I’ve been a member of the Food Ethics Council since 2000 and today our executive director, Dan Crossley, has written an open letter to the Secretary of State for Environment, Food and Rural Affairs expressing concerns about the consultation on genetic technologies that closes tomorrow (March 17th). This issue is of global concern so I’m publishing our open letter on my blog to share it more widely.
“Public consultation on the regulation of genetic technologies
The ‘public consultation on the regulation of genetic technologies’ has potentially profound consequences for the future of food and farming.
I am writing to do two things. Firstly, to express concerns about the consultation process itself. Secondly, to propose two tests that we would urge Defra to apply before moving forward with any decision about weakening regulations on gene-edited GMOs, as we believe the consultation fails to address some critically important questions. Note – we will publish this as an open letter on our website.
I am Executive Director of the Food Ethics Council, a registered charity whose mission is to accelerate the shift to fair food systems that respect people, animals and the planet. I hope that we share a vision of a world where everyone eats well and global hunger is a distant memory; where farmers and food producers make a decent living, animals are treated humanely, and the biosphere is nurtured in all our actions.
Concerns about the consultation process and framing
While we welcome the principle of open consultation, we are keen the UK government learns lessons from previous consultations on genetically modified organisms. GMOs including gene-edited GMOs, are highly contested areas, with contested science and different, often competing, views. We want meaningful, constructive engagement and a whole food systems approach, from ‘field to fork’.
The consultation is presented in a one-sided way, which is not desirable or appropriate, as it feels to lots of civil society organisations like a fait accompli. This is likely to lead to further polarisation. It also excludes a number of important aspects of the technology, as well as moral perspectives. Much of the consultation document uses technical language that is not appropriate for a non-specialist audience. For these reasons, many will be put off taking part in the consultation. We want to encourage active participation of as many people as possible (in their role as food citizens) in government consultations of this kind, as I’m sure you do.
Defra’s consultation document states that “GE has the potential to make producing abundant, healthy food part of reducing the environmental impact of a growing global population. It could fine tune and speed up the natural breeding process targeted towards environmental gains in England and help us reach climate and biodiversity goals. It could also help us produce pest and disease resistant crops and disease resistant or resilient livestock to help us adapt to the changing climate. And in many cases, the potential to reduce inputs into agricultural production will also indirectly reduce carbon emissions.”
This begs questions, both about supporting evidence for the claims of potential benefits and about potential concerns or risks, including concentration of corporate power and ownership over food production, contamination and ‘off-target effects’, which do not appear to have been appropriately considered or presented in the consultation document. The absence of information about existing technologies and processes (e.g. biodiverse agroecology) that already achieve, if not excel in realising, similar outcomes confirms the apparent bias. If the consultation is (as we hope) genuine and Defra is truly undecided about whether to weaken regulations, then surely it should not be presented only with claimed benefits.
Two tests the ‘regulation of genetic technologies’ consultation needs to pass
In our view, there are (at least) two critical tests the consultation will need to pass in order for the exercise to have been meaningful. We do not believe the consultation currently looks set to pass these tests. However, in the spirit of wanting constructive engagement, we set these out below, together with selected key questions that we believe it is important to address. Our two tests are:
- WILL THE (POTENTIAL) BENEFITS AND HARMS RELATING TO FOOD AND FARMING AS A WHOLE BE PROPERLY ACCOUNTED FOR?
- WILL THE ETHICAL CASE BE CLEAR AND ROBUST?
Related to these, below are a selection of important questions to address:
- What is the scientific evidence underpinning the consultation? Please can Defra publish supporting evidence so it is available to all interested parties. What evidence is there for claims of benefits made? And what evidence of risks?
- What science substantiates the highly contestable proposition that gene-edited GMOs possessing genetic changes “could have been introduced by traditional breeding” and that “the safety of an organism is dependent on its characteristics and use rather than on how it was produced”?
- If approved, what measures are there to ensure the technology is regulated effectively and only used within a specific set of approved uses that deliver public goods?
- What are ‘other techniques’? The consultation refers to gene editing and ‘other techniques’. Defra must be clear, specific and explicit on which other techniques, as different techniques are likely to have different outcomes, which may or may not be acceptable.
- How do gene-edited GMOs fit into the broader food system, i.e. given that agriculture does not exist in isolation?
- If the weakening of regulations is approved, how will this impact the UK’s ability to trade in food (and agricultural products) with others, particularly the EU where much of our current agricultural production is exported to?
- What is the ethical justification for genome editing in UK agriculture (and food systems more broadly)? The consultation document does not specify the ethical framework within which the final decision will be made. Where is the full ethical appraisal? If that does not yet exist, will that ethical analysis be done before any final decision is made about whether to approve the weakening of regulations?
- What impacts would the weakening of regulations achieve in the balance of power – including between large corporate agribusinesses, primarily owned by those in the Global North, and smaller farmers, especially (but not only) in the Global South?
- Who will have the economic and technical means to benefit from these regulatory changes, and crucially who will be disempowered?
- What estimates have been made about the effect of weakening regulations on the benefits that might accrue to corporations, the academic establishment that owns many of the patents and industrial producers, at the expense of biodiversity-enhancing farmers and other ‘food citizens’?
- How can we make the regulatory framework more democratic and independent of corporate and research interests?
- If regulations were weakened, what estimates have been made of the extent to which this would, given the evidence of recent history, further lock the UK into industrial farming models, and thereby risk undermining the claimed environmental wins through these technologies?
- What are the opportunities foregone by weakening regulations on gene editing processes and gene-edited GMOs and their products?
We are making a short submission to the consultation separately. However, in the absence of answers to the tests and questions above, it is very difficult to make a full and reasoned response.
We believe in bringing ethics to the centre of our food systems. It is imperative that the ethical criteria against which a decision is made are fully articulated, gain consensus support and ultimately are met. Ethical justification must weigh benefits against harm and who (or what) will gain the benefits and who (or what) is excluded and at risk of harm.
Before moving to any decision to weaken the regulations, we would ask you to respond to, and consult further on, the serious questions we raise about the ethics – and the potential effects and impacts – of new genetic technologies.
We would be grateful if you could write back to explain how you intend to meet our tests. We look forward to hearing from you.”
Please do explore the Food Ethics Ccouncil website to see the wide range of issues we cover, from food citizenship to meat, livestock and dairy to food and poverty. The Council works to accelerate the shift towards fair food systems that respect people, animals and the planet.