3.
section 3.13 |
Analysis of
submissions from
Interested Persons
appendix 2
Outcomes of Consultation: Submissions
from Interested Persons
Section contents
3.
Analysis of submissions from Interested
Persons
28
3.13 Global developments and issues
216
Introduction
216
Global environmental issues
217
Global food production solutions offered by genetic
modification
217
Negative environmental effects of genetic modification
219
Globalisation of resources
219
Global competition
220
The "biotechnology revolution"
220
Comparative technological advantage
221
Competitive opportunities from avoiding genetic
modification
222
Consumer responses to genetic modification
222
Consumer concern about genetic modification, especially
food products
222
Consumer demand for "safe" products
223
Consumer price and quality preferences
224
Globalisation of indigenous issues
225
Global legal obligations
225
Restrictiveness of New Zealand's regulatory regime
225
High compliance costs
226
National strategies for technological development
226
National biotechnology strategies
227
National public education strategies
227
Royal Commission on Genetic Modification | Report Appendix 2
p216 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
3.13 Global developments and
issues
Introduction
The Warrant under item (h) called for information on:
the global developments and issues that may influence the manner in which New Zealand
may use, or limit the use of, genetic modification, genetically modified organisms, and
products
Global developments and issues raised by submitters in relation to genetic
modification tended to focus around several themes including:
*
global environmental issues
*
globalisation of resources
*
global competition
*
consumer responses to genetic modification
*
globalisation of indigenous issues
*
global legal obligations
*
national biotechnology strategies.
Thirty-eight submitters made substantive comment on the issue of global
developments. In terms of type of submitter, the highest proportion (17 submitters)
came from industry networks or associations. Of the 38 submitters who commented
on global developments, the largest sectoral responses were received from
biotechnology (eight submitters), primary production (four submitters) and
environmental advocacy (four submitters). Findings from cross-tabulation of data
on the submitters who made substantive comment on global developments showed
that almost two-thirds of this group (24 submitters) took a `strongly for' stance on
genetic modification.
The majority of submitters focused on developments that might influence the use
of genetic modification in New Zealand, with fewer submitters commenting on
issues that might limit the use of genetic modification. Some of the submitters
made comment on global developments and genetic modification without relating
these comments specifically to New Zealand. Most submitters discussed global
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p217
Royal Commission on Genetic M odification | Report Appendix 2
developments in terms of genetic modification in general, rather than making
specific reference to genetically modified organisms or products.
Some submitters, such as New Zealand Biotechnology Association (NZBA)
[IP47], identified a range of global developments including population growth,
human health, consumer trends, new industries, sustainable development and
climate change as being issues that might be influenced by genetic modification.
Global environmental issues
The growth in environmental resource pressures was identified as a key theme by
submitters: such pressures included world population growth, food shortages, loss
of arable land, increasing salinity, water shortage, climate change, pests and
pollution. Association of Crown Research Institutes (ACRI) [IP22] identified that
global environmental problems were occurring on a large scale and that solutions
to such problems would require a major effort.
Submitters put forward arguments for and against the use of genetic modification
as a means of addressing these global environmental problems. In particular,
submitters focused on potential solutions that genetic modification might offer in
boosting global food production.
Global food production solutions offered by genetic
modification
Several submitters outlined ways in which genetic modification could help reduce
pressure on global food supply by:
*
increasing overall global food production
*
reducing food distribution problems through helping countries to develop
self-sufficiency in food production.
They also commented on fair and appropriate use of biotechnology in dealing with
global environmental issues.
Ability to increase global food production
A range of submitters identified the potential of genetic modification to increase
global food production as a factor that might encourage use of the technology.
Several agricultural crop producers and research companies made comment on
this issue. New Zealand Feed Manufacturers Association/Poultry Industry
Association of New Zealand/Egg Producers Federation of New Zealand [IP35]
commented that many developing countries "desperately need some of the
potential benefits of GE food". Monsanto New Zealand [IP6] noted in its
submission that food security would drive expansion in the use of genetically
p218 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
modified crops, particularly in the developing countries. Aventis CropScience
[IP14] also noted that its crop production enterprise was driven by global needs for
food safety, sustainability and a cleaner environment; and that it saw biotechnology
as playing a critical role in feeding the world's population (projected to be nine
billion by 2025). Crop and Food Research [IP4] agreed that ensuring the
sufficiency and security of world food supply would provide strong incentives for
other parts of the world to pursue genetic modification.
Several religious organisations also provided comment on the potential for genetic
modification to help alleviate pressures on world food supply. Interchurch
Commission on Genetic Engineering [IP49] stated that vitamin A ("golden
grain") rice was one application of genetic modification that might improve the
nutritional status of millions of people.
However, other submitters rejected the arguments that genetically modified foods
could solve food supply problems. Pacific Institute of Resource Management
[IP84], for example, suggested that there were "risks to food security through
some GM disaster in agriculture affecting food production".
Global food distribution issues
Ensuring an adequate global food supply was not the only problem identified.
Some submitters considered distribution of food to those in need to be a more
significant issue. ACRI [IP22] noted in its submission that, although technically
the world "produces sufficient food for the moment, there is no likelihood that in
the immediate future food will be readily available to those in greatest need". The
Association commented further that genetic modification technologies provided
powerful tools to help address problems of world hunger and, along with other
biotechnologies, they were the key to helping nations become self-sufficient in
food production.
The need for equitable solutions
Interchurch Commission [IP49] noted that it was necessary to look at culturally
and ethically appropriate means of addressing global nutritional deficiencies.
Public Questions Committee (Methodist, Presbyterian, Churches of Christ,
Quaker) [IP93] supported this view, commenting that social problems needed
social answers and that genetic engineering was not the only solution for social
problems. New Zealand Catholic Bishops' Conference [IP38] also dealt with
ethical issues when it stated that the benefits of genetic modification should be
shared fairly and equitably, and decisions should "take into account the needs of
the poorest and most vulnerable".
Submitters identified developing countries as being most in need of genetically
modified crops. New Zealand Arable-Food Industry Council [IP56] provided an
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p219
Royal Commission on Genetic M odification | Report Appendix 2
example of this view, quoting from another source: "The African continent, more
than any other, urgently needs agricultural biotechnology."
ACRI [IP22] noted: "New Zealand has a role to play in sharing its biotechnology
`know-how' with its neighbours."
Negative environmental effects of genetic modification
Submitters also identified potential negative environmental effects arising from
the use of genetic modification, and saw these as reasons for limiting its use. For
example, Pacific Institute of Resource Management [IP84] noted that genetic
modification destroyed biodiversity in agriculture and that it could result in the
threat of "super-weeds" or "super-pests".
Environmental issues in relation to genetic modification are addressed in more
detail in connection with Warrant item (j) (ii) (see "Areas of public interest:
environmental matters").
Although global environmental pressures might seem distant from New Zealand,
ACRI [IP22] emphasised that New Zealand could not take its own comfortable
situation for granted and that New Zealand's global future could not be considered
in isolation from the rest of the world.
Globalisation of resources
The increasing global mobility of people, goods, services and knowledge was a key
theme that submitters commented on in relation to the use or limitation of genetic
modification.
Researched Medicines Industry Association of New Zealand [IP55] noted in its
submission that the pharmaceutical and biotechnological industries operated on a
global scale and that the products of these industries were becoming available in
the principal markets of the United States, Europe and Japan in an increasingly
"synchronous" manner. NZBA [IP47] also commented on global pharmaceutical
trends, noting that genetic modification offered opportunities for large-scale
production of existing substances that would otherwise not be available in
sufficient quantities, for example, human insulin. University of Auckland [IP16]
outlined the issue of growth in international tourism and travel and the implications
for New Zealand if tourists had medical conditions for which they needed access to
genetically modified products for treatment. National Testing Centre [IP44]
highlighted the global nature of medical treatment, noting in its submission that
many new genetically modified treatments would become available overseas and
New Zealand people might travel to receive treatment.
p220 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
New Zealand Grocery Marketers Association [IP54] noted that the food industry
was now intrinsically and irreversibly linked to international trade in food and the
international marketplace and that there were few examples of large New Zealand
manufacturing companies that were not part of an international network.
The globalisation of research was another trend identified by the submitters.
Several submitters stressed the importance of New Zealand maintaining a critical
mass of qualified researchers actively engaged at the cutting edge of new
developments. Without the ability to use genetic modification techniques, New
Zealand would lose valuable human resources, given the mobility of human
capital.
Lincoln University [IP8] commented that international students now made up
21% of its student body, that research was undertaken from a global perspective
and that, in order to remain viable, universities needed access to modern research
techniques. The University stated that technologies such as genetic modification
were accepted in all modern technologically oriented countries.
Global competition
Submitters identified a range of issues relating to genetic modification that had led
to increasing competition in the global arena, including the "biotechnology
revolution", comparative technological advantages and competitive opportunities
from avoiding genetic modification.
The "biotechnology revolution"
Several submitters referred to the "biotechnology revolution", which was
characterised by the rapid pace of change that biotechnology discoveries had
generated. Submitters saw a parallel between the "biotechnology revolution" and
earlier periods of rapid change in technology. New Zealand Dairy Board [IP67]
noted that the science of genomics was in a position similar to that of the silicon
chip 20 years ago. The fastest development had occurred in pharmaceuticals, from
the first approval of a drug based on genetic modification technology in the 1980s
to the "scores of GM based medicines" currently available. The Board also
commented that "GM is revolutionising the food industry" and that there was "a
developing convergence between the agribusiness, food, pharmaceutical and
chemical industries". Auckland Uniservices [IP23] was also of the opinion that
biotechnology was now regarded as the major emerging industry of this century.
Foundation for Research, Science and Technology [IP21], describing the scale and
extent of change, noted that more than 2500 companies worldwide were funded by
around NZ$8 billion annually to develop biotechnology products and that world
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p221
Royal Commission on Genetic M odification | Report Appendix 2
sales of biotechnology products exceeded NZ$27 billion. Monsanto [IP6] noted
that worldwide the total area planted out in genetically modified crops in 1999 was
nearly 40 million hectares (ie, more than New Zealand's total land area).
Factors considered by submitters to be generating momentum in the biotechnology
revolution included:
*
the universality of science and the speed of information flows (Environmental
Risk Management Authority (ERMA) [IP76])
*
access to increasing amounts of DNA-sequencing information and the
development of new tools with which to use this information (Institute of
Molecular BioSciences, Massey University [IP15])
*
the race to secure international patent rights over gene sequences of
important crops and the applications of important genes (HortResearch
[IP5])
*
innovation, global competition and the international search for new products
and markets (New Zealand Game Industry Board [IP33])
*
consumer demand for genetically modified medicines, vaccines and new
diagnostic tools (Otago University [IP19])
*
world food security (Monsanto [IP6]).
Several submitters reinforced the economic imperatives of New Zealand being
part of the "biotechnology revolution". Auckland Uniservices [IP23] put forward
an opinion that favoured active participation in biotechnology, asserting that
"those countries which do not invest [in biotechnology] will be badly disadvantaged
in the future", and noted that this was especially important for countries like New
Zealand that relied heavily on biological production. Auckland Uniservices
considered biotechnology to be possibly the "last opportunity for the foreseeable
future to participate in a major knowledge-led economic transition".
Similarly, Dairy Board [IP67] considered genetic modification technologies to be
the means of securing New Zealand's standard of living, noting that New Zealand
was overwhelmingly dependent on biological products: farm, fish, forest and
horticulture. The Board commented that biological exports exceeded 60% of New
Zealand's export earnings and that: "There are no other exports which are growing
rapidly enough to reduce that dependence."
Comparative technological advantage
With respect to the implications for New Zealand of increasing use of genetic
modification in other parts of the world, Crop and Food Research [IP4] noted that
it was likely to be difficult for New Zealand's biological industries to maintain their
competitive position unless they had access to technologies that were similar to
p222 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
those of their competitors. Dairy Board [IP67] also noted that New Zealand
needed to maintain and enhance its competitiveness in biological product exports,
which it considered to be "our only major source of international competitive
advantage". The Board suggested that the major social and economic risk to New
Zealand was "that the New Zealand dairy industry will be prevented from
developing and using GM, while its competitors are not".
Competitive opportunities from avoiding genetic
modification
Other submitters tended to see the opportunity presented by the "biotechnology
revolution" differently. Many of those who identified with organic farming, for
example, saw an opportunity for New Zealand to market organic produce under a
generic New Zealand "GM-free" label.
Submitters also offered comment on the competitive opportunities that might
arise if New Zealand avoided genetic modification. Some submitters approached it
largely in marketing terms: "As the rest of the World seems to be embracing GE
technology ... New Zealand has the opportunity at this stage to reject it and
thereby have a potential competitive advantage in marketing" (Royal Forest and
Bird Protection Society, Marlborough Branch [IP40]). Others saw the "GM-free"
option in terms of market differentiation.
Consumer responses to genetic modification
Consumer attitudes towards genetic modification, genetically modified organisms
and products have been a significant factor in the use of this new technology,
especially for food production.
Submitters considered three critical overseas developments as affecting how New
Zealand should address genetic modification, including:
*
consumer concern about genetic modification, especially for food products
*
consumer demand for "clean, green", "safe" and "natural" products
*
changing global consumer preferences towards genetic modification in
response to perceived price and quality benefits.
Consumer concern about genetic modification,
especially food products
Several submitters highlighted consumers' preferences about genetic modification
and emphasised the importance business attached to such concerns. Submitters
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p223
Royal Commission on Genetic M odification | Report Appendix 2
saw concerns about genetic modification as particularly significant for New
Zealand's business, both locally and overseas.
Arable-Food Industry Council [IP56] stressed that New Zealand "must be in a
position to respond to consumer preference in a competitive international
market". Carter Holt Harvey/Fletcher Challenge Forests [IP17] noted that
"uncertainty about future consumer acceptance" in overseas forestry markets of
"wood produced from New Zealand biotechnology and trees" had the potential to
slow investment in genetic modification technology in the New Zealand forestry
sector. Canterbury Commercial Organics Group [IP65] also talked of a "large and
growing resistance to GE food production technology". Similarly, Environment
and Conservation Organisations of New Zealand [IP102] noted a "worldwide
distrust" of genetic modification, particularly in agriculture and food products.
Other submitters gave more specific responses. National Beekeepers Association
of New Zealand, Poverty Bay Branch [IP62] quoted a news agency report of
October 2000 that described several major international brands as "distancing
themselves" from having any genetically modified organisms in their products.
ZESPRI International [IP46] also cited cases where global food retailers "swiftly
removed and avoided" brands associated with genetic modification. Monsanto
[IP6] identified "consumer concerns" behind the slow adoption of genetically
modified crops. Royal Society of New Zealand [IP77b (social sciences)] also
mentioned "international consumer reaction to GM foods" as an issue. All these
submitters reinforced the importance of consumer reaction for marketing strategies
both within New Zealand and overseas markets.
Consumer reaction to the development of health-related technological advances
in vaccines and in diagnostic and treatment options is discussed under Warrant
item (j) (i) (see "Areas of public interest: human health").
Consumer demand for "safe" products
Consumer demand for "safe" or "natural" products was an additional key global
development mentioned by submitters that could limit New Zealand's use of
genetic modification technology. Several submitters who supported a "clean
green" image for New Zealand stressed that New Zealand could, and should,
differentiate itself from the rest of the world in this developing technology.
Opinions expressed included:
*
to be successful as a trading nation New Zealand had to differentiate ("to
decommoditise its production") and being "GM-free" might be a unique
opportunity to do that (National Beekeepers Association, Poverty Bay
[IP62]).
p224 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
*
New Zealand's remoteness presented a natural advantage: the country had
the opportunity to remain free of genetically modified organisms in its
agriculture and environment (Bio Dynamic Farming and Gardening
Association in New Zealand [IP61]).
*
New Zealand could be the "control" if the rest of the world experiments
with genetic modification (Royal Forest and Bird Protection Society,
Nelson/Tasman Branch [IP43])
*
New Zealand should take a similar stance on genetic modification to its
policy on the nuclear issue of the 1970s, and declare New Zealand "GM
free" (Forest and Bird, Nelson/Tasman [IP43]).
Meat Industry Association of New Zealand [IP32], in an accompanying witness
brief, commented: "perversely, genetic modification may become important for
maintaining the `clean and green' image [of New Zealand]. Biological solutions
may come to be seen as safer than chemical solutions."
Consumer price and quality preferences
A further global development seen as possibly affecting New Zealand's options on
genetic modification was the perceived consumer preference for cheaper or for
higher quality genetically modified products.
A global consumer preference trend, identified by several submitters (including
AgResearch [IP13], Game Industry Board [IP33] and Meat New Zealand [IP31]),
was that wealthy consumers in Europe and North America increasingly were
"looking for value, health, and nutrition from knowledge-based products".
Similarly, Monsanto [IP6] said that consumer acceptance would grow
internationally as the biotechnology benefits moved from "current input
(agronomic) traits to the next generation output (quality) traits which will result in
improved and specialised nutritional food and feed products". Monsanto felt that
New Zealand needed to be "well placed to capitalise on biotechnology innovations
as consumer acceptance of the technology grows".
However, different markets segments (both within New Zealand and overseas)
placed value on different commodities. Several submitters saw advantage in New
Zealand focusing on consumers in highly developed niche markets, not low-value
commodities. Some saw organic farming as catering to this specialised consumer-
market segment.
Submitters offered differing evidence on which global trends were in New
Zealand's economic interest.
Consumer issues in relation to genetic modification are also discussed under
Warrant item (j) (i) (see "Areas of public interest: human health").
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p225
Royal Commission on Genetic M odification | Report Appendix 2
Globalisation of indigenous issues
A number of submissions referred to indigenous persons' rights and issues of
genetic modification in a global context. Ngä Wähine Tiaki o te Ao [IP64] stated
that indigenous peoples internationally were resisting "biopiracy" for the purposes
of genetic modification, and saw this as occurring for the benefit of "corporates".
Others referred to international agreements and discussions on indigenous
peoples' rights, in particular the Convention on Biological Diversity, the "Rio
Declaration", the Mataatua Declaration and the Draft Declaration on the Rights
of Indigenous Peoples. WAI 262 claimants, Ngäti Wai, Ngäti Kuri, Te Rarawa
[IP89] commented that international awareness of the importance of respecting
indigenous knowledge and practices "has gathered a momentum of its own". New
Zealand Institute of Patent Attorneys [IP71] noted that intellectual property rights
of indigenous peoples was an area of active international debate.
Indigenous issues in relation to genetic modification are also addressed under
Warrant item (f) (see "Intellectual property issues"), Warrant item (g) (see
"Responsibilities under the Treaty of Waitangi") and Warrant items (d, l) (see
"International obligations and implications").
Global legal obligations
Submitters raised issues on the global regulatory responses to genetic modification
in terms of worldwide obligations and the differing national regulatory frameworks
that have developed. The international legal obligations are discussed in more
detail under Warrant items (d, l) (see "International obligations and implications")
and New Zealand's statutory and regulatory system is addressed under Warrant
items (2, n) (see "Statutory and regulatory frameworks").
Several submitters saw New Zealand's current regulatory framework as a factor
that might limit the use of genetic modification in New Zealand for reasons of
high compliance costs and more stringent regulation than some comparative
systems overseas.
Restrictiveness of New Zealand's regulatory regime
Some submitters compared New Zealand's regulatory framework for genetic
modification with that in other countries, in particular Australia, and noted the
differences in approaches and potential impacts that might result. Biotenz [IP25]
noted that Australia currently had a more accommodating approach to genetic
p226 |
Section 3: Analy sis o f Submissions from Interested P ersons
Report Appendix 2 | Royal Commission on Genetic M odification
modification than New Zealand:
Australia ... like most other first world countries, is actively promoting inward
investment in GM technology through financial assistance and support. If New Zealand
does not adopt a similar approach, then we will simply become an importer of
technologies and our best scientists and engineers in this area will move off-shore. The
infrastructure required to support them, which will be substantial, will also be lost to New
Zealand.
New Zealand Wool Board [IP30] also raised this issue and noted that if the
regulatory environment in New Zealand for genetic modification was tougher
than that in Australia then activities such as research would simply shift across the
Tasman. The Board commented that global developments in regulatory
environments would have an impact on where investment took place. It emphasised
that New Zealand was a small, biologically based nation for which isolationism was
not a viable economical option. This submitter considered New Zealand to be a
country where people, skills, knowledge and money were now highly mobile and
where future economic success would be dependent on evolving production
systems in the face of ever-changing and developing world markets.
High compliance costs
NZBA [IP47] considered that ERMA's approach to risk assessment was costly and
restrictive. New Zealand Transgenic Animal Users [IP45] also commented that
New Zealand had high compliance costs and that the strict requirements of the
Hazardous Substances and New Organisms (HSNO) legislation inhibited the
ability of New Zealand researchers "to gain from and effectively partake" in global
research activity. A contradiction within the existing regulatory system was
identified by Wool Board [IP30]: the Board contended that there would be no
economic benefit in preventing research and development of genetically modified
organisms and products in New Zealand when they could be lawfully imported
from other countries. On this issue, ERMA [IP76] identified a growing
international inability to control the movement of goods and organisms across
borders.
National strategies for technological
development
Submitters commented on national strategies for biotechnology advanced by
other governments and in what areas New Zealand might develop its own national
strategies for dealing with biotechnology issues.
Section 3: Analysis o f Submissions from Interested Persons
| H1 | p227
Royal Commission on Genetic M odification | Report Appendix 2
National biotechnology strategies
Several submitters commented that New Zealand lacked a national biotechnology
strategy and that such a strategy was needed in order to recognise New Zealand's
biodiversity, maintain its biosecurity and provide for the needs of its biotechnology
industries. For example, Institute of Molecular BioSciences [IP15] observed that
New Zealand must engage in genetic modification research in order to protect
"our unique biodiversity" and noted that, even if New Zealand were to pursue a
policy of no commercial development of genetically modified organisms, "a
graduate capacity would still be crucial to interpret global trends in GM
technologies and to credibly maintain New Zealand's Biosecurity" as the use and
development of products derived from genetically modified organisms increased
in other countries.
Some of New Zealand's closest trading partners (and biotechnology competitors)
have already adopted national biotechnology strategies to guide the development
of their biotechnology industries and promote national economic growth and
investment. Several submitters pointed to Australia, Canada, the United Kingdom,
Ireland and the United States as examples of countries whose biotechnology
strategies the Commission might wish to consult. Auckland Uniservices [IP23]
commented that:
Australia has a vibrant and growing biotechnology industry ... [This] has considerable
significance for New Zealand, given the two countries' ... increasingly related and
interdependent economies. ... the Commission should closely consider what is happening
with biotechnology in Australia, and only adopt a different position ... after careful and
detailed analysis.
National public education strategies
Governments are also responding with a variety of national education strategies
designed to educate consumers and the public generally on the risks and benefits
of genetic modification. Twenty-three submitters noted a concern about public
education as an issue, implying that they saw a need for the New Zealand
Government to mount a similar public education campaign. New Zealand
Organisation for Rare Diseases [IP98], for example, observed that, as with earlier
technological advances (such as vaccination, pasteurisation and microwave ovens),
"the appropriate response is education and information".