Response to the Government Position Paper
1.1 We would have preferred a single body to deal with gene biotechnology. If each commission is intended to deal with the applications in a particular area, there is a danger that none of them will deal with the technology itself. One major concern about gene biotechnology is the creation of viruses and other vectors capable of crossing species boundaries. Others include the use of antibiotic marker genes, and the possibility of the horizontal transfer of transgenes from one species to another (by various mechanisms, not simply cross-pollenation). These are about the technology rather than the applications¹.
1.2 Many issues cross the boundaries that have been set up between the committees. Most obviously, the dividing line between crops and foods is at best arbitrary. Many of the questions we should ask about GM soya as a crop do not change when it is harvested and becomes a food. In deciding how to apply the precautionary principle, the two commissions will have to discuss the question of the possible benefits in the same way. Cotton is not grown for human consumption, but after harvesting the plants can be used as animal feed and so enter the human food chain. Which commission will be involved if it is proposed to grow GM crops or animals from which drugs (or, in the case of pigs, even replacement organs) will be harvested?
1.3 Each commission must include members who are qualified scientists and not connected directly or indirectly with industry or government research establishments involved in the development of new GMOs. The lay members must also be prepared to learn enough about gene biotechnology to understand the scientific issues involved: especially in a field in which there is so much uncertainty it is not possible to take the science (worse, a partial view of the present state of the science) for granted and discuss the ethical considerations in isolation. This may make it difficult to find enough suitable people to staff three commissions.
1.4 Since the decision has already been taken to have three bodies (including the Food Standards Agency) dealing with GMOs, a way must be found to overcome these problems. For more than one panel to discuss the same issue may be time consuming, but is far better than failing to have it discussed at all. The remits for the commissions must therefore make it clear that they are to consider the technology itself, not just the applications, and that where an application overlaps two commissions, both must consider it. This might be done by having joint meetings.
2.1 The membership of the commissions must include scientists who are up to date with the technology being discussed but who are not connected with the production of GMOs, either directly or indirectly. This is necessary to ensure both that the lay members of the commission are given a balanced view of the science and that the questioning of witnesses is thorough. Scientists who are connected with the development of new GM organisms and those who are not are likely to have different experiences and different points of view, and both are required on a commission.
2.2 It is not enough that members should leave the room when matters connected with their company or laboratory are being discussed. This can achieve fairness between companies, but there are issues on which the biotechnology industry is likely to have a common view which it cannot be assumed is shared by everyone else in society.
3.1 The commissions should be required to follow the precautionary principle, that new technologies should not be implemented unless the likely benefits outweigh the possible hazards. The burden of proof must be firmly on those who are proposing to introduce gene biotechnology. This may create difficulties with the World Trade Organisation, but that is a matter for the Government. The commissions conclusions should represent their own best judgement of the case, not what they anticipate the WTO might require.
3.2 In considering applications of gene biotechnology, the commissions should be required to ask not just what are the possible benefits but whether the benefits could be achieved in another way. For example, it is argued that the herbicide resistant GM crops will reduce the amount of chemicals used in farming. We would expect a commission will consider such a claim in detail, especially asking what would happen if the resistance spread to the weeds. But the commission should also investigate whether there are other ways of reducing the use of herbicides which do not present the same problems as gene biotechnology.
3.3 As an example, we would cite the recent report by the Royal Society and the Royal Academy of Engineering on the future of nuclear energy². This considers in some detail not only what the world's energy needs are likely to be in fifty years time but also whether they could be met by other means. (In fact, the panel concluded they could not; the point is that they felt it part of their duty to inquire.)
4.1 The commissions should be proactive, seeking to anticipate issues before large investments have been made. Again, the RS/RAE Report illustrates what can be done. The working group that produced it was set up to consider the problems associated with plants that might be needed twenty or more years from now. As with energy, there is no immediate shortage of food in the world, so whenever there is uncertainty it is reasonable from the standpoint of society to require that more research be carried out before large scale trials and commercial production are allowed.
4.2 The commissions should also be able to have research carried out on their behalf. In Norway, for example, a Government agency, the Directorate for Nature Management, commissioned an independent scientist directly to produce a report on the ecological risks from horizontal gene transfer associated with the use of naked DNA in research, production and gene therapy. The commissions should not be obliged to accept an assurance that there is no evidence of risk when this means only that no research has been carried out to determine whether there is or not. Absence of evidence and evidence for absence are not the same thing.
4.3 The commissions should also be encouraged to discuss ethical issues which can be seen to be likely to arise but for which the relevant technology has not yet been developed. If it were to decide at an early stage that a certain application was undesirable, it could recommend that the Government not fund research that was designed to advance it, and industry would naturally be discouraged from investing in it. It is much easier for a Government to decide not to pursue a technology when there has not already been a large investment either from public or private sources.
This response was prepared by Professor Peter T. Saunders, Department of Mathematics, King's College, Strand, London WC2R 2LS.
1.As an example of the problem, the recent report Genetically Modifed Crops: the Ethical and Social Issues (The Nuffield Council on Bioethics, 1999, ISBN 08522701 4 5) says nothing about either horizontal gene transmission (for example, via soil bacteria) or the evidence that transgenes are more likely to transfer again than are other genes. Yet both are clearly relevant to any discussion of the ethics of gene biotechnology in agriculture. What is more, both were mentioned on The Archers (1 August, 1999). A body which completely ignores an important issue that is discussed on a popular radio serial is unlikely to gain the confidence of the public, nor will it deserve it. This is a major reason why the scientists on the commissions must not all have similar interests and experience.
2.Nuclear Energy -- the future climate. Royal Society document 11/99. (published June, 1999)
Article first published 1999
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