Open Letter To Govt On RCGM Report
11 October 2001
OPEN LETTER TO GOVERNMENT
from the Trustees, Members, Associate Members and Supporters of Physicians and Scientists for Responsible Genetics (New Zealand)
We, the undersigned scientists, recognise the Recommendations of the Royal Commission as a guide to proceeding, with due caution, in the use of genetic engineering. While the Commission's Report could not be, nor was it intended to be, a scientifically rigorous document, it offers certain strategic options which we feel it is valuable to take up. We believe it would be a serious error of judgement to conclude that the Commission's report is a definitive and authoritative assessment of all of the relevant scientific facts. The Warrant of the Commission was :
To receive representations upon, inquire into, investigate, and report upon the following matters:
strategic options available to New Zealand to address, now
and in the future, genetic modification, genetically
modified organisms, and products; and
any changes considered desirable to the current legislative, regulatory, policy, or institutional arrangements for addressing, in New Zealand, genetic modification, genetically modified organisms, and products.
Thus, no scientific investigation or research into genetic modification was required by the Commission’s warrant.
(1) We support many of the Recommendations of the Royal Commission, particularly Recommendations 6.12, 6.14, 7.1, 7.2, 7.4, 14.1, 14..2 and 14.3.
(2) It is impossible to guarantee containment of pollen from GM plants in field trials and we have serious concerns about the possible environmental impact of genetically modified crops on New Zealand soil and ecosystems. We therefore welcome Recommendation 6.12 which states that the Environmental Risk Management Authority (ERMA) should require research on these impacts before release of genetically modified crops is approved; and Recommendation 7.1 which states that "prior to the release of any Bt-modified crops, the appropriate agencies develop a strategy for the use of the Bt toxin in sprays and genetically modified plants."
(3) In the light of the above Recommendations we make the strongest possible recommendation that the moratorium on the release of any GMOs into the environment, both commercially and in open field trials, be extended so that the relevant research can be conducted.
(4) Consequently, we recommend that both Recommendations 6.12 and 7.1 should be implemented retrospectively. In other words all applications for field trials of GMOs for which approval has already been granted should be reconsidered.
(5) Recommendation 6.14, which states that "public research funding portfolios be resourced to include research on the socio-economic and ethical impacts of the release of genetically modified organisms," should also be implemented retrospectively in respect of all ERMA approved field trials. We suggest this should apply particularly to the ERMA approvals to conduct field-trials on GM-pine trees (GMF99001 and GMF99005), as approval for these was given without appropriate ecological and soil research by the forestry research organisations.
(6) Recommendation 7.4 states that "in connection with any proposal to develop genetically modified forest trees, an ecological assessment be required to determine the effects of the modification on the soil and environmental ecology, including effects on soil micro-organisms, weediness, insect and animal life, and biodiversity." This Recommendation should also be implemented retrospectively and ERMA should be required to insist that research, as envisaged in this Recommendation, be an integral and on-going component of undertaking any field-trials of this kind. The extended moratorium on conducting field trials could be used to address this consideration.
(7) We support Recommendation 14.1, that Section 68 of the HSNO Act be modified and that the establishment of a Bioethics Council (Recommendation 14.2) together with a Parliamentary Commissioner on Biotechnology (Recommendation 14.3) be appointed.
(8) We strongly urge that any future committee or council be put together in a manner such that it is, and can be seen to be, truly representative, containing scientists who are able to offer an alternative view to the consensual view of governmental bodies, academic institutions and representatives of industry. To date this has been sadly lacking in such committees as the Independent Biotechnology Advisory Council (IBAC).
(9) We consider that patents on living processes, organisms, seeds, cell lines and genes should be not be allowed. Patents on life-forms and living processes threaten food security; they sanction biopiracy of indigenous knowledge (of Maori in the case of New Zealand) as well as genetic resources; they can violate basic human rights and dignity, compromise healthcare, impede medical and scientific research.
(10) We find no convincing evidence to date that GM crops offer any benefits to farmers or consumers. Instead, many problems have been identified, including yield drag, increased herbicide use, erratic performance, and poor economic returns to farmers. GM crops also intensify corporate monopoly on our food, which is marginalizing family farmers in several countries and preventing the essential shift to sustainable agriculture that can guarantee food security and health around the world.
(11) We consider there is a clear need for an independent, centrally funded and developed public education programme about genetic engineering. Had one existed prior to the hearings of the Royal Commission, public debate about the issues would have almost certainly been conducted at a much more sophisticated level, and community organizations would have been able to have ready access to up-to-date and unbiased factual information.
PSRG rejects the conclusion that continuing the moratorium on field trials and commercial releases of genetically modified organisms in New Zealand will have an adverse effect on truly scientific research. The over-emphasis of research funders on molecular biology to the detriment of other approaches has long been in need of re-adjustment in order to preserve the local knowledge base that has been developed over decades within New Zealand’s academic and other publicly-funded research institutions. The exciting new developments in molecular genetics research must now be incorporated into a wider view of biological knowledge rather than being pursued as an exclusive goal, as has finally been acknowledged by the leaders of the Human Genome Project. By doing this, our country will continue to make important contributions to humanity’s legacy of scientific achievements.
SIGNED by the Trustees and Members of Physicians and Scientists for Responsible Genetics
Paul G Butler, BHB, MB, ChB, FRNZCGP
General Practitioner, Trustee PSRG, AUCKLAND
Clearwater, BSc, MSc, PhD
Principal Scientist, Clearwater Research and Consulting, Trustee PSRG, AUCKLAND
Bernard J Conlon, MB, BCh, BAO, DCH, DRCOG, DGM,
MRCGP (UK), FRNZCGP
General Practitioner, Trustee PSRG, MURUPARA
Peter R Wills, BSc, PhD
Associate Professor, University of Auckland, Trustee PSRG, AUCKLAND
Anderson, BSc, PhD
Lecturer, Retired, Trustee PSRG, TAURANGA
Businesswoman, Retired, Trustee PSRG, TAURANGA
A full list of signatories will be collated on the PSRG website http://www.psrg.org.nz/op_let.html