Analysis of Public
Submissions
Analysis of
Public Submissions
3.
section 3.13
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appendix 3
Outcomes of Consultation: Submissions
from the Public
Section contents
3.
Analysis of Public Submissions
22
3.13
Main areas of public interest
98
Background
98
Outline of this section
98
Distribution of concerns
99
Human health
99
Environmental matters
101
Economic matters
102
Cultural and ethical concerns
103
Social matters
104
Risk and uncertainty
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3.13
Main areas of public
interest
Background
Warrant item (j) invited submissions on the main areas of public interest. Four
main areas were identified in the Warrant:
the main areas of public interest in genetic modification, genetically modified organisms,
and products, including those related to -
(i)
human health (including biomedical, food safety, and consumer choice):
(ii)
environmental matters (including biodiversity, biosecurity issues, and the health of
ecosystems):
(iii)
economic matters (including research and innovation, business development,
primary production, and exports):
(iv)
cultural and ethical concerns
Public submitters also wrote extensively about social concerns.
Outline of this section
This section of the report will outline views expressed by public submitters on the
four main areas as identified in the Warrant, as well as social matters and risk and
uncertainty. It will include the following sub-sections:
*
general overview
*
human health
*
environmental matters
*
economic matters
*
cultural and ethical concerns
*
social matters
*
risks and uncertainty.
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Distribution of concerns
Table 3.20 provides a summary of public submitters' concerns across the broad
range of topics they raised. The areas of concern that stand out are environmental
risks, uncertainty around risks, health risks and food safety risks.
Submitters were also concerned about the capture of any benefits from genetic
modification by multinationals. There was a general belief that only a few (almost
always multinationals) will benefit from genetic modification and many (namely
the general public) will suffer the costs. Other notable concerns included the
ethical and spiritual implications of genetic modification, the irreversible nature of
genetic modification application, the eroding of consumer choice and adverse
economic impacts. The adverse economic impacts related to organic farming in
particular, but also the opportunities New Zealand would forgo (for instance,
taking advantage of niche markets based on our "clean, green image") if we take
the genetic modification road.
Human health
Public submitters were more concerned about health prevention measures than
diagnosis and treatment. This focus on prevention measures was consistent with
their worries about the negative impacts of genetic modification. They often
viewed genetic modification as the latest in a long line of technologies that
potentially harmed their health, including cellular telephones, chemicals in the
environment and in food, and well-known disasters such as thalidomide and Agent
Orange. Some public submitters compared the ill health of themselves and others
with the perceived good health of their ancestors and attributed the differences to
technological interventions.
Submitters' main concerns focused on the health impacts from contamination of
the environment and food by genetic modification applications. They viewed any
tampering with the natural order of the environment and food as threatening to
their health. Anticipated problems included:
*
allergies from genetic modification-contaminated food, including new foods,
and genetically modified pollens from genetically modified crops and
unintended cross-fertilisation
*
illness from unintended horizontal gene transfer in the environment
*
loss of food quality, particularly its nutritional value.
Public submitters were also concerned about genetic modification-based
treatments. There was some support for medical uses of genetic modification
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Concerns about GM
Number
%
Environmental risks
4979
49.8
Uncertainty around risks (lack of information)
4548
45.5
Public health safety risks
3620
36.2
Food safety risks (including lack of labelling)
3002
30.0
Benefits captured by multinationals
1905
19.1
Ethical and spiritual implications
1605
16.1
Irreversible
1519
15.2
Uncertainty around benefits (lack of information)
1106
11.1
Consumer choice
1043
10.4
Adverse economic impacts on industry (eg organic farming,
tourism)
1023
10.2
Inter-generational equity
882
8.8
Biodiversity
729
7.3
Social and economic equity
591
5.9
Lack of trust
403
4.0
Public education on GM
383
3.8
Generalised disaster
311
3.1
Religious implications
280
2.8
Inappropriate reliance on science/technology
233
2.3
Cultural implications
195
2.0
New Zealand retaining control of flora and fauna
165
1.7
Biosecurity
64
0.6
Animal rights
60
0.6
Organic crops affected by GM crops
48
0.5
Sovereignty
8
0.1
Human rights
7
0.1
Multiple response
Table 3.20
Public submitters' concerns about genetic modification
(n = 9994)
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technologies so long as any application or research was contained. However, a
large number of submitters did not want to be exposed to genetic modification-
based medicines and demanded their right to choose whether to use them or not.
Submitters commonly cited insulin as an example of a genetic modification-based
treatment over which people have not been given choice.
Ethical issues raised by public submitters about genetic modification-based
treatments included the potential breeding out of human imperfections, the use of
animals as "bio-factories" for human benefit and the "wrongness" of gene
manipulation.
Submitters also referred to the uncertainty around other so-called "wonder
treatments" such as thalidomide as justification for their caution. They noted a
lack of evidence of the long-term safety of genetic modification-based health
treatments and the lack of testing of new technologies.
Environmental matters
Environmental issues dominated public submitters concerns. Almost half of the
public submitters made substantial comments about environmental issues. Often
their concerns were of a general nature: they were concerned about the general
degradation of the environment or ecosystems as a consequence of genetic
modification activities. Some were concerned that the introduction of genetic
modification would mean the loss of New Zealand's "clean, green" environment or
the loss of New Zealand's genetic modification-free environment. Others
anticipated more major consequences, for instance predicting a general destruction
of the environment or some sort of undefined significant disaster. The range of
concerns is briefly summarised below.
The application of genetic modification was viewed as a serious threat to the
integrity of the environment. Integrity was identified as an environmental value
for different reasons. Some submitters, particularly Maori, argued that people are
custodians of the environment. Genetic modification activities violate this
relationship in that inherent in the application of this technology is the notion that
people have the right to have dominion over the environment. Others valued the
integrity of the environment for religious or spiritual reasons, for instance from
the perspective of Jewish, Christian, Muslim or other belief systems. Others took a
"nature knows best" stance, arguing that any intervention of the scale that genetic
modification entails is contrary to the natural order.
The threat to biodiversity that genetic modification poses was another strong
theme amongst public submissions. The release of genetically modified organisms
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into the environment could result in:
*
the extinction of some species, for instance from general environmental
degradation or as a consequence of specific problems such as genetically
modified pollens or "super-bugs"
*
the creation of new and dangerous genetically modified organisms such as
"super-weeds"
*
contamination of the environment from genetic modification activities, for
instance with genetically modified organisms escaping from field trials or
laboratories
*
the irreversibility of genetic modification releases.
Genetic modification could lead to the destruction of the environment as an
economic good. Public submitters believed that the current state of the
environment ("clean and green") provided New Zealand with the opportunity to
maintain and expand current industries, particularly agriculture and horticulture,
but also tourism. It also provides New Zealand with the opportunity to develop
new industries and markets, particularly those based on environmental quality and
freedom from genetic modification applications.
Some submitters also acknowledged benefits to the environment from genetic
modification technologies. These technologies could be used for pest control, to
reduce the use of chemicals in food production and other agricultural activities,
and to reduce the amount of land used for agricultural and horticultural production.
The latter could be achieved if genetic modification technologies enabled land to
be used more intensively, thus freeing up other land or preventing commercial
encroachment on to areas of high natural value.
Economic matters
Public submitters were less concerned about the economic impacts of genetic
modification, compared with impacts on health and the environment. Nevertheless,
almost one in 10 of the submitters expressed concern about the impacts genetic
modification use would have on industry, particularly organically based agriculture
and horticulture.
When public submitters wrote about the economy, they almost always focused on
the primary production sector. Very few considered the biotechnology industry
and its direct contribution to the economy. They were more concerned about its
impact on the primary production sector. Also, public submitters tended to
perceive the economy as comprising two parts: the powerful and bad multinationals
and the local and good small producers. They saw the application of genetic
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modification as exacerbating this undesirable dichotomy. As multinationals
foisted genetic modification upon New Zealand, the New Zealand economy
would increasingly come under the control of foreign ownership and monopolies.
Genetic modification, they believed, threatens the country's economic self-
determination.
Submitters saw genetic modification avoidance as an opportunity to reverse
current trends. That New Zealand is isolated, coupled with our cleanness and
greenness, could become a strength if New Zealand is one of the few countries
that rejects genetic modification. The country would be well-placed to provide
genetic modification-free and organic produce to meet growing demand from
countries that can not meet their own needs given their genetic modification use.
Further, given that these larger economies would be precluded from participating
in this niche market, our producers would not need to compete with larger
producers that have economies of scale that currently give them competitive
advantage.
In general, public submitters gave little attention to the value of the biotechnology
industry for its own sake. However, some argued that New Zealand has the
opportunity to develop its research capabilities in specialist biodynamic and
organic areas. New Zealand, they believed, could become world experts in
production processes that will become increasingly attractive to the rest of the
world.
Cultural and ethical concerns
When writing about cultural and ethical concerns, public submitters variously
argued from religious, ecological, ethical, moral and ethnic perspectives. However,
their messages were similar: genetic modification is wrong because it is tampering
with "what is supposed to be". It was common for submitters to cite Mad Cow
Disease as the consequence of people tampering with the natural order: feeding
herbivores meat products. From a religious perspective, genetic modification was
rejected, for instance because it was "against the teachings of the Bible" or
inconsistent with Muslims or Jewish beliefs about appropriate composition of
food. From an ethnic perspective, which could often also be viewed as a spiritual
perspective, tampering with the natural order was also unacceptable. For instance,
a number of submitters pointed out how unacceptable the mixing of human and
other genetic material is to Maori. Some people wrote about an ecologically
based spiritualism that found any tampering with "Mother Nature" as abhorrent.
Other ethical perspectives, including animal rights and vegetarianism, also
shaped people's attitudes towards genetic modification, since they believed it
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included exploitation of animals and mixing of genes from different species. The
unease people felt about patenting, although sometimes argued from an economic
perspective, was usually based on a belief that ownership of the "code of life" is
immoral or unethical.
Altogether, of those public submitters addressing Warrant item (j), 18.1% raised
concerns from an ethical and spiritual or cultural perspective (see Table 3.20). This
figure, however, in some ways under-represents the extent of ethical, spiritual and
cultural concerns of public submitters, many of whom articulated their unease in
terms of more specific issues of genetic modification such as risk to the environment
and food safety.
Sometimes public submitters also explained concerns about consumer choice and
sovereignty as ethical issues. They often explained their rights to have choice, or
give consent, as a human rights issue, with any removal of these rights undermining
their individual sovereignty. They particularly defended their rights to have
choices, or give consent, in health treatments, environmental management and
food production and consumption. Sometimes, sovereignty was also discussed
from a national perspective, expressing the right of the people of New Zealand to
make a decision free of outside influence.
Despite the importance of cultural and ethical considerations, some public
submitters believed these considerations are ignored by decision-makers. Some
submitters felt that economic considerations are valued more highly than ethical
considerations by decision-makers. There was a high degree of mistrust expressed
by public submitters, particularly about:
*
political decision-makers overly conscious of the needs of `big business'
rather than the people
*
scientists responding to the needs of their funders, including the
biotechnology industry, rather than the public and inclined to "do the
science for its own sake" and personal ego gratification rather than for the
benefit of the public
*
any evidence about the safety and benefits of genetic modification, given
their views about scientists, industry and government and the wide range of
previous disasters. Commonly identified disasters included DDT,
thalidomide, asbestos, cigarettes, Agent Orange and introduced pests.
Social matters
A number of public submitters were concerned about equity issues. As Table 3.20
shows, of those submitters addressing areas of public interest, 5.9% commented on
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current equity issues and 8.8% were concerned about inter-generational equity.
When referring to equity today, it was the view of submitters that the application
of genetic modification could create inequities or exacerbate those already existing
in New Zealand and between developed and developing countries. Given the
current control of, and advocacy for, genetic modification production and research,
public submitters expected the benefits to be captured by the "haves" and the costs
to be borne by the "have nots". Similarly, they expected such distribution of costs
and benefits on an international scale, with developing countries bearing the costs
(for instance, through the destruction of local production processes) and developed
countries (particularly through their multinational companies) to benefit. Those
concerned about inter-generational equity issues were concerned that decisions
made today may preclude future generations from access to health, a quality
environment, quality food and economic choices.
Some public submitters feared that the application of genetic modification
technologies would lead to total social breakdown. Some saw the origins of this in
current decision-makers' willingness to disregard ethical and cultural considerations
in favour of technological advancement and economic gain.
If we value democracy as a cornerstone of our current society then, some
submitters argued, that basis will be corroded by the introduction of genetic
modification. Submitters argued that the principles of choice and consent,
inherent in their concepts of democracy, need to be protected. These principles
are particularly pertinent to the genetic modification debate, they argued.
Risk and uncertainty
As Table 3.20 shows, public submitters' concerns about risk and uncertainty and
benefit and uncertainty were, together, greater than any other areas of concern.
These concerns, discussed in detail in the section entitled "Evidence and
Uncertainty", stemmed from both a general distrust of the sources of information
available to them and a belief that risk assessment processes are still undeveloped
and imperfect. Thus, public submitters generally believed that scientists and those
providing approvals for genetic modification applications lack the skills and
mechanisms (as well as the will) necessary to properly identify and quantify the
levels of risk. They also considered the evidence around benefits and safety to be
uncertain.