Analysis of Public
Submissions
Analysis of
Public Submissions
3.
section 3.5 |
appendix 3
Outcomes of Consultation: Submissions
from the Public
Section contents
3.
Analysis of Public Submissions
22
3.5
Evidence and uncertainty
56
Background
56
Outline of this section
56
General comments
56
Environmental matters
60
Social matters
62
Health matters
62
Food matters
63
Economic matters
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3.5 Evidence and uncertainty
Background
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.
While only a small percentage of public submitters commented specifically on
evidence matters, greater numbers expressed concern about the levels of uncertainty
about current and future use of genetic modification technologies.
Outline of this section
This section of the report includes:
the views of public submitters in general, and with reference to:
*
environmental matters
*
social matters
*
health matters
*
food matters
*
economic matters.
General comments
Generally, public submitters were unlikely to raise issues related to uncertainty and
evidence. (As Table 3.10 shows, 359 submitters commented on uncertainty and the
nature of evidence.) However, given the large number of public submitters overall,
even this small proportion covered a wide range of topics. Although public
submitters rarely addressed the issue as outlined in the Warrant specifically,
anxiety about uncertainty permeated their submissions. As well as raising concerns
about uncertainties in general and a need for public information, they commented
about uncertainty with respect to four areas: environment, health, food and
economy. In each of these areas, submitters wrote of uncertainties around risk,
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safety, costs and benefits, other compounding factors, such as ethical
considerations, and any evidence to support their apprehension.
Many submitters raised concerns over the lack of trustworthy information
available to the public. There were two main perspectives. First, there was a call
for more information from people who felt ill-informed to make a decision about
genetic modification, and wanted all the facts presented in an unbiased forum.
Second, some submitters wanted to see the government provide funding for the
dissemination of information highlighting the risks of genetic modification. This
second group were angry that the government was funding pro-genetic
modification groups (perceived as linked to big business) while groups opposed to
genetic modification (perceived as small collections of individuals) were struggling
to raise funds and make themselves heard.
Submitters also made general comments, in particular noting their lack of faith in
the safety of genetic modification technologies in general, given the relative
`newness' of the technology, insufficient or inadequate testing, equivocal results,
and their lack of trust in the corporate producers and their claims of benefits from
genetic modification. The lack of trust, which often was also extended to scientists
and government (and the legislative and regulatory framework), stemmed from
their belief that these entities do not work in the public interest. Some public
submitters also noted their lack of certainty about the levels of genetic modification
research and application in New Zealand currently and their lack of faith in the
ability of producers to control the genetic modification technologies they develop
and use.
Public submitters also displayed concern about safety assurances by scientists,
arguing that the procedures used to genetically modify organisms were themselves
random, and scientists could not be sure where exactly inserted genes would "end
up" in the organism. They worried that this could result in dangerous products
with unforeseeable consequences.
Public submitters tended to judge evidence of risk as more certain and evidence of
safety and benefits as less certain. Submitters were generally aware that there was
no conclusive proof of serious danger, but felt that there was ample to justify a
precautionary approach. The comment was frequently made that "... absence of
proof of risk is not proof of absence of risk." Submitters backed up their scepticism
about genetic modification safety and claimed benefits by referring to:
*
unanticipated negative environmental and economic impacts of past (non-
genetic modification) technologies and current genetic modification
technologies. Amongst the latter, the examples identified included studies
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showing Monarch butterflies dying from genetically modified corn pollen,
genetically modified crops affecting the soil, and cross-pollination from
genetically modified crops to wild varieties creating "super-weeds"
*
unanticipated health risks such as new allergies arising from genetically
modified pollen, the evidence that insertion of genes from the Brazil nut
into soy could cause potentially fatal allergic reactions in people eating soy
products, the poisoning of a number of people in America through a batch of
genetic modification-produced tryptophan, and studies showing evidence of
possible horizontal gene transfer through genetically modified pollen in bee
guts
*
some submitters produced as evidence the application by Monsanto to
increase the allowable residue of its herbicide `Round-Up' on food to
support their concern that genetic modification would necessarily result in
greater chemical use in food production
*
bad company practice through previous disasters (including non-genetic
modification technologies) in which companies denied wrongdoing, hid
evidence of risks, and attempted to evade responsibility
*
the ambiguity of scientific results, given factors such as a perceived
untrustworthiness of scientists, and conflicting reports from scientists.
Many submitters displayed outrage and anger over pro-genetic modification
claims of benefits arising from genetic modification. This outrage was most often
expressed over the "GM can feed the world" argument. One submitter's comment
that it is a "cheap attempt to sway public opinion" reflected the views of others.
These submitters pointed out that starvation was not due to a global food shortage,
that genetically modified crops promising "miracle benefits" were proven to be
rarely better than non-genetically modified varieties (possibly worse), and that
leaders of developing countries themselves criticised these claims. Much intense
anger (though less widespread) was also expressed over scientists and businesses
getting funding and public support from claims of miracle health benefits that
failed to materialise or would, at best, take many years to materialise. These
submitters were outraged that proponents of genetic modification were preying on
the fears of the sick and raising "false hopes" in a conscious act of deception.
Table 3.10 summarises the attitudes of submitters who commented on evidence
relating to the safety of, or risks posed by, genetic modification technologies.
Overall, few public submitters specifically commented on the strength of evidence
around genetic modification safety and genetic modification risk. However, only a
handful of those who commented believed that there is evidence that genetic
modification is safe or no evidence that it poses risk. Most of those who
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commented believed that there is evidence that genetic modification poses risks
or no evidence that it is safe. A small group believed the evidence is still
equivocal. One submitter, who identified himself as a former manager at a
pharmaceutical company wrote:
... the only evidence able to be adduced is from parties who have a vested interest in
seeing Genetic Engineering proceed. This evidence may or may not be true and factual but
it must be regarded with considerable scepticism. One of the simple facts of scientific
papers and presentations is that they are heavily funded by commercial concerns and have
been shown to be tainted in the past. Both the Pharmaceutical Industries and more clearly
the Tobacco Industries are examples of this ... [As a former manager] I can testify to the
view of a research paper being held back from publication when it does not suit the
company's product objectives.
Existence of evidence or information
Number
%
Evidence that GM is safe or no evidence that it poses risk
No scientific evidence/information that GM poses significant risks
11
3.1
There is scientific evidence/information that GM is predominantly safe
2
0.6
No evidence/information that GM poses risks
2
0.6
There is evidence/information that GM is predominantly safe
0
0.0
Evidence is equivocal
21
5.8
Evidence that GM poses risk or no evidence that it is safe
There is evidence/information that GM poses significant risks
166
46.2
There is scientific evidence/information that GM poses significant risks 108
30.1
No evidence/information that GM is predominantly safe
36
10.0
No scientific evidence/information that GM is predominantly safe
13
3.6
Table 3.10 Existence of evidence or information about GM-safety or
risk (n = 359)
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Environmental matters
The comments of public submitters reflected their general belief that scientists'
and producers' uncertainty about the impacts of genetic modification technologies
and applications was reason enough to avoid them altogether. Uncertainty around
impacts related to:
*
unknown but probably negative impacts of genetic modification applications
on current and potential organic farming
*
impacts of non-contained genetically modified crops on other crops
*
impacts of non-contained genetically modified crops on wild varieties
*
general degradation of the environment from, for instance, toxins from
roots of genetically modified plants washing into waterways, genetically
modified crops allowing greater use of herbicides and their run-off and
impact on wild plants
*
unpredictable changes and imbalances through manipulation of the
evolutionary process that could take years to manifest and lead to catastrophe.
One quote "Make no mistake, Nature will retaliate" is typical of these
submitters' views
*
risk of genetic contamination of indigenous flora and fauna.
Public submitters also commented on factors that potentially exacerbate people's
levels of anxiety because of uncertainties around the impacts of genetic
modification. Factors identified by submitters included:
*
non-containment of genetically modified crops
*
lack of ethics in genetic modification research and development
*
lack of choice faced by both other producers (such as organic producers) and
the general population in areas where genetic modification applications
occur.
Public submitters usually did not cite evidence to back up their concerns. When
they did cite evidence, it was usually of a more anecdotal nature. Thus, a number of
people cited the negative impacts of genetically modified crops on beneficial
insects (such as studies on the Monarch butterfly) and birds as evidence of the
unpredictable nature of genetic modification impacts. Reference was occasionally
made to the book Silent Spring as proof of the dangers of ignoring environmental
impacts of new technology. They also referred to the contamination of American
and Canadian corn and canola crops by genetically modified crops, and the
resulting loss of markets in Europe.
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They were more likely to draw analogies from environmental disasters unrelated
to genetic modification, pointing out often irreversible consequences of previously
sanctioned technologies. The ecological damage caused by gorse, rabbits, possum,
thar and deer were presented as evidence of the unforeseen negative impacts from
introducing apparently useful, but harmful, exotic species.
Submitters also offered the uncertainty felt by others as evidence of the
unacceptable risk from genetic modification. The most commonly cited evidence
was the reluctance of insurance companies to insure against impacts. They
interpreted this reluctance as proof of great risk and potentially disastrous
consequences. "Genetic engineering is so risky that insurance companies refuse to
touch it, so why should we?" was one expression of this view. Also raised, though
less frequently, was scientists' "unwillingness" to give 100% assurances of safety.
This was seen to be proof of risk.
One of the strong themes in public submissions was growing public distrust in the
scientific process, which they saw as unduly influenced by scientists' funding
sources. One submitter's statement summed up wider concern:
A growing dependence on private funding means that many academics are having their
research interests aligned with those of their donors. Crown Research Institutes, which are
involved in genetic engineering and work closely with many universities, are required to
operate as successful going concerns, and to sell their research. This means that industry
is able to capture the benefits of publicly funded research and may mean that findings
which are damaging to industry interests are withheld.
The perceived lack of independence of scientists means that their assurances about
genetic modification safety do not lessen public anxiety. Public submitters wrote
about what, in their view, were the unrealistic claims of benefit from genetic
modification. One example they commonly cited was of scientists exaggerating the
ability of `Golden Rice' to provide the necessary daily dietary quantities of vitamin
A. They also drew parallels to non-genetic modification cases (eg the tobacco,
nuclear power and pharmaceutical industries) in which, they argued, scientists
routinely assured the public that products were harmless.
Submitters saw reason to distrust corporate involvement in genetic modification
and believed multinationals were trying to monopolise food sources. They
expressed concern that companies would attempt to claim royalties from farmers
who have genetically modified crops growing on their land due to uncontrollable
factors such as pollen drift. Submitters often cited the landmark Canadian lawsuit
in which Monsanto is suing a farmer for this very reason as indicative of how New
Zealanders could lose control over their crops, farms, and home gardens.
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Submitters' uncertainties about genetic modification were also heightened by
their religious/ethical/values stances. Some commended the "natural balance" of
ecosystems, only achievable through natural selection processes and destroyed
through genetic modification. The attitudes of many submitters were summed up
by one who wrote to make the point that "... any way, I like imperfection because
that's what makes us what we are." Other submitters identified the Bible as
evidence to back up their belief that genetic modification is wrong
More generally, public submitters were inclined to trust their own feelings and gut
reactions to genetic modification. They considered these feelings to carry as much
weight as any other arguments. As one submitter wrote "... genetic modification
makes me feel SICK and UNEASY to the depths of my very being. It must be
stopped!!" [submitter's emphasis] They felt that their own beliefs and feelings
should be considered and respected by Government and the Commission. Others
believed that this would not be the case and strove to provide more scientific
evidence to back up their ethical and emotional stance.
Social matters
Several submitters raised concerns about the impacts, or the uncertainties around
those impacts, of genetic modification on human society. Their fears included:
*
a potential (but unspecified) breakdown of society
*
a general decline in morals and ethics as they are disregarded in the pursuit
of profit
*
the effects of genetic screening or eugenics on society (which they compared
to the ethnic cleansing policies of Nazi Germany). Some people with
specific medical conditions were concerned that people like them could, in
the future, be genetically screened out
*
the impacts of genetic modification applications on social and economic
equity. For instance, some groups may be disadvantaged (or "ghettoised") by
their lack of access to the benefits of genetic modification or genetic
modification-free products.
Health matters
Public submitters wrote about their unease regarding the claimed benefits from
genetically modified health technologies and their concerns about the impacts of
genetic modification activities (in the environment and elsewhere) and their
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impacts on the health of themselves and their children. Their concerns included:
*
uncertainty about the capacity of the treatments to achieve the claimed
outcomes and their effects on individual health. Submitters cited evidence of
genetically modified human insulin causing allergic reactions and other
negative health impacts on users. Some also presented AIDS, which they
attributed to vaccine work with monkeys, as evidence of negative health
effects of crossing species
*
uncertainty about the health effects of releasing genetically modified
products into the environment. The most commonly cited area of concern
was the release of genetically modified pollens and their unknown effects on
asthma and other allergies. Another less frequently raised concern came
from people interested in homoeopathy. They wondered whether genetic
modification would alter or remove medicinal benefits of plants, either
immediately or unexpectedly, in the future
*
the unknown effects of exposure to genetic modification activities (including
health treatments) on people's social, psychological, spiritual, cultural or
ethical integrity. These effects may arise because people are opposed to
genetic modification and have little choice about their exposure to it or have
no control over access to it
*
the unknown effects of genetic modification technologies on the health of
future generations. As evidence, public submitters referred to the ongoing
effects of chemical such as Agent Orange, DDT and thalidomide
*
uncertainty about the impacts of genetic modification on the public health
system. The level of health benefit from genetic modification-based
treatments is still unknown, as are the opportunity costs of avoiding genetic
modification-based treatments and the extent to which the health system
may be overburdened by any negative health effects from people ingesting
genetically modified food.
Food matters
For public submitters, uncertainties associated with genetically modified food
related to people's lack of choice about what they eat, the potential impacts of
genetic modification on organic food production, and its impact on food safety and
quality.
Consumer choice was an important issue for public submitters, and they identified
several reasons why the introduction of genetic modification into food production
decreased their confidence in having choices. First, the lack of food labelling
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information precludes consumers in general from being able to choose what they
eat. Secondly, particular groups of consumers with special need for certainty about
their food composition are compromised. These include, for instance, Maori,
who reject the inclusion of human genetic material in animals, Jewish and
Muslim people with religious dietary restrictions and vegetarians and vegans
who reject ingesting all animal products. Third, patenting of genetically modified
products may restrict consumer choice by, for instance, raising the costs of some
foods so that they become unaffordable.
Uncertainties around organic food production, given the unknown effects of
genetic modification technologies, were also raised by public submitters. While
their greatest concern was for commercial production, they were also concerned
about home gardening. They felt that any genetic modification activities placed
current and future production under threat, especially as cross-pollination and
other potential impacts are still largely uncharted. The insertion of Brazil nut
genes in soy beans and the possible contamination of genetic modification-
produced tryptophan were cited as evidence of current, unanticipated risks.
With the application of genetic modification in food, uncertainty around food
quality increases. Public submitters strongly defended people's rights to quality
food, which they characterised as safe, nutritionally healthy, tasty and available.
Several factors increase uncertainty around these components of food:
*
The concept of substantial equivalence in food testing concerned a number
of submitters who argued that the lack of adequate testing for those foods
deemed substantially equivalent decreased consumer certainty about food
safety. A number of these submitters were also concerned about a possible
double standard in which genetically modified food could be both
substantially different (allowing it to be patented) and substantially equivalent
(allowing it on to the market with little or no testing).
*
The failure of innovations like the Green Revolution and mono-cropping
have increased public anxiety about the impacts of genetic modification on
food quality and availability rather than assuaging it. Submitters cited the
deteriorating taste of fruit and vegetables, especially tomatoes, as evidence
that technological intervention often reduces food quality.
*
Genetic modification activities can undermine availability of food. While
scientists argue that genetically modified food has the potential to alleviate
food shortages, submitters argued that shortages are as much to do with
distributional problems and politics and cited difficulties in the distribution
of aid in developing countries and war zones as evidence. Some also noted
the negative impacts of genetically modified food production on land use in
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developing countries, where subsistence farming is progressively
undermined.
Economic matters
Although public submitters were most concerned about uncertainties relating to
the environment, health and food, some also raised concerns about the economy
and the potentially negative impacts of genetic modification on existing and future
economic activities. For the most part, they focused on organic production,
particularly on the damage any application of genetic modification technologies in
the environment was likely to have on commercial production. While they were
concerned about current organic activity, their greatest concern was for the
damage to future production. A common view amongst submitters was that the
demand for organic produce overseas, especially in Europe, would continue to
grow. Any release of genetically modified organisms would deny New Zealand
farmers the opportunity to become certified producers and take advantage of that
demand. It would also deny future workers the opportunity of employment in the
organic farming sector. Their view was that organic and genetic modification
production cannot coexist. Submitters referred to the landmark canola case in
Saskatchewan, Canada (already mentioned) as evidence of the conflict between
genetic modification applications and other farming activities.
Submitters saw a unique opportunity for New Zealand to capture a niche market
in non-genetic modification and organic production. They contrasted that
opportunity to a future in which New Zealand "follows the herd" and adopts
genetic modification and once again finds itself in a position where it has to
compete directly with larger and more productive countries. These submitters saw
the opportunity to be the world's only guaranteed supplier of pure food as too good
for New Zealand to ignore.
At the same time as there is an increasing world-wide demand for organic produce,
public submitters argued, there is a corresponding decline in the demand for
genetically modified products. By going down the biotechnology road, New
Zealand runs the risk of investing in a declining market area. As evidence, some
submitters indicated their belief that America, Canada and other producers are not
able to sell genetically modified products such as canola and corn.
Submitters noted that tourism continues to offer New Zealand a basis for
economic diversity and growth. However, they were concerned about possible
risks, as yet undefined, of genetic modification activities on that industry. One
possible outcome of New Zealand's adoption of these technologies may be damage
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to indigenous flora and fauna, loss of our clean, green reputation and, therefore,
our decline as a favoured destination by those seeking high environmental values.
Any degradation of fish species, including exotic and indigenous species, may also
affect tourism, some also believed.
Another area of uncertainty identified by public submitters related to market
intelligence. Submitters pointed out our lack of knowledge about the economic
impacts of New Zealand adopting or rejecting genetic modification technologies.
Some wrote of mixed signals about profitability of products of genetic modification,
particularly agricultural products. A few submitters questioned New Zealand's
international trade relationships, asking whether we would lose our independence
if genetic modification technologies were embraced. Others had the same
concerns, but as a consequence of genetic modification avoidance. A few referred
to former United States Ambassador Josiah Beeman's warning that we risk trade
sanctions if we do not follow the of genetic modification path.
Although referred to only rarely, some public submitters also raised concerns
about New Zealand's participation in, and development of, a knowledge economy.
They were concerned that any rejection of genetic modification technologies
could lead to a loss of expertise, as researchers and students are closed out of future
technologically based economies, variously described as a knowledge economy and
a technological society. Other submitters, on the other hand, saw opportunities for
New Zealand to lead the world in research into organic and biodynamic forms of
agriculture and holistic medicine.