GM Science Review - Comments on First Report

From: Mark Cantley, Brookhouse, Lancaster

Response 1: why are we holding this discussion - again?

Why is this debate taking place? Why is the development and use of GM crops a matter of such momentous concern to all citizens that this unique and extended exercise is considered necessary, unlike all the many minor and major matters with which government routinely has to deal? The decision to stage this great national pseudo-drama looks more like a massive mis-judgement.

Practically all of our plants and animals used in agriculture are the outcome of centuries and millennia of selection and breeding. For the plants and micro-organisms, the last half-century has seen extensive use of mutagenesis, induced by chemicals or uv radiation, followed by selection of those surviving this rough genetic surgery, and offering some desirable trait. All our agriculture has long been using "gm crops", and suggestions that we should "stop, or refrain from, meddling with nature" cannot be taken seriously. So why the paranoid over-emphasis on the latest generation of smart tricks?

There is a huge implicit message conveyed by the heavyweight process, but I find it unconvincing, and worse, misleading. The first concerns about conjectural risks of modern biotechnology, recombining DNA molecules with greater precision, were expressed in 1973, over 30 years ago. After a pretty massive international debate, involving scientists, politicians, the public and the media - we did arrive at a political conclusion. The countries of the developed world, through the Organisation for Economic Cooperation and Development, set up a Group of National Experts on Safety in Biotechnology, and in 1986, following years of deliberation, the Council of Ministers adopted a Recommendation, which recognised that "there is no scientific basis for specific legislation to regulate the use of recombinant DNA organisms". The report - "Recombinant DNA Safety Considerations: Safety considerations for industrial, agricultural and environmental applications of organisms derived by recombinant DNA techniques", is still available for all to read, on the OECD website, at www.oecd.org/dataoecd/45/54/1943773.pdf.

The GM Science Panel Report spares us this history - but the history in fact remains relevant, as the one country which has based its policies on the OECD 1986 conclusion is the USA - and there is little sign that they have any regrets over that choice. The Report suggests that future applications of the precision techniques of modern biotech may pose more major challenges to regulation - but they do not add up to a convincing case for the heavy anticipatory regulatory burden which has been imposed in the EU over the past 12 years.

My suspicion is that the high profile arguments about GM crops have as much relevance to food safety as the war witnessed by Gulliver in his travels, between the Big-endians and the Little-endians, concerning which end to open first in eating an egg. So my first reaction to the Report remains - why are we doing this?

Response 2 - a lack of proportion and sense of context

The current UK debate on the use of modern biotechnology:

* lacks a sense of proportion: modern biotechnology is not presenting major threats to human health or the environment, (though it is certainly demonstrating benefits in both areas) - so why the massively dramatised, overblown, national debate?

* lacks a sense of historical context - the debate on the safety and regulation of biotechnology has been going on for over 30 years, and we have learned a lot, most of it rather reassuring;

* lacks a sense of geographical context - the UK is a member country of the European Union, the Organisation for Economic Cooperation and Development, and of various agencies of the United Nations, and it participates actively in the global scientific community - in all of these contexts, debate on modern biotechnology has taken place for many years, some of it useful;

* lacks a sense of the ongoing societal learning process - part of it the progress of science - which has provided such astonishing advances in our quality of life, by almost any objective measures, over the past two centuries.

The main new elements in the products and practices based on modern biotechnology are greater knowledge and precision. These are not inherently toxic, offer immediate and increasing benefits, including enabling us to feed better a larger world population on the currently cultivated area, in a more sustainable manner. So why are we frightened of the new knowledge?

Fear of innovations based on the recent advances in biological knowledge seems to reflect a very parochial response. Given that the EU is the world's leading trading bloc, and the UK one of its leading centres in science and technology, we should surely be welcoming progress towards a more productive, sustainable and knowledge-based economy.

The needs - e.g. for the shift to more sustainable agriculture - and the opportunities, are evident. One of the finest summaries is surely that splendid sentence in the Executive Summary of the Nuffield Council on Bioethics' May 1999 report on "Genetically Modified Crops: the ethical and social issues": "The moral imperative for making GM crops readily and economically available to developing countries who want them is compelling". Why are we agonising so long about using the fruits of our successful research?

Response 3 - on the correct and incorrect application of the Precautionary Principle

The GM Science Panel Report discusses on pages 46-47 the famous - or notorious - "precautionary principle". Why "notorious"? Because, in many US eyes, it has become a synonym for knee-jerk protectionism. It is unfortunate that the principle has indeed been misquoted and misapplied by various individuals and European governments, so frequently as to lend substantial justification to the US reaction.

In fact the core idea is common sense - when the ground ahead is uncertain, and the consequences of error might be serious, look before you leap. This is spelt out in the 27-page communication on the precautionary principle published by the European Commission in February 2000, and endorsed in the following months by the European Parliament and Council of Ministers - thus, the fundamental reference on this subject in the present context.

The Commission communication has a 3-page summary, which states:

"Where action is deemed necessary, measures based on the precautionary principle should be, inter alia:

* proportional to the chosen level of protection,

* non-discriminatory in their application,

* consistent with similar measures already taken,

* based on an examination of the potential benefits and costs of action or lack of action (including, where appropriate and feasible, an economic cost/benefit analysis),

* subject to review, in the light of new scientific data, and

* capable of assigning responsibility for producing the scientific evidence necessary for a more comprehensive risk assessment."

What this adds up to is a clear pointer to the DYNAMIC character of this principle. We must hope that this will be recognised, especially as the precautionary principle or approach is now enshrined elsewhere, for example in the preamble and Article 1 of the Cartagena Protocol on Biosafety; and in the first article of the Commission's current proposal for a new system of regulation and authorisation of chemicals.

On pages 46-47 of the Panel Report, there is a short discussion of the precautionary principle. It makes no reference to the European Commission's communication on this topic. It selects from one of the other reports cited a list of eight points alleged to be "A summary of key characteristics of a precautionary approach to the appraisal of risk". This "summary of key characteristics" unfortunately omits the most important - namely, its dynamic character. In a field which has seen:

* very rapid scientific and technological progress;

* rapid commercial developments (at least in, some areas of the world);

* a near-perfect safety record regarding absence of significant damage to human health or environment;

* a substantial record of environmental benefits as compared with conventional practices; and

* substantial research into the safety of modern biotechnology for over twenty years;

it is singularly unfortunate that the report of the GM Science Review fails to take note of these dynamic developments - in spite of thirty years of dynamic history.

Response 4 - an important historical example of how to use the precautionary approach, or principle

There has been one important case study on the correct application of the precautionary principle, which remains of relevance to the ongoing debate on the regulation of modern biotechnology. Consider the history from 1973 to 1986, and its lessons.

Concerns were expressed about the conjectural risks of modern biotechnology, in 1973 - 30 years ago. A committee was set up by the US National Academy of Sciences, under Paul Berg. Their report was published in July 1974, as a letter in Nature and Science. It advocated a temporary moratorium on certain types of experiment, and that moratorium lasted some 18 months, while related research and discussion continued. There was an international conference on the risks, at Asilomar, California, in February 1975, with press present. That initiated several years of widespread public debate, across the developed world.

The US National Institutes of Health set up their Recombinant DNA Advisory Committee, which produced research guidelines in 1976; similar committees were also at work in the UK, Germany, Sweden, France, The Netherlands ... The European Commission proposed in 1978 a draconian directive on research on recombinant DNA (rDNA), and then realised that the scientific debate was advancing fast, and that the initial conjectures about possible risks were overblown. Wisely, they withdrew that proposal in 1980, replacing it with what became the Council Recommendation 82/472 - advocating national registration of rDNA research, just in case anything adverse turned up. This was a balanced and sensible measure, and at each occurrence of the word "risk", it was preceded by the adjective, "conjectural". Would that a similar prudence prevailed to-day!

The international debate was carried forward at the Organisation for Economic Cooperation and Development, under a Group of National Experts on Safety in Biotechnology. By 1986, they had completed their basic work, indicating that the new techniques were not leading to risks of any different kind from those routinely handled in various sectors of the applied life sciences (pharmaceuticals, pesticides, seeds, food and feed, etc).

Guided by the international debate, the research, the increasing experience, the US government decided that they could handle the products of modern biotechnology under existing agencies and statutes - there was no need for new legislation. They published this "Coordinated Framework" as a proposal in 1984, and following the public comment and debate, finalised it in 1986. Happily for the US, this remains the basis of their current policy, which has permitted continuing rapid research and innovation, in health care and in agro-food applications among others, with leading edge performance and competitiveness.

The whole story illustrates the correct application of the precautionary principle - starting cautious, and being prepared to adapt - towards tighter or looser regulation - as knowledge and experience accumulate. It is a dynamic principle, as is made clear by the European Commission's communication on the subject - reference COM(2000)1.

Why has similar development not taken place in Europe, starting from a scientific and industrial base no weaker than that of the US? Who restarted this prairie fire of delusions and accusations, of unnecessary alarms and legislation, of treaties and trade wars, simply because they couldn't learn from history? Is it just a promotional campaign for organic farmers, and does "GMO" really stand for "Greenpeace Membership Opportunity"?

Response 5 - governments offer a one-dimensional response to a multi-dimensional challenge

The gm crop debate serves as an instrument for the pursuit of other agendas. Many of the arguments seem to reflect some other underlying issue - of hostility to multinational companies, or agricultural protectionism, or anti-Americanism, or opposition to the principles of intellectual property (a pity, if we wish to move to a more sustainable, knowledge-based economy!) or simple back-to-nature movements.

In such contexts, research into the safety issues becomes a red herring. The debates become passionate, because they are becoming proxy battle-grounds for other passionately held opinions; the poor old gm crops suffer the misfortune of being in the battlefield. Certainly quite a few of them have been pulled up or trampled along the way.

The public policy debate has not benefited from clear leadership from government. One is repeatedly inclined to ask, "Who's in charge round here?" That question has given governments problems over the past 25 years. It seems to be difficult or impossible for governments to get their acts together, to respond to a multi-dimensional challenge. Evidently it requires a coordinated approach, since it has implications (mainly benefits) for the Ministries of Research, Industry, Agriculture, Health, Environment, Trade, Education, Development ... Why have the Ministries of Environment been left in charge of matters clearly far beyond their competence, so that they have now succeeded in:

* blocking the development and diffusion of more environment-friendly products, processes and practices;

* causing a major geopolitical trade war with our principal trading partner and longstanding ally;

* inhibiting the transfer to, and use of, much-needed technologies by developing countries whose need for these technologies and their fruits is evidently far greater than ours;

* colluding in the hijacking of the CBD by the so-called "Biosafety Protocol", a measure of total irrelevance to the objectives of conserving biological diversity;

* colluding and promoting in Europe and worldwide a cat's cradle of crazy regulations which are neither comprehensible nor useful, but merely strangle research, innovation, and the shift to more sustainable products and practices;

* thereby paralysing and confounding the occasional serious efforts made by other ministries, scientists, industries and men and women of competence and goodwill, to promote and profit from the surge of new knowledge and smarter techniques which thanks to the ingenuity of our scientists and the success of research budgets is now available?

What, in short, do we pay these guys for? And what have they done instead?

Response 6 - on risk assessment: where's the evidence, or when will it arrive?

There is a - what shall we say? - a hypothesis? an assumption? a pretence? that the methods and results of modern biotechnology are inherently dangerous.

The GM Science Panel report chews at this here and there, and makes some poor logic and unjustified conclusions. They admit here and there that the gm products are not presenting any different or bigger risks at present (in fact, there's a pretty big pile of evidence that they're producing smaller risks, and more sustainable practices) - but given the power of the techniques, they might get us into deeper water later. Maybe.

But in the meantime, we have been conned and bamboozled into allowing - and paying for, and suffering the consequences of - a whole industry of Inquisitors, witch-hunters, heresy-detectors and Lords-High-Everything-Else - to go chasing after the mythical risks of gm crops and micro-organisms, while ignoring the actual results of biosafety research over the past 30 years and practical experience around the world over the past 20. The evidence has been publicly presented, in international fora - for example, in the bi-annual International Symposia on "BIOSAFETY RESULTS OF FIELD TESTS OF GENETICALLY MODIFIED PLANTS AND MICROORGANISMS", from Goslar in 1992, to Beijing this year; the EC-sponsored research over the past 15 years - EUR70 Million EURO, 80 projects, involving over 400 laboratories around Europe - for no significant evidence of risks, and increasing evidence of substantial benefit of increased safety (better designed, cheaper vaccines) and more sustainable agricultural practices that don't require so much use of pesticides, fuel or sprays.

Looks to me as though we have a naked Emperor - nay, an army of them. Again, what are we paying these guys for, and what are they doing with our money?

Response 7 - why are we frightened of the new knowledge? And why are our county councillors going mad?

There are some new ingredients in the GM crops, and they seem to have been kept pretty secret. I'd call them intelligence, knowledge and precision. They're not inherently toxic, but it seems they can frighten people.

We are addressing the conjectural risks of these beasties by what has been called - and the electronic magazine sp!ked recently quoted this most appropriate description from a government spokesman - "organised paranoia". It seems to be infectious.

It has infected a number of our county councils, who are pretending that they can ban the growing of GM crops in their territory. I guess if they don't like brown eggs, or want to insist that they be opened at the little end, they could try insisting on that too. Who do they think they are fooling? If they do manage to ban from their schools and colleges the serving of foods from gm crops, or brown hens' eggs, they are managing:

* to send a grimly anti-educational message to the children and students in their schools and colleges - science is fine at school or college, but don't try applying it in innovations;

* to cause economic damage to some unfortunate farmers, importers, food processors who suffer loss;

* to lay the County Council open to actions for damages from these aggrieved parties - though as the action of the Councillors is probably illegal, with any luck the costs will be met by personal surcharges on the Councillors, rather than put on the rates.

In fact these fine-sounding declarations are ineffectual and illegal, constituting infractions of the free market legislation of the European Community, and wasting the taxpayers' resources. Has any council, or has the government, notified the European Commission of these interferences with the free marketing or cultivation of goods authorised for placing on the market after very rigorous safety scrutiny?

To sum up: we are being frightened by shadows, trapped by funny words - "species", "gene", "transgenesis", "mutation" - in games which are totally irrelevant either to the safety of our food, or to the protection of our environment. I can only congratulate the 99.9% of the UK population who have not participated in the public meetings on gm crops on their excellent and balanced judgement.

When there's a real problem, please let us know. Meanwhile, please stop crying "Wolf!" - it frightens the children.