Gene editing consultation – part 2
Answering the questions in Section 3 (Part 2) of the government’s gene editing consultation: broad reform of legislation governing organisms produced using genetic technologies
This is one of a series of linked pages on the UK Government’s gene editing consultation. Please see our main consultation page for more information and guidance on taking part.
In this section the government is looking for signs of public support for looser controls on all forms of genetic modification including ‘old type’ GMOs and whatever might emerge in the future. The questions are framed in a way that is very off-putting for non-specialists. We offer some suggestions here, but the important thing is to show that strongly disagree with Defra’s plan and would like to see more regulation of GMOs, not less.
There are a number of existing, non-GM regulations that control the use of organisms and/or products derived from them. The GMO legislation applies additional controls when the organism or product has been developed using particular technologies. Do you think existing non-GM legislation is sufficient to deal with all organisms irrespective of the way that they were produced or is additional legislation needed?
We recommend answering NO – existing non-GM legislation is NOT sufficient to deal with the use of any form of genetic engineering for crop plants, farmed animals, human food, animal feed, human and veterinary medicines or other activities.
If you are using the table on the Citizen Space online form this means ticking the NO row for all columns (or the second, No, box if using a device with a small screen).
If you want to provide evidence to support your response, the following points, which are based on suggested responses to questions in earlier sections of the consultation, would be suitable here:
The safety net of process-based regulation
The type of deregulation being proposed by the UK government ignores the unintended genetic changes that are common with all forms of genetic engineering.
Process-based regulation looks at how an organism was created and whether the genetic engineering process has introduced any unintended changes in the organism. It is an essential safety net where new and/or experimental technologies are concerned.
Genetic engineering of plants or animals disrupts the environment
Releasing genetically novel organisms into the environment disrupts the delicate balance of nature and risks a range of unpredictable harms.
Altered genes can spread to wild relatives, changing or polluting the natural ecosystem in ways that are very difficult to predict, control or repair. If plants or animals are genetically altered to make them resistant to pests or diseases, it does not take long for those pests or diseases to evolve in response. This has been widely seen with herbicide tolerant and insect-killing GM crops around the world: weeds and pests have quickly adapted and new problems of herbicide-resistant weeds and insecticide-resistant pests have emerged.
Co-existence with non-GM crops and livestock
Most farming in the UK – and most of the food produced and sold here – does not involve the use of genetic engineering and there are significant markets, in the UK and abroad, for certified non-GM products. In the EU, retailers are already reaping the commercial benefits of selling certified non-GMO food products.
Many consumers will not wish to buy products produced using genetic engineering and many farmers will not wish to use such methods.
The right to choose is a long-established part of UK farming and food policy. It recognises that conventional, organic and genetically engineered crops and animals can only ‘coexist’ if one system of production does not negatively impact the others.
Regulation, transparency and labelling are necessary if we are to achieve fair coexistence. At present there are no proposals for how coexistence will work at farm level, within the supply chain and at the consumer interface. Farmers, food producers and consumers should all have a say in the development and implementation of effective coexistence rules.
Social and ethical considerations
All technological advances bring new risks and raise ethical questions, such as, “Why are we doing this?”, “How will it be used?” and “What will its impact on society be?”. This is particularly true with genetic modification, where what is being created could outlast us and be passed on to future generations. In addition to assessing risk to health and the environment, the government has a duty to consider and assess, on a case-by-case basis, the value and ethics of adopting each new application of genetic engineering. This kind of assessment should take place as early as possible in the research and development phase.
If we don’t allow for the possibility of saying no to proposed technological interventions, or allow ourselves to place rational limits on them, we lose the ability to shape our world, as well as our accountability for the things we shape.
Undermining consumer choice and confidence
UK consumers do not want to grow, buy or eat genetically engineered foods.
A 2020 survey by Food Standards Scotland found that, next to chlorinated chicken, genetically engineered foods are a top issue of concern for 57% of consumers. Another 2020 study conducted by the National Centre for Social Research, which focused on Brexit-related issues, found that 59% wish to maintain the de-facto ban on genetically engineered crops. A 2021 survey by the UK’s National Economic and Social Research Council found that 64% of those who took part were opposed to the cultivation of genetically engineered food.
British food is associated with high standards, but this perception will be quickly undermined if the products of genetic engineering are distributed, unlabelled and without any traceability or accountability, throughout our food system.
Social, ethical and values-based criteria
The national and international discussion over genetic engineering has recognised that, with such a far-reaching technology, assessment criteria must go beyond narrow scientific and technical aspects. Social, ethical and values-based criteria have been put forward and some countries, such as Norway, have begun to use them in their legal and regulatory frameworks for genetic engineering technologies.
It has also been acknowledged that citizens; specialists in the social sciences and ethics; and members of civil society all have a key role to play in developing and implementing such criteria. Citizen panels and assemblies are likely to be an important part of this process at all levels of decision making.
Where you have answered no, please describe what additional regulatory or non-regulatory measures you think are required, including any changes you think need to be made to existing non-GMO legislation. Please explain how any additional measures should be triggered.
We recommend using your own words to make it clear that you want to see existing GM regulations kept and extended to allow effective citizen involvement and consideration of social and ethical concerns.
Points you may like to make which are relevant to all the categories Defra lists:
For each category listed in the consultation, existing GM assessments should be retained and extended to include social, ethical and values-based criteria.
- Genetic engineering regulations should require a detailed, and independently assessed justification of the social and environmental need for the proposed new organism, backed up by a consideration of alternatives.
- The impacts of commercial roll out should be assessed, including the effect that intellectual property rights will have on farmers and others in the food chain.
- There should be long-term safety assessments including the use of whole genome sequencing to look for all unintended effects.
- Once approved, all genetically engineered organisms should be subjected to post-release monitoring and consumer labelling to support choice and the opportunity for recall.