3.
section 3.6 |
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
3.6
Where, how, and for what purpose ...
113
Introduction
113
Types of response to `where', `how', and `for what purpose'
114
Where genetic modification is used
114
How genetic modification is used
115
Purpose of genetic modification
115
Uses of genetic modification technology in New Zealand
116
Specific examples of use of genetic modification technology
117
Government funding and approval agencies
118
Land-based production uses of genetic modification
120
Environment-focused use of genetic modification
121
Human health-related use of genetic modification
122
Food-related use of genetic modification
123
Extent of information on use of genetic modification
125
Report Appendix 2 | Royal Commission on Genetic Modification
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Royal Commission on Genetic M odification | Report Appendix 2
3.6 Where, how, and for what
purpose ...
Introduction
Warrant item (a) asked for investigation into and representation on:
where, how, and for what purpose genetic modification, genetically modified organisms,
and products are being used in New Zealand at present
Fifty-seven submitters made substantial comment on this Warrant item. Within
this group, 28 submitters had economic and productive issues as their main
sectoral focus. Seven had environmental issues as a principal focus and six had
health issues. Most submitters were from industry associations or networks (14
submitters), research organisations (13 submitters), other advocacy networks (nine
submitters) and private companies (seven submitters).
Of the 57 submitters, 41 were identified as being `strongly for' or `tending to be
for' genetic modification; 12 were considered to be `strongly against' or `tending to
be against'. Four were assessed as `neither for nor against' the use of genetic
modification technology.
Many submitters expressed concern about the public availability of the information
specified in this Warrant item. This issue is discussed more fully in other sections
(eg, sections "Statutory and regulatory processes" and "Areas of public interest: an
introduction").
Submitter responses to the Warrant item provided a wide range in the level of
detail. Responses indicated the following:
*
The terms "where", "how" and "for what purpose" were interpreted in
various ways. Submitters who were not actively involved in research or in
the use or application of any genetically modified products or processes
usually did not provide specific details of what was currently happening in
New Zealand.
*
Submitters clearly had differing levels of access to information about genetic
modification activities and products.
*
It was unclear whether all the examples provided by submitters related
specifically to activities and uses "in New Zealand at present" (the wording
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Report Appendix 2 | Royal Commission on Genetic M odification
of the Warrant item). Several witnesses noted activities that had been
undertaken in New Zealand in the past; they noted research or use that was
based on overseas experience; or they mentioned work that was planned for
the future.
*
Although individual submitters cited the research that they believed was
being conducted in their own organisations, no one submitter purported to
provide a complete picture of all the research being undertaken in a
particular industry or sector.
Responses to Warrant item (a) are described according to:
*
Types of response to "where", "how", and "for what purpose"
*
Uses of genetic modification technology in New Zealand
*
Specific examples of use of genetic modification technology
*
Extent of information on the use of genetic modification.
Types of response to `where', `how', and `for
what purpose'
Most submitters gave a general outline of current undertakings in their own
organisations with respect to research or product development using genetic
modification techniques or their perception of what was happening in their
industry sector. Some submitters noted their support for other organisations'
research activities. The remainder tended to express reservations about the use of
genetic modification techniques.
The more detailed information about the process and overall purpose for using
genetic modification was usually supplied by those organisations that were actively
involved in using genetic modification processes and products. This group
included several research facilities (research institutes, universities and Crown
Research Institutes) and private companies. Several references to specific projects
were provided.
Where genetic modification is used
Submitters variously interpreted "where" genetic modification technology was
used, usually as a broad geographical location or a general industry or sector. Most
submitters indicated the general industry or range or type of activity in which
genetic modification, genetically modified organisms and products were employed.
Relatively few submitters gave specific geographic locations where genetic
modification techniques were used. Typical references included: "medical research",
Section 3: Analysis o f Submissions from Interested Persons
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in the "biological industries", in the "environment sector", "in the apple industry",
"in New Zealand research institutions", "in contained field trials", "in containment
laboratories and containment greenhouses" and "throughout New Zealand at
various organisations".
Some submitters noted specific locations. For example, AgResearch [IP13]
mentioned its main research and development sites at Ruakura, Grasslands
(Palmerston North), Wallaceville, Lincoln and Invermay (Mosgiel).
How genetic modification is used
In response to "how" genetic modification technology was used, most comments
came from submitters whose organisations were actively involved in using or
investing in genetic modification technology. They usually gave detailed
information and examples of the processes and products involved. These activities
embraced basic or fundamental research and, to a lesser extent, the product from
use of this technology. Many of the comments were incorporated into their
comments on the purpose of use.
Typical of more detailed categorisation were the comments in a witness brief from
Foundation for Research, Science and Technology (FRST) [IP21], which identified
three broad areas of research: "proof of concept" studies (see below), research
targeted at producing genetically modified products, and research aimed at
understanding and addressing the key effects associated with genetic modification.
Purpose of genetic modification
Submitters also treated variously the notion of "for what purpose" genetic
modification techniques were being used. The majority interpreted the Warrant
item to mean current uses in New Zealand. Most of those submitters who had
direct involvement in a particular research activity (or used products or processes
using genetic modification technology) interpreted purpose to mean the sector in
which the genetic modification activity occurred. They usually gave information
that scoped the nature of activities undertaken.
Several provided details of a representative selection of the activities being
undertaken. For example, Landcare Research [IP12] noted the use of genetic
modification in possum fertility control for the purpose of solving a major
environmental pest problem. Landcare Research detailed the project in an
accompanying witness brief.
Submitters noting examples of specific projects in specific industry sectors gave
details of work in four main areas: land-based production (including animal and
plant production), environment, human health, food for human consumption. To a
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lesser extent, application of this technology in veterinarian medicine and animal
feed was mentioned, as well as its industrial uses.
Most organisations focused on one particular activity (for example, medical
applications or horticulture). However, some organisations' research activities
spanned several sectors (for example, Crown Research Institutes were involved in
the agricultural production sector and also the environment sector).
Uses of genetic modification technology in
New Zealand
Most submitters responded to the Warrant item's "where, how, and for what
purpose" in terms of the current use of genetic modification. From information
provided by submitters, the overall impression about the extent and range of
activity involving genetic modification technology in New Zealand in 2000 may be
summarised as follows:
*
Genetic modification technology was widely used in university and other
research institutions in New Zealand as an integral part of ongoing research
activities.
*
Genetic modification-related research had been conducted for many years.
*
Many organisations (including those in the productive sector, private
companies and patient advocacy groups), which did not themselves use
genetic modification techniques, acknowledged that they either actively
supported and/or directly benefited from research using this technology.
*
"Use" included basic or fundamental research (for example, where genetic
modification was used as a tool in a research process) and applied research
(for example, development of a particular genetically modified product).
*
Continuing use of genetic modification technology was clearly anticipated
by most submitters.
*
Genetic modification technology was applied in a wide range of New
Zealand's productive base. Its use spanned land-based production (including
horticulture, agriculture, forestry), human health applications (for research
and specific products, especially vaccines), in animal welfare and animal
feed, in the environment (including bioremediation, maintenance of
biodiversity and pest control), as well as industrial applications.
*
There was no commercial production of genetically modified food, although
some food products or food ingredients imported from overseas could
contain genetically modified material.
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*
Research being undertaken using this technology was with the express
approval of Environmental Risk Management Authority (ERMA).
*
Despite ERMA's requirements, unauthorised experiments had been
conducted. Green Party of Aotearoa/New Zealand [IP83] identified that
15% of experiments under way in August 2000 were unauthorised.
*
Submitters identified specific projects that were known to involve use of
genetic modification technology. A complete list of all current projects was
generally perceived to be not readily available.
Specific examples of use of genetic
modification technology
Specific examples of what submitters stated was currently happening in New
Zealand in the use of genetic modification technology are outlined below.
Comments from 13 submitters were selected to illustrate the responses.
Information from two government agencies involved in the funding and approvals
for genetic modification research (FRST [IP21] and ERMA [IP78]) is outlined
first. Then comments of 11 submitters from the major industry groupings
(universities, Crown Research Institutes, private companies and sector
organisations) illustrate a range of genetic modification uses: Carter Holt Harvey/
Fletcher Challenge Forests [IP17], Institute of Molecular BioSciences, Massey
University [IP15], Crop and Food Research [IP4], AgResearch [IP13], Monsanto
New Zealand [IP6], Landcare Research [IP12], University of Auckland [IP16],
Malaghan Institute of Medical Research [IP10], Auckland Healthcare Services
[IP91], New Zealand Grocery Marketers Association [IP54] and New Zealand
Vegetable and Potato Growers' Federation/New Zealand Fruitgrowers'
Federation/New Zealand Berryfruit Growers' Federation [IP75].
Examples cover four broad sectoral areas:
*
land-based production (including animal and plant production)
*
environment
*
human health
*
food for human consumption.
Some of the activities identified span more than one sector. For example, "proof of
concept" research (FRST [IP21) had implications for both agriculture and the
environment. Some activities involving food were in both plant research and
production of food for human consumption.
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Government funding and approval agencies
The activities of two government agencies involved in the funding and approvals
for genetic modification research span the broad sectors identified.
Foundation for Research, Science and Technology
FRST [IP21] said that it was the primary investor in research, science and
technology in New Zealand investing around $383 million on behalf of the New
Zealand Government. It estimated that approximately $130­135 million (or 33­
35% of the Foundation's total investment) was invested in research programmes
that used or were associated with gene technology. In an accompanying witness
brief, three types of research were identified:
*
"Proof of concept" research. Approximately $27 million was invested in
research where genetic modification and other gene technology techniques
were being used as "proof of concept". Such research was aimed at extending
scientific understanding and might or might not lead to genetically modified
products or solutions. Examples included: the recent discovery of a gene in
Inverdale sheep that causes increased fertility; use of genetic modification in
research to understand the effect that a plant growth regulator or hormone
has on the storage and shelf-life of vegetables.
*
Research involving development of genetically modified products or
solutions. Approximately $6.4 million was invested in research targeted at
producing a particular genetically modified product or solution. Examples
included: producing a genetically modified crop plant with increased pest
resistance to improve plant performance; generating genetically modified
cows with improved casein content in their milk; developing vaccines
against bovine tuberculosis; and producing novel, high-value, ornamental
species.
*
Research aimed at understanding the issues and addressing the effects
associated with genetically modified organisms. Approximately $1.4 million
was invested in research in this area. Specific examples provided included:
research to better understand characteristics of the target organism (eg,
pollen release and movement); and research to better understand how
genetic modification tools work and to develop new tools to help minimise
risks (eg, vectors that do not include antibiotic resistance markers).
Environmental Risk Management Authority
ERMA [IP76] noted:
No approvals by the Authority or by any other agency to the Authority's knowledge have
been given for the release of a viable GMO. This includes current applications put before
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the Authority and approvals carried over from the previous regime. Current use of GMOs
has therefore been restricted to teaching, research and developmental work carried out in
containment in the main by Universities and the Crown Research Institutes.
Much of the GMO development work has been in understanding the function of specific
genes. Such research has been for the purposes of modelling diseases and possible
treatments and for understanding the fundamental mechanisms controlling plant growth.
Once the gene function has been understood attempts have been made to shift genes
firstly within and then between species. This work has included the development of
agronomically important characteristics in plants and the development of
biopharmaceuticals.
ERMA further noted that its comments on current usage of genetic modification
technologies in New Zealand were derived primarily from the applications put
before it for importation or development of genetically modified organisms.
However, the Authority was aware that pharmaceuticals derived from genetically
modified organisms (such as insulin and hepatitis vaccine) were already in use in
New Zealand.
Seven approvals by ERMA for field tests with controls are listed below, namely
approvals to:
*
PPL Therapeutics for the establishment of a manufacturing flock of sheep
genetically modified to contain a copy of a human gene, so as to produce a
biopharmaceutical in the milk of the sheep
*
Crop and Food Research for genetically modified petunia for altered plant
form or pigmentation, to assess field performance of the vegetative plant
*
Kimihia Research Centre to evaluate agronomically important characteristics
of genetically modified sugarbeets for herbicide resistance
*
Pioneer New Zealand for genetically modified, herbicide-tolerant and
insect-resistant maize for breeding purposes
*
Crop and Food Research to evaluate resistance and yield performance of
individual lines, over a five-year period, of potato cultivars genetically
modified for increased resistance to bacterial soft rots and tuber moth
*
AgResearch to perform large-scale fermentation of genetically modified
Escherichia coli to obtain registration of the hydatids vaccine by the Animal
Remedies Board and maintain hydatids vaccine supplies for trial and future
commercial overseas markets
*
Carter Holt Harvey to study factors influencing gene expression and to
assess the influence of genetic modification involving the insertion of
marker genes on growth and morphology of pine trees.
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Land-based production uses of genetic modification
Submitters provided examples of the use of genetic modification in research
directed toward land-based production. A wide range of scientific investigations
included studies in forestry, symbiosis, apomixis and resistance to pests, diseases or
herbicides.
Carter Holt Harvey/Fletcher Challenge Forests
Carter Holt Harvey/Fletcher Challenge Forests [IP17] noted that it did "not have
commercialised applications of biotechnology in use in forestry in New Zealand at
the present time". It confirmed that Carter Holt Harvey had obtained approval
from ERMA in 1999 "to field test a strain of genetically modified radiata pine
incorporating genetic markers". It had subsequently produced 120 such seedlings.
It also noted examples of possible applications in projects to increase wood yields,
improve wood quality, reduce tree damage from the exotic fungus Dothistroma and
reduce the survival of pests.
Institute of Molecular Biosciences, Massey University
Institute of Molecular BioSciences [IP15] noted that its staff members were
"engaged predominantly in basic research using recombinant DNA techniques to
address a wide range of questions in biological processes". It noted eight examples
of general types of research being undertaken and itemised some of the individual
projects. For example, under the broad category of research into "host-microbe
interactions including pathogens and symbionts", it listed project "GMO99/MU/
10" as "Evaluation of dothistromin production by the pine pathogen Dothistroma
pini".
Crop and Food Research
Crop and Food Research [IP4] noted seven areas of its research that currently used
genetic modification. They were:
*
modification of the biochemical pathways for carotenoids and flavonoids to
introduce new colour combinations into ornamentals and improve food
properties such as nutritional quality and colour
*
modification of the biochemical processes of senescence to improve the
shelf-life of perishable products such as vegetables and ornamentals
*
introduction of new pest- and disease-resistance characters
*
investigation of "apomixis", a form of asexual seed production in plants with
potentially worldwide benefits for plant improvement
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*
production of potential pharmaceuticals in plant tissue
*
improvement of genetic modification techniques through the development
of new vector systems and transformation methods for crops that cannot
currently be transformed.
*
gene discovery within crop plant species
AgResearch
AgResearch [IP13] advised that it used three major methods of research: traditional
breeding, genetic marker-assisted selection for traits and genome manipulation
(which results in genetically modified animals, plants or micro-organisms that
either have new gene sequences inserted or the functions of particular genes
modified). It provided examples of 14 projects involving a range of organisms,
genetic modification techniques and applications. The organisms used included
bacteria, parasitic worms, cattle, sheep, mice, and pasture plants (ryegrass and
white clover). Among the techniques identified were: gene libraries, gene isolation
and functional analysis, gene deletion and gene insertion techniques in bovine
cells, transgenic mouse models (micro-injection and gene targeting techniques),
bacterial cloning, and gene disruption by transposon mutagenesis.
Monsanto New Zealand
Monsanto [IP6] stated that it had evaluated several projects in New Zealand and,
"owing to uncertainty of future direction", put them on hold. These projects
included: commercial release of `Roundup-Ready' canola (canola that will tolerate
applications of Roundup herbicide), a trial of herbicide-tolerant wheat and
herbicide-tolerant radiata pine. It also noted "Monsanto-developed genetic material
... and processes (eg, promoters) are freely available to the scientific community
and are in use in a number of scientific programmes."
Environment-focused use of genetic modification
Landcare Research
Landcare Research [IP12] said that it was directly undertaking or subcontracting
genetic modification work to the value of $2.8 million in 2000-2001. About $2
million was for research on development of potential products derived from
genetic modification for improving environmental management. It gave details of
research into 12 areas: conservation genetics, DNA typing for identification and
monitoring of mammal pests, whakapapa of harakeke (New Zealand flax, Phormium
tenax), horizontal gene transfer in bacteria, origins of nitrogen-fixing rhizobia,
rapid assessment of plant pathogenic bacteria, possum fertility control, stoat
biocontrol, new pest control toxins, wasp control, biosensors and bioremediation.
It expected its genetic modification-related work "to rise slowly as we increase our
focus on describing, understanding and protecting genetic diversity of New
Zealand's flora and fauna".
Human health-related use of genetic modification
University of Auckland
University of Auckland [IP16] said "genetic modification, genetically modified
organisms and products are widely used in New Zealand at present. In the
University's Schools of Biological Sciences and Medicine, GM, GMOs and
products derived from GMOs are being widely used for medical research." It
noted that the technology is used extensively in fields such as biochemistry, clinical
biochemistry, molecular biology and medicine, as well as in some areas of
engineering. Some specific therapies based on genetically modified products were
detailed, including erythropoietin, growth hormone, granulocyte-colony
stimulating factor (G-CSF) and plasminogen activator.
Malaghan Institute of Medical Research
Malaghan Institute [IP10] also confirmed it made "extensive use of GM, GMOs
and GM products to achieve the objectives of its biomedical research programmes".
It recounted developmental work over the 1970s and 1980s into protein hormones,
growth factors, cytokines and immuno-modulatory agents, and noted: "Today,
many hundreds of recombinant proteins are available for research purposes."
Various research projects at the Institute made "wide use of interleukins, ...
interferons, colony-stimulating factors, peptide hormones and other recombinant
immuno-modulatory proteins". In addition, the Institute said that it employed
extensive use of cell lines genetically modified to produce specific cytokines and
frequently imported such genetically modified organisms into containment. Over
the past five years, transgenic and gene knockout mouse models had been
"increasingly used ... to facilitate research into cancer, asthma, tuberculosis and
multiple sclerosis".
Auckland Healthcare Services
Auckland Healthcare Services [IP91] noted that genetic modification technology
was currently being used for investigation and diagnosis of genetic disorders and
congenital metabolic diseases in areas such as prenatal diagnosis, diagnosis
confirmation, carrier detection, predictive testing, predisposition testing, diagnosis
and treatment of congenital metabolic disorders in newborn babies. Predictive
testing included DNA testing of individuals who are at risk of developing a late-
onset genetic disorder such as Huntingtons disease before the onset of symptoms.
Congenital metabolic diseases, for which Auckland Healthcare's National Testing
Centre screened newborn babies, included the conditions of phenylketonuria
(PKU), maple syrup urine disease, congenital hypothyroidism and cystic fibrosis.
Food-related use of genetic modification
New Zealand Grocery Marketers Association
Grocery Marketers Association [IP54] summarised the situation for the food
processing as follows:
*
Derivatives from GM crops were being used as ingredients in food
processing.
*
Genetic modification was also useful to food processing in the production of
enzymes and additives, potentially enabling more efficient production of
such micro-ingredients.
*
The extent to which genetic modification was used by the industry and its
different uses was not recognised or appreciated by many consumers.
*
The application of genetic modification in the food processing industry
extended beyond products. The technology could be used to detect
pathogens, toxins and chemical contaminants, as well as degradation of
quality.
The Association also gave some examples of the processed foods in which
genetically modified ingredients "may be used in New Zealand". Its list included
six genetically modified organisms such as forms of soybean, canola, potato and
sugarbeet. Details were supplied of the ingredients, additives and processing aids
that could be derived from these genetically modified crop plants. A list of the
foods in which these products and processes were used was also provided. For
example, information for soybean, cotton and potato is shown in Table 3.5.
Vegetable and Fruitgrowers Federations
New Zealand Vegetable and Potato Growers' Federation/New Zealand
Fruitgrowers' Federation/New Zealand Berryfruit Growers' Federation [IP75]
confirmed that in New Zealand "there are no genetically modified fruit or
vegetables grown commercially". The Federations also stated that several trials
were under way. These included: a trial to produce potato plants with genetically
modified resistance to potato tuber moth; a trial to produce genetically modified
resistance to alfalfa mosaic virus in peas; and a project breeding tamarillo plants
with resistance to tamarillo mosaic virus. In addition, the Federations referenced
HortResearch's genomics programme involving sequencing genes from apples,
kiwifruit and berryfruit, including the possibility "to introduce crop improvements
via smart breeding and marker assisted selection".
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Table 3.5
Ingredients derived from genetically modified crops and
their use in foodstuffs
GMO
Ingredient, additives and
Used in following foods
processing aids
Soybean
soybean flour
soy drinks, soy sauce, tofu
soybean protein
processed meats/sausages/salamis
hydrolysed vegetable protein
bread
textured vegetable protein
dairy ­ drinks, yoghurts, desserts, ice cream
soybean oil
baked goods ­ cakes, pies, pastries, biscuits
lecithin
soups and sauces
additive and flour carriers/diluents cooking oils, salad dressings
tocopherols ­ vitamin E
margarines and spreads, peanut butter
confectionery, savoury snacks, infant food
Cotton
cotton seed oil
baked goods
cooking oils
salad dressings
margarines
Potato
potato
soups
potato starch
sauces, pickles and chutneys
modified starch
confectionery
savoury snacks
Source: Submission of New Zealand Grocery Marketers Association [IP54]
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Extent of information on use of genetic
modification
A few submitters noted that their organisations did not directly undertake genetic
modification-related research but that they supported and benefited from such
activities, or that their members were actively engaged in such activities. These
submitters included Meat Industry Association of New Zealand [IP32], New
Zealand Game Industry Board [IP33], Diabetes Youth New Zealand [IP60], Royal
Society of New Zealand [IP77a (biological sciences)] and Lysosomal Diseases
New Zealand [IP99].
A greater number of submitters expressed their concern at a lack of information on
who was using this technology and for what purpose. Others were uncertain about,
or against, the use of this technology. Several queried the reliability of the
information on current use. This group comprised approximately a dozen
submitters on this Warrant item. Specific comments included:
*
"We ... are concerned that such information is not easily available" (Public
Questions Committee (Methodist, Presbyterian, Churches of Christ,
Quaker) [IP93]).
*
"... at present GM experimentation is going on in New Zealand without
public knowledge or consent" (Friends of the Earth (New Zealand) [IP78]).
*
"Genetically modified food infiltrated the food supply in New Zealand with
no agreement of the government or people of this country" (Pacific Institute
of Resource Management [IP84]).
*
"Trial crops are being grown regardless of risks, products are being imported
and incorporated into unlabelled food" (Nelson GE Free Awareness Group
[IP100]).
*
"Maori Congress from reading the submissions to the Royal Commission
has discovered that genetic modification has taken place [in a number of
areas] ... The list is relentless and continues to be added to without the
knowledge of Maori. ... [Biotechnology] companies have failed
spectacularly in their efforts to advise us of their work. And it begs the
question as to why?" (National Maori Congress [IP103]).
*
"A survey of 433 members of the Association of Anglican Women has
indicated a high level of uncertainty and lack of information upon which to
make considered opinions." (Anglican Church in Aotearoa New Zealand
and Polynesia [IP42]).
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*
Green Party [IP83] expressed its concerns about research being undertaken
without Environmental Risk Management Authority (ERMA) approval. It noted:
As at 16 August 2000 ERMA had approved:
39 applications to allow a genetically modified organism to be either developed in
containment or imported into a contained facility. Such approvals include genetically
engineered mice for medical research;
10 field trials of genetically modified organisms in containment (including three
approvals for animals - goats, PPL Sheep and AgResearch cattle), several plant
approvals - including sugarbeet, potatoes, petunias and maize, and one fermentation
approval.
Of the genetically engineered field trials granted approval before the formation of
ERMA, seven are still current although several are in the post harvest monitoring stage
which was a condition of their approval. These trials were for sheep, pine trees and
crops.
Earlier this year [2000] ERMA completed a nationwide check of 27 research facilities
around New Zealand to find out what GM work was being conducted. ERMA found that
of the 1065 GM experiments, 152 current experiments had not been approved and a
further 39 were old work without approval where the material had since been
destroyed.
In short, of the current experiments then under way in New Zealand labs and research
facilities, around 15% were found to be unauthorised, or illegal. The absence of
monitoring or approval for these experiments raises issues around the ethics of the
projects, their safety, the containment of the organisms and the intent of the
scientists conducting them.