Genetically modified insects and the precautionary principle

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Last week the Guardian newspaper reported on the findings from the UK House of Lords’ science and technology committee into the development and use of GM insects. According to the committee’s chairman, Lord Selborne:

“GM insect technologies have the potential not only to save countless lives worldwide, but also to generate significant economic benefits for UK plc, where we are an acknowledged world leader.”

No surprises there. The case for GM insects to be developed as a form of vector control has many proponents and seizing an economic opportunity is to be expected from the Lords. Apart from a cursory explanation of the means of developing GM insects, and a mention of the fact that the committee would like to see a reform of European Union regulation around GMOs (more on this later), the reporter fails to consider any environmental issues that may arise from the release of transgenic insects, in what seems to me to be a failure of research and the rehashing of the committee’s summary report.

Thankfully, in an attempt to provide a balanced argument the Guardian also published a piece that was more critical of the report, describing it as  “an unsophisticated form of moral blackmail” and laying out the possible extinction risks associated with gene drive systems. The scientific knowledge gap is highlighted by these authors, who write:

“We are not against GM insects. Our point is that we do not know enough. Nobody knows enough.”

Though I commend these authors for responding to the Lords’report in a more critical way, there are still a couple of findings in the report that hadn’t been directly addressed and which I think need exploring further.

The first is the issue of EU regulations of GMOs that the Lords describe as “failing lamentably” and would like to see amended. This critique is aimed at EU Directive 2001/18/EC which states that “due attention be given to controlling risks from the deliberate release into the environment of genetically modified organisms”. This is to be conducted through case-by-case environmental risk assessments, public consultation, a requirement to consult all relevant scientific and ethical committees, and development of “a mechanism allowing the release of the GMOs to be modified, suspended or terminated where new information becomes available on the risks of such release” before consent will be granted. It is a very robust piece of legislation which, when linked with Regulation (EC) No 1946/2003 that restricts the release and transboundary movement of any GMO within EU member states, makes this not “lamentable” as the Lords would have us think, but sound legislation based on the Cartagena Protocol which states that products from new technologies must be based on the precautionary principle and allow nations to balance public health against economic benefits. And which allows countries to ban imports of a genetically modified organisms if they feel there is not enough scientific evidence that the product is safe. It seems to me that an attack on the governing EU legislation is also an attack on the Cartagena Protocol which environmentalists need to be aware of.

The international consensus of the definition of the Precautionary Principle is:

“When human activities may lead to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or diminish that harm.”

And this brings me to my second concern about the House of Lords report, wherein Professor Rosemary Hails states that:

“the Precautionary Principle properly applied would also take into account the risks of not developing a particular technology and the benefits forgone. It is a misuse of the Precautionary Principle that has led us to this place.”

This reconstitution of the Precautionary Principle is a matter of great concern and has already been discussed at some length by the House of Commons Science and Technology Committee in their Fifth Report: Advanced Genetic Techniques for Crop Improvement: Regulation, Risk and Precaution wherein Sir Mark Walport framed the precautionary principle not as a response to scientific uncertainty, but as a guide to evidence-based decision-making. He said:

“Decisions must be informed by the best evidence and expert advice. The application of the ‘precautionary principle’ can help to guide this. This simple idea just means working out and balancing in advance all the risks and benefits of action or inaction, and to make a proportionate response. All too often, people citing this principle simply overreact: if there is any potential hazard associated with an activity, then it should not be done, or, if it is already being done, it should be stopped.”

By removing the imperative for evidence and advice that is provided to governments to be based on the principles and rigour of scientific enquiry, the report is effectively providing ministers with a means of bypassing environmental legislation. A recent example of this is when George Eustice MP recently cited food security as a reason to maintain the use of neonicotinoid pesticides under this bastardised definition of the Precautionary Principle.

If it were as simple as Sir Mark maintains to identify and stop hazardous activities we would not be facing some of the world’s current health and environmental catastrophes. That is why we must legislate against them and that is why scientific evidence needs to be the basis for that legislation. And when that evidence is lacking or inconclusive, aren’t we safer not taking the risk in the first instance?  If, as Prof. Hails maintains we need to consider the risks of not using certain technologies for their potential benefits we have to ask ourselves whose benefits are we talking about.

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