3.
section 3.8 |
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
3.8
Risks and benefits
146
Introduction
146
Submitter profile
146
Content of the submissions
146
Key themes
147
Risks and safety
147
Risks of the use of genetic technology
148
Safety of the technology
148
Assessing the risk
150
Benefits and costs
151
Benefits of use
151
Costs of use
153
Benefits of avoidance
155
Costs of avoidance
156
Advantaged and disadvantaged groups
157
Concluding observations
158
Royal Commission on Genetic Modification | Report Appendix 2
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3.8 Risks and benefits
Introduction
Warrant item (c) required the Commission to consider:
the risks of, and the benefits to be derived from, the use or avoidance of genetic
modification, genetically modified organisms and products in New Zealand, including -
(i) the groups of persons who are likely to be advantaged by each of those benefits; and
(ii) the groups of persons who are likely to be disadvantaged by each of those risks
Submitter profile
Of the 48 submissions that made substantial comment on this Warrant item, 12
were from industry networks or associations, 10 from research organisations and
six from other advocacy networks or associations. Four private companies, four
consumer networks and associations and three Maori organisations made
substantial comment on the Warrant item. Two religious and spiritual organisations
made comment, two government bodies and two occupational or professional
associations. One submission came from an organics organisation and two from
uncategorised organisations.
The majority of the submissions that made significant comment on this Warrant
item were either `strongly for' or `tended to be for' genetic modification (31). Less
than half the submissions came from organisations that had indicated that they
were against genetic modification. Three of the submitting organisations were
neutral in their stance.
Content of the submissions
The submissions considered whether benefits, in terms of positive outcomes,
would result from the use or avoidance of genetic modification. Most of the
submissions sought to respond by identifying the specific benefits or risks that
accompanied the use or avoidance of the technology and to comment on
advantages and disadvantages that would result.
Although submitters used the term "risk" to identify and discuss hazards that
might result from the use of genetic modification, many also used "risk" to mean
the cost to resources, values or opportunities that would be imposed by the use or
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avoidance of genetic modification. To reflect these different uses of the word, this
section uses the word "risk" when describing submitters' views on the possible
adverse events and the word "cost" when describing the possible adverse effects or
impacts of the use or avoidance of genetic modification technology.
Key themes
The central theme that emerged from the submissions was the relationship
between the submitters' perceptions of the risk of genetic modification and of
benefit. Submissions from both the proponents of the technology and its opponents,
as well as from those organisations that took a more neutral stance towards the use
of the technology, recognised that benefits would result only if the risks of its use
did not outweigh any possible benefits. Many of the submissions, therefore,
included extensive discussion on:
*
the risks and safety of the technology
*
the benefits and costs of its use
*
the advantages or disadvantages that would result from its use or avoidance.
Risks and safety
The submissions could be divided into two main categories: those that were from
"proponents" of genetic modification, in that they emphasised the benefits that
would flow from its use; and those that were from "opponents" of technology, who
tended to stress the risks of the technology. None of the submissions from
proponents of genetic modification, however, advocated the unrestricted use of
genetic modification. Many of the submissions referred to conditions under which
the technology could be used safely, such as ensuring that a robust risk assessment
process was carried out under the supervision of appropriate regulatory agencies
before any release of genetically modified organisms. Several submissions also
emphasised the need for community acceptance of the proposed use of the
technology and for a range of non-scientific factors to be taken into account as part
of the risk assessment process.
Similarly, not all the submissions from opponents excluded the possibility of the
future release of genetically modified organisms and products or suggested that
there could never be any benefit in use of such technology. The majority of the
submissions from opponents of genetic modification emphasised the inherent
unpredictability of the technology and the risk that its use could cause irreversible
and widespread harm. Some submissions also expressed concern about the
difficulties of controlling and monitoring the technology once it had been released
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and, in particular, the risks of accidental escapes and cross-contamination (of
non-genetically modified systems by genetically modified ones). Nevertheless,
many of these submissions also accepted that there was already some benefit
being realised from the use of genetic modification in research and for medical
purposes, where the technology was used in laboratory containment. Some
submissions also contemplated the future use of genetic modification outside of
laboratory containment, but not until extensive research had been undertaken
and sufficient knowledge of the technology developed to permit a proper
assessment of the risks. Until then, the risks of using the technology outside
laboratory containment outweighed the benefits.
Risks of the use of genetic technology
Both the proponents of genetic modification and its opponents identified several
possible risks associated with its use. Environmental risks from horizontal gene
transfer to non-target plant and animal species and from the contamination of
non-genetically modified plants by pollen from modified varieties were discussed
in many of the submissions. Such risk was the focus of the majority of the
concerns. Several submissions expressed concern about the risk that horizontal
gene transfer posed to soil; some commented on the risk that pollen from
genetically modified plants posed to bees.
Several submissions, such as that from Safe Food Campaign [IP86], emphasised
concerns about the risks of genetically modified food, particularly of the
development of unexpected allergenicity properties in genetically modified food
sources and increased resistance to antibiotics through the use of antibiotic
resistance as marker genes.
Whereas some submissions suggested that genetic technology was risky because of
the unpredictability of the technology, others suggested that it was risky because of
the difficulties of ensuring that genetically modified agricultural products did not
contaminate unmodified products (either through cross-contamination by pollen
or because of human mistakes in handling genetically modified commodities). The
submissions from Commonsense Organics [IP66] and Greenpeace New Zealand
[IP82] cited various overseas events that had resulted in unauthorised releases of
products (eg, Starlink corn); they also quoted evidence to show that there had been
instances both of cross-contamination by pollination and of product contamination.
Safety of the technology
Most of the submissions that supported the use of genetic modification
acknowledged possible risk but emphasised that there was evidence that the use of
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the technology was safe. Organisations involved in the research and development
of genetically modified plants claimed that, during the 20 years over which the
technology had been used, there had been no evidence of any adverse incidents.
Other organisations, such as those involved in the production and distribution of
food, pointed to the work of the relevant regulatory bodies in ensuring the safe use
of genetic modification. Medical research organisations, and groups representing
patients, particularly emphasised that no risks had been identified from the use of
gene therapies.
Although many submissions expressed confidence in the safety of genetic
modification, most were cautious in their approach to issues of risk management.
Submissions pointed out that no technology was risk free and that science could
not, therefore, give an unconditional guarantee of safety. Submissions, particularly
from the Crown Research Institutes, referred to the need for "responsible" use of
genetic modification and for a robust risk assessment process to be carried out
within a credible regulatory framework.
The submissions from the opponents of genetic modification, however, expressed
doubts whether the technology could be used safely, either because of concern
about the inherent risks of the technology or because of doubts that the adverse
impacts of genetically modified organisms released into the environment could be
managed.
Green Party of Aotearoa/New Zealand [IP83] placed particular stress on the
inherent unpredictability of genetic technology and provided witness evidence to
demonstrate the possibility of unexpected effects resulting from the use of
genetically modified organisms. The submission referred to the identification of
"risk pathways" that suggested modified organisms could behave, under certain
conditions, in ways that had not been predicted during the risk assessment process.
There were two main convergences in concerns about the safety of the technology:
environmental risks and risks posed by genetically modified food. Submissions
from organisations such as Safe Food Campaign [IP86] and GE Free New Zealand
(RAGE) in Food and Environment [IP63] emphasised the inadequacy of the tests
carried out by the Australia and New Zealand Food Authority to ensure the safety
of genetically modified food. Several submissions called for the banning of
genetically modified food because of safety concerns; others, such as that of Green
Party [IP83], suggested there was a need for robust and appropriate pre-market
safety testing to ensure the safety of genetically modified foods before they were
made available to consumers. Submissions also stressed the need for enforcement
of labelling requirements so consumers could avoid the risks of genetically
modified food.
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Many of the submissions from the opponents of genetic modification pointed out
that, even where there was no evidence of harm having resulted, there was also no
evidence that the technology could be used safely in the future. Several also
pointed out that, in relation to food, the long-term effects on human health of
ingesting genetically modified food were unknown.
Assessing the risk
Several submissions from organisations involved in the research and development
of genetically modified food pointed out that benefits from its use could not be
realised until an assessment of the risks and benefits established that the risks
would not outweigh the benefits. The proponents of genetic modification,
however, emphasised that this risk-benefit analysis could be carried out only in
relation to specific uses of genetic modification and could not be done in relation
to the technology as a whole.
There was general agreement among the supporters of genetic modification that
risk assessment should be based on scientific principles. Several submissions, such
as that from New Zealand Dairy Board [IP67], suggested that non-scientific
factors should not be allowed to impinge upon or distort the objective process of
risk assessment. Submissions from other proponents of genetic modification,
however, considered that a decision on the use of genetic modification could not
be based solely on an objective scientific approach to risk because a scientific
assessment could not take into account the cultural, social, political and economic
factors that influenced perceptions of risk. Although science might be able to
identify and determine the benefits of the use of the technology in relation to the
size and probability of risk, it could not determine whether the level of risk
associated with the use would be acceptable to the community. Any use of genetic
modification without community acceptance would be unethical and, possibly,
unwise. New Zealand Life Sciences Network [IP24] said:
the assessment of risk is only partially scientific and factual. Many risks are unable to be
characterised in an objective sense and must be determined and weighed using subjective
criteria ... the balance to be achieved between acceptable and unacceptable risk can be
informed by science but not determined.
Submissions advocating a risk assessment process based, at least partially, on
scientific principles were confident that the behaviour of the technology could be
predicted and that the current knowledge and understanding of the technology
was sufficient to identify the risks and to assess the probability of harm occurring.
Submissions from the opponents of genetic modification, however, emphasised
that the technology was unpredictable; therefore, the risks and potential harm
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were also unpredictable and could neither be assessed nor be managed. Several of
the submissions stated that the risks of genetic modification were "unknown and
unknowable" and any assessment of risk would, therefore, be based on conjecture.
Some submissions, such as that from Bio Dynamic Farming and Gardening
Association in New Zealand [IP61], called for the assessment of the risks of genetic
modification to be empirical and based principally on observation of behaviour.
Other submissions, such as that from Sustainable Futures Trust [IP51], pointed
out that:
The risks of GM, being a scientific endeavour, are assessed by those schooled in the
scientific method of objective rationality. When both the risks and their consequences are
uncertain and potentially catastrophic, the processes of assessment need to be open and
inclusive of all the stakeholders, where subjectivity, values, morals and consensus enter
into the discourse. This is the emerging realm of post normal science (Ravetz 1999)
1
Other submissions, particularly those from Maori organisations, called for an
inclusive risk management assessment that would take into account the range of
factors that influence perspectives on the use of genetic modification. An inclusive
assessment process would ensure that genetic modification, genetically modified
organisms and products were not released into the community until after an
accepted level of risk had been determined.
Benefits and costs
Benefits of use
Except in relation to the use of genetic modification for research and for medical
purposes, only the submissions from proponents of genetic modification were
confident that benefits would result from the use of the technology.
Particular emphasis was placed on the range of commercial benefits that were
expected to result from the use of genetic modification. Submissions identified
benefits to agriculture, horticulture and forestry through improved production
methods, increased productivity, lower production costs and new or improved
products. Because of the level of concern expressed about genetically modified
food, some submissions, particularly those from organisations involved in food
production and distribution, emphasised the benefits in taste, quality and safety
that consumers of genetically modified food were expected to experience.
1
Ravetz J (ed). 1999. Post-normal science. Futures (special issue), 31 (7): 641­757.
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Several of the submissions from organisations that otherwise supported the use of
genetic technology doubted that benefit would result from its use in relation to
food. Submissions from New Zealand Vegetable and Potato Growers' Federation/
New Zealand Fruitgrowers' Federation/New Zealand Berryfruit Growers'
Federation [IP75], Meat New Zealand [IP31] and New Zealand Game Industry
Board [IP33] all suggested that their members were unlikely to use genetic
modification until there was clear indication that its use was acceptable to
consumers.
Some submissions also suggested that new commercial opportunities would
arise from the use of genetic modification, both in the area of primary production
and for medical and health purposes. Genesis Research and Development [IP11]
referred to various new opportunities that had resulted from its involvement in
gene technology. Dairy Board [IP67], in addition to identifying benefits in relation
to existing dairy products, noted that new opportunities would arise from "the
production of new products, particularly those with functional foods, nutriceutical
and pharmaceutical applications."
Much of the discussion in the submissions focused on the possible future benefits
of genetic modification and indicated that there was a need for further research
before the uses would be developed. Submissions from research and development
agencies often discussed research currently under way into specific uses; and some
submissions, particularly those from companies involved in the research and
development of genetically modified crops, suggested that the introduction of
genetically modified crops would result in an immediate benefit in New Zealand.
Other submissions were more speculative in their discussion of both the uses and
the benefits of genetic modification. Several submissions from medical research
agencies referred to the increase in medical applications of the technology after
completion of the Human Genome Project.
The discussion in most submissions, however, suggested that, although several
New Zealand organisations were involved in research, it was unlikely that the
research would result in the release of genetic modification, genetically modified
organisms and products for commercial purposes in the near future.
Many of the submissions that discussed the commercial benefits that were
expected to result from the use of genetic modification also suggested there would
be flow-on benefits to the national economy. Several of the submissions suggesting
that the future profitability of the primary sector depended on the use of genetic
modification particularly emphasised the importance of that sector to the New
Zealand economy. Other submissions suggested that economic benefits would
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result from the development of new businesses and creation of new commercial
opportunities through the use of the technology.
Some submissions suggested that the use of genetic modification would result in
environmental benefits, both direct and indirect. Genetic modification in
agriculture and horticulture would result in the use of processes and products less
damaging to the environment and to natural resources than those currently used.
Conservation genetics and other environmental management tools would extend
the knowledge of New Zealand's native species, decrease the threat from imported
pests and ensure the protection of the natural biodiversity.
Submissions from health service providers and medical research organisations
discussed the benefits to patients arising from the use of genetic modification for
diagnostic and therapeutic purposes.
Several of the submissions emphasised the benefits that were expected to result
simply from continued research into genetic modification. Submissions from
organisations involved in primary production and in medical research suggested
that, even if it were decided to prohibit the use of genetic modification, genetically
modified organisms and products in the wider environment, continuation of
research in laboratory containment could result in benefit. Continued laboratory
research would not only ensure that New Zealand's knowledge of gene technology
remained current but would also allow the development of valuable intellectual
property. Other research organisations, however, emphasised the importance of
field trials to the research process. To the opponents of genetic modification, any
use of gene technology outside laboratory containment, including field trials for
research purposes, would incur a high level of environmental risk and should not
be permitted.
Some of the submissions from opponents of genetic modification also accepted
that benefits could result from the use of genetic modification. The submission
from Green Party [IP83], for example, identified gene technology as contributing
to understanding inheritance and diagnostic techniques:
Gene technology, including in some cases the creation of GMOs in the laboratory has
contributed worthwhile knowledge about the genetic basis of some diseases, heritability,
and provided diagnostic techniques useful in treating disease in humans, plants and
animals. These techniques can also be used to speed up conventional breeding by
determining whether natural progeny have the desired traits or not.
The use of gene therapy for these purposes was approved, and also for the
development of medicines such as insulin, but only if the technology was used in
laboratory confinement where the risks of its use could be contained.
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Costs of use
As well as being concerned about the risks of using genetic modification,
submissions suggested costs that would result from its use.
The introduction of genetically modified crops was of particular concern. Many
submissions suggested that the introduction of genetically modified crops would
result in costs to the organics industry if cross-pollination of organic crops by
genetically modified crops led to the loss of organic certification. The submissions
suggested that the risk of organically grown crops being contaminated by
genetically modified crops was high and would lead to loss of the required organic
certification. Several submissions pointed out that additional financial costs would
be imposed on organic growers if they were required to set aside part of their land
to create a buffer zone to protect against possible contamination of organic crops
through cross-pollination.
The submissions pointed out that, because of concerns about the safety of
genetically modified food, overseas consumers were increasingly rejecting
genetically modified food in preference for food that was not genetically modified.
The rejection of genetically modified food, the submissions suggested, had
resulted in a significant increase in the demand for organic products and increased
sales overseas of New Zealand-grown organic produce. Contamination would not
only adversely affect the ability of the organics industry to take advantage of this
increased demand, but also had the potential to restrict overseas demand for
conventionally grown New Zealand products. Concern about possible consumer
rejection of genetically modified food was also expressed in submissions from
organisations currently involved in conventional food production, which suggested
that their members might chose not to use genetic modification for food
production.
The submission from ZESPRI International [IP46] considered the impact that use
of genetic modification could have on products that did not necessarily use organic
production techniques. The submission stressed the importance of the export
market to countries where there was growing consumer resistance to genetic
modification. It suggested that use of genetic modification could lead to the
creation of non-tariff barriers to market access. The submission said:
A decision to allow commercial GM food production in New Zealand could be used as a
pretext to refuse New Zealand non-GM food products. Retailers could judge the publicity as
undesirable for sales. Our marketing evidence is that the GM status for New Zealand
commercial food production calls into question the GM status of all New Zealand food
produced.
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The potential for significant commercial costs to be imposed on the bee products
export industry if products were found to be contaminated by pollen from
genetically modified crops was a specific concern raised in two submissions from
organisations commercially involved in the industry.
Many submissions from both the opponents and the proponents of genetic
modification suggested that New Zealand's "clean and green" image was a useful
marketing tool that would be compromised by the introduction of genetically
modified crops. The joint submission from Vegetable and Potato Growers'
Federation/Fruitgrowers' Federation/Berryfruit Growers' Federation [IP75], which
accepted that there were likely benefits to the horticultural industry from the
development of genetically modified crops, commented that:
The potential impact associated with the first releases of commercial GM crops on New
Zealand's "clean, green image" will need to be considered as part of the regulatory
processes assessment of economic risks and benefits. We are not implying that GM is `un-
clean and non-green", but "clean and green" is a real marketing tool and may be affected
by the production of GM crops in New Zealand.
Whereas several of the submissions from proponents of genetic modification
suggested that there would be benefits to the agricultural sector from the use of
genetic modification, submissions from the technology's opponents suggested that
the introduction of genetically modified crops would result in financial costs. The
submissions pointed to evidence from overseas that the yields from genetically
modified crops had not been as high as was suggested and that the need to recover
the high development costs had resulted in a premium being added to the price of
the seed. Some submissions also suggested that the use of genetic modification
would result in a loss of agricultural diversity and, because of restriction on the
saving of seed from the previous year's crops, in a growth of dependence on a few
major companies.
The submissions from Maori organisations were particularly concerned about
the cost to cultural and spiritual beliefs that would be imposed if genetic
modification were permitted in New Zealand.
Benefits of avoidance
Many submissions suggested that, because of the increasing overseas demand for
organic produce, there would be significant economic benefits not only in
protecting organic crops from possible contamination, but also in actively
promoting the growth of the industry by prohibiting the release of genetically
modified organisms. Extension of the industry, submissions suggested, would help
differentiate New Zealand products, making them more than commodity products.
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Rather than preventing the development of new industries, submissions suggested,
the avoidance of genetic modification could encourage the establishment of a
range of new industries that capitalised on New Zealand's genetic modification-
free status.
Costs of avoidance
In most of the submissions from proponents of genetic modification, the
anticipated costs of avoiding the technology were opposite to the expected
benefits. Without genetic modification, it was expected that there would be costs
to industry sectors, particularly the primary production sector, through loss of
international competitiveness, financial costs to sector industries through being
unable to access technology and products that would increase productivity and
decrease production costs. There would be environmental costs, particularly in
the area of pest control and resource management.
Although many of the costs identified were "passive" costs (ie, the cost would be
incurred because the benefit was not realised), some submissions suggested that
avoidance of genetic modification would be to the detriment of the status quo in
certain areas. Several of the submissions, for example, stressed that avoidance of
genetic modification not only would prevent future benefits to human health but
also could mean that patients currently dependent on genetically modified
medicines would have difficulty in accessing alternatives. Few submissions,
however, suggested that avoidance of genetic modification should be extended to
prohibit the use of genetically modified diagnostic techniques or medicines.
The universities in particular were concerned that avoidance of genetic
modification would result in difficulties in recruiting and retaining suitably
qualified staff. This, in turn, would result in costs both to current research
programmes and to graduate and undergraduate teaching.
In the area of pure research, concern was expressed that avoidance of genetic
modification would result in the curtailing of current research projects and could
prevent the continued use of transgenic animals for research purposes. Although
SAFE (Save Animals From Exploitation) [IP85] expressed strong concerns that the
use of animals for research purposes was likely to increase as a result of genetic
modification, few other submissions expressed opposition to the continued use of
genetic modification for research and teaching purposes.
Some of the submissions considered the social costs that might be experienced if
genetic modification were avoided in New Zealand. The submissions from
several of the tertiary institutions mentioned that, without access to the technology,
New Zealand would not be able to develop a "knowledge economy". Other
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submissions expressed concerns that, if New Zealand limited its involvement
with genetic modification, the potential for future benefits would be curtailed, to
the detriment of the population as a whole. University of Canterbury [IP7], when
emphasising the importance of retaining research and teaching staff, stated that:
Uneducated societies are more at risk of being exploited on issues of biotechnology than
educated societies. Likewise they are more likely to miss out on some of the acceptable
benefits of adopting biotechnology.
Advantaged and disadvantaged groups
The submissions responded in several different ways to the requirement under
Warrant item (c) that consideration of the risks and benefits of genetic modification
should include consideration of the groups of persons likely to be advantaged by
the benefits and disadvantaged by the risks of genetic modification.
Submissions from organisations involved in research and development of genetic
modification, genetically modified organisms and products tended to specify the
users of the products and other commercial interests, including those with a
financial interest in the promotion of genetic modification, as the groups that
would be advantaged or disadvantaged.
Submissions that emphasised the risks of genetic modification, and therefore
stressed the disadvantages of its use. often illustrated the potentially widespread
nature of the harm that the technology could cause. Thus, they suggested that the
advantage of avoidance or disadvantage of use would be incurred by "society" or by
"the New Zealand public".
Groups were identified more specifically when the advantage or disadvantage
would be incurred because the use of the technology would either benefit or
threaten special characteristics or needs of the group members. The submission
from Comvita NZ Ltd [IP74], for example, identified people involved in the
honey and bee products industry as being likely to be disadvantaged from its use.
Patient representative groups, such as Lysosomal Diseases New Zealand [IP99],
stressed the importance of genetic modification to their members.
Several submissions emphasised the disadvantage that would be experienced by
Maori if their traditional lore and cultural and spiritual beliefs were breached by
the use of genetic modification technologies.
The submissions tended to reinforce a view of the predominance of either risk or
benefit of genetic modification. They expressed this either by referring to broad
groups of people as advantaged or disadvantaged, or by identifying the groups
whose specific needs would be met or denied by use of the technology.
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Concluding observations
The submissions on the benefits and risks of genetic modification divided into
two main categories: those that saw the use of the technology as predominantly
beneficial and those that considered the risks of its use usually outweighed any
benefit.
Submitters' perceptions of the predominant risk or safety of the technology
shaped their views on the likely benefits or costs of its use. Because benefits could
arise only from the use of the technology, the proponents of genetic modification
emphasised the risk assessment and risk management processes that were
undertaken to ensure that the technology was used safely. Opponents of genetic
modification emphasised that it could not be used safely because current scientific
understanding of the effects of the technology was too limited to be able to predict
and assess possible risks.
Opponents of genetic modification agreed that there were benefits arising from
the laboratory use of genetic modification for research and medical purposes,
where any adverse outcomes could be contained. Opponents particularly
emphasised the potential damage to the environment that could result from
unintended and unforeseen effects of genetic modification.
Proponents of genetic modification acknowledged there were risks associated with
the use of the technology but were confident that there was sufficient knowledge
to identify and assess the risks. None of the submissions from the proponents of
the technology suggested that genetic modification should be used without
regulatory controls to ensure its safe use.
The view expressed in the submissions diverged sharply over the likely benefits of
genetically modified food. Some submissions recognised that consumer rejection
of genetically modified food would limit its benefits but suggested that, in general,
genetic modification used in relation to food and food crops was beneficial. Other
submissions expressed strong doubts about the safety of genetic modification in
food and either called for a complete ban on its use or suggested that it should be
subjected to a rigorous safety procedure.
The submissions identified a range of groups that would be advantaged or
disadvantaged by the use of the technology. Except where the technology would
benefit or adversely impact on the special characteristics or needs of a specific
group, the submissions tended to describe the affected groups in general terms.