Analysis of Public
Submissions
Analysis of
Public Submissions
3.
section 3.2 |
appendix 3
Outcomes of Consultation: Submissions
from the Public
Section contents
3.
Analysis of Public Submissions
22
3.2
Strategic outcomes, issues and options
30
Background
30
Outline of this section
30
Strategic outcomes
31
Health outcomes
31
Environment outcomes
32
Social outcomes
32
Economic outcomes
33
Strategic issues
34
Issues of choice
34
Issues of risk and risk management
35
Issues of acceptability
37
Strategic options for genetic modification
38
Health-related options
39
Environment-related options
41
Social-related options
41
Economy-related options
42
Royal Commission on Genetic Modification | Report Appendix 3
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3.2 Strategic outcomes,
issues and options
Background
Information about strategic issues and outcomes is sought from Warrant items
under "Relevant matters". Warrant items (k) and (m) request information on,
respectively:
the key strategic issues drawing on ethical, cultural, environmental, social, and economic
risks and benefits arising from the use of genetic modification, genetically modified
organisms, and products
the range of strategic outcomes for the future application or avoidance of genetic
modification, genetically modified organisms, and products in New Zealand
With reference to strategic options, the Warrant asks the Commission to receive
representations upon, inquire into, investigate, and report upon:
the strategic options available to enable New Zealand to address, now and in the future,
genetic modification, genetically modified organisms, and products
Outline of this section
To present the views of public submitters, this section is divided into three parts:
*
The first, addressing Warrant item (m), outlines the range of strategic
outcomes public submitters identified as desirable for the main areas of public
interest identified in the Warrant. These include human health (including
biomedical, food safety and consumer choice); environmental matters
(including biodiversity, biosecurity issues and the health of ecosystems); and
economic matters (including research and innovation, business development,
primary production and exports).
*
The second addresses Warrant item (k) by describing the strategic issues
raised by public submitters relating to the ethical, cultural, environmental,
social, and economic risks and benefits arising from genetic modification.
The issues they raised focused on acceptability, choice and risk assessment
and management.
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*
The third part addresses Warrant item (1) by reporting public submitters'
views about the strategic options available to enable New Zealand to respond
to genetic modification, given their desired social, environmental and
economic outcomes and the issues they raised about acceptability, choice and
risk assessment and management.
Strategic outcomes
The vast majority (92%) of public submitters were opposed to genetic modification
(this is discussed further below and demonstrated in Table 3.2). The sort of social,
environmental and economic world that public submitters sought could be
inferred from their comments about why they generally rejected genetic
modification. This section of the report summarises these desired outcomes,
which relate to avoidance rather than application of genetic modification, with
reference to human health, social matters (both nationally and internationally),
environmental matters and the economy. Where possible, the ways that public
submitters defined health, social matters, the environment and the economy are
also included. In general, submitters opposed genetic modification and, therefore,
only rarely outlined strategic options that would include use of genetic modification.
Health outcomes
Public submitters focused on two dimensions of health: treatment and prevention.
While they identified both these dimensions as important, they tended to place
slightly more emphasis on prevention. Thus, they tended to focus on factors that
they considered as having an effect on their health. These included the environment
in which they, and their children, lived and the food they ate. A smaller proportion
of public submitters also wrote about the diagnosis and treatment of disease and
other health-related conditions.
If submitters specified the sorts of health outcomes they considered desirable, they
most often referred to the following:
*
being allergy free
*
being disease free or being exposed to fewer diseases
*
living in a healthy environment, often defined as a natural environment
*
having healthy children
*
ensuring the health of the next generation
*
ensuring that the next generation has the same access to, and choices about,
health
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*
survival of the human species and the ecosystem in which humans live
*
equal opportunity to health both within New Zealand and between nations.
This covered both access to health care and affordability of healthy options
(eg access to genetic modification-free food). Many public submitters were
also concerned about health within developing nations and their equitable
access to health outcomes
*
having spiritual wellbeing and cultural health.
Environment outcomes
Environmental quality was of great concern to submitters, who mostly wrote
about the indigenous flora and fauna of New Zealand and the physical landscape.
Some referred to the environment in more ecological terms, with a minority
including humans as part of the wider ecosystem or ecosystems.
In general, public submitters expressed a positive, often idealised, view of the New
Zealand environment. Many described the natural and physical environment as
pristine and clean and green and described that purity as enhanced by New
Zealand's nuclear-free stance. If public submitters doubted the pureness of the
current New Zealand environment, they indicated the belief that, as one submitter
wrote, "... it is still within our control to make this country a safe, clean, green
Paradise!" Encapsulated in their concept of environmental virtue, was an
assumption of New Zealand remaining genetic modification-free. Some people
equated being genetic modification-free with embracing organic production while
others argued that New Zealand could work towards fully organic production.
Social outcomes
The characteristics of public submitters' desired social environment could be
inferred from their comments about the aspects that would be lost through the
application of genetic modification. These characteristics included:
*
equity, within New Zealand, between nations and between generations. The
aspects of equity most commonly raised included equal access to resources,
acceptance of diversity (including ethnicity, culture, religious belief, ethical
belief) and lack of discrimination (particularly relating to physical differences
such as disability). Often those discussing equity issues did not elaborate
further than their demand for equity and fairness
*
individual and national self-determination, achieved through individual
choice, individual or collective control over, or consent about, some
important matters, recognition of human rights, individual or collective
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feelings of safety, individual and collective (group or national) pride and
acceptance of difference
*
stability. Public submitters' desire for stability in the social environment to
some extent equated with the concept of equilibrium in ecosystems. They
wrote about harmony and certainty
*
democracy, described as public input into decision-making and consumer
choice.
Economic outcomes
The part of the economy most commonly discussed by public submitters was food
production, particularly primary production and food processing. To a lesser
extent, they also referred to other industries such as forestry, tourism, and fishing
(both for food and recreation and tourism). Only rarely did they refer to
biotechnology, including research and production.
Public submitters often talked about the economy as a dichotomy between locally
owned industry (generally perceived as small and good), and multinationals
(generally seen as large and bad). One submitter's comments summed up views of
many, by describing multinationals as "... self-seeking commercial interests posing
as world benefactors [who] apply seductive or threatening pressures. We must
close our eyes and ears to them." They also tended to characterise New Zealand
products, particularly from primary production, as high-quality and clean and
green. This image of New Zealand's purity was seen as an important competitive
advantage for New Zealand businesses that submitters worried could be threatened
by the adoption of genetic modification. In general, however, submitters indicated
that economic considerations are still of less importance than human health,
environmental quality and social equity.
Public submitters' comments about the economy of the future and the economic
outcomes New Zealand currently seeks, or should seek, reflected their widespread
confidence in the future. Their views about the current state of the environment
were similarly positive. A common view was that, with a genetic modification-free
future, New Zealand would experience economic growth leading to national
wealth and increased employment. As other countries adopted genetic modification
they would necessarily be seen as "contaminated". New Zealand, because of its
geographic isolation, would be the only producer able to guarantee a pure product
and demand for New Zealand produce would be phenomenal. New Zealand's
competitive advantage lay in the fact that " ... as an island country we have every
opportunity to be fully organic which carries no risk and is better for farmers, will
feed people and not kowtow to large corps". This economic growth would be
based on small-scale production, particularly food production using organic
processes, through locally owned industries. Such economic activity would enable
New Zealand to be more self-sufficient, thus freeing the country from dependence
on multinationals, the United States and other outside influences perceived as
having unwelcome control over New Zealand's environment and economy.
Only a very small number of public submitters felt that genetic modification could
prove an actual benefit to New Zealand's future, and many of those felt resigned to
it rather than enthusiastic. These submitters felt that it is "... better to be carving
our own destiny than to be impotent when one is imposed on us". Knowing that
genetic modification is here to stay, these submitters would prefer to see New
Zealand at the forefront of the technology rather than left behind.
Strategic issues
Public submitters raised a number of strategic issues around the use of genetic
modification with respect to human health and environmental, social and economic
matters. These include issues around consumer or public choice, risk and risk
management, and acceptability.
Issues of choice
Whatever the area under consideration, public submitters were concerned about
choice. These concerns related to personal and national self-determination and
sovereignty. For many submitters this was the key issue, arguing that "... the
cornerstone of any advanced society is that of an individual's freedom to make
choices ...". For instance, public submitters argued their right to have choice over
the state of the environment in which they lived (that is, whether it remained
genetic modification-free), whether they would consume genetically modified or
genetic modification-free food or whether they would accept genetic modification-
based medical treatments. Thus, they considered strict labelling requirements for
food and medical products an imperative.
Public submitters were also concerned about the impact of some people's actions
on the ability of others to have a choice. For instance, they argued that any release
of genetically modified organisms would preclude others from having a choice to
produce or consume locally produced organic food. Many of the concerns raised
about genetic modification in food were expressed in these terms. Public submitters
expressed a desire to have non-genetically modified food available, accessible and
affordable and many felt that the introduction of genetic modification would
necessarily impair their choice.
Closely linked to submitter notions of choice was the ethical issue of consent. A
substantial number of submitters concerned about issues of personal choice also
discussed their right to consent to genetic modification in their environment.
These submitters feared that they would be subjected to "the genetic modification
experiment" without their consent. This issue was most often discussed in relation
to food, but also in relation to medical applications. Submitters expressed a desire
to know details of their medical treatment or what they were eating with the right
to "opt-out" of anything involving genetic modification. A number of submitters
saw evidence of this right being eroded in the cases of genetically modified insulin
and the lack of a stringent food labelling regime.
Issues of risk and risk management
For most public submitters, the risks associated with genetic modification were
perceived as too difficult to identify and potentially too great to contemplate.
Benefits claimed by scientists and companies involved in genetic modification
were seen as too few, obtainable by other means, and benefiting too few people
(mainly multinational corporations) to justify an "... experiment, the consequences
of which are unpredictable, uncontainable, and potentially irreversible".
Information about risks associated with genetic modification is poor. Therefore,
submitters argued, the concept of risk management is inherently flawed, and they:
... would like to see the dubious science of `risk management' explained and debated
thoroughly by the public. Risk management assessments are constantly used as a
justification for genetically engineered experimental and commercial cropping yet many of
us find the reasoning and application of risk management bizarre, insane, incorrect and
collusive with the interests of big business.
The majority of commentators argued that risk avoidance, through the rejection of
genetic modification, was the only responsible way forward.
Public submitters perceived risk assessment as difficult because the contexts (for
instance, ecosystems, human bodies) within which direct and indirect impacts
potentially occur are complex. Therefore, the types of impacts, their location,
timing and cumulative effect cannot be predicted with any certainty. Given these
difficulties, some submitters questioned the ability of agencies responsible for
assessing risk to assess that risk. In particular, submitters were concerned about the
assessment of food and the capability of the American Food and Drug
Administration (FDA) and the Australia New Zealand Food Authority (ANZFA)
to assess food safety adequately.
Submitters expressed concern that regulatory agencies were too lax in their risk
assessment techniques, accepting the safety studies produced by companies at face
value without conducting their own independent trials, and focusing too narrowly
on the tests in question. Submitters were concerned that wider environmental
impacts of genetic modification were being ignored, citing, for example, a study
initially passed by the Environmental Risk Management Authority (ERMA) that
later needed closer scrutiny when it was discovered that genetic modification waste
products were being ejected without treatment into the sewer system. A few
submitters likened the situation to the introduction of possum and ferrets into
New Zealand without consideration of the wider impact on indigenous flora and
fauna.
However, submitters also argued that, regardless of the difficulties of assessing
risk, these agencies and others need to continue assessment processes and pursue
approaches to improve their assessment techniques. The submitters' comments
demonstrate a conundrum. On the one hand, they want a 100% guarantee that
current or potential use of genetic modification technologies (eg, for health care
and food production) are safe. But on the other hand, they believe that current
assessment skills and techniques cannot provide certainty around safety and many
do not trust the organisations concerned. Many submitters view company research
as biased and regulatory agencies as compromised by links to industry, citing the
"revolving door" as evidence of a biased system:
Many of us like to think we are living in a democracy, not a dictatorship run by
Multinational Corporations and large Food Manufacturing Companies, who manipulate
governments and their appointed agencies including the FDA, ANZFA and ERMA. People
with a long history of employment in these Multinational companies are too often found
in these agencies and I do not believe that they are therefore capable of making unbiased
decisions for the people's good.
Given this conundrum, public submitters recommended caution. A high number
of submitters suggested applying a form of the precautionary principle emphasising
safety, in which the onus is on the producer to guarantee safety, rather than on
others to prove risk. "When in doubt, don't" is a submitter's quote that sums up
this view, emphasising that genetic modification should not go ahead until and
unless it is first proven safe.
Submitters outlined core principles required of any risk management approaches
adopted. These included corporate responsibility and liability with regards to
unintended consequences (the `polluter pays' principle), the independence of risk
assessment and risk management agencies, giving priority to considerations such
as safety over profit and a strong regulatory framework.
Issues of acceptability
For the small proportion of public submitters who discussed the use of genetic
modification to achieve particular outcomes, its acceptability depended on a range
of factors, particularly the cultural, ethical, religious and/or value stance of
themselves or identified groups. For instance, the use or manipulation of human
genes would be unacceptable for Maori, given human beings' tapu status, as
would the inclusion of pig genes in food for Jewish and Muslim people and the
inclusion of any animal genes (including dairy products, eggs and so on) in food
for vegans. One vegetarian submitter described her concern that:
... many vegetarians feel threatened by GM because genes taken from animals are being
copied and used in vegetables. Despite the fact that scientists argue that the genes which
are being used are only exact copies of animal genes, most vegetarians, including myself,
would never consider this sort of reasoning to be acceptable.
Other factors also identified, but less frequently, as influencing the acceptability of
genetic modification included:
*
the nature of benefits gained, to people, the environment or the economy
*
submitters' personal health status or that of close relatives or friends
*
submitters' occupations or involvement in particular economic activities.
Given these factors, genetic modification technologies may be acceptable if they
enhanced environmental quality, but unacceptable if there is risk of developing
pests such as "super-weeds", increasing herbicide resistance or cross-species gene
transfer. They may also be unacceptable if they interfered with, or undermined,
the integrity of the environment. For many submitters, any interventions to the
environment that altered its original state were perceived as unacceptable. They
used terms like "as God intended" and "as Nature intended" to explain their
valuing of the environment in its natural state. Often these submitters were
concerned that "... human beings behave as if we are outside Nature instead of
realising we are part of it." These submitters included people arguing from a
generic ethical perspective, a Maori perspective, a Jewish perspective, vegetarian
and vegan perspectives and an economic perspective (particularly as organic
farmers).
Some submitters were very concerned with animal rights, writing that "... many
people prefer to live in a world which is moving away from the cruel treatment of
animals and will oppose genetic engineering ..." and refused to sanction any uses of
genetic modification in which animals were exploited. This included the production
of animals genetically modified for xenotransplantation, the production of human
health treatments and vaccines, and the use of animals in research. These concerns
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transcended the genetic modification debate, with these submitters being:
... opposed to GM in medicine where animals are used, eg where it involves the inhumane
use of animals, eg `spare parts' animals. I believe that animals should have no role in the
treatment of human diseases.
These submitters were adamant that human beings do not have the right to tamper
with the genetic make-up of other animals merely to improve their own condition.
Strategic options for genetic modification
Public submitters were overwhelmingly opposed to genetic modification in New
Zealand (see Table 3.2). They viewed the introduction of genetic modification as
inconsistent with, or threatening to, their environmental, social and economic
aspirations. Their anxieties about genetic modification were compounded by their
doubts about its acceptability to various groups, their scepticism about the
possibility of risk assessment and risk management and their concerns about loss of
choice.
The strategic options available to enable New Zealand to address genetic
modification, as identified by public submitters, reflected their general anxiety
about the technology. Most submitters (9,695 of the total 10,861) made some
references to how New Zealand should respond to genetic modification.
Nevertheless, as Table 3.3 shows, some of these submitters did make exceptions to
an overall rejection of all genetic modification activities. These related to their
acceptance of New Zealand's pursuit of certain health, environmental and social
outcomes (discussed previously), the achievement of which could be aided by the
application of genetic modification.
Table 3.3 shows that over half the submitters who commented on New Zealand's
strategic options clearly rejected any application of genetic modification. A
significant number of these expressed two opinions, preferring a complete
rejection of genetic modification, but also recognising that they might not be able
to halt it. Therefore, they demand, at the minimum, a strict labelling regime to
allow them the choice to avoid genetically modified products. A further 26.4%
indicated a strong objection to genetic modification, but wrote predominantly
about food. It was not clear from their comments whether they accepted other
applications or not. Only small proportions of submitters were generally accepting
of genetic modification, always well less than 1% suggesting strategic options that
allowed for any widespread application. When considering risk assessment and
risk management options, public submitters were far more likely to suggest a
precautionary approach and most unlikely to suggest genetic modification
application in the absence of firm controls.
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Differences between public submitters were slight, with the vast majority indicating
a preference for minimal genetic modification activity. However, there were some
differences between organisations and individuals or groups of individuals. In
particular, organisations were more likely to be accepting of application of genetic
modification than individuals or groups of individuals, but also more likely to
suggest the need for a strong regulatory framework. This is not surprising,
however, as a regulatory framework would not be needed if genetic modification
was rejected altogether - the preference of most submitters.
Some public submitters highlighted uses of genetic modification they would be
willing to allow under certain conditions. The range of acceptable applications
identified by public submitters is discussed below, under four headings:
*
health-related options
*
environment-related options
*
social-related options
*
economy-related options.
Health-related options
Most exceptions to a total ban on genetic modification related to the pursuit of
health outcomes. Given their focus on both prevention and health treatment, the
strategic options identified reflect public submitters' interest in maximising both
prevention and treatment opportunities. When commenting on health prevention,
submitters focused mainly on environmental quality and food production and
Stance on genetic modification
Number
%
Strongly against
7035
64.8
Tends to be against
2963
27.3
Neither for or against
659
6.1
Tends to be for
132
1.2
Strongly for
72
0.7
Table 3.2
Public submitters' general stance on genetic
modification (n = 10,861)
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Strategic options orientation
Number %
Generally accepting of GM
Accept most GM uses but within a strongly controlled regulatory framework
42
0.4
GM use except for a limited and selected range of excluded activities
40
0.4
Embrace all aspects of GM
39
0.4
Accept most GM uses
25
0.3
Adopt GM because its use is an inevitable global phenomenon
22
0.2
Embrace all aspects of GM technology within minimalist regulatory framework
6
0.1
Generally reject GM
No GM, no GMOs or GMPs permitted in New Zealand
5461
56.3
No GM for a specified use (often food-related), no comment on other uses
1546
15.9
No GM in food, no comment on other uses
1014
10.5
GM free except for a limited and selected range of uses
552
5.7
Risk assessment and risk management options
Need strongly controlled regulatory framework (particularly for food labelling)
979
10.1
Continue moratorium (whether voluntary or compulsory) pending further research
777
8.0
Wait and see what happens overseas
404
4.2
No patenting of GM products
236
2.4
Case by case assessment balancing risk against benefit (taking cautious approach) 184
1.9
More consultation with the public
137
1.4
Need minimalist regulatory framework
6
0.1
Multiple response
Table 3.3
Strategic options for genetic modification in
New Zealand (n=9,695)
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processing. When commenting on health treatment, some submitters also
commented on health research into treatments. The widespread demand for a ban
on genetic modification of food and food products was usually argued on health
grounds.
To achieve health outcomes through health treatments, submitters identified a
range of exceptions to a total rejection of genetic modification. These ranged from
general support for the use of genetic modification in health (in contained
laboratory settings and with strong controls and risk management) and/or
treatments to genetic modification technologies in the treatment of specific health
problems, including multiple sclerosis, diabetes, arthritis, Attention Deficit
Disorder, cancer, Huntingtons chorea and Parkinsons disease.
Submitters were more likely to support non-targeted genetic modification
application for a range of health problems than targeted use for specific health
problems. Examples of specifically defined exceptions to applications of genetic
modification included:
*
any intra-species uses (genetic modification within a species)
*
any inter-species uses (genetic modification between species)
*
any application to inheritable genes such as for Huntingtons chorea. A few
submitters rejected such applications as undermining human diversity and
denying the legitimacy of human imperfection.
Environment-related options
Exceptions to a total ban on genetic modification were also identified for the
achievement of desired environmental outcomes. These environmental outcomes
related to both environmental quality, for instance through pest control, and
environmental enhancement, for instance through enhancing biodiversity and
revegetation. Thus, for a very small number of submitters the application of
genetic modification technologies may be acceptable for:
*
eradicating pests such as possum, Old Man's Beard, gorse and rabbits
*
treating pollution such as oil spills
*
revegetation of indigenous species
*
recovering extinct species or saving threatened species
*
reducing the use of pesticides and insecticides.
Social-related options
A few submitters also identified exceptions to a total ban on genetic modification
to achieve social outcomes. These social outcomes usually related to equity issues,
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within New Zealand, between developed and developing nations, and between
current and future generations. Thus, some submitters accepted the use of genetic
modification to address particular equity issues such as a reduction in the costs of
food. However, the vast majority of submitters who commented about equity
issues in relation to food argued that the distribution of food was at the heart of
problems around food supplies rather than the production of sufficient food. They
were also distrustful of "miracle claims" surrounding genetically modified crops,
highlighting studies in which promised benefits (`super yields' for genetically
modified crops, and supposedly vitamin A-rich `Golden Rice') failed to materialise.
There were some submitters who had few qualms about genetic modification in
itself but were worried about the economic and ethical framework in which it is
occurring. Their primary concern was that private, corporate interests are
exercising complete control over new developments, developing genetically
modified products in areas of highest profit while simultaneously restricting
independent research into other benefits. This concern was best expressed by
submitters who felt that "... the profit motive has no place in GM-research." For
these submitters, the capitalist system and the market economy should have no
place in such fundamental research. These submitters were happy to see more
research and development of genetically modified products (usually in contained
situations, but sometimes more widespread) if it was under strict public control
and scientists were known to be working for the benefit of humanity.
Economy-related options
Public submitters were far less equivocal about the strategic use of genetic
modification to achieve economic outcomes. Because most public submitters saw
New Zealand's economic future in organic and genetic modification-free primary
production, they were less likely to accept any use of genetic modification
technologies. While some accepted some laboratory-based research, very few
could see field trials or release as consistent with their preferred economic future.
A great number of submitters saw genetic modification as having the potential to
destroy the New Zealand economy, for instance through massive crop failures,
evaporating global demand for genetically modified products, or over-reliance on
foreign corporations.
Although many submitters argued that genetic modification would lead to
worsening public health, some argued that the use of genetic modification in
health treatments would have economic benefits, given a reduction in health costs.
Some public submitters argued for a continuation of what they assumed to be
closely controlled use of genetic modification in laboratory settings, to achieve
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economic outcomes and to enable New Zealand's participation in the global
biotechnology sector. In extremely rare instances, public submitters argued for
minimally controlled use of genetic modification to achieve economic outcomes.