3.
section 3.7 |
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
3.7
Evidence and uncertainty
127
Introduction
127
Submitter profile
127
Content of the submissions
128
Key themes
128
Public perception
128
Causes of public uncertainty
128
Acceptable and unacceptable uses
130
Research into public attitudes
131
Changing public perception
132
Risks and safety
132
Risk management
133
Uncertainty about impacts
139
Environmental impacts
139
Health impacts
140
Commercial and economic impacts
141
Research and education impacts
142
Social impacts
143
Concluding observations
143
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3.7 Evidence and uncertainty
Introduction
Warrant item (b), called for information on:
the evidence (including the scientific evidence), and the level of uncertainty, about the
present and possible future use, in New Zealand, of genetic modification, genetically
modified organisms, and products
Submitter profile
Thirty-five submissions made substantial comment on this item of the Warrant.
Of these, 20 submissions came from the economic/production sector. Five
submissions were received from organisations in the environment sector; three
from organisations in the health sector and six submissions were received from
other sectors, such as governance organisations. One submission was received
from an organisation with a cultural or ethical focus.
The majority of the submissions supported the use of genetic modification,
genetically modified organisms and products in New Zealand. Twenty-one of the
submissions making substantial comment on the Warrant item had taken an
overall stance that was `strongly for' genetic modification, with another two
submissions `tending to be for' the use of genetic modification. Only five were
`strongly against', with a further four submissions taking a stance that `tended to be
against' genetic modification. The remaining three submissions took a stance that
was `neither for nor against' genetic modification.
The majority of the submissions came from organisations with an interest in either
researching genetic modification or the development or promotion of genetic
techniques or genetically modified products. Five of the submissions came from
private companies, some of which dealt with genetically modified products and
some of which dealt with natural and organic products. Nine submissions came
from industry networks or associations and six from research organisations. Seven
advocacy networks and associations also made substantial comment and the
remaining eight submissions came from a variety of organisations, including two
from Maori organisations and two from consumer networks and associations.
One organics organisation and one occupational or professional organisation
each made submissions.
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Content of the submissions
Some submissions discussed briefly the future uses of genetic modification.
Several submissions from patient representative organisations and from other
agencies working in the health sector stressed the increasing importance of the
technology, particularly since completion of the human genome project.
Submissions from primary sector organisations outlined the likely future uses of
the technology in pastoral agriculture and cropping. Aventis CropScience [IP14]
listed the genetically modified plant varieties that it intended to make available in
New Zealand. The forestry industry submissions also referred to the future use of
genetic technology in the production of timber and timber products.
None of the submissions, however, dealt in any length with the future uses of
genetic modification. Instead, this Warrant item was used as an opportunity to
express views on the level and scope of uncertainty relating to genetic modification,
and, in particular, to deal with issues relating to the risks and safety of the
technology. This focus on uncertainty, rather than evidence of use, may have been
the result of an apparent overlap between this Warrant item and the previous
Warrant item (a), which had sought information on the present use of genetic
modification in New Zealand.
Key themes
Three key themes relating to uncertainty emerged from the submissions making
substantial comment on this Warrant item. These were:
*
the public's perception of the technology
*
uncertainty about the ability to manage the risks of genetic modification
*
the possible impacts of the use of genetic modification.
Public perception
Several submissions discussed the public's perception of genetic modification,
genetically modified organisms and products. Irrespective of whether the
submissions supported or opposed the use of genetic modification, there was
agreement that the public had, in general, a negative perception of genetic
modification and was uncertain whether it should be used.
Causes of public uncertainty
There was no shared common view of the cause of public uncertainty about
genetic modification. Some submissions, particularly those from opponents of
genetic modification, considered that the public's reluctance to accept genetic
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modification was because of the risks associated with the technology. They
suggested that an awareness of the inherently unpredictable nature of gene
technology and the potential for widespread and irreversible adverse effects
provided a justified basis for public uncertainty about the acceptability of genetic
modification.
Proponents of genetic modification, and some submissions that took a more
neutral stance, suggested that the public's concern about the safety of genetic
modification was no different from the doubts that had been expressed in the past
when a new technology was introduced. They suggested that public uncertainty
would diminish with time and familiarity. Submissions from the opponents of
genetic modification, however, saw no similarity between past new technologies
and the development of genetic technology, which was seen as moving into areas
beyond current scientific knowledge. These submissions did not, therefore, accept
that public uncertainty would lessen with time: they suggested that public
uncertainty could be removed only when there was adequate proof that the use of
the technology would be without risk.
Several submissions suggested that public uncertainty arose from insufficient
knowledge and understanding of the technology. Monsanto New Zealand [IP6],
for example, suggested, "Much of public uncertainty in New Zealand arises from
poor communication to the public of the science behind genetic modification and
of the real and potential value of its products." Other submissions suggested that
uncertainty about the technology resulted not simply from a lack of understanding
of the technology but also from the difficulty the public experienced in accessing
"reliable" information. In the absence of easy access to information, even people
who had an understanding of the technology had insufficient information on
which to make judgments about its use.
Submissions from various organisations involved in the research and development
of genetic modification suggested that increasing the public's understanding and
knowledge of the technology would help allay some of the public uncertainty
about the use of genetic modification. The view that access to information would
increase the acceptability of the technology was not shared by all the submissions.
Interchurch Commission on Genetic Engineering [IP49] agreed that there was a
need for more information to be made available to the public but did not agree that
increased information would necessarily result in a greater public acceptance of
genetic modification. Interchurch Commission suggested that uncertainty was
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caused by "fear of the unknown" and by "feelings of powerlessness" and
commented that there were "deep-seated and fundamental ethical concerns to be
addressed with the general public" which would not necessarily be dispelled by
providing additional information about the technology. Other submissions,
particularly from religious and spiritual groups, confirmed this view, and some
submissions from Maori groups indicated that there was considerable uncertainty
about the appropriateness of using genetic modification within the Maori
cultural and spiritual framework, the precepts of which amounted to a rejection of
the technology.
Some submissions claimed that the public's negative perception of genetic
modification and uncertainty about its safety was the result of an international
political campaign against "free trade and the global marketplace", which the
submission from New Zealand Life Sciences Network [IP24] suggested was based
on the "calamity theory". The submission explained that this theory "postulates
[the] worst-case scenario as though it were an inevitability" and therefore
encouraged the public to be uncertain about the safety or appropriateness of the
use of genetic modification..
Acceptable and unacceptable uses
Submissions tended to agree that, because of the current level of uncertainty, it
would be difficult to determine what future uses of the technology would be
acceptable to the public. Notwithstanding the general concern and uncertainty
about genetic modification, some submissions suggested that the public already
accepted certain uses of genetic modification. Submissions also suggested that
other uses of genetic modification were unlikely ever to be acceptable.
Some uses of genetic modification that were identified as likely to be unacceptable
to the public for a long period of time, such as cloning and xenotransplantations,
fell outside the Warrant's ambit. Of the uses that came within the scope of the
Warrant, the creation of transgenic organisms using human genes was one use that
many submitters were certain would not gain public acceptability.
Several submissions also stated the belief that genetic modification in food was a
use that would never be acceptable because of the long-term risk to human health.
Other submissions did not go as far as to suggest that genetically modified food
would never be acceptable, but did suggest that there was a general discomfort
with the idea of eating modified foods knowingly. Submissions from organisations
involved in the production of food, while strongly disagreeing that there was a risk
to human health, acknowledged that genetically modified food was not widely
acceptable to the public and that there was strong consumer resistance to its use.
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Because of this, the submitters suggested New Zealand producers would be
unlikely to use genetic modification in the production of foodstuffs such as meat,
fruit and vegetables until there was a change in public attitudes.
Submissions also suggested that, despite public uncertainty, some uses of genetic
modification were already accepted by the public. Submissions from organisations
involved in pure research stated that low-risk, scientific research projects involving
genetic modification that were carried out in containment in the laboratory were
generally accepted. These submissions, particularly those from universities,
emphasised that any policy with regard to genetic modification should not result in
the prohibition of genetic modification for research and teaching purposes.
Medical research organisations also emphasised that the use of genetic modification
as a diagnostic and therapeutic tool was already widely accepted by the public. The
submissions suggested that this public acceptance arose either because the use was
seen as being carried out in containment or because the use of the technology was
considered to be a matter of individual choice. Only a handful of submissions
suggested that medicines and treatments involving genetic modification were not
acceptable. The reasons given were concerns either about safety or about the
reduction of research into alternative, non-genetically modified methods of
treatment if the focus shifted to development of treatments using gene technology.
Research into public attitudes
Several submissions considered that it was not easy to determine which future uses
of genetic technology would be acceptable to the public because of the different
factors that influenced individual perception. Nevertheless, because the
acceptability and consequent use of genetic modification would be determined by
the public's perception of genetic modification, the submissions suggested there
was a need to research public attitudes towards the technology.
Some submissions indicated that research into public attitudes had already been
undertaken or were under way. Landcare Research [IP12] discussed the research it
had undertaken into public attitudes as part of its research into possum control.
AgResearch [IP13] advised that it had been asked by University of Waikato to
contribute to a Foundation for Research, Science and Technology (FRST) tender
proposal to determine key potential effects and acceptability of genetically
modified organisms. Church groups, such as Interchurch Commission [IP49] and
Anglican Church in Aotearoa New Zealand and Polynesia [IP42], had also carried
out research and consultation among church members to determine attitudes
towards genetic modification.
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Research organisations, however, indicated a need for increased social, as well as
scientific, research as part of the development of genetic modification, genetically
modified organisms and products. The submission from Landcare Research [IP12]
commented:
Our experience is that social research is invaluable in defining some of the uncertainties
about the likely use of particular GM products, and hence the specifications that a GM
product will need to meet. We strongly believe that ongoing research on attitudes, social
learning and public acceptance will be essential and, increasingly, at least as important as
biotechnological research.
Changing public perception
Several of the submissions made suggestions on how the public's uncertainty about
genetic modification could be changed to increase acceptance of the technology.
Submissions suggested that the provision of reliable information would develop
greater public understanding and acceptance of the technology, and that uncertainty
about its safety would be resolved by increasing public confidence in the ability of
science to manage any risks resulting from its use. Submissions from the
proponents of genetic modification believed that uncertainty would lessen if the
public felt confidence in a regulatory framework that assessed the risks and the
benefits resulting from the technology and ensured that the technology was
applied within the bounds of public acceptability. Submissions from opponents of
genetic modification, however, suggested that public confidence in the present
regulatory framework and, in particular, in the regulatory agencies was very low.
Risks and safety
Most of the submissions identified safety concerns as the major source of
uncertainty about future use of genetic modification in New Zealand. There was,
however, general acceptance that the use of genetic modification for research
purposes in laboratory containment should continue because of the low level of
risk from such use. The discussion in most of the submissions focused on the
environmental risks associated with the use of genetic technology for agricultural
purposes, and the risks to human health from genetically modified food.
Opinions diverged sharply about the use of genetic modification outside laboratory
containment for agricultural research purposes. Whereas agricultural research in
laboratories was accepted in most of the submissions, the opponents of genetic
modification made no differentiation between field trials of genetically modified
plants or animals and the release of genetically modified organisms into the wider
environment. Research organisations, however, considered field trials to be a
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necessary extension of laboratory research. The submissions pointed out that
field trials were subject to strict controls that minimised the likelihood of risk and
were, therefore, different from the general release of genetically modified
organisms and products.
In considering whether or not there were risks associated with the use of genetic
modification, many submissions focused on environmental risks. Such risks
included: the development of "super-weeds" from herbicide-resistant, genetically
modified plants; the risk of cross-pollination of non-genetically modified crops by
pollen from genetically modified plants; and the risk of contamination of honey
products if bees collected pollen and other materials from genetically modified
plants. The horizontal transfer of genes from genetically modified organisms to
non-target organisms was also identified as a risk.
Several submissions were concerned about the risks to human health posed by the
consumption of genetically modified foods. Submissions identified a risk that
consumption of the food from plants into which genes had been inserted could
allow transfer of those novel genes to humans. Some submissions suggested that
there was a risk that genetically modified foods could contain unknown allergens
or toxins or could produce unanticipated toxic and allergenic reactions as a result
of genetic modification. The use of antibiotic resistance as marker genes was also
identified as a risk to both human and animal health and to the environment.
There was considerable disagreement in the submissions as to whether there was
any evidence to show that the risks associated with the use of the technology were
actual rather than theoretical. Opponents of genetic modification quoted overseas
studies that found that some of the possible adverse effects identified, particularly
the contamination of non-genetically modified crops by pollen from genetically
modified crops, had already occurred. They suggested that science lacked sufficient
knowledge to predict the risks and ensure the safety of the technology. Supporters
of genetic modification, however, pointed to the 20 years over which genetically
modified organisms had been safely used and stressed the considerable body of
knowledge of the technology that had been built up over that time. Submissions
also cited a number of international regulatory agencies that had approved the
release of genetically modified products. The findings of overseas inquiries, such
as the April 2000 report of the United States Congress Committee on Science,
were also cited in submissions as evidence of the safety of genetic modification.
Risk management
It was clear from the submissions that the debate between those who supported the
use of genetic modification and those who opposed its use outside laboratory
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containment focused on whether the risks associated with the use of genetic
technology could first be ascertained and then managed within an acceptable level
of risk.
Submissions from those who opposed the use of genetic modification expressed
concern about the technology's inherent unpredictability and the difficulty of
reversing or containing any harm to human health or to the environment caused
by the release and use of genetically modified organisms. Green Party of Aotearoa/
New Zealand [IP83] expressed strong doubts about the current ability of science to
understand and predict the outcomes of the use of genetic modification and
suggested that:
The inherent uncertainties of the technology itself mean that it poses inescapable risks in
New Zealand, both to human health and to the environment. Genes do not operate in
isolation; the transgene will affect, and be affected by, the other genes in the cell, and by
where it is positioned and how many copies of it are inserted. Currently none of this can
be controlled by genetic engineers when they create new chimaeric organisms.
This submission was particularly concerned about a number of hypothetical
pathways, inherent in the nature of the recombinant process itself, by which
unpredictable disruptions of biological systems could occur. It stressed the need
for further research before the risks associated with the use of the technology
could be fully ascertained and a decision made on its use in the community.
Several submissions also expressed uncertainty about the safety of the technology
and recommended the application of the "precautionary approach" or
"precautionary principle" to the use of genetic modification. Submissions that
advocated the precautionary principle did not, however, appear to have a shared
understanding of the meaning of the term
1
. In some submissions the term was
taken to mean that no use of genetic modification should be permitted until
uncertainties about its safety and impact had been thoroughly researched and
satisfied. The submission from Friends of the Earth (New Zealand) [IP78] applied
the principle, as set out in the Hazardous Substances and New Organisms Act
1996, to advocate the compulsory labelling of all genetically modified products
and products containing genetically modified ingredients.
Other submissions suggested that adoption of the precautionary principle was
neither necessary nor appropriate to ensuring the safety of genetic modification.
1
For a discussion of varying interpretations of the precautionary principle, and its use internationally and in New
Zealand, see Appendix 1 ("Current status of genetic modification in New Zealand: Genetic modification and the
precautionary approach").
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Biotenz [IP25] pointed out that there was no internationally accepted formulation
of the principle and suggested that calls for its application were politically
motivated and would lead to political rather than scientific decisions on the safety
of genetic modification.
Proponents of genetic modification neither considered that the technology was
unpredictable nor believed that the risks were inherent in the technology itself.
Risk, several submissions stated, arose from the use of the technology and not from
the technology itself. The actual risks associated with a particular use of genetic
modification could be identified and managed only on a case-by-case basis. The
submissions were confident that sufficient reliable research information existed, or
was being rapidly developed, "to allow society's decision-makers to have a
workable understanding of the risks of the technology" and considered it
unnecessary to delay the use of genetic technology until there was less or no
uncertainty. Some submissions also shared the view expressed by New Zealand
Biotechnology Association [IP47] that:
... research investments into the uncertainties of GM needs to be increased. While this is
seen as integral to any research strategy/proposal involving GM a heightened awareness
will help alleviate public concerns.
Opponents of genetic modification did not share this confidence and expressed
considerable uncertainty as to whether current science had developed sufficient
knowledge of the actual risks of genetic modification to give adequate assurances
of safety before the technology was used. The submission from Bio Dynamic
Farming and Gardening Association in New Zealand [IP61] said:
It is reasonable to expect those who would expose us, our food, and our natural and
agricultural environments to genetically modified organisms to demonstrate that they can
manage the risks to very high standards ... Risk management should be empirical. It
should be based principally on observation of behaviour. ... In the long run, the only way
to know what an organism does in particular circumstances is to observe it. Anything else
is conjecture ...
Level of risk
The proponents of genetic modification saw the demand for complete certainty as
being a requirement that proposed uses of the technology satisfied a "zero risk"
standard. Several of the submissions suggested that the standard was "unrealistic
and unachievable" and suggested that the appropriate response to public uncertainty
was to identify and assess the risks of a particular use of genetic and to manage
those risks effectively to reduce their negative impacts.
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Submissions that took a more neutral stance on the use of genetic modification
also suggested that absence of risk was unrealistic, although many stressed the
need for caution in adopting the technology and for ongoing scientific research
into its uncertainties. The submission from Rural Women New Zealand [IP52],
for example, said:
It is in the nature of developing technologies - where the level of empirical knowledge
is low - that various levels of uncertainty are inevitable and that risks may not be fully
calculable. These uncertainties must be recognised.
The only real certainty is of our lack of certainty. Honest science is modest and cautious
... Science gets into trouble when it takes on spurious certainty in aid of commerce or
government ...
Scientific risk management
In response to uncertainty about the risks of genetic modification, many of the
submissions from research organisations and from private companies involved in
the research and development of genetically modified products, suggested that an
acceptable level of risk management would be achieved through properly
conducted, scientific risk assessment processes. The submission from New Zealand
Dairy Board [IP67] suggested:
The proper approach to the uncertainties involved in any new technology or scientific
discovery is to research the possible known consequences, and to assess the risk of
possible unforeseen consequences, by proper scientific methodology.
Other submissions supported the view that science allowed for a reduction in
uncertainty by ensuring appropriate risk management. Many submissions also
added that a robust regulatory system would ensure that a proper scientific
assessment of the risks was undertaken. Approval of the current regulatory
framework was expressed by several submissions from organisations working
within the primary sector and within health and medicine research. Some of the
opponents of genetic modification, however, expressed strong doubts about the
ability of regulatory authorities such as Australia New Zealand Food Authority and
Environmental Risk Management Authority to respond appropriately to public
uncertainty about the use of genetic modification.
Scientific uncertainty
Submissions from opponents of genetic modification were not confident that
scientific method would offer certainty that the risks could be managed. The
submission from Safe Food Campaign [IP86] sought to "conceptualise what the
level of `scientific uncertainty' ... means". The submission pointed out that
traditional risk assessments were based on quantifying the probability of
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occurrence based on past events. It suggested that:
Genetic modification defies traditional risk estimates as both the probability of
occurrence of harm and level of possible harm are unknown.
This submission concurred with that of Bio Dynamic Farming and Gardening
Association [IP61] that current risk assessment was based on "conjecture" rather
than on empirical fact.
The strongest expressions of uncertainty about the lack of long-term scientific
research came in the submissions from consumer networks and associations
expressing concerns about the effects of genetic modification on food and, as a
consequence, on human health. Submissions from organisations in the area of
food and food ingredient production, however, emphasised the safety of their
products and cited the effectiveness of the relevant regulatory agencies in ensuring
food safety.
Proponents of genetic modification considered that sufficient knowledge had been
developed over the 20 years in which the technology had been used to ensure the
safety of current use of genetic modification. Some submissions also stated that the
technology was more precise in achieving desired outcomes than the equivalent
traditional methods, particularly in relation to the development of specific traits in
plants by genetic modification rather than by conventional plant breeding
techniques. Submissions from organisations in the health sector suggested that
genetically modified products, such as human insulin from recombinant DNA
production methods, were purer than pharmaceuticals produced by conventional
means. It was not accepted, therefore, that use of genetic modification necessarily
involved an unacceptable level of risk.
Opponents of genetic modification not only were uncertain about the ability of the
scientific method and of current scientific knowledge to identify and accurately
assess the risks of using genetic modification in New Zealand but also were
distrustful of scientists and of the context in which genetically modified products
were developed. This distrust was clearly evidenced in the submission from Royal
Forest and Bird Protection Society, Nelson/Tasman Branch [IP43], which stated:
Scientists themselves have given us a feeling of uncertainty and unpredictability. They
have been influenced by a world view which is manipulative and exploitative. To carry out
research they have had to canvas funding from vested interests which gives an emphasis to
exploration but not to environmental effects. Their world focuses narrowly on genes,
without consideration of organic wholes, such as organisms, ecosystems, societies and
communities. Globalisation is pushing genetic engineering biotechnology with quick
profit the goal. Government has been helping, with power and kudos as well as profit, the
goal.
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Submissions from research organisations emphasised that scientists themselves
had a responsible attitude to ensuring the safety of genetic modification, genetically
modified organisms and products. Several submissions explained that, in addition
to satisfying any regulatory requirements, concerns and potential risks had been
addressed by agencies voluntarily developing their own policies and best practice
procedures and by establishing committees to oversee and monitor such activities.
AgResearch [IP13], one of the organisations involved in primary sector research
and development, outlined its internal risk management and best practice policies.
The submission referred to the inclusion of an environmental research strategy in
its research projects that had environmental outcomes. It also mentioned
contributions of its staff to the exploration of the ethical dimensions of
biotechnology through a number of forums.
Amongst the private companies involved in the development of genetic
modification, the submission from Monsanto New Zealand [IP6] described in
detail the environmental and health and safety assessments undertaken by the
company, in response to public concerns, during the research and development
stages of its products.
Access to scientific information
Several submissions mentioned the importance of information in allaying
uncertainties about genetic modification. Sometimes the reference was to
information by way of general knowledge or education. Some submissions,
however, stressed the importance of information to risk management. Concern
was expressed in some submissions over difficulties in accessing scientific
information relevant to the risks of genetic modification. A number of submissions
from opponents of genetic modification, for example, suggested that the barriers
to accessing test results and other research information, particularly information
held by private companies, led to uncertainty about the safety of the technology,
and also raised ethical doubts about its development. The submission from Golden
Bay Organic Employment and Education Trust [IP104] stated:
Since unbiased and independent short and long term testing of GE, GE organisms, and GE
products is not available and since the data that has been made available has been
provided by the corporations, institutions and scientists who stand to profit monetarily,
the level of uncertainty is very great.
Comvita New Zealand [IP74], a private company dealing in bee products, had a
particular interest in ascertaining that the use of genetically modified crops
would not result in contamination of honey and other bee products. The
submission commented on the scarcity of good science information relating to
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this question, "at least in the public domain" and referred specifically to research
on bees carried out in Canada, the results of which had not been made available
because of "the work was confidential". Other submissions, from both the
proponents and the opponents of genetic modification, also referred to the
difficulty of gaining access to research information held by private companies.
Concern was expressed that the development of genetic modification by private
interests would result in research information essential to risk management
becoming increasingly less available.
Uncertainty about impacts
The submissions demonstrated that the uncertainty about the impact of genetic
modification focused mainly on the likely environmental impacts, on the impacts
on human health from the ingestion of genetically modified food and on the
commercial and economic impact of the use, or avoidance, of genetic modification.
Medical research organisations and the universities expressed concern about the
impact that prohibition of genetic modification in New Zealand would have on
research and tertiary education and there was some discussion of the social impact
of either the use of genetic modification or its avoidance.
Environmental impacts
The submissions indicated uncertainty about the possible environmental impacts
of the use of genetic modification. The submissions from the opponents of genetic
modification, in particular, were uncertain about the safety of releasing genetically
modified organisms into the New Zealand environment. The submissions
expressed concern that the impact of genetic modification on non-target systems
would threaten ecosystems, weaken biodiversity and increase the possibility of the
development of plant diseases and insect pests more resistant to control measures.
Several submissions pointed out that much of the research on the impact of
genetically modified organisms had been carried out overseas: insufficient research
had been done to predict with any accuracy the likely impact on the New Zealand
environment, particularly on indigenous flora. Particular concern was expressed in
some submissions about the possible impacts of genetic modification on soil and
on honey bees.
The submissions from private companies and from organisations involved in the
primary production sector emphasised that there was sufficient scientific evidence
to prove that no adverse environmental impacts would be caused by the current
uses of genetic modification. Nevertheless, they agreed that there was a need to
carry out research specifically in relation to the New Zealand environment.
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Submissions from the Parliamentary Commissioner for the Environment [IP70],
as well as from environmental agencies such as Greenpeace New Zealand [IP82]
called for additional research into the potential environmental and ecological
effects of genetic modification, as did a number of the Crown research institutes.
Submissions from some of the research organisations and particularly from
Landcare Research [IP12] referred also to the potential environmental benefits
that would result from the use of genetic modification. The submissions suggested
that, within the next decade, it would be possible for the technology to be used for
the management of pests, diseases and endangered species and for the avoidance of
environmental degradation and promotion of sustainability.
Health impacts
The majority of submissions that discussed the use of genetic modification for
therapeutic or pharmaceutical purposes considered that the impact, at least for
individual patients and their families, would be beneficial. Several submissions,
including some that concentrated mainly on the environmental impacts, did not
consider this usage of the technology. Only a few submissions suggested that there
might be "difficulties" with the use of genetic modification, genetically modified
organisms and products in the treatment of disease or genetic conditions. The
submission from Nelson GE Free Awareness Group [IP100], for example, stated:
"There is much proof that there are many problems in the medical application of
Genetic Engineering", and raised issues about the approval of drugs overseas and
the role of pharmaceutical companies in the promotion of genetically modified
products. Submissions also expressed concern that focusing on the development of
genetic technology could result in the neglect of research into alternative, non-
genetic strategies.
Patient representative groups and medical research organisations were, however,
more concerned about the impact of the withdrawal of genetically modified
treatments if use of the technology were to be prohibited in New Zealand. All the
submissions stressed the increasing importance of retaining and extending the use
of genetic modification for therapeutic and diagnostic purposes and the potential
for new developments in the treatment of diseases that were presently difficult to
treat.
Despite the general acceptance of genetic modification for medical purposes,
several submissions suggested that genetic modification would have a negative
impact on human health through the ingestion of genetically modified food.
Submissions from organisations such as Safe Food Campaign [IP86], Green
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Party [IP83] and Pacific Institute of Resource Management [IP84] expressed
strong doubts about the safety of eating genetically modified food. Other
submissions also suggested that the public is more uncertain about the impact of
genetic modification in food than it is about the medical use of the technology.
The submissions suggested that uncertainties stem either from a concern about
the effect that genetically modified food might have on individual health, or
because of ethical concerns, or for some other undefined "unease", particularly
with transgenic food.
Commercial and economic impacts
Several submissions indicated that there was uncertainty about the commercial
impact of genetic modification, genetically modified organisms and products,
particularly on the primary production sector.
Submissions from organisations involved in the research and development of
genetic modification for application in the primary production sector and in
forestry emphasised the benefits these products would have for primary sector
industries through increased productivity and lower production costs. Submissions
also suggested that New Zealand could not remain internationally competitive
unless the use of genetic modification was permitted.
Some submissions from organisations opposing the use of genetic modification
suggested, however, that primary industry would not necessarily benefit from
genetic modification. Submissions cited overseas information that suggested that
the yield from genetically modified crops would not be as great as was expected.
Submissions also pointed to shrinking markets for genetically modified food as a
result of international concern and rejection of the technology. Many suggested
that, rather than having a positive economic benefit, the use of the technology was
likely to result in less than expected returns from conventional farming, together
with a missed opportunity for the country to take advantage of the growing
demand for organic food.
Several submissions expressed concern at the impact that the use of genetic
modification would have on overseas markets for organic and natural products.
Submissions from organisations involved in the marketing of natural and organic
products were concerned that adoption of genetic modification would lead to a
removal of certification from their products. Submissions stressed the importance
of taking into account marketing and economic issues as well as safety issues when
applications for the use of genetic modification were considered.
The joint submission from New Zealand Vegetable and Potato Growers'
Federation/New Zealand Fruitgrowers' Federation/New Zealand Berryfruit
Growers' Federation [IP75] also suggested that the possible impact on other
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industries should be taken into account when permitting the use of genetic
modification in New Zealand. The submission referred to the importance of New
Zealand's "clean green" marketing image and suggested that the impact of
permitting the use of genetic modification on this image is uncertain. The
submission also indicated that, because of an apparent rejection of genetically
modified food by consumers, the Federations' members were unlikely to produce
genetically modified products in the short-term. The use or avoidance of genetic
modification was, however, a matter of individual grower choice. Other submissions
from food producers suggested that the use of genetic modification would be
avoided in the short term because of the likely impact on product sales.
The joint submission of New Zealand Feed Manufacturers Association/Poultry
Industry Association of New Zealand/Egg Producers Federation of New Zealand
[IP35] was concerned about the impact that avoidance of genetic modification
would have on the industry. The submissions suggested that additional costs would
be incurred by the industry if it were required to authenticate the source of its
products. The submission suggested it would be difficult and costly, for example, to
obtain "authenticated GE free soya meal" for stock feed, if labelling were required
or if genetic modification were prohibited. The submission also pointed out that
the poultry industry would have no control over decisions on the use of genetic
modification taken by the overseas sources of breeding stock, on which the New
Zealand industry is dependent.
A few submissions questioned whether there was a need for genetic modification
in agriculture. Sustainable Futures Trust [IP51] suggested that, because current
food production was sufficient to meet the country's needs, there was no need for
the technology to increase food production. BIO-GRO New Zealand [IP58] also
questioned the need for genetic modification to increase food production. BIO-
GRO suggested that sustainable food production was best met by encouraging the
development of organic food production rather than by using genetic modification,
genetically modified organisms and products.
Research and education impacts
Submissions from research organisations and the universities were particularly
concerned about the impact that avoidance of genetic modification would have on
research and on tertiary education in New Zealand. Universities in particular
suggested that avoidance of the technology would affect not only New Zealand's
research capabilities, but also, because of the international importance of
biotechnology in research and learning, teaching at undergraduate and graduate
level. Submissions suggested that students, particularly overseas students, would
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not attend New Zealand universities if teaching in the area of gene technology
were prohibited, and there would also be difficulties in staff retention and
recruitment.
The use of genetic technology for research purposes, however, was not a
contentious issue in most of the submissions, and submissions from both proponents
and opponents of genetic modification tended to accept the use of the technology
in the area of teaching and research. There were, however, some uncertainties that
might impact negatively on research, particularly research into genetic
modification. Several submissions opposed the conduct of field trials of genetically
modified plants and animals. Clinical trials of genetically modified medicines were
not, however, addressed in the submissions. There was also opposition to the use
of transgenic animals for research purposes from SAFE (Save Animals From
Exploitation) [IP85] and other submissions concerned about the use of genetic
modification.
Social impacts
Submissions suggested there was uncertainty about the social benefits that would
result from the use of genetic modification. Doubt was expressed over the effect of
using genetic technology in ways unacceptable to the public, or without public
knowledge, particularly in respect of genetically modified food. Submissions urged
that the social costs, including the cost to the ethical and cultural beliefs of
individuals and ethnic groups, should be taken into consideration when assessing
the benefits of using the technology.
Several submissions referred to the social as well as the economic cost of ignoring,
or of unnecessarily withholding, the benefits of genetic modification from the
population. New Zealand National Commission for UNESCO [IP90], for example,
pointed out that if the technology resulted in positive benefits, "then these benefits
for humanity cannot be foregone." The submission, however, suggested that there
was a need for further research and for open access to information to reduce the
level of uncertainty and apprehension.
Concluding observations
The submissions all recognised that there was a high level of uncertainty amongst
the general public about the use of genetic modification, genetically modified
organisms and products in New Zealand. Most of the submissions accepted that
concern about the safety of gene technology was the main cause of uncertainty but
disagreed as to whether this concern was justified.
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Submissions generally accepted that there were less uncertainty about the use of
genetic modification for therapeutic purposes and also accepted the use of genetic
modification for research purposes. The two main areas of uncertainty about the
use of genetic modification were in relation to environmental impacts and its use
in food.
Despite the uncertainty about the use of genetic modification, genetically modified
organisms and products in New Zealand that was either expressed or recognised in
the submissions, few submissions called for a total and permanent ban on the use
of genetic modification. Neither did any of the submissions advocate unrestricted
use of the technology. Submissions across the range of organisations called for a
cautious approach to the use of the technology but differed significantly in their
views of the manner in which caution should be exercised.
Many of the opponents of genetically modified organisms saw caution as requiring
a delay in releasing genetically modified organisms into the environment until
research in laboratory confinement had created a sufficient body of scientific
knowledge to ensure the safe use of the technology. Even in relation to genetically
modified food, most submissions did not call for a total and permanent ban. The
majority of submissions expressing uncertainty about genetically modified food
required increased assurance as to its safety and the implementation of labelling of
all food products which were genetically modified, or which contained genetically
modified products or which were the result of a production process involving gene
technology.
Proponents of genetic modification agreed to the need for a cautious approach.
These submissions, however, suggested that caution should be exercised on a case-
by-case basis, in relation to a specific use of the technology. This approach
required a robust regulatory system and effective regulatory authorities to ensure
that appropriate risk assessment and risk management measures, based on
scientific principles, were applied before the use was approved. Although a number
of submissions agreed that there was a need for research into specific impacts of
genetic modification, particularly environmental impacts, they did not agree that
field trials posed any risk to the environment. Submissions from organisations
whose activities related to the production and marketing of genetically modified
food did not agree that there was any risk to human health, but recognised that
consumer resistance might affect the use of genetic modification in the food chain.
From the responses to Warrant item (c), it appears that:
*
There is general agreement that genetic modification for research purposes
should be permitted in New Zealand, but there is disagreement that
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laboratory research should include field trials of genetically modified plants
or animals.
*
There is general agreement about need for further research into the impacts
of genetically modified organisms on the New Zealand environment, but
there is disagreement as to whether this research should be undertaken in
relation to specific proposed uses or whether it should be undertaken only at
laboratory level.
*
There is uncertainty as to whether consumption of genetically modified
food poses a sufficient risk to human health to warrant a total ban on all
genetically modified food or food ingredients, or whether it is sufficient to
permit people a choice by requiring the labelling of food that has been
genetically modified or has been produced using genetic modification.
*
There is disagreement over the acceptable standard of risk.
*
There is disagreement over the effectiveness of the current regulatory
authorities in ensuring the safe use of genetically modified organisms.