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Does NZ Need An Update To Genetic Modification Rules? – Expert Reaction
The National Party is proposing to update New Zealand’s biotechnology rules and open up access to gene editing and genetic modification.
The proposed benefits include climate and pest resistant crops, technologies to treat cancer and cardiovascular diseases, and reducing methane emissions from farming.
Two Prime Ministers Chief Science Advisors, Science New Zealand, Plant & Food Research, and a gene editing expert panel convened by the Royal Society Te Apārangi, have all previously supported an update to the current system.
The SMC asked experts to comment.
Professor Andrew Allan, School of Biological Sciences, University of Auckland, comments:
“The current GMO rules are not fit for purpose. They were drafted and made law before the development of new techniques, therefore making the application of the law vague and not based on biology or science.
“By restricting the use of GMOs NZ is missing out on new tools to fight the climate crisis. Our existing crops are under threat and traditional breeding methods can’t keep up with warming temperatures.
“A relaxing of the GMO rules should be associated with a case-by-case decision tree as to whether an edited organism provides a measurable benefit, without an increased risk (risk above that of traditional breeding or established practice).
“With a change in the law, overseas markets will continue to receive NZ products labelled GMO-free and new products labelled appropriate to that product. Having an edited crop in NZ does not taint all NZ products.
“New Zealanders will react to such a change as they do to any other new or novel advance. Many will want the novel item (early adopters), many will follow these adopters, and some will be worried and refuse. There will be choice.”
No conflict of interest declared.
Professor Jack Heinemann, Professor of Genetics, University of Canterbury, comments:
“NZ is not falling behind other countries in the OECD who have more permissive regulatory frameworks for genetic modification. More than a decade after CRISPR/Cas editing was invented, there are just three gene edited organisms on the global market. So if we are falling behind in something, it isn’t because we do less gene editing in crops and livestock.
“Gene editing is still developing as a technique; there is still lots to learn about it; future value is not assured. Pushing it too fast is the risk, not an economic or climate salvation.
“Regulation is a public good and current regulation is fit for purpose. The NZ legal framework is similar to most other countries’ despite what some are saying in the media. All countries use a combination of product and process regulation just as New Zealand does. Even the most permissive countries, such as the United States, do so.
“The Australian regulator recently reaffirmed its commitment to using process-informed regulation like NZ’s. Most of the world including many OECD countries use a similar regulatory trigger.
“The existing NZ approach allows regulators to consider the impacts of GMOs on food producers and the wider economy and environment. It protects the country from releases that could result in market rejection and reputational damage.
“All GM organisms on the food market now have been through some form of a safety assessment. So they should be safe. That isn’t proof that others won’t be harmful. There is very limited or no post-production product-based regulation that would apply to products. If types of genetic engineering are deregulated, then who checks their safety in the future?”
No conflict of interest declared.
Josephine Johnston, Lecturer, Bioethics Centre, University of Otago, comments:
“Any law tightly tied to technology is likely to need revision over time. Our laws and regulatory framework for genetic modification, which now includes gene editing using CRISPR and related technologies, were first passed in 1996 and were revised in 2003. Unsurprisingly, they are in need of a refresh now to ensure that we are optimizing the benefits and managing the risks of these technologies for science, medicine, primary industries, and the environment.
“Although our existing laws do allow for field trials and release of GMOs, additional medical, agricultural, and environmental advances are on the horizon such as gene editing treatments for specific human diseases, crops that are genetically modified for higher yield or to be disease resistant, and gene drives for use in pest control.
“Thus far, New Zealand has taken a very cautious approach to these technologies. This approach is understandable in light of both our clean, green international image and our regrettable history of introducing invasive plants and animals that we now struggle to control. That cautious approach, along with our international commitments to addressing climate change and our Te Tiriti obligations, should deeply inform reforms in this area of law and technology.
“Blanket ‘all GMOs are bad’ or ‘all GMOs are good’ approaches will not cut it in this area. A balanced and nuanced public discussion is required so that we can work towards assessing each specific application carefully on its own merits and in light of our nation’s unique environment and culture.”
Conflict of interest statement: “Josephine Johnston has no financial or other interests in gene editing technology and therefore no conflicts of interest regarding this topic.”
Professor Kurt Krause, Infectious Diseases Physician; Professor of Biochemistry, University of Otago, comments:
“National’s new policy on GM and GE regulation and utilisation is innovative, forward thinking and encouraging. Certainly it is long overdue in New Zealand as compared to our Australian, UK and North American colleagues.
“For example, the amount of red tape required to work with bacteria that are harmless both inside and outside of the laboratory is much too high and this needs to be reexamined and streamlined.
“In addition, for New Zealand to fully benefit from coming advances in biotechnology, e.g. CRISPR, vaccine design and RNA-based therapeutics, it will need to modernize its approach to the entire GM/GE area.
“The good thing is that this is the perfect time to reexamine and move ahead, and we have decades of science to fall back on. Given that National’s new policy quotes both Sir Peter Gluckman and Dame Juliet Gerrard, perhaps the move ahead will be bipartisan, broadly beneficial and science driven.”
No conflict of interest declared.
Dr Tony Conner, Emeritus Scientist, AgResearch, comments:
“Any move to reconsider the GMO regulations in New Zealand is refreshing news. Since the introduction of the HSNO Act in the mid-1990s the science involving genetic modification has seen considerable advances that address many of the original concerns. The current regulations on GMOs in New Zealand have been unfit for purpose for some time, resulting in New Zealand’s primary industries missing opportunities to reduce the environmental footprint of production systems, while improving yield and quality of produce.
“Over the past 20 years the distinction between genetic modification and traditional plant breeding has become increasingly blurred. There is now a plethora of tools and techniques encompassing plant biotechnology that provide a complete continuum from ‘hardcore GM’ involving the introduction of totally foreign DNA from bacteria to plants, through to traditional plant breeding.
“Since the dawn of agriculture 10,000 years ago with the domestication of the first crop plants, the tools used for plant breeding have gradually become more sophisticated. This has resulted in decreased disruption of genomes, accompanied by increasing precision associated with the genetic change. This provides the confidence that any risks can be ascertained and managed.
“Scientists can now use the tools of genetic modification to engineer plants with their own DNA without the introduction of foreign DNA. The resulting plants are equivalent to genome rearrangements using irradiation breeding that has been commonly used in all major crop plants for over 80 years.
“It is now possible to engineer plants to assist in the rapid breeding of elite varieties, then as a last step crossing out the GM status. For some bizarre reason, New Zealand regulations consider such non-GM plants as being GM. This overlooks 120 years of classical genetics knowledge on inheritance.
“Gene editing is now possible and can be performed with amazing accuracy. A single nucleotide of DNA in a genome can now be targeted for change or deletion. This is a precise form of mutation breeding that has undertaken in crops for over 80 years by randomly inducing mutations using specific chemicals.
“In many cases it is no longer possible to determine whether an organism is the result of genetic modification or traditional breeding; unless the exact methodology is revealed by the developer.
“The risks of modern genetic technologies to natural ecosystems, agricultural ecosystems, food industries and consumers will be no different than the effects of growing, processing and eating new varieties from traditional breeding. Furthermore, the precision and power of genomics and molecular biology offer greater confidence of achieving and monitoring the desired outcome in comparison with traditional breeding. It is not the technology that causes potential harm, but rather what the technology is used for. That is why some form of regulation is useful, but the HSNO act has always been overly precautionary. It is time for a change.”
No conflict of interest declared.
John Caradus, CEO, Grasslanz Technology Ltd, comments:
Note: Grasslanz Technology is a fully owned subsidiary of AgResearch.
“Broadly, Genetic Modification can be categorised as:
- Transgenesis: Genetic Modification (GM) – also previously called Genetic Engineering (GE)
- New Breeding Technologies – targeted gene editing using site-directed nucleases resulting in gene deletion, modification or gene insertion – gene editing (GEd)
“The types of plants that could be modified have very different uses:
- Plants for non-food use – trees for wood
- Plants used for animal feed – forages
- Plants used for human food – cereals, fruit and vegetables
“In New Zealand, a GM organism means any organism where genes or other genetic material have been modified by in vitro techniques. This is no longer fit for purpose.”
Are the current GM rules fit for purpose?
“When the HSNO Act was brought into law New Breeding Techniques were neither developed nor used.
“Some countries have proactively differentiated some products developed using New Breeding Technologies, while others have consciously included them as part of their current GM legislation, and yet others are yet to decide. The notable outliers are the European Union and New Zealand who have consciously included crops and forages developed using New Breeding Technologies under the same legislation as all other GM crops.
“Some gene editing methods result in organisms with no foreign DNA, and are indistinguishable from non-GM plants, and yet in NZ are classified as GM.
“In NZ, there is an ever-increasing list of foods from GM crops that can be sold, if appropriately labelled, but still the ability of farmers and growers to exploit the benefits of GM crops and forages is constrained. So, the issue with foods from GM crops cannot be largely about safety to human health; that leaves then impacts on the environment and consumer acceptance.
“Regulatory systems should be based on the benefit/risk of the product, not on the process/technology used to deliver the product. The regulatory process in NZ is focused more on the process of development than the resulting product.
“The uncompromising approach to the Precautionary Principle (which is used by NZ) inevitably results in no action ever being taken, because an assurance of absolute safety can never be given, leading to paralysis and a cessation of technological advancement.”
What technologies and opportunities are we missing out on by restricting GM?
“Current benefits associated with GM include increased crop yields, reduced pesticide and insecticide use, reduced carbon dioxide emissions, improved soil structure, improved crop nutritive quality/value, and decreased costs of production.
“Mitigating environmental issues may provide an acceptable balance between perceived risk and benefit of GM and GE crops and forages, e.g., reduced greenhouse gas emissions, nitrogen leaching into waterways, pesticide use, increased soil carbon, and/or clear health benefits to the consumer.
“Genetic modification (GM) has been widely adopted globally and has shown improved yield, quality and environmental impacts and has the potential to provide consumer benefits through improved product quality, nutritive value, and shelf life.
“Other opportunities resulting from GM technologies that may benefit future crops include drought and salinity tolerance, nutritional and health benefits, disease resistance, improved processability, reproductive efficiency and plant phenotype.”
What should we be careful about if the rules are relaxed?
“GM technologies – just like many non-GM technologies – can bring risks, but these can be monitored and quantified and allow decisions to be made about commercial, societal and environmental benefits versus real risks.
“GM technologies are a valuable option that needs to be promoted to solve current challenges and as a result improve not simply economic outcomes but also the environment.
“To manage and understand potential risks associated with GM crops particular focus should include testing for:
- Human and animal health and welfare impacts, including testing for allergenicity;
- Impacts on beneficial non-target organisms, principally arthropods; and
- An awareness of gene flows from GM crops needs to be also considered and understood.”
How might overseas markets react to our export products if there is a rule change?
“There are inconsistent approaches to regulating GM plants across different jurisdictions/ countries – and NZ is becoming an outlier.
“Many countries allow the consumption of GM food or feeds but do not allow GM plants to be grown which simply creates confusion – e.g. Europe (food and feeds) and NZ (food).
“GM technologies have been extensively used in providing many benefits in crop plants – most often for use as animal feed – 70 to 90% of all GM crops, principally soybean and maize, but also including cotton and canola, are used to feed animals.
“The biggest users being USA, China, and Europe – major export markets for NZ.
“Most GM crops used for animal feed have input traits that do not change their composition or nutritional value for animals.
“Feeding GM crops does not result in detection of transgenic DNA or their translated proteins in meat, milk, or eggs.
“While there are factions of society who will always be against the use of GM in food production, the evidence from studies attempting to understand market forces and public attitudes is that the use of GM plants in New Zealand for food production is unlikely to have long-term deleterious effects in overseas markets.”
How might New Zealanders react to such a change in an area that has been highly controversial?
“A recent survey (Research First 2022) in NZ showed:
- 32% supported gene editing in food production (62% for pasture quality traits)
- 47% were neutral (32%)
- 21% were against (15%)
“GM technologies like many non-GM technologies can bring risks, but these can be monitored and quantified and allow decisions to be made about commercial, societal and environmental benefits versus real risks.
“An open debate involving industry and political leaders about benefits and risks of GM/GE technologies is required leading to an urgent review of the HSNO Act.”
Conflict of interest statement: “The author is employed by Grasslanz Technology Ltd which has an R&D investment portfolio that includes both genetic modification and gene editing of forages and microbes to provide mitigating solutions to current environmental and animal welfare issues facing both New Zealand and other pastoral economies.”
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