The UK Government is planning to reduce regulation around gene-edited livestock and crops in England, arguing that this technology is essentially no different from natural breeding and should not be regulated the same way as older methods of genetic modification. While this does not immediately affect the production of GM crops and livestock in Scotland, under the Internal Market Act we would not be able to prevent these foods being sold in Scotland. There is also the business of cross-contamination in border areas.
Nourish organised a discussion on this theme between our members to inform our response to the consultation (that closed on 17th March). The group that came together included a range of people representing unions, NGOs, farmers, retailers, scientists and researchers, including one currently working with gene-editing techniques. The meeting concluded that we weren’t of the view that the technology is inherently evil but we unanimously agreed that we need there to be regulation that is fit for purpose to keep us safe, and in that, we could learn something from Norway on this.
How (not) to run a public consultation
In Norway a panel is in the midst of an 18-month review. It is an independent, broad and democratic assessment involving civil society, individuals representing a range of special interests and expertise, and members of the public. The process encompasses five pillars: health, environment, ethics, sustainability and economics.
In the UK, by comparison, we have a rushed 10-week biased consultation that was taken to task for being an example of how not to “public consultation“. First, its questions are misleading. They state that genetic changes ‘could have been produced through traditional breeding’. In fact, gene-editing techniques produce errors and mutations (damaged DNA) across the genome. The interventions are typically multiple and therefore result in multiple ‘off target’ and ‘unintended’ effects. Gene-editing is by definition different from natural selective breeding, and the suggestion that GM products ‘could have been produced through traditional breeding’ is unproven and unlikely to be true. This was also recognised by the European Court of Justice in 2018. Certainly, no decisions about removing regulation should be based on unproven theories.
Second, the questions ask detailed technical questions and supporting evidence that only an audience of specialists can answer properly. Third, at the very least, a consultation on this theme should be conducted UK-wide – not just in England – as the Internal Market Act renders devolution on this matter a red herring.
The case for regulation
It is clear that we need regulation for a range of reasons. When it comes to safety and risk: the risk assessments done by scientists only ask limited questions around ‘what is the harm to human health?’ There are many potential risks to a wide range of socio-political structures as well as to biodiversity. Risk can be direct/indirect, immediate or longer term, cumulative… Once released, the products of these new technologies have further interactive effects. Scientists know very little about these new technologies, and therefore at a minimum, risk management measures should be retained. De-regulation stops informed discussion as we lose the chance to label, and therefore monitor and trace.
As for GM techniques used in livestock breeding: we need to establish answers to questions about unintended negative effects on animals including the bringing about of pain and illness, the increase and proliferation of dangerous zoonotic diseases, and unintended other negative effects on animal welfare including their general quality of life. With increased potential for using animals purely as instruments for profit and gain, there are deep ethical questions to be asked and red lines to be drawn.
Then there are well-documented risks around their reduction of biodiversity and ecosystems’ resilience. The introduction of GMs has, through patenting and aggressive marketing, resulted in the concentration of monopolies with enormous negative impact, particularly for smaller farmers across the world. 5 companies now control 56% of GM seeds and 73% of agro-chemicals. An example of the socio-economic harm caused directly by the introduction of GM seed (alongside unintended negative consequences on other species), is the well-known case of Monsanto’s (now Bayer) promotion of seeds resistant to pesticides excluding the brand they developed (Roudup). These effects are not only actively playing themselves out elsewhere in the world: in England, unprotected experimentation (of GM potatoes, broccoli, fish oil for salmon farming, wheat) is alive and kicking.
A much wider risk assessment is needed around impact on exports/imports too. The likely outcome of deregulation of gene-editing in England is bans on exports of UK produce into the EU, not only GM produce but on a much wider scale, because we will not be in a position to identify what is GM and what is not. It will also destroy the organic sector, as contamination cannot be contained.
It is clear that with introducing new genetic material, we are stepping into making fundamental changes to our world which concerns all people and planet. The public needs to be brought on board for a wide democratic discussion about this. The evidence is that the general public generally does not want GM and at a minimum remains weary of the unknown risks involved.
Labelling and similar regulation is essential in that it protects individuals’ rights and ability to decide on how they want to live with GMOs in their environment. In that deregulation removes people’s (customers’, retailers’ and farmers’) ability to make these choices, it threatens their fundamental human rights.
At a minimum we need full engagement and transparency around what is known/remains unknown, and we need trusted and full safety assessments of wider questions including safety assessments conducted outside lab environments. Efforts need to be made into education around all the issues concerned, a large democratic and representative/inclusive consultation, and public reporting of government’s next intended steps and mechanisms around these. This activity will also need to include discussion and engagement around values and wider ethical questions. Science and social science need to develop their assessment criteria and a range of effective tools that can be used to engage the wider public. Before introduction, mechanisms for monitoring and keeping audit trails have to be developed, piloted and established.
When a proper debate has been had, we’ll need to see if the conclusions still point to the need for GMOs as the holy grail for sorting out our food system challenges.
Bring it on!