Response to the Government Position Paper-
Ethical Aspects of Biotechnology and Genetically
Modified Organisms.
Prof. Peter Saunders
1. Remits:
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. Membership
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. The Precautionary Principle
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. Looking Ahead
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.
email: peter.saunders@kcl.ac.uk
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)
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