Will the public consultation on deregulating GMOs deliver?

“Public consultation.”

Two words destined to send most people desperately scrolling for videos of cats doing funny things, or lists of the top 10 ‘must eat’ lockdown comfort foods.

And yet public consultations have meaning – or at least they should.

On 7 January the UK government launched a public consultation into the deregulation of crops and farm animals created using gene editing.

Gene editing is a new and largely experimental genetic engineering technology. We don’t know what its uses or impacts on health or the environment might be. This is because only two gene-edited crops are being grown commercially anywhere in the world: a herbicide-tolerant oilseed rape (SU Canola) and a soybean with an altered fatty acid profile. Both have had only very limited uptake in North America.

In spite of wide-ranging promises made by Defra Minister George Eustice when he launched the consultation at this year’s Oxford Farming Conference, there is no evidence gene-editing will produce more nutritious, better yielding crops and healthier animals, that it will reduce costs to farmers and impacts on the environment, or that it will help agriculture meet the challenges of climate change.

This makes the government’s continued focus on genetic engineering as a sustainabilityquick win’ all the more baffling. But that focus is also a threat to building an agroecological future that draws much-needed attention – and funding – away from truly sustainable solutions.

Beyond GM is currently collaborating with GM Freeze, as part of a Farming the Future funded initiative, to raise awareness of, and respond to, those threats. Part of that initiative includes a response to the consultation.

Three pillars

Our response to the consultation has three pillars:

• Responding to the consultation on its own terms

• Demonstrating public opposition to de-regulation

• Undermining the legitimacy of the consultation

Aware that the majority of UK citizens oppose GM but may not have, at their fingertips, the high levels of “evidence” the Defra consultation is requiring, we have produced advice to the public which sits on both the Beyond GM and GM Freeze websites. This helps those who wish to respond navigate the question and the issues they raise. This has been accompanied by shared social media visuals and a short video.

The initiative is also reaching out to Defra, the Food Standards Agency (and its Scottish equivalent Food Standards Scotland), to MPs and Peers who may be supportive, to actors in the devolved nations, to animal welfare and consumer groups and to those involved in countryside and conservation.

We’ve also created a core email group where those involved in responding to the consultation can update each other on activities and ask for support.

A concrete outcome of this group was that Beyond GM and Slow Food in the UK took the lead in producing a joint letter to major UK supermarkets, asking them to support strong regulation and make a clear statement that they will not stock foods made from unregulated and unlabelled gene-edited plants and animals.

The letter very quickly gained support from more than 50 UK organisations – and not just the usual suspects. Alongside the Soil Association and the Landworkers’ Alliance it was also signed by Green Christian, Students for Sustainability and numerous academics, among them Professor Emeritus of Food Policy at City University, Tim Lang.

This initiative has received a lot of social media support and is now picking up media attention, especially in high-readership trade magazines such as Retail Times, The Grocer and Natural Products News.

We’ve now received an unequivocal response from the Co-Op saying that its policy of prohibiting GM will extend to gene-editing, which was covered in the Daily Mail. We are in discussion with other retailers and have stepped up our outreach to supermarkets now by offering to facilitate bespoke online briefings with their teams.

Beyond GM is also co-hosting a Farmer’s Assembly in collaboration with the ETC group. Farmers are so often left out of the discussion and we fear their voices could be lost if they don’t respond to the consultation. This online meeting will be a chance to connect with peers and hear a variety of views. We hope it will be the first of more assemblies and that it will inform and support our work on responding to the threat that genome editing poses to agroecology.

Each of these actions helps respond to the consultation on its own terms and demonstrate public opposition to deregulation. But the government has also made some key missteps that provide an opportunity to undermine the legitimacy of the consultation.

A flawed process

Beyond GM has submitted a complaint to Defra Minister George Eustice about the process of the consultation. Our complaint lists the multiple ways in which the consultation is not being conducted in line with Cabinet Office Consultation Principles.

Perhaps the most important of these Principles states that: “Consultations should have a purpose. Do not consult for the sake of it” and that government should “not ask questions about issues on which you have already formed a final view”.

The government has clearly formed a final view and this alone makes the consultation a hollow exercise.

Public consultations are also supposed to be targeted, easy to understand and to respond to. They are also supposed to be informative, providing enough information to ensure that those consulted understand the issues and can give informed responses. They should also include “validated impact assessments of the costs and benefits of the options being considered when possible.”

This consultation does not meet any of these acid tests. It is notable that, in addition to complaints from the general public, we have come across researchers working in this area who find the entire consultation heavy going and/or who have failed to understand what it is actually about.

Ministers are not, of course, obliged to respond to complaints from civil society or citizens. But the fact that George Eustice and Defra Permanent Secretary Tamara Finkelstein have not acknowledged the letter at all, let alone responded to the serious concerns raised, is indicative of a level of contempt for civil society and the general public we find baffling.

We believe that the process could have been so much better – and still could be. We remain committed to trying to have that discussion with the government.

Hasty recklessness

Politically speaking there is an awful lot going on in the UK’s food, farming and environment sphere at the moment. It’s easy to dismiss gene editing as just one of many topics. But it’s worth remembering that, for the UK government, gene editing is the key tool in the ‘sustainability tool box’ and deregulation is essential to put that tool to use.

For the UK to consider removing regulatory controls from an entire class of genetically engineered products is, at best, hasty and at worst, reckless. Even those who have a more positive attitude to GM have signalled this belief to us.

Prior to the launch of the consultation, we, and others, made repeated requests to Defra to understand and even feed into the scope of the consultation before its launch. We received no responses.

Such a heads up would have signalled the government’s willingness to have a dialogue and would have helped us organise our own thoughts and preparations. But, in the end, civil society was given less than 24 hours’ notice of the launch of the consultation which runs for just 10 weeks (instead of the usual 12) until 17 March.

Ten weeks is no time at all to accelerate from zero to a full-blown awareness-raising campaign and yet this is what we have had to do.

It’s also not time enough for anyone other than those who have already formed an opinion to make a considered response to a complex issue.

The outcome is by no means written in stone, but the government’s hasty recklessness has served to exclude the general public, reinforce the same old battle lines and foment the same old divisive discussions that have stymied us all for years.

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Author: Pat THomas

Director of Beyond GM. She is a journalist and the author of multiple books on environment, health and food. Pat is a former editor of the Ecologist magazine and has also sat on the boards of the Soil Association and the Organic Research Centre.

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GMOs in Conservation – Testing the Fences

In the first Jurassic Park movie, there is a scene where the head zookeeper reveals that the genetically engineered velociraptors have been systematically testing the electric fences that confine them to find out where they are weakest and where they are strongest.

Remarkably prescient for a popular film, it has become, throughout its franchise, a kind of I Ching of genetic engineering, covering themes of noble purpose gone astray and science for greed and profit vs science as a search for meaning and truth, the battle of man vs nature and the limits of genetic engineering and of conservation.

After nearly three decades it remains a good example of how science, fiction and metaphor can and do collide in the real world.

The rise of GMO 2.0

Over the last few years, ‘testing the fences’ has become fundamental to the biotech industry’s PR plan. For decades, genetic engineers have been fighting a losing battle to get the public to accept genetically engineered food. The first genetically modified (GMO) food approved for release was the Flavr Savr tomato, which came onto the US market in 1994 – a year after Jurassic Park made its cinema debut. 

In all that time, genetically engineered crops – modified to produce their own pesticides or to be resistant to repeated spraying with highly toxic weedkillers – have failed to reach any kind of meaningful scale anywhere except in the Americas. Consumer resistance is one reason for this, but the relatively limited types of GMO crops (maize, soya, oilseed rape and cotton dominate the marketplace) their association with higher pesticide use and the associated environmental destruction, as well as higher overall costs for farmers have also been influential.

Even so, the science of genetic engineering continues to advance. In recent years the number of potential uses for the technology has grown to encompass human health and medicine, farm animals, personal hygiene and cosmetic products and, perhaps most controversially, conservation.

Each of these uses represents a fence to be tested – Is the science a better fit or not? Is public acceptance greater or not? Can regulations be bypassed or done away with altogether, or is regulation crucial to safety and some measure of control in the face of uncertainty?

This rapid expansion of biotechnology into different areas is due to a new suite of genetic engineering technologies known as genome editing, which includes gene editing techniques such as CRISPR as well as synthetic biology and gene drives.

Of these, CRISPR is undoubtedly the most well known. What makes these new GMO technologies – sometimes referred to as GMO 2.0 – different is that they can create genetically engineered organisms more cheaply, more easily and more quickly than ever before.

A need for speed?

As the multiple crises that our planet faces have become apparent over the last few years, there is an increasing sense of urgency, a sense that we must act and we must act now.

In this swirl of panic and concern has emerged a report from the International Union for the Conservation of Nature (IUCN), Genetic Frontiers for Conservation: an assessment of synthetic biology and biodiversity conservation.

The report, three years in the making and published in May 2019, presents itself as an attempt to lay out the pros and cons of re-programming nature through new genetic engineering technologies.

Gene drives and synthetic biology, it said, could be a way of, among other things, reviving declining or even extinct species, eradicating invasive species, improving soil and therefore plant health and biodiversity. It could engineering trees to absorb more carbon or be resistant to diseases, such as the invasive fungus that plagues the American chestnut tree, and re-engineering insects for pest management.

It is a controversial approach on several levels and opens up important questions around the use of genetic engineering in rewilding, climate change mitigation and conservation.

Some of these questions are practical – the technology has yet to be proven to work. Some are ethical: What are plants and animals for? Are there legitimate boundaries between natural and synthetic? What are our responsibilities as stewards of the planet? Do these responsibilities also require the acknowledgement of limitations?

Questions, but not many answers

Questions have also emerged about the IUCN proposal itself. In its report Driving under the influence,  ETC Group in Canada reveal that of more than 40 individuals associated with the report, over half had a known pre-existing bias in favour of biotechnologies and/or a potential conflict of interest.

Pro-synthetic biology interest groups appear to have had a disproportionate influence on the writing of the report: at least 15 members of the group appear to be associated with or employed by Revive and Restore, Genetic Biocontrol of Invasive Rodents (GBIRd) or Target Malaria.

These three organisations are among the world’s most prominent and well-funded proponents of the development and deployment of gene drive organisms for environmental release.

Turning fields into labs

A new briefing from the Third World Network Biosafety Information Service spotlights concerns over the bewildering array of GE technologies – including gene drives – that essentially convert the environment into the laboratory, and can affect not only target organisms, but non-target organisms as well. This has implications for all kinds of plants, including crops and perhaps especially organic crops, that could easily be contaminated through inadvertent contact with gene drive ‘biomachines’.

In fact, we don’t know the full extent of how gene drives – which force genetic changes through entire species in the wild ­– might interact with the natural world. 

An increasing number of scientists, however, are raising the alarm. Among them is Prof Kevin Esvelt of MIT, developer of the gene drive. Esvelt believes that early and irresponsible promotion of the technique means: “We are walking forwards blind. We are opening boxes without thinking about consequences. We are going to fall off the tightrope and lose the trust of the public.”

That quote, from an article published in Pacific Standard notes: “Not since Robert Oppenheimer has a scientist worked so hard against the proliferation of his own creation.”

Risks as well as benefits

Some arguments for genome editing in conservation seem superficially compelling.

Synthetic biology – creating new man-made species in the lab – could help save some threatened species like the horseshoe crab.

The blood of this prehistoric creature is in demand because it contains a medically valuable molecule that aids the detection of bacterial contamination in medicines and medical devices. As a result, it is being harvested to near extinction. A synthetically produced alternative could help conserve these species and the shorebird populations that depend on them.

Gene drives are proposed as a way of neutralising disease carrying insects such as mosquitoes.

CRISPR, it is proposed could be used to improve disease immunity in populations of the endangered animals such as the black-footed ferret or to re-engineer bees to be immune to pesticides.

But gene editing can cause unintended adverse effects in animals. A recent Wall St Journal investigation uncovered unintended effects including enlarged tongues and extra vertebrae. Brazil’s plans to breed hornless dairy cattle, gene-edited with TALENs were recently abandoned when a study by the US Food and Drug Administration revealed that one of the experimental animals contained a sequence of bacterial DNA including a gene conferring antibiotic resistance.

The recent release of gene-edited, gene drive mosquitoes in Brazil is also instructive. The insects were supposed to breed with native mosquitoes and produce weak offspring that would die quickly without passing on their altered genome. Instead, the offspring have proved to be robust and are now breeding well beyond their original breeding grounds.

It is also a relatively short step from re-engineering wild animals to conserve them to re-engineering them for other purposes. Geese, badgers and bison, for example, are all implicated in infecting farm animals with various diseases. What are the potential consequences of genetically ‘editing’ these wild animals so they don’t impact farm animals and therefore farm profits? Could a genome-edited wild animal unwittingly become a reservoir for zoonotic diseases for which we do not yet have viable treatments? What happens to engineered soil microorganisms when released in the wild? How might they alter the soil structure and microbiome if, for example, genetically engineered organisms become the dominant species?

Who gets to speak?

In considering the use of genetic engineering for conservation, it quickly becomes apparent that there are many more questions than answers.

IUCN will make discussions around this issue a theme of its World Conservation Congress in Marseille, France, 11-19 June 2020 and delegates will vote on specific actions the organisation should take and on a set of ‘principles’ that will guide the development of an IUCN Policy during the period 2020–24.

What is not clear yet is what will underpin those discussions, assessments and collaborations. What research will be included? What will be ignored? What values and goals will inform these decisions? What weight will be given to the concerns of different stakeholders? What does ‘informed consent’ mean for a technology that has multiple and unknown potential consequences?

IUCN recommends that conservationists and others need to engage with this topic and we agree. As proposed uses for genetic engineering technologies advance, all sides have been forced to ‘test the fences’ – to ask themselves where the limits lie and to consider the strengths and weaknesses of their positions.

But this process is not legitimate unless it ensures meaningful public dialogue on the use of genetic engineering in the natural world on which all of us depend.

It’s time to open up the conversation.

Further information: Beyond GM is a UK initiative, the aim of which is to raise the level of the debate around genetic engineering in food, farming and the environment. Launched in 2014, it is run by individuals with a deep experience of food, farming, activism and communication. Its work reaches out to multiple stakeholders but has a particular focus on citizen engagement.

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Pat Thomas

Director of Beyond GM. She is a journalist and the author of multiple books on environment, health and food. Pat is a former editor of the Ecologist magazine and has also sat on the boards of the Soil Association and the Organic Research Centre.

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