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Conko/Miller Op-ed in Tech Central Station
May 04, 2004
This is part 1 of a two-part series. To read part 2, please click here.<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />
<?xml:namespace prefix = u1 />Controversies continue to engulf the "new biotechnology"—also known as gene-splicing or genetic modification (GM)—applied to agriculture and food production. Perhaps pseudo-controversies would be a more apt term, given that every new supposed problem has turned out to be nonexistent or inconsequential, and biotech's benefits are proven: They include less use of chemical pesticides, higher crop yields and more environment-friendly farming practices. Yet each new scare story is given life by the half-truths and misrepresentations of biotech's vocal, well-organized opponents, who are heavy on lobbying and lawyering but light on science and scholarship.Biotech's most doctrinaire antagonists don't disguise their hostility. Technophobe Jeremy Rifkin claims that it threatens "a form of annihilation every bit as deadly as nuclear holocaust." Greenpeace demands biotech products' "complete elimination [from] the food supply and the environment." And sacked <?xml:namespace prefix = st1 ns = "urn:schemas-microsoft-com:office:smarttags" />UK environment minister Michael Meacher, speaking on behalf of Greenpeace, has admitted that there could never be sufficient testing to convince him of the safety of biotech foods: "The real problem is whether 10, 20, 30 years down the track, serious and worrying things [will] happen that none of us ever predicted." Meacher also reaches into the activists' bag of tricks to smear biotechnology with the post hoc, ergo propter hoc fallacy ("one thing happens after another; therefore, the former caused the latter"). He writes, "coinciding with the introduction of [gene-spliced foods] in the US, food-derived illnesses are believed by the official US Centers for Disease Control to have doubled over the past seven years. And there are many reports of a rise in allergies—indeed a 50 per cent increase in soya allergies has been reported in the UK since imports of GM soya began." He could just as plausibly have ascribed these maladies to the assumption of power by Democratic and Labour governments in the U.S. and U.K., respectively, or to some other equally spurious coincidence of events.Other groups pose as open-minded skeptics, rather than antagonists, but beneath the rhetoric their arguments and actions lead us to much the same place: The goal of all the radical activists is to create a groundswell of anxiety toward biotech, and to elicit unnecessary, hugely burdensome government regulation that will make product testing and commercialization practically untenable. Nevertheless, their publications and announcements receive extensive media and government attention, largely because the lavishly funded organizations—including the Pew Initiative on Food and Biotechnology, the Center for Science in the Public Interest, Environmental Defense, Union of Concerned Scientists, and Resources for the Future—aggressively tout themselves as occupying the disinterested middle ground in the biotechnology debates. But their PR machines saying that doesn't make it so. These and other similar organizations feign "moderation" by vaguely acknowledging biotech's potential, and by raising scientific-sounding concerns, but genuine moderation means more than the absence of absurdist rhetoric. Just as the value of real estate depends on "location, location and location," the value of dialogue on biotech's risks and rewards requires "context, context and context." Balance requires that discussions of biotechnology's risks and benefits be placed within the context of the risks and benefits of older, "conventional" techniques of genetic modification. But activists' relentlessly yet subtly alarmist reports and forums invariably emphasize the things that might go wrong, while studiously avoiding the essential context. They conveniently ignore vast amounts of data, including literally millennia of experience with pre-gene-splicing genetic modification, and they continue to deny the well-established scientific consensus that no unique risks attend the use of gene-splicing techniques. And they carefully nourish the myth that "genetic modification"—by which they mean only gene-splicing—is a distinct category that is somehow fundamentally different from other, earlier methods of genetic improvement.
In fact, every hypothetical risk of gene-spliced organisms also exists with conventional breeding methods, and risks are most often greater with the older, less precise techniques. Although standard assessment methods for new plant varieties most often are able to identify potentially harmful outcomes, occasionally the imprecise, trial-and-error techniques of conventional breeding methods lead to problems. Two conventionally bred varieties each of squash and potato and one of celery were found to contain dangerous levels of endogenous toxins and had to be barred from commercialization. Such mishaps are far less likely when genetic changes are wrought with the more precise and predictable gene-splicing techniques, and none has been observed in spite of widespread use of gene-spliced crops and foods for more than a decade. Nevertheless, groups like Pew, CSPI, UCS and RFF continually fret over the alleged "uncertainty" about the new biotechnology's safety. Never is there any hint that similar—and often greater—uncertainties characterize the more conventional breeding techniques. Nor is there any discussion of the safety testing that plant breeders, farmers and others conduct as a matter of course. Why these omissions? Precisely because the activists intend to frighten the public and intimidate regulators into tightening already burdensome regulation. CSPI, for example, frets about the "transfer of the engineered gene to other species, the emergence of pesticide-resistant pests, and the adverse effects on small farmers or developing nations." One of its reports laments that when it comes to gene-spliced organisms, "Toxicants and anti-nutrients that may affect food safety and nutrition are not always evaluated," and it calls for wholesale changes in the way biotech foods are regulated (read: more regulation). An April 2004 report from the Pew Initiative on Food and Biotechnology took an innovative tack to implying that government regulation is inadequate. It conceded that although the current "first generation" of gene-spliced agricultural products may be overseen appropriately by existing current oversight procedures, in the coming "second generation" of products, "[m]any of these genetic modifications will be substantially more complex than the single-gene, single-trait modifications of the first generation of [gene-spliced] crops. The new products are expected to enter into the regulatory review process in the next two to ten years and could pose novel issues for the regulatory agencies." The constant refrain: more uncertainty, more concerns, the need for more regulation. A 2002 report from the Pew Initiative agonizes about the potential of foods from future generations of gene-spliced organisms to cause allergic reactions, because scientists understand "little about the fundamental mechanism by which people develop allergies," and "[t]he ability of [gene-splicing] to move genes from one organism into another creates the possibility of introducing allergenic proteins into foods that would not ordinarily contain them." The Union of Concerned Scientists recently commissioned testing that supposedly found gene-spliced material in "conventional" seed preparations, and—in the press but not in any scientific journal—they were quick to condemn this "contamination." The Center for Science in the Public Interest has raised various other questions about gene-spliced plants, including the "transfer of the engineered gene to other species, the emergence of pesticide-resistant pests, and the adverse effects on small farmers or developing nations." When considered in a vacuum—as though farmers, plant breeders and others had never before sought and wrought genetic improvement of food plants—these seem like legitimate concerns. However, all types of plant breeding—including traditional techniques as well as the newer molecular methods—routinely introduce new DNA, proteins and other substances into the food supply. Since the 1930's plant breeders have performed "wide cross" hybridizations in which large numbers of "alien" genes are moved from one species or one genus to another to create plant varieties that cannot and do not exist in nature. Common commercial varieties derived from wide crosses include tomato, potato, pumpkin, black currant, oat, rice, wheat and corn, among others. Using pre-recombinant DNA technology such as wide-cross hybridization and mutation-induced breeding, breeders and food producers lack knowledge of the exact genetic changes that produced the useful traits. More importantly, they have no idea what other changes have occurred concomitantly in the plant, including those that could alter the ability to cause allergic reactions. Only recombinant DNA techniques allow breeders to identify and fully describe the changes that have been made in the progeny. This increased precision and predictability make foods from recombinant organisms safer than conventional ones—but, paradoxically, they are far more intensively regulated. Neither government regulators nor the minions at the radical NGOs have shown the slightest concern about the real risks of plant breeding. Instead, they bleat endlessly about the hypothetical risks of recombinant DNA technology, which never materialize. The NGOs' selective memory, in effect, repudiates biology and the history of agriculture. Gene flow is ubiquitous. All crop plants have relatives somewhere on the planet, and some gene flow commonly occurs if the two populations are grown close together. Growing hundreds of crops, virtually all of which (save only wild berries and mushrooms) have been genetically improved, the practitioners of "conventional" agriculture in North America have meticulously developed strategies for preventing pollen cross-contamination in the field—when and if it is necessary for commercial reasons. The history of canola—the general term for the genetically improved rapeseed developed by Canadian plant breeders a half-century ago—offers a good example. The original rapeseed oil, used as both a lubricant and as an edible oil, was harmful when ingested because of high levels of a chemical called erucic acid. Conventional plant breeding led to the development of genetic varieties of rapeseed with low concentrations of erucic acid, and this "canola" oil has now become the most commonly consumed oil in Canada. High-erucic acid rapeseed oil is still used as a lubricant and plasticizer, however, so the high- and low-erucic acid varieties of rapeseed plants must be carefully segregated in the field and thereafter during processing. This is accomplished routinely and without difficulty by Canadian farmers and processors. But the activists choose to ignore such relevant history and context. Contrary to their remonstrations that they are non-partisan and agnostic about biotechnology, their workshops, conferences and publications show a pervasive, risk-averse, anti-innovation, pro-regulation bias. The new biotech is already subject to illogical, unscientific, excessive, regulation, but the activists demand more.
Another tactic favored by activists and calculated to confuse the public discourse is to establish a kind of moral equivalence between those who hold ideological, anti-biotechnology views and those who are committed to sound science as the basis for public policy.
For example, the Pew Initiative created a clever device intended both to conceal its own bias and real agenda and to lend legitimacy to radical views: a "stakeholder forum" comprised of representatives of the food and biotechnology industry, farmer organizations, food retailers, and anti-biotechnology activists. The forum was portrayed as a "balanced" dialogue between biotech's supporters and opponents that included views across the entire spectrum. However, the reality is quite different: a kind of Potemkin Village town meeting. The views represented ranged from the center to the far, far left, with the latter heavily represented. (And in order to mollify their critics, even the middle-dwelling big agribusiness and biotech companies capitulated to the reality of greater, discriminatory regulation of gene-spliced organisms and products derived from them.) The anti-biotech faction included such tenacious, mendacious opponents of agricultural biotechnology as Environmental Defense's Rebecca Goldburg, the Union of Concerned Scientists' Margaret Mellon, and U.S. Public Interest Research Group's Richard Caplan. The 19-person committee contained just three academic scientists—one of whom also has long been a biotechnology critic. Pew's notion of "balance" was to mix intractable, anti-technology radicals with academics and industry representatives who have largely moderate, mainstream views. It was transparently obvious in which direction the "consensus" was intended to go. It is also revealing that every member of Pew's stakeholder forum had to agree at the outset that the current, biased, excessive regulatory apparatus is still in some way insufficiently stringent.In spite of the litmus test and the stacking of the committee, the stakeholder negotiations broke down when the most extreme anti-biotech ideologues overplayed their hand. They made demands that went beyond even the excessive restrictions that the food and biotechnology industry representatives were willing to concede. Although the industry representatives were prepared to endorse a wholly unwarranted new requirement for a formal pre-market notification process for all new gene-spliced food crop varieties, the more radical faction insisted that FDA must reject its current scientific, official approach and require a formal pre-market authorization of all gene-spliced food crops, regardless of the level of risk individual crops posed.This agenda was pushed especially hard by one member of the stakeholder forum, Greg Jaffe of the Center for Science in the Public Interest. Although his group poses as unbiased and moderate, it too has a hidden agenda. Jaffe is credited with drafting legislation introduced in Congress by Senator Richard Durbin (D-IL) to establish a mandatory approval process for gene-spliced foods. CSPI then orchestrated a campaign to garner support for the Durbin bill, all the while pretending to be nothing more than an uninvested bystander that favored the legislation on its merits. CSPI also trotted out North Carolina State University entomologist Fred Gould to support the Durbin legislation. Gould, a respected laboratory scientist but longtime supporter of discriminatory, unscientific biotech regulation, had supervised the publication earlier in 2002 of an internally inconsistent and problematic National Research Council committee report about the scientific basis for biotech regulation at USDA. On the one hand, it endorsed the long-held scientific consensus that gene-splicing is a refinement of previous techniques and "presents no new categories of risk compared to conventional methods of crop improvement," but on the other, concluded that regulatory requirements should be higher than "strictly justifiable based on scientific measures of health and environmental risk," to maintain the "legitimacy" of regulatory agency authority. (An interesting concept: that an unscientific, discriminatory, and hugely expensive approach to oversight somehow maintains the legitimacy of regulatory agency authority.)It should come as no surprise that the NRC report's reviewers included a veritable Who's Who of former and current regulators (who had worked on the regulations in question and, therefore, had a palpable conflict of interest) and anti-biotechnology activists; or that many of the same persons (and institutions) who signed the CSPI petition supporting Senator Durbin's bill were to be found on the Pew stakeholder's forum, or that they participated in Pew conferences, workshops and reports. Want to produce an anti-biotechnology treatise? Just round up the usual suspects!The activists' agenda is to keep the pseudo-controversy roiling and to elicit ever more strict and burdensome regulations, so that biotech products become more expensive to develop, less competitive and, therefore, less likely to appear and survive in the marketplace. In the absence of any evidence of unique or incremental risks of the new biotech—and always ignoring the essential context of the new and old biotech—the radical NGOs invoke as a rationale for discriminatory oversight the canard that the public demands more regulation. In the second and final article of this series, we will discuss public attitudes toward biotechnology, their misrepresentation and manipulation.