Comments on proposed Genetically Modified Organisms (GMO) Regulation for Australia
by Lorna Salzman
Principles for GMO regulation:
GMO regulation should address three categories: public health; ecology; medical.
GMO applications and particularly agricultural and crop experimentation outdoors should be regarded uniformly as potentially dangerous and therefore prohibited in cases where alternatives to the proposed application exist. Thus, medical applications for hereditary incurable diseases involving a single consenting individual fully informed of the risks would need ethical guidelines primarily, whereas applications involving intrusion into existing ecological relationships or ecosystems should be banned a priori where benefits are speculative, alternatives available and any likelihood, no matter how small, of irreversible change or damage is conceivable.
Food supply regulation must use not only the precautionary principle but should be based on the assumption used in other fields such as toxic chemicals and ionizing radiation that greater dose equals greater risk, and that, statistically, ingestion of small amounts of GMO foods by large numbers of people will result in adverse health effects to a specific number of individuals. Because of the difficulty in connecting individual health problems to a particular food ingested at a particular time, GMO proponents could make the indefensible claim, often used regarding radiation exposure, that there is "no observable harm". This should not be allowed. For this reason, further introduction of GMO foods into the general food supply of humans as well as animals should be completely banned until some kind of ethical tests providing information on long-term results are available that show no long-term adverse health or ecological impact and which have been replicated by other independent scientists or scientific bodies.
A conundrum exists with regard to the insistence on actual experimental planting outdoors of GMO seeds and crops because by the time adverse impacts are noted it will be too late to retrieve the plants. Thus, safety and ecological research should be confined to high security laboratories and precautions taken, as initially proposed for DNA research in the US, to prevent escape of GMOs into the wild. All existing test crops outdoors should be burned immediately.
Labelling is socially discriminatory because only those who are informed and concerned enough to read ingredient labels will actually read them. Nonetheless, it should be required for those foods and ingredients that are already on the market or used in animal feed.
Acknowledgement should be made of the fact that scarcely any tests of any kind have been performed on foodstuffs and that most of these were done by the agricultural or pharmaceutical sector themselves. Such tests should be regarded as inherently suspect and deficient and should not be utilized as the basis for ascertaining safety or regulation. Testing should be taken over by independent, government financed institutions and independent peer review, demanding replicable results, should be required. Individuals involved in testing, research or marketing of GMO products should be prohibited from membership in any kind of regulatory, consultative or oversight body.
Public education on GMO foodstuffs and on the ecological impact of GMOs should be conducted through schools, universities, mass media and private organizations, much as other crucial global issues such as global warming and biodiversity have been addressed. Most important, the efforts of chemical and agricultural companies like Monsanto, AgrEvo, Novartis, etc. to influence government, regulators and decision-makers not to regulate or restrict their research and marketing of GMOS needs to be confronted and resisted by elected officials. Access by these corporations to elected officials or government agencies cannot be prevented but the public should have the right to know what, where, when and how they are attempting to influence legislators and regulatory agencies. A public interest ombudsman, with a government-funded advisory team, should be appointed to represent public grievances, and a public interest committee consisting of citizens, ethicists, clergy, representatives of environmental, health, nutrition and ecological organizations or institutions, etc. should be established, with funds allocated so that the committee can exert oversight of the GMO issue, hold public hearings and inquiries, provide impartial information and in general form a counterweight to the corporate lobbyists.