gut making these resistant to that antibiotic.
11
24. Te Runanga o Ngai Tahu [IP41] was also concerned about the use of these
genes:
Can antibiotic resistant genes integrate with the beneficial bacteria in the human
digestive system and develop virile [strains] of harmful bacteria that are resistant to
antibiotics? Who is liable if this happens and we are faced with serious infections that
cannot be treated with traditional antibiotics? The relative speed with which genetically
modified organisms are rushed into the environment without knowing possible future
affects appears to be more "suck it and see" than scientific.
12
25. The Environmental Risk Management Authority (ERMA) published a
discussion paper in December 2000 entitled "The Use of Antibiotic Resistance
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Marker Genes in Genetically Modified Organisms". The summary of this report
suggests that the use of these marker genes has had little or no effect on the
incidence of antibiotic resistance:
The major source of the development and spread of antibiotic resistant microorganisms in
humans is the human use (and often overuse) of antibiotics in both the community and
hospitals. Within hospitals person-to-person transmission is aided if infection control
practices are less than ideal.
Some antibiotic resistant bacteria occur naturally in the environment but many are a
result of contamination with human and animal excreta in sewage, slurry and manure.
Antibiotic resistance is therefore also acquired through ingestion of resistant
microorganisms from animals or soil contaminating food or water.
13
26. Alternatives to antibiotic resistance genes are currently available and more
are under development. The Advisory Committee on Releases to the Environment
(ACRE) Best Practice Subgroup of the Department of Environment, Transport
and the Regions in the United Kingdom said:
Many selectable markers in common use encode resistance to antibiotics, although a
number of alternative selection systems are available. Possible alternatives include
reporter genes; genes that confer resistance to cytotoxic agents and genes that confer an
ability to utilise compounds that are normally inaccessible.
14
27. Furthermore, post-selection methods for excising the marker genes using
site-specific recombination are being developed.
15
Risks associated with the inserted gene
28. Genetic modification confers a desired trait on a plant or animal. Submitters
who commented on risks associated with the inserted gene sequence were
concerned with the eventual expression of that trait and the risks of the expressed
gene on human health and the environment. Further discussion on this issue can
be found in chapter 7 (Crops and other field uses) and chapter 9 (Medicine).
Horizontal gene transfer
29. Horizontal gene transfer is the transfer of genetic material from species to
species, through the uptake of DNA and its incorporation into a new genome.
Horizontal gene transfer appears to be common between microorganisms, such
as bacteria and fungi. Professor Brian Goodwin, Professor of Biology at
Schumacher College, Dartington, in the United Kingdom, and a witness for
Sustainable Futures Trust [IP51], described the phenomenon in his witness
statement:
There is clear evidence that genes transferred to plants can transfer to soil bacteria and
thence to other plants. This requires that there be DNA sequences in the construct that are
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homologous to those of bacteria. All constructs used in genetic engineering have such
homologies ... Therefore horizontal gene transfer can be expected to occur ... It has
been shown that such transfers occurred from transgenic sugar beet to soil bacteria, as
monitored by the movement of an antibiotic marker gene from transgenic plant material
to a strain of Acinetobacter.
16
30. Professor Goodwin supplied the Commission with scientific references to
show that there are many routes available for such transfer to occur:
Plant material that remains in the field after harvesting can decompose and release DNA
into the soil, where it can be stabilised by adsorption to polymers such as humic acid or
soil particles and then be taken up by soil bacteria by transformation, or directly by the
plants. Bacteria are capable of transferring genes to either closely or distantly related
species, and transfers are known to occur from bacteria to yeast cells to plant cells and to
mammalian cells. All species are therefore genetically linked via horizontal gene
transfer.
17
31. A number of submitters said, however, little is known about how common
the movement of genetic material is between transgenic animals and other species
or of the effects of horizontal gene transfer on soil ecology. Dr A. Neil Macgregor, a
soil scientist from the Institute of Natural Resources, Massey University, a witness
for Physicians and Scientists for Responsible Genetics, described this as an area of
intense current research effort:
Below ground, information about the effects of GE-plants and animals is growing but still
rare and extremely fragmented. There is sufficient evidence to suggest that even in
fragmentary form, that biological mechanisms in soil will likely play a crucial role in the
overview [of] how GE and other production technologies should be developed, if at all.
A living genetically modified plant exists in a tight ecological relationship with the soil
microflora. Although the product of the modified gene (eg Bt) may be exudated from the
live plant, little is known about actual DNA transfer from live plants.
18
What happens to the DNA we eat?
32. The Commission heard many concerns that, through horizontal gene
transfer, genes from ingested genetically modified organisms would be taken up
by the body.
19
Nearly everything we eat contains DNA;
20
in fact, humans consume
between 0.1 and 1.0 g of DNA per day.
21
33. Most of the DNA we eat is broken down into fragments too small to be
functional.
22
This occurs first by food preparation and cooking, and then by
digestion through enzyme and microorganism action, which begins in the
mouth, and continues through the gut.
23
A recent study using sensitive DNA
detection techniques on farm animals fed Bt corn found no trace of Bt-corn genes,
though fragments of natural chloroplast DNA were found in the blood
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lymphocytes of cows and the muscle, liver, spleen and kidney of chickens.
24
Other
similar studies have been unable to detect either transgenic or natural plant DNA
in cow's milk.
25
Investigations into the effects of feeding high concentrations of
DNA
26
to mice have, however, shown that some of this DNA survives digestion.
27
Though most was excreted,
28
some was transported into the white blood cells and
into organs like the spleen, liver and kidney. When pregnant mice were fed DNA,
fragments were found to transfer to foetuses through the placenta.
29
34. These data do not, however, demonstrate that plant DNA can be transferred
to, and stably maintained in, mammalian cells,
30
as there is no evidence to suggest
that these fragments do anything except function as nutrients.
31
35. Experiments have shown that injection of naked DNA into rabbits causes
an immune system response or an allergic reaction.
32
This process is the body's
natural defence against larger DNA fragments passing through the gut barrier,
and is now being used to create vaccines.
33
36. Because DNA is part of all plants and animals, it has always been a part of
the human diet. The body, therefore, is designed to deal with it. Furthermore,
many gut microorganisms are known to carry antibiotic resistance genes and no
problem with transfer to gut epithelial cells has ever been reported.
34
Indeed,
experiments in gene therapy have shown it to be very difficult to introduce genes
into human cells.
35
Nevertheless, more investigation into the effects of substances
entering the body is required, especially with respect to those people with known
gut diseases.
Cross-pollination and outcrossing
37. The transfer of genetic material through cross-pollination or sexual
reproduction within one species was sometimes referred to as vertical gene
transfer. Professor Klaus Ammann, Director of the Botanical Garden, University
of Bern, Switzerland, appearing for the New Zealand Life Sciences Network
[IP24], told the Commission:
The environmental risks of genetically engineered crops have been categorised as follows
(Journal of Molecular Ecology, vol 3, 1994):
1. Invasiveness of the transgenic crop (in the agricultural system as a weed or in natural
habitats)
2. Invasiveness of transgene itself (vertical gene flow through hybridisation with wild
relatives)
3. Side effects of the transgenic products (for instance effects on non-target organisms).
36
38. The risk of the escape of a transgene through vertical gene flow is different
for plants and animals. Plants distribute their pollen and seeds using wind, insects
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and animals (birds eat the fruit, or seeds are picked up on wool or fur). Animals
mate and therefore "contain" their eggs and sperm to a greater extent. Fish
reproduction falls somewhere between these two examples. It would seem to be
easier to contain the outcrossing of transgenic animals than transgenic fish or
plants.
39. The Green Party was concerned about the escape of transgenic fish from
commercial hatcheries. Their submission stated:
One NZ example which has caused concern is the development in containment (until
discontinued in February 2000) of transgenic salmon modified to express extra growth
hormone and thus to grow much faster than natural salmon.
The salmon were being raised in outdoor tanks, with water from a spring circulated
through the tanks and then into the river. Until public concern led to a review of
conditions by ERMA the screens designed to prevent the escape of eggs were not required
to be regularly checked for holes and the mesh size was close to the lower range of egg
size. There is still no way of knowing for sure whether any eggs escaped into the river and
grew into adults.
40
Kaatz's bees
37
Various submitters described a case of apparent horizontal gene transfer of a herbicide
resistance gene into the intestinal microflora of honeybees. The Pacific Institute of Resource
Management [IP84] said:
The German Television station ZDF reported on Sunday May 21, 2000 that a
German researcher found a gene transfer from genetically engineered rapeseed to
bacteria and fungi in the gut of honeybees. Professor Hans-Hinrich Kaatz from the
Institut für Bienenkunde (Institute for Bee Research) at the University of Jena
experimented during the last three years with honeybees on an experimental field with
transgenic rapeseed in Saxony, Germany.
The rapeseed was engineered to resist the herbicide glufosinate. Professor Kaatz built
nets in the field with the transgenic rapeseed and let the bees fly freely within the net.
At the beehives, he installed pollen traps in order to sample the pollen loads from the
bees' hind legs as they entered the hive. This pollen was fed to young honeybees in
the laboratory. Professor Kaatz then took the intestine out of the young bees and
spread the contents on growth medium to grow the microorganisms. He probed the
microorganisms for the pat-gene, the gene that confers resistance to glufosinate. In
some bacteria and also in a yeast he found the pat-gene. This indicates that the gene
from the genetically engineered rapeseed was transferred in the bee's gut to the
microbes.
38
Dr Beatrix Tappeser described this result as a "clear indication of horizontal transfer which
has been, and is still, characterised as highly improbable". This case became a rallying point
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40. The Green Party submission pointed to research using Japanese medaka
carried out at Purdue University, Illinois. Computer modelling suggested
modified fish might displace wild fish by out-competing them for food and by
interbreeding with them. The Green Party said:
Purdue University researchers found last year that a 0.1 percent intrusion of transgenic
fish into a wild stock could bring that population to extinction within 40 generations
where the gene reduces the offspring's ability to survive. They dubbed this theory the
`Trojan gene hypothesis' on the grounds that the gene gets into the population looking
like something good but ends up destroying the population.
41
41. However the public submission from New Zealand King Salmon said it
was hard to predict the impact transgenic fish would make on ecological systems
because testing the transgenics in the wild would require release. New Zealand
King Salmon considered the impact of transgenic fish on the wild population
would depend on the number of escaped salmon, their potential to reproduce and
the potential of the transgene to confer advantage in the wild.
around which the discussions of horizontal gene transfer flowed. However Professor Klaus
Ammann suggested that the results described were far from conclusive. Professor Ammann
stated that he knew Professor Kaatz's work well and was "one of the committee members to
revise his projects". He told the Commission that the research was a long way from being
completed and had never been published in a scientific peer-reviewed journal, although Dr
Tappeser stated, "Professor Kaatz had submitted his research to the science journal, Nature,
but they had refused to accept it". Professor Ammann also considered that there was "no
proof that this ... gene is not coming from normal sources". Under cross-examination from
Greenpeace [IP82], Professor Ammann denied that horizontal gene transfer had ever been
shown to be a significant risk:
There have been at least 100 experiments conducted to prove that there is horizontal
gene transfer from a higher organism like [a] flowering plant to bacteria, and it has
not been proven. And, I must say I am appalled by Greenpeace Europe who, on the
basis of two lines in an announcement of the German TV channel, just made a big
story out of it. I think that's not the way we should proceed ... I can understand
concerns, but I cannot understand blowing up a case which has not been scientifically
proven. ... I think everybody in this room should be concerned about horizontal gene
transfer, but it just simply doesn't occur, you know. And, in many cases, where it
would be really interesting to know it occurs, there have been done lots of
experiments and nothing has been proven, nothing.
39
The scientific world awaits the publication of the final results of Professor Kaatz's research
with interest. Until then, this remains an unproven case of horizontal gene transfer between
a plant and intestinal microorganisms.
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Randomness of gene placement and lack of gene
stability
42. A further risk arises from the method of transgenesis used to create the
genetically modified organism. Genetically modified organisms can be created
by the random insertion of one or more copies of the gene construct into the DNA
of the organism. Then some of the resulting genetically modified organisms may
not be viable, if transgene insertion has disrupted essential genes. Even when the
resulting genetically modified organisms are viable and stable over several life
cycles, the transgene may later move within the genome, with unpredictable
consequences. In her witness statement, Dr Mae-wan Ho said:
GM constructs are also structurally unstable, and are frequently rearranged, deleted or
repeated in part or in whole. The resultant GMOs, likewise are unstable and do not breed
true, so significant genetic and epigenetic changes may occur in subsequent generations,
multiplying the unpredictable risks to health and biodiversity. Current regulatory
systems do not take this into account.
42
43. We heard evidence from research scientists that new techniques are being
developed to overcome risks associated with the gene construct and the method
of transgenesis. Dr Phillip L'Huillier, a molecular biologist presenting for
AgResearch [IP13], gave evidence that AgResearch's transgenic sheep and cows
were created using a method called homologous recombination, which gives rise
to a more specific gene insertion. This technique is similar to the methods used in
animal cloning and results in the new gene being placed accurately within the
genome, at a site normally occupied by a known, normal gene.
44. Similar techniques that can be used to integrate transgenes specifically into
chloroplast DNA in plants are under development. The ACRE report stated:
Transgenes can be integrated into chloroplast DNA by homologous recombination. In
this way the precise location of the gene can be controlled. Because of the specificity of
the integration event, fewer duplications or illegitimate insertions occur.
43
45. This report also recommended that transgenic plants should be as similar
as possible to their unmodified equivalents:
There are a number of reasons to aim to produce transgenic plants with as little
extraneous DNA as possible:
* it facilitates analysis (characterisation, including sequencing) of the insertion site
* it aids the monitoring of stability and inheritance of the transgene
* it reduces the chances of pleiotropic effects
* it simplifies the environmental risk assessment
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* it removes one of the main criticisms of the technology regarding the propagation of
plants containing antibiotic resistance genes and other marker traits, eg herbicide
tolerance.
44
46. The Commission is aware that the rapid pace of development of this
technology will lead to improved techniques for the transgenesis of plants and
animals over the next decade.
Environmental impacts
47. There were two main focuses for the anxiety about the use of genetic
modification: the potential impact on human health, and the potential
environmental impact. The level of concern about the latter was particularly
high. The view expressed by one of the public submitters appeared to be shared by
many:
... humans are messing with something very unique and ... doing so may cause
irreversible harm to the ecosystem.
45
48. Several of the organisations and individuals we heard were concerned that,
if genetically modified organisms and products were released for use outside
laboratory containment, the inherent instability of the technology and the high
risk of human error meant it was likely modified organisms would escape from
genetically modified crops and animals and contaminate unmodified plants,
insects and animals in both the natural and the agricultural environments.
Underlying the concerns about these adverse impacts was a widely held belief
that the effects would be irreversible. Dr David Suzuki, a Canadian ecologist,
wrote in his witness brief for the Sustainable Futures Trust:
The difference with this technology is that once the genie is out of the bottle, it will be
very difficult or impossible to stuff it back. If we stop using DDT and CFCs, nature may be
able to undo most of the damage ­ even nuclear waste decays over time. But GM plants are
living organisms. Once these new life forms have become established in our surroundings,
they can replicate, change and spread, so there may be no turning back.
46
49. The damage done by modified organisms, some submitters suggested,
could be cumulative rather than acute. Dr Macgregor, for example, suggested
that environmental harm could result from an accumulation of ecologically
insignificant instances of horizontal gene transfers in the soil biosphere. He
suggested there were largely unexplored areas of soil ecology for which testing
procedures were not being developed.
50. The issue concerning submitters was not the speed with which such
damage would be caused, but that it would be irreversible. The submission
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received from the Green Party emphasised that harm caused to the ecology of the
soil or through the food chain if New Zealand released genetically modified
organisms into the environment would not be remediable. Some submitters,
therefore, suggested no genetically modified organisms should be released from
laboratory use until further research into potential risk pathways had been carried
out. Other submitters clearly believed there should be a total ban or long-term
moratorium on all uses of genetic modification in New Zealand.
Invasiveness of genetically modified organisms
Ecological impacts
51. Many submitters raised the possibility of invasive genes altering natural
ecosystems as a result of the release of genetically modified organisms. A number
of witnesses suggested that, because research sought to identify the linear effects
of genetically modified organisms, insufficient attention was paid to the wider,
ecological impacts of the hazards. Dr Peter Wills, a theoretical biologist and
Associate Professor in Physics at the University of Auckland, who appeared for a
number of New Zealand organisations,
47
referred to the need to look at and
understand the "strange interconnectedness" of ecosystems. Dr Doreen Stabinsky,
Science Adviser on the Genetic Engineering Campaign to Greenpeace US and
Greenpeace International, told the Commission that studies done in the United
States reviewing the results of field tests showed that ecological data had not been
systematically collected. She suggested that, even if ecological data had been
collected, there was a very limited base of knowledge about ecosystems and the
interrelationships between organisms, and between organisms and their
environment.
Weediness
52. Weediness is a characteristic of plants that allows them to be aggressively
invasive, thereby upsetting natural ecological balances. Many submitters
expressed concern that genetic modification of plants, particularly agricultural
crops, would result in an increase in weediness.
53. Dr Stabinsky contended that the use of genetic modification to confer
desirable traits on agricultural crops, such as insect or drought tolerance, could
also confer characteristics on the recipient plant that made survival easier. A plant
developing these characteristics had the potential to persist in the environment by
withstanding either natural selection or conventional agricultural weed control
methods, and thus increase in number. The development of weediness in plants,
therefore, had implications for natural and agricultural ecosystems. It was
suggested there was also potential for cross-pollination of future crops by the
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genetically modified crops. However, recent data from a 10-year survey of
genetically modified crops in the United Kingdom showed modified plants had
no more tendency to weediness than their unmodified equivalents. These crops
had all been modified for resistance to herbicides or insects. The study showed
that all the genetically modified crops had a poor survival record in the field and
were eventually replaced by wild counterparts.
48
Outcrossing
54. The transfer of unexpected traits to living organisms could result from
either sexual or non-sexual genetic transfers. The particular examples of
outcrossing brought to the Commission's attention were from the accidental
release of genetically modified salmon into the wild, and cross-pollination from
genetically modified plants. Cross-fertilisation by genetically modified animals
was not addressed, probably because the containment of such animals is easier
and because, at present, modification of animals is not carried out extensively.
Apart from welfare concerns, the issues relating to animals focused on the
consumption by humans of products from genetically modified animals and the
potential for horizontal gene transfer to organisms in the soil through animal
excreta.
55. The hybridisation of unmodified plants by pollen from modified plants was
of concern for a number of reasons. There was the potential for unmodified plants
to develop unintended characteristics, such as weediness, that would have
environmental effects. A number of submitters were concerned that foods
manufactured from crops unintentionally cross-pollinated by modified crops
would not be subject to the usual safety assessment processes. Accidental
contamination by StarLinkTM corn was cited as an example of this happening.
Without assessment, it was feared, allergens and toxins resulting from genetic
modification would not be detected.
56. Environmentalists and Maori expressed concern at the potential for
indigenous plants to be cross-pollinated by exotic, genetically modified plants of
the same genus. Maori were particularly concerned that plants that had
traditionally provided food resources would be altered by cross-pollination,
affecting their value as a resource and causing spiritual pollution.
57. Control of pollen flow was the focus of a number of submissions. Many
submitters emphasised the difficulty of establishing satisfactory separation
distances between modified crops and unmodified plants. Beekeepers highlighted
the role that bees played in pollen transfer. The focus of their concern was
primarily the commercial threat posed by the presence of genetically modified
material in honey and other bee products.
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Targeting the wrong species
58. A perception of modified genes and the modification process as inherently
unstable and unpredictable caused many submitters to suggest that genetic
modification would result in alteration to non-target species. Plants, animals and
insects introduced into New Zealand in the past were used as illustrations of the
devastation that unintended effects cause to non-target organisms. The Green
Party, for example, said:
... New Zealand's ecosystems have evolved in isolation from the rest of the world since the
time when the Gondwanaland continent drifted apart. Our indigenous species tend to be
very different from species in other countries. While New Zealand's ecosystems have been
modified by introduced pests such as possums, deer, goats, gorse and others the lesson
from these is that they have behaved differently from in their country of origin and their
ecological impacts have been different.
49
59. Many submitters isolated aspects of the research carried out on the effect of
Bt-resistant corn on Monarch butterflies and cited these as examples of the
potential for genetic modification to impact adversely on other species in the
environment (see box opposite).
60. The Commission noted that a number of research projects being carried
out in Crown Research Institutes included research into non-target effects.
AgResearch advised research was currently being undertaken on the
environmental impacts of new technologies, including the impacts of transgenic
plants expressing insecticidal toxins. This involved quantification of the effects
on the soil ecosystem, including soil foodweb composition, biomass and nutrient
status. Research into pest control, especially the control of major environmental
pests such as possums and stoats, we were told, included evaluating the effect of
any proposed controls on non-target species. This work was being carried out by
Landcare Research [IP12], which was involved in a range of projects aimed at the
control and eradication of many introduced animal and plant species.
Reduction in biodiversity
61. People were particularly concerned that genetic modification would lead
to a reduction of New Zealand's biodiversity. Submissions from environmental
organisations, such as Greenpeace and the Royal Forest and Bird Protection
Society of New Zealand [IP79], emphasised the depletion already caused by the
introduction of exotic species and by cultivation, and the importance of protecting
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Non-target species: Monarch butterflies and
Bt corn
50
Bacillus thuringiensis (Bt) is a soil bacterium that produces a protein with insecticidal qualities.
Traditionally, a fermentation process has been used to produce an insecticide spray from
these bacteria. In this form, the Bt toxin occurs as an inactive protoxin, which requires
digestion by an insect to be effective.
Crop plants have now been engineered to contain and express the genes for Bt toxin, which
they produce in its active form. Bt corn is used primarily to control corn borer (a
lepidopteran insect), which is difficult to control by spraying. Bt-corn strains are therefore
toxic to lepidoptera (moths and butterflies).
Monarch butterfly larvae feed exclusively on the leaves of milkweed plants, which are
commonly found in and around cornfields in the United States. Pollen from nearby corn can
become distributed on the leaves of these plants, and therefore be eaten by these larvae.
In 1999, two studies showed that Monarch butterfly larvae, and larvae from related species,
had lower survival rates eating leaves dusted with Bt-corn pollen than after eating leaves
dusted with non-Bt corn pollen. People used these studies to suggest that Bt corn was
responsible for the recently observed decline in the Monarch butterfly population. However,
the Environmental Protection Agency (EPA) noted that these preliminary controlled study
data were not useful for risk assessment of widespread or recurring Bt-corn pollen effects on
Monarch butterflies without additional field study information.
As a result the EPA issued a call-in of data on this topic. Shortly thereafter the data was
presented to a scientific advisory panel for their recommendations. This resulted in a report
evaluating many studies on the effects of Bt-corn pollen on Monarch larvae mortality.
Investigations have revealed that while a large percentage of Monarch butterfly larvae may
feed on milkweed found in the corn belt region of the US, there is no overlap between
breeding time and time of pollen shed through most of this region. Other studies have
shown that corn pollen does not move far from the field, and that the quantity of pollen
settling on an area decreases rapidly with distance. Together with toxicity studies showing
low toxicity of many major Bt-corn strains, this implies that pollen densities that could
represent significant exposure to feeding larvae are found only within five metres of
cornfields, and then rarely. Even within corn fields pollen densities were usually found to be
too low to cause mortality in Monarch larvae. Some preliminary investigations have
suggested that Monarchs may avoid laying eggs on milkweeds surrounded by corn plants.
These findings indicate that, outside corn fields, Monarch larvae exposure to Bt-corn pollen
is minimal, and that, within fields, Monarchs will have a low probability of encountering a
toxic level of pollen.
The report also suggests that the elimination of pesticides through the use of Bt corn may be
beneficial to Monarch butterfly populations, and concludes that there is not sufficient
evidence to support the belief that there is significant risk to Monarch butterflies from Bt-
corn use. The EPA is however continuing to monitor this situation.
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New Zealand's unique flora and fauna from further threats. A member of the
Royal Forest and Bird Protection Society, Nelson/Tasman Branch [IP43], Jocelyn
Bieleski, said:
Our natural ecosystems in New Zealand are unique, and their isolation, until recently, has
made them vulnerable and valuable beyond measure. Indigenous forest ­ indigenous
flora and fauna and fish belong here in their own right. ... The forest is one of our living
ecosystems which has successfully adapted and developed to a complex self-maintained
diverse community, which has sustained its integrity over eons. Yes, there has been
genetic change as adaption applies, but this has not been engineered by humans in haste.
... Genetically modified organisms will threaten the indigenous biodiversity. With their
release will also come changed soil composition, pollen production and insect mutation.
Through mutations new bacteria and viruses are likely.
51
62. The Commission, however, heard evidence of the potential for genetic
modification to protect and preserve biodiversity. The Sustainable Futures Trust,
for example, gave cautious recognition of the value of genetic modification for
conservation purposes, but only where there can be an assurance of no adverse
effects. Landcare Research described research currently under way into a possible
genetically modified control for possums and for wasps, and the public submission
from the Department of Conservation referred to its involvement in research
involving conservation genetics where species are accurately mapped. It was
clear from the Landcare Research submission that, while it sees genetically
modified controls as being possibly the only method of dealing with this major
environmental threat, it is adopting a cautious approach to the use of the
technology. Other Crown Research Institutes indicated that genetic modification,
rather than posing a threat to biodiversity, might provide the solutions to some of
the hitherto more difficult problems associated with the management of natural
resources and the environment.
Human health impacts
63. The Commission heard almost an equal amount of worry expressed about
the dangers of genetic modification to human health as to the environment.
64. Some concerns were expressed about the use of the technology for medicines
and therapeutics. Medicines, however, are subject to rigorous testing which
minimises the potential for harm. In addition, submitters believed any adverse
effects from using genetically modified pharmaceuticals and therapies would be
limited to the individual. The use of the technology for personal health was,
therefore, an issue of individual choice. As long as there was careful research into
and limitations on any unethical uses of the technology, and as long as
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pharmaceuticals and therapies were rigorously tested and clearly labelled, and
patients advised of the genetic origin of any of the treatments they received, there
appeared to be a greater acceptance of the use of genetic modification in these
areas. However, because dietary supplements tend to fall between pharmaceuticals
and food and may have less regulatory oversight than food, they were one use of
genetic modification regarded as posing a special risk. Issues relating to the use
of genetic modification for personal health are discussed in greater detail in
chapter 9 (Medicine).
65. Submitters suggested that the development of characteristics such as
herbicide resistance in genetically modified crops would lead to an increase in
the use of more toxic herbicides. Particular mention was made of the link between
glyphosate herbicides and non-Hodgkin's lymphoma in humans. The Com-
mission's own research uncovered a considerable number of papers (one of which
was presented by the Life Sciences Network during cross-examination of the
Pacific Institute of Resource Management [IP84]) showing there was no
significant risk of non-Hodgkin's lymphoma with glyphosate exposure and that
Roundup was one of the least toxic herbicides currently available.
66. Submitters suggested the consumption of food either containing genetically
modified ingredients or manufactured by a process using genetic modification
would create serious risks of damage to human health. While there was some
reference to possible carcinogenic effects of genetic modification
52
and to
alterations to the nutritional value of modified foods,
53
the main worry was the
creation of new allergens in foods that have not hitherto been considered
allergenic, and new toxins in foods previously considered safe. Safe Food
Campaign [IP86], for example, said:
Part of our concerns centre around the "scientific risk-based approach" that ANZFA takes
when testing GM foods. We do not believe that the allergenicity, toxicity and substantial
equivalence tests are adequate to approve GM foods for consumption. Tests for aller-
genicity, like those for toxicity, are only for known allergens and toxins. As some GM
foods include genes from organisms outside our diets, we believe that some GM foods may
contain allergens and or toxins previously unknown to us and therefore outside those
tested for.
54
67. We noted, in particular, the expressions of anger that genetically modified
food had entered the New Zealand market without any regulatory requirements
other than those for conventional food. Permitting unassessed food to remain on
the shelves, submitters suggested, exposed consumers to unacceptable risk.
68. Issues relating to genetically modified food are dealt with in greater detail
in chapter 8 (Food).
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Questioning the need
69. A number of submitters questioned whether there was a need for genetically
modified products and technologies, particularly in agriculture. Submitters such
as the Green Party suggested that genetic modification was seen as a "magic
silver bullet" to solve problems without addressing the causes. Dr John Clearwater,
an entomology consultant, in particular to the organic apple industry, and a
witness called by Physicians and Scientists for Responsible Genetics, said:
Many genetically engineered species are the product of the "magic bullet" concept that
seeks a single, dramatically effective solution to a problem.
55
70. The use of genetic modification, submitters suggested, was a "reductionist"
approach to often complex problems that required a more holistic solution. In
particular, there appeared to be little demand for a technology with so many risks.
In its written submission, the Canterbury Commercial Organics Group [IP65]
asked:
Lack of clear need, adverse impacts on the organism "benefited" by the technology,
lingering public health concerns, scientific uncertainty, and the need for clear labelling
all lead to the questions: Why do we need these products? What consumers are
clamouring for them?
56
71. A number of submitters also considered that genetic modification tended
to deflect attention from alternative solutions and technology, and to divert
funding from the research and development of alternative health treatments and
food sources which did not create the same degree of risk as genetic modification.
The organics industry particularly felt it had not benefited from government
research funding, and the Commission was pleased to note that additional
funding was made available to this production sector during the period of our
inquiry.
72. The Commission heard evidence that there might not always be a choice
between genetically modified and unmodified solutions. For example, Dr Kenneth
McNatty, a scientist with AgResearch, told us that, because animals are becoming
increasingly resistant to conventional parasite control methods, research is under
way into the development of genetically modified alternatives. Although some
have suggested that treatments based on organic principles would provide more
effective and safer control of animal and plant pests, there might be situations in
which genetic modification would provide the best and possibly the only effective
alternative to conventional methods. Landcare Research, for example, emphasised
that using genetic modification in response to major environmental threats, such
as from possums, that caused significant damage and did not respond to other
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control methods, might be the only possible alternative:
At present, pest problems in New Zealand, like possums and stoats, are being addressed by
the best management strategies we have. The current way New Zealand is managing pests
has substantial risks, particularly those from the use of poisons. GM offers more precise
and better targeted ways of addressing these intractable pest problems, which could
reduce or avoid the risks of current control methods, and reduce New Zealand's reliance
on large scale use of broad-spectrum poisons.
57
73. We also heard evidence from representatives of sufferers of rare diseases
that genetic modification would provide the only viable option for treatment.
74. The Commission considers there may often be a need to find the most
appropriate solution, in all the circumstances, regardless of whether it involves
genetic modification or not. Short-term gains will always need to be balanced
against long-term solutions in the decision-making process.
The corporate context
75. There was a significant level of doubt as to whether genetically modified
products were anything more than a cynical manipulation of the consumer for
corporate profit. Allan Fricker, speaking for the Sustainable Futures Trust, said:
In the case of genetic modification in agriculture, and to a lesser extent in health, it is the
commercial sector that is involved that carries those costs of development and
production. And commerce cannot afford not to develop its products, not to apply and
to sell its products. And so, in a sense, the commercial imperative gets in the way of the
decisions that need to be made.
58
76. Concerns about corporate involvement in the development of genetically
modified products were raised particularly in relation to issues of liability for any
harm caused by the technology and the creation of intellectual property. These
are dealt with in later chapters. The Commission considers, however, that
concern about corporate involvement in the development and promotion of
genetic modification has had important implications for public perception of the
safety of genetic modification. First, the relationship between commercial
interests and science in the development of gene technology caused doubts about
the integrity of science, of scientists and of the scientific process. Second, it was
suggested that the commercial impetus behind genetically modified products,
particularly food products, might influence and undermine the effectiveness of
the regulatory agencies responsible for ensuring the safety of those products. In
particular, we heard considerable criticism of the Australia New Zealand Food
Authority (ANZFA) leading us to invite ANZFA to attend a special hearing to
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respond. Issues relating to ANZFA and food safety are discussed in more detail in
chapter 8 (Food).
Concern about scientists
77. A number of submitters raised the issue of public confidence in science and
scientists. Some of the concern rested on doubts about whether scientific
knowledge was sufficient to assess the risks of using genetic modification.
Sometimes, however, the lack of trust of scientists in particular was explicitly
linked to the relationship between commercial interests and the funding of
science. For instance, Dr Morgan Williams, Parliamentary Commissioner for
the Environment [IP70], while discussing the work commissioned on the control
of possums and the possible use of genetic modification technology, told us:
... what we've found, and it came out through this possum GE study, was that [the] New
Zealand community's asking, how independent is our science voice today? Who actually
owns that voice? ... and there's a widespread perception that the soul of science is, or has
been, bought, and ... the objectivity, rightly or wrongly that was bestowed upon science
in previous decades, is not seeking to be as strong as it was.
59
78. Dr Roger Wilkinson, who appeared as a witness for Landcare Research,
was responsible for the research into possum control carried out on behalf of the
Parliamentary Commissioner. He said:
People don't trust genetic engineering. ... They also don't trust genetic engineers. Some
groups described how scientists have let us down too many times ... The Industry group
observed the lack of trust in proponents. ... Scientists were described in the Opponents
group as arrogant. ... Biotechnology companies were described as being interested only
in profits: ... Someone in the Provincial group even suspected a conspiracy. ... Motives
of scientists were regarded as important, along with the source of their research funds
and who their employers were.
60
79. Some submitters suggested that, because of commercial pressures, scientists
and the corporate developers of genetically modified products might not carry
out proper assessments of the risks of releasing genetically modified organisms.
We heard this suggestion particularly in relation to the production of genetically
modified food where the integrity of companies in providing research results was
questioned. In New Zealand, scientists are guided by the code of ethics
promulgated by the Royal Society of New Zealand. We were told by Emeritus
Professor George Petersen, the immediate Past President of the Academy
Council of the Royal Society of New Zealand [IP77], that:
We have already collaborated with ERMA New Zealand in drawing up guidelines
specifically for researchers in the field of genetic modification, as defined under the
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HSNO legislation, and this has been published which ERMA and distributed widely. ... I
expect that we will incorporate these recommendations, and probably others, in our own
general code of ethics that is due to be reviewed over the next few months.
61
80. In response to questioning by the Commission about the integrity of
scientists being compromised by the source of funding for their research, Dr
Audrey Jarvis, appearing for the Interchurch Commission on Genetic Engineering
[IP49], agreed that as long as scientists retained their integrity and independence,
the source of funding was not an issue. She said:
... the integrity is terribly important. This has always been important for scientists. There
will often be the odd scientist who does not have integrity. ... I guess any person [may]
not have integrity. ... we're not saying that scientists don't have integrity. ... I've been to
talks, been involved with scientists involved with ERMA, ... and they have concerns about
the ethical issues ...
62
Precautionary principle
81. Arguments for prohibiting the release of genetically modified organisms
into the environment or for preventing the importation of genetically modified
food often invoked the precautionary principle as the basis for this approach.
82. Since its introduction into environmental law in the 1970s the
precautionary principle has been widely incorporated into a range of international
laws, treaties, protocols and other instruments. Although it has become a
principal tenet of international environmental law, it remains the focus of much
debate, particularly in relation to biosafety and biotechnology. In addition, many
differing definitions of the principle are found in different contexts.
83. Two formulations of the principle were held up by submitters as being
applicable to the release of genetically modified organisms in New Zealand. In
relation to possible environmental damage, Principle 15 of the 1992 United
Nations Conference on Environment and Development (the Rio Declaration)
was cited. This states:
Where there are threats of serious or irreversible damage, lack of full scientific certainty
shall not be used as a reason for postponing cost-effective measures to prevent environ-
mental degradation.
84. Article 11.8 of the United Nations Cartagena Protocol on Biosafety (the
Biosafety Protocol), agreed in Montreal in January 2000, is relevant to the release
of genetically modified organisms for food or animal feed. It states:
Lack of scientific certainty due to insufficient relevant scientific information and
knowledge regarding the extent of the potential adverse effects of a living modified
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organism on the conservation and sustainable use of biological diversity in the Party of
import, taking also into account risks to human health, shall not prevent that Party from
taking a decision, as appropriate, with regard to the import of that living modified
organism intended for direct use as food or feed, or for processing, in order to avoid or
minimise such potential adverse effects.
85. Greenpeace New Zealand [IP82] called for the precautionary principle to
be implemented in the Hazardous Substances and New Organisms Act 1996
(HSNO). The principle, Greenpeace suggested:
... mandates action to prevent harm to the environment, without requiring full scientific
certainty that the threat of serious or irreversible harm will be realised. Invoking the
precautionary principle, Aotearoa/New Zealand will ban:
* The deliberate release into the environment of genetically modified organisms in
Aotearoa/New Zealand for the purposes of both field trials and commercial release.
* The importation for food processing, human or animal consumption of living entities
such as maize kernels, tomatoes or cereal grain that if released by accident or
negligence could germinate and replicate in the environment. In the cases of seeded
fruits and vegetables, these foods should be banned for import on the basis of the
ability for the seed to retain their viability after passing through the human digestive
system.
63
86. The Green Party also invoked the Biosafety Protocol which, it said:
... gives countries the power to protect their environment under international law. The
agreement covers trade of genetically engineered organisms, including bulk commodities,
seeds, animals and microorganisms. It is intended to protect countries from potential
environmental impacts of importing genetically engineered organisms.
64
87. In its submission, the Green Party made reference to the precautionary
approach set out in section 7 of HSNO.
All persons exercising functions, powers, and duties under this Act, ... shall take into
account the need for caution in managing adverse effects where there is scientific and
technical uncertainty about those effects.
88. A number of the submitters suggested that a delay or ban on the release of
genetic modification would accord with this approach.
89. Other submitters, while not specifically invoking any of the formal
definitions of the principle, sought other ways of explaining their view of the
approach that should be taken. Safe Food Campaign, for example, suggested:
... [a] `no regrets' approach would prove beneficial no matter what outcomes eventuate
from genetic modification. If the best case scenario develops, with very few problems of
minor consequence eventuating from genetically engineered foods, and only minor
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problems being experienced from the release of genetically modified organisms,
New Zealand would still have benefited from the enhanced economic returns from the
premiums gained from organic markets.
65
90. Friends of the Earth (New Zealand) [IP78] considered the theme of its
Interested Person submission was best summed up:
... in the precautionary principle. It is our position that knowledge of the risks of genetic
modification (GM) is at present extremely limited, uncertain and often based on
assumptions that do not reflect the public interest.
66
91. Submissions and witnesses on behalf of a number of the Crown Research
Institutes pointed out that precaution is an element of scientific methodology,
particularly of risk assessment. Dr Max Kennedy, from Industrial Research
Limited, was a witness on behalf of the New Zealand Biotechnology Association
(NZBA) [IP47]. To questions from Luke Anderson for GE Free New Zealand on
the application of Cartagena Biosafety Protocol, he said:
I think the concept which the Biosafety Protocol is putting forward, which is risk
assessment and a detailed consideration of that on a logical basis, is something that the
NZBA supports wholeheartedly. I think that the concept of doing anything without that
risk assessment is really not something that is sustainable or supportable.
67
92. Dr Kennedy went on to say that concern for protecting biodiversity or
human health from risks posed by genetically engineered organisms was part of
normal risk assessment methodology. The whole purpose of such methodology,
he suggested:
... is to consider the unknowns and to try to quantify those unknowns. So the fact that
there is debate over it shouldn't be a surprise and it is not really something that risk
assessment is unfamiliar with.
68
93. The role of the precautionary principle in New Zealand law was considered
at some length in the closing legal submission presented by the Life Sciences
Network which pointed out that, although none of the international formulations
of the principle were incorporated into New Zealand domestic law:
... the concept of caution is incorporated into domestic legislation and policy by the
promulgation of the Hazardous Substances and New Organisms Act 1996 ("HSNO" or
"HSNO Act") itself. More particularly, that approach is overtly to be found in section 7 of
HSNO requiring the adoption of a cautious or precautionary approach.
69
94. Although we heard much discussion of the precautionary principle and the
precautionary approach from those who opposed the release of genetically
modified organisms into the environment, there was no consensus on the
meaning of either term. The meaning of precaution often rests in the values held
by the speaker.
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95. The Commission considers there is more merit in hearing and responding
to the message contained in the words than in seeking to define the meaning or
determine how the principle should be applied. In any event, we were not
convinced that a single principle could be applied across the board to the use of
genetic modification in New Zealand. Decisions on the use of the technology
must rest on a range of factors, including the risks and acceptability to the public
of the proposed use. They are factors that should inform the process of managing
genetic modification.
Risk analysis
96. It was clear to the Commission that a number of the people who spoke
before us doubted genetic modification could be subjected to the usual methods
of scientific risk analysis. In their view this was both because of the inherent
instability of the process of genetic modification, and because there was, as yet, an
inadequate body of knowledge on which to either base an assessment of the risks
or establish risk management mechanisms.
97. Dr Mark Lonsdale, an ecologist with CSIRO in Australia, who appeared as
a witness for the Parliamentary Commissioner for the Environment, spoke of the
four pillars of risk analysis. He named these as being:
*
Comparative risk analysis, which is how you compare one risk with another
*
Risk assessment, which is how to decide what the risks are of a particular
technology
*
Risk management, which is how, having made a decision to proceed, you
then manage the risks
*
And then risk communication, which is how you talk to people about those
risks and get people on side and keep them on side.
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98. Dr Lonsdale added monitoring as a fifth pillar:
... to detect the impact of hazards at an early stage ... or to provide data to refine future
risk assessments.
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Risk assessment
99. Submissions from organisations involved in the research and development
of genetically modified organisms emphasised the importance of research and
the application of gene technologies being based on high-quality science and
scientific knowledge. In its submission, the New Zealand Association of Scientists
[IP92] said:
Wherever possible, factual information and data should be used to address the risks and
benefits of research, field trials and the release of GMOs and products. With research that
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involves risk, with field trials and with release, each situation should be considered on an
individual, case-by-case basis.
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100. Dr Wills raised doubts whether it was possible to assess the risks of genetic
modification accurately. He suggested that accepted methods of assessing risk
were inappropriate for genetic modification because the risk factors associated
with the technology could not be known or quantified in advance.
101. Other witnesses also suggested there was insufficient scientific knowledge
of the behaviour of genetically modified organisms to allow for proper assessment
of the risks. Professor Terje Traavik, a virologist from the Department of
Medicine at the University of Tromsø, Norway, and a witness for Greenpeace,
speaking in the context of horizontal gene transfer, said:
There is already sufficient evidence on the unpredictability of genetic engineering
techniques and the interaction of genetically engineered organisms with the environment
to indicate that we do not understand enough about the short, medium or long-term
consequences of their release. Horizontal gene transfer from GMOs is a real option. Such
events may result in extensive and unpredictable health, environmental and socio-
economic problems. Under some circumstances the consequences may be catastrophic.
Our present level of knowledge about horizontal gene transfer is inadequate for reliable
risk assessments. This applies to GMOs in general as well as to any particular GMO.
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102. However, Dr Cohen, a scientist in the HortResearch Plant Health and
Development Group, said that scientific methods had been developed to evaluate
and quantify the two components of risk assessment: assessment of the probability
that something might occur and assessment of the consequences that might
follow in the event of an occurrence.
103. In addition, the Association of Crown Research Institutes (ACRI) [IP22]
and other organisations involved in researching genetic modification did not
accept that gene technology was inherently unpredictable or that there was
insufficient scientific knowledge to assess the risks adequately. In its submission,
ACRI said:
... that sufficient reliable research information exists, or is being rapidly developed, to
allow society's decision-makers to have a workable understanding of the risks of the
technology.
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104. The Commission also heard evidence that some of the anticipated risks of
genetic modification were unlikely to arise, or would arise only in specific
circumstances and were, therefore, capable of being managed.
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Risk assessment models
105. Dr Lonsdale pointed out that risk assessment is "a very involved process".
He suggested:
We are early in the development of this science as it applies to GMOs. Even for small-scale
releases, there is a feeling amongst proponents that they are being asked to address
endless questions to no purpose, and a counter-view amongst regulators that they may
be missing something. This is in part because of the newness of the technology, but there
is also a need for systems thinking that will identify the range of risks that are pertinent
to a particular GMO.
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106. The ACRE report explains the basic principles of best practice in the
design of genetically modified plants and sets these within the context of risk
assessment. Other agencies in New Zealand and elsewhere are revising existing
assessment models to ensure that, based on current scientific knowledge, risk
assessment methods identify the hazards and risks of the technology.
107. Public interest in risk assessment models is also high. The Commission
had the benefit of a number of submissions from the public that addressed this
issue. Wendy McGuinness provided a substantial public submission in which she
addressed issues of decision-making in relation to the use of genetic modification.
She said:
My personal view is that the only way through this debate is the adoption and
implementation of a rigorous decision-making methodology as to whether genetic
modification should be adopted in terms of the scale, form and timing.
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108. The question of whether decisions on the use of genetic modification should
rest on scientific principles of risk assessment, or should include wider issues was
mentioned in some of the submissions we received. In its written submission, the
New Zealand Arable-Food Industry Council [IP56] expressed its opinion that:
... regulatory authorities give primary consideration to scientific assessment of risk in
making GM decisions; the Council strongly opposes the possibility that political
considerations become involved in GM risk assessment.
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109. Many of the groups asking for prohibition of the release of genetically
modified organisms, however, were concerned that too much reliance was being
placed on scientific risk analysis methods. Those people who opposed genetic
modification on cultural and ethical grounds were particularly concerned that
there appeared to be no mechanism for taking such considerations into account
when making decisions on genetic modification.
110. Proponents of genetic modification, we noted, did not necessarily disagree
with the view that factors other than scientific factors should influence decisions
on genetic modification. The Life Sciences Network, while supporting the
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effectiveness of scientific risk assessment, also suggested:
At its most scientific, risk assessment and management is the process by which people,
communities, organisations, countries make informed judgements about proposed
activities and actions weighing relative risks and benefits. Having made the assessment it
is then possible to ensure a positive balance of benefits over risks is maintained.
However, the assessment of risk is only partially scientific and factual. Many risks are
unable to be characterised in an objective sense and must be determined and weighed
using subjective criteria.
78
111. The New Zealand Dairy Board [IP67] also acknowledged the cultural,
social, political and economic aspects of the risk management process. The
Board, however, said this type of factor should not:
... be allowed to impinge upon or distort the science. That should be as objective as it is
possible to achieve. Other concerns should not be ignored, but they should be recognised
and assessed for what they are, and not used as a basis for exaggerating, or minimising,
the extent of the risk as assessed scientifically.
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Risk communication
112. As noted earlier, Dr Lonsdale discussed risk communication as one of the
pillars of risk analysis. He pointed out that the costs of bad risk communication
were high and that risk communication itself should be an area for research. He
suggested that a model of communication "involving dialogue with regulators,
stakeholders, and the public is likely to be more fruitful".
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113. A number of other submissions mentioned the need for more information
about genetic modification to be made available. The Federation of Maori
Authorities [IP69], for example, suggested:
Transparency and easy flow of information will contribute significantly to educating the
public in the issues we potentially face in having biotechnological research, development
and practice undertaken in New Zealand.
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114. The New Zealand Association of Scientists supported the need for
communication, saying:
We think that communication is paramount. We believe that there has been too little
communication. Science has worked in a world of its own and failed to recognise its wider
social responsibilities and communication. We believe that this forum is part of the
process of disseminating information, and we believe that the more widely these issues
are discussed, at least the more knowledgeable and the more rational decisions will be
made.
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115. The Royal Society of New Zealand [IP77b] in its submission discussed the
public perceptions of genetic modification and pointed out that feelings of lack of
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control contributed to a sense of the lack of safety of the technology. Rosemary
Du Plessis, the Society's social science representative, said:
There is public concern about GM research, and the effects of field trials, and the
commercial release of GMOs. Improving mechanisms for public participation and
decision-making about the use of GM technologies is one, not the only way, of improving
people's sense of control over the risks that are involved in this field.
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116. Dr Lynn Frewer, a psychologist at the Institute of Food Research in
Norwich, England, appeared as a witness for Crop and Food Research [IP4].
Dr Frewer's witness brief discussed public attitudes towards genetically modified
food:
Research has demonstrated that risk perception is "socially constructed" ­ that is, the
way that people represent risks psychologically is a more important predictor of the way
in which people will react to risks than probabilistic risk assessments used by technical
risk experts to assess different hazards.
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117. Dr Frewer went on to say that risk perception research had demonstrated
that risks that were perceived as involuntary and unnatural were viewed as more
threatening than those over which people perceived they had a choice, even if the
probability of occurrence of the involuntary risk was very low.
118. Some submissions suggested some of the concern about the safety of
genetic modification might be dissipated if the public were more informed about
genetic modification and its risks. In a background paper prepared for the
Commission, Dr Michael Berridge wrote:
Public perceptions about the risks and benefits of GM technologies are not always based
on facts and are frequently dictated by uncertainty about the nature of gene
manipulation, lack of knowledge about genes and natural genetic variation, and a lack of
public trust in scientists and the scientific process ... The main issue here is one of
communication ­ the need to raise the level of public dialogue and to provide factual
information and realistic evaluation of benefit and risk.
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119. The Commission agrees that the issue of communication is central to the
future management of genetic modification in New Zealand. The level of
concern about the potential risks to the environment and to human health is
significant. While measures such as those discussed in later chapters of this
report can and should be taken to manage the scientific and environmental risks
of the technology, we consider careful thought should be given to the nature of the
communication between scientists and others that should be an integral part of all
management strategies. In his witness brief, Dr Cohen pointed out:
There are two major components of in the analysis of risk. Firstly the probability that
something might occur and secondly the consequences that might follow in the event of
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an occurrence. Scientific methods have been developed to evaluate and quantify both of
these risk components. However, public perceptions of risk can arrive at completely
different conclusions about both of these components.
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120. Dr Cohen made reference to the perception of risk sometimes being
modified by an "outrage reaction" if a strongly held opinion is challenged. The
Commission had the opportunity of viewing a video on general principles of risk
communication by Dr Peter Sandman, a social scientist from the United States of
America.
87
Dr Sandman also referred to the concept of "outrage". He suggested
that the public viewed risk as being a combination of "hazard" and "outrage",
where "hazard" was the actual risk and "outrage" the public's perception.
Outrage, Dr Sandman suggested in his video, was as real, and therefore as
measurable and manageable, as hazard. Since facts do not quench outrage,
Dr Sandman's basic message was to emphasise the need for communication,
transparency, consultation and acknowledgement of the areas of scientific doubt
and public concern.
121 There is clearly a high level of concern about the environmental impacts of
genetic modification, not just among the public but also among some members of
the scientific community. Much of the evidence we heard about the risks of
genetic modification, although properly drawing attention to possible hazards
and risk pathways of genetic modification, is however the subject of ongoing
debate, and we heard evidence from other witnesses, particularly scientific
witnesses, that the risks of adverse impact could be assessed and managed. Some
of the claims of possible environmental and health damage were exaggerated or
based on inconclusive research data or on unproven hypotheses.
122. The Commission found it regrettable, for example, that the research into the
health hazards of genetically modified potatoes carried out in the United
Kingdom by Dr Pusztai had not been completed and therefore was not subjected
to the normal scientific process of review. It must, therefore, be considered
inconclusive. Dr Elaine Ingham, a witness for the Green Party, suggested
research she had conducted showed that a bacterium designed to digest crop
remnants to produce alcohol, Klebsiella planticola, could have had catastrophic
consequences had it escaped into the ecosystem, but this evidence was discredited.
123. The Commission acknowledges that many of the scientists who appeared
before us are committed to ensuring a cautious approach to the development of
genetic modification because of concern about its potentially negative impacts.
We are concerned that a significant degree of polarisation appears to have
developed within the science community between those who promote the
benefits and therefore the use of genetic modification and those who stress the
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risks of this technology. The public would be better served by balanced, informed
public debate about the issues raised by research and their implications for the
use of the technology.
124. Most of the Interested Persons who appeared before the Commission
urging caution suggested that the risks of gene technology were such that further
research must be carried out and more scientific knowledge developed before the
hazards and risks of genetic modification could be properly assessed. Some
clearly thought that, because of the inherent uncertainties of the technology, it
was unlikely there would ever be sufficient knowledge to provide an adequate
assurance of safety. The point of tension between those who saw genetic
modification as having the potential to provide benefits to the environment and
those who saw it as having potentially catastrophic impacts lay, therefore, in the
belief or otherwise that the risks of the technology could be subject to current
scientific risk assessment processes and risk management techniques.
125. Issues relating to genetic modification do not give rise to easy debate.
Nevertheless, we consider all the stakeholders in biotechnology should be
prepared to continue the exchange of views and information that has been an
important part of the Commission's process.