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Engineering the Farm
The Social and Ethical Aspects of Agricultural Biotechnology
By Britt Bailey, Marc Lappé ISLAND PRESS
Copyright © 2002 Island Press
All rights reserved.
ISBN: 978-1-61091-067-5
CHAPTER 1
Ethical Issues Involving the Production, Planting, and Distribution of Genetically Modified Crops
Sheldon Krimsky
The discovery of plasmid-mediated gene transfer in 1973 afforded science a revolutionary technique for rearranging and modifying the genetic structure of biological species. Other techniques for transferring genes followed, including the use of viruses, DNA projectiles, and microinjections. Thus far, there appear to be no natural or species barriers limiting the transfer of genetic material across organisms of different phyla and even kingdoms that cannot be overcome by the set of processes known as recombinant DNA or gene transplantation technology.
Agriculture was one of the first industrial sectors to have invested heavily in the new field of biotechnology. By the early 1990s a massive experiment in agricultural biotechnology was underway in which a new generation of crops containing genes from sources outside the plant species was introduced into food production in many parts of the world. The genes transferred include some that express new proteins, some that mark specific parts of the genome (marker genes), some that regulate gene expression (e.g., promoter sequences), and finally some that provide identifying clues that the gene transfer has been accomplished (e.g., antibiotic resistance genes).
We are at the early stages of this global agricultural experiment. Scores of new food products with altered phenotypes are slowly moving from genetics laboratories into commercial products. By the year 2000, approximately one-fifth of the U.S. corn acreage, one-half of the soybean acreage, and three-quarters of the cotton acreage, comprising nearly 30 million hectares, was planted with crops genetically modified for resistance to insects and tolerance to herbicides.
This global agricultural experiment in biotechnology has been met with controversy in Europe, parts of Asia and South America, Australia, Canada, and New Zealand. This essay explores the ethical and value components of the controversies that have erupted in the wake of the first introductions of genetically modified (GM) crops since the early 1990s. These controversies have affected international trade agreements and have divided environmentalists.
Among the issues that have spurred some of the most highly contested debates are the following: (1) the ecological effects of releasing GM seeds into the environment; (2) the impact of GM crops on global seed markets; (3) farmer and consumer preferences in the adoption of GM products; (4) the role of risk assessment in evaluating the safety of transgenic seeds; and, (5) the impact of the global use of genetically engineered crops on biodiversity.
In recent years science policy analysts considered it possible and desirable to separate the scientific from the ethical issues in science and policy studies; I find this cannot be easily accomplished for the controversies involving biotechnology. The normative and the empirical parts of the biotechnology disputes are tightly interconnected. Sometimes the empirical issues provide false cover for the normative questions. Other times the value conflicts are based on disputed scientific claims. Many of the ethical issues involved in the political debates over GM foods/crops are not sui generis but depend on the resolution of empirical questions.
The one contested issue involving GM crops that comes closest to resting on purely ethical considerations is whether it is morally permissible (irrespective of consequences) to alter plants by genetic engineering technology. Human rights and animal advocacy groups have proclaimed the genomes of humans and animals as inviolate for human genetic manipulation. Their moral justification rests on "natural law" (e.g., species nature or the sacredness of human germ cells) or consequentialist arguments such as the uncertainties that may result from tampering with nature.
Others have appealed to a secular repugnance for bioengineered plants. Those who claim that applying gene transplantation processes to the germ plasm of crops violates the natural order might be hard pressed to apply the same standards to the other human interventions during the ten thousand years of plant domestication. Are there morally distinguishable issues that make the current techniques of gene modification a transgression against the natural order and the earlier ones not? How are human-selected gene sequences different from those made by hybridization, chemically or radioactively induced mutations, cell fusion, or synthetic foods? An issue that bears directly on whether GM crops/foods should receive special ethical status is the uniqueness or lack thereof of plant germ plasm modified by gene engineering techniques.
Issue 1: Are GM crops/foods unique?
The question of the uniqueness of genetically modified organisms (GMOs) may be divided into two parts. Are compositions of GMOs unique? That is, by applying recombinant DNA processes, can a product be made that would not otherwise be found in nature or that could not otherwise be constructed by other techniques, such as conventional plant breeding? The second part of the uniqueness issue pertains to whether the risks of GMOs to human health or to the environment are unique. Will the introduction of GMOs to the biosphere produce novel hazards?
Three reports of panels convened by the National Academy of Sciences (NAS) concluded that the use of genetic engineering techniques to produce crops do not result in any unique risks in comparison to techniques of conventional plant breeding. The first report issued by the NAS Committee on the Introduction of Genetically Engineered Organisms into the Environment was published in 1987. A second, longer study was released in 1989, also by a committee of the NAS. Finally, a third study, released in 2000, was titled Genetically Modified Pest-Protected Plants: Science and Regulation.
The 1989 NAS report stated that "no conceptual distinction exists between genetic modification of plants and microorganisms and classical methods or by molecular methods that modify DNA and transfer genes." It also stated, "crops modified by molecular methods in the foreseeable future pose no risks significantly different from those that have been accepted for decades in conventional breeding." The conclusion was reaffirmed in the third NAS report, which highlighted two points: (1) There is no evidence that unique hazards exist in either the use of rDNA techniques or in the movement of genes between unrelated species; and, (2) the risks associated with the introduction of rDNA-engineered organisms are "the same in kind as those associated with the introduction of unmodified organisms and organisms modified by other methods."
Although still a contested issue within scientific circles, the claim that there are no unique risks to rDNA techniques has been a key factor in shaping regulatory policy. Genetically engineered crops are regulated by one of three agencies (the Food and Drug Administration, the U.S. Department of Agriculture, and the Environmental Protection Agency) by and large in the same manner that conventional crops are regulated. There is only minimal pre-testing of GM crops. Because there is a presumption the transgenic food products are safe, a strong burden is placed on those who question the safety of the GM food to demonstrate the risks.
What is the basis upon which points 1 and 2 are accepted? Is there scientific evidence or is it based on a trans-scientific argument? The question of unique hazards breaks down into two parts: (1) Are there hazards? and (2) Are they unique? The issue of whether there are hazards in using rDNA techniques has been resolved in the affirmative (e.g., the Brazil nut allergen transferred to a soybean). Are the hazards from the rDNA process unique? A reasonable interpretation of the meaning of unique can be framed by asking if a hazard can arise from conventional methods of genetics. Has anyone tried to produce the same results by conventional methods? If it hasn't been tried (successfully or not), how can one know that it is or is not a unique hazard? Besides the use of rDNA techniques, how else would the Brazil nut gene enter the soybean? Is that gene found naturally in soybeans?
In another interpretation, unique hazards might refer to a general class of hazards and not any particular one. Under this interpretation it is not inconsistent to state that rDNA technology is the only known way to transfer the Brazil nut allergen to the soybean but it is not the only technique that can transfer allergens from one crop to another, and thus does not introduce unique risks.
Until the term unique hazards is clarified and the empirical questions pertaining to non-rDNA methods for transferring allergens are answered, the query "Are GM crops/foods unique from the standpoint of hazards?" remains unresolved. If GM products were unique compositions of matter resulting in unique hazards, there could be ethical reasons to treat those products differently than conventional crops/foods. This example illustrates the interrelatedness of the normative and empirical dimensions of the problem.
Issue 2: Does society have a right to hold transgenic crops to a higher standard of oversight than conventionally bred crops?
Putting aside whether or not there are unique hazards, it is clear that many public interest groups and the majority of the public in a number of countries believe transgenic crops should be held to a higher standard than conventionally bred crops. To say that rDNA techniques produce unique hazards does not imply that there are no hazards associated with conventional breeding (e.g., hybridization or cross-pollination). The use of rDNA technology in food production may deserve more oversight because it is newer and less rigorously tested than are other methods of crop modification that have been in place for much longer periods. Moreover, even if one were to assert that rDNA techniques do not produce unique hazards, one might still wish to give greater primacy to the hazards of genetic technologies over those of conventional breeding because of the very novelty of the risk potential entailed by the specific gene transfer. Society makes all sorts of risk selection choices based on collective values and perceived risks.
Do regulatory agencies bear a responsibility to respond to public demand for more oversight over GM products? The jurisdiction of regulatory agencies is established through legislative mandate. Within the boundaries of their jurisdiction, agencies make choices. Health agencies decide what goes on food labels. European and U.S. labeling standards are distinctively different, although both respond to health promotion. European labels focus more attention on chemical residues whereas U.S. labeling has a strong emphasis on nutritional content. The priorities agencies set often respond to public perceptions of risk.
Agency personnel and others who comprise the "community of experts" may differ with the public in setting public health priorities. But in democratic societies, even a consensus of elites must defer to the voices of popular opinion. Examples where public concerns influenced agency decisions include the safety standards for nuclear power plants and the risks of toxic waste sites. In both cases the public's concerns about safety exceeded and predated those of regulatory agencies. Eventually, the government's policies became more in step with public concerns.
In the case of GM crops/foods, public risk concerns in the United States and Europe exceeded those of their respective regulatory bodies. This was clearly illustrated when the USDA withdrew its initial proposal for new federal organic labeling standards that would have included GM products under the organic label. The GM crops/food policies developed by U.S. regulatory bodies were heavily influenced by large biotechnology corporations. When there are sharp differences between agency and public views over risk, governments have resources at their disposal to influence public opinion. However, when public skepticism persists, as it has with respect to genetically modified crops/food, then the representative bodies and their executive branches have an ethical responsibility to recalibrate their priorities in order to meet the democratic mandate.
Issue 3: Do people have a right to exclude themselves from the experiment?
Once again, setting aside the question of whether there are hazards or unique hazards associated with GM crops/foods, do people have a right to exclude themselves from this experiment with the global food supply? Suppose that a GM product meets regulatory standards. Are there any ethical grounds for giving consumers a choice over whether they consume the GM product? In many areas where new drugs, new foods, and new technologies are introduced, consumers have had a choice to be first users, last users, or nonusers. This has been the case with the introduction of the synthetic fat (Olestra) used as an oil substitute in chips, as well as sugar substitutes, which have been approved by the FDA. The premise behind the proposal to label GM foods is based on the idea of consumer sovereignty, namely, that people have a fundamental right to know what they are eating, how it was produced, and whether there are any uncertainties about its health effects.
Countries that have adopted labeling include Japan, South Korea, the European Union, Australia, and New Zealand. We label foods for many reasons other than the nutritional content. From public opinion surveys, a majority of Americans seem to support labeling. On what ethical grounds is a labeling policy dismissed? Is there a conflict between the FDA's statutory mandate for labeling and the conditions of production for GM foods? Is the FDA forced by its statutes to reject labeling of GM foods, or has the agency interpreted the law in a way that favors industry's interests?
According to the FDA, a label must be materially relevant to the safety or nutritional value of a food product. In its 1992 policy on bioengineered foods, the FDA stated that "[it] has no basis for concluding that bioengineered foods differ from other foods in any meaningful or uniform way, or that as a class, foods developed by the new techniques present any different or greater safety concern than foods developed by traditional plant breeding." The agency has historically interpreted the term "materially relevant" to mean "information about the attributes of the food itself," and has required labeling where the absence of information poses health risks or misleads the consumer because of other information provided by the manufacturer.
In addition, the law states that the label cannot make or imply false health claims about a food product. On these grounds the FDA opposed mandatory labeling on milk produced with the aid of synthetic bovine somatotropin (rBST), commonly known as synthetic bovine growth hormone, or any other food developed using bioengineering, with some minor exceptions for cases where there have been material changes in nutritional quality or the introduction of an unexpected allergen. The FDA also opposed voluntary labeling unless it contains language stating there is no health or nutritional difference between the bioengineered and the nonbioengineered food product.
The FDA is not opposed to labeling irradiated food on grounds of "materiality." Although it has consistently held that irradiated food is not nutritionally inferior to its natural source, with regard to irradiation the FDA concluded that it "could cause changes in the organoeptic properties of the finished food and that without special labeling, consumers might assume that such foods were unprocessed." As of September 2000, the FDA reported that it had no data or other information that would support a regulatory decision that food or its ingredients produced using bioengineering meets its statutory criteria for mandatory labeling. But considering the strength of public opinion, the FDA acknowledged that "providing more information to consumers about bioengineered foods would be useful." To resolve the conflict between the public's desire and the agency's labeling requirement, the FDA proposed a guidance document to "assist food manufacturers who wish to voluntarily label their foods as being made with or without the use of bioengineered ingredients."
Without mandatory labeling of GM foods, consumers do not have a right to extricate themselves from the experiment on the food supply. They can, however, make an effort to purchase organically produced food, which, at least currently, is certified to be 99 percent GM free. From an ethical standpoint, consumers in the United States are not afforded a right to GM-free food. Only those consumers with access to organic foods have an opportunity to purchase GM-free products.
Issue 4: What ethical responsibility has society to address genetic pollution?
A farmer planting non-GM seeds may find that some of his yield consists of GM crops either from seeds or pollen that was deposited from a neighboring farm. The trespass of unwanted GM germ plasm to a non-GM farm is referred to as genetic pollution.
(Continues...)
Excerpted from Engineering the Farm by Britt Bailey, Marc Lappé. Copyright © 2002 Island Press. Excerpted by permission of ISLAND PRESS.
All rights reserved. No part of this excerpt may be reproduced or reprinted without permission in writing from the publisher.
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