genetically engineered crops

Wed Jun 23 09:25:00 EST 1993

Since my last message seems to have been misconstrued a bit, I'm
going to clarify and expand a bit.  As has been stated, EEC, FDA,
etc. already have safegaurds in place, though transgenic crops are
a 'new beast' which they haven't had to really deal with before.

There are some real and legitamate concerns here, and I think that
just as a pharmaceutical company must prove the safety and efficacy
of a drug before it can be marketed, the onus should be on the
developers of transgenic plants to prove their safety before being
allowed to produce and market.  The onus should not be on concerned
individuals and opponents to prove that a risk exists.  Two issues
need to be addressed in risk assessment: 1) the safety of consuming
the product; 2) the chances for disasterous genetic events from
cultivating the crops.  Both of these risks, of course would have to
be evaluated relative to what exists for non-genetically engineered
organisms, and for the 2nd, compared to what exists in nature.  If
there is a statistically increased risk for either, then the crop
should not be used.

Now item #1 above can be tested fairly reasonably by feeding the
engineered crop to a variety of lab animals, at first some should
be fed for several generations, and comparing to animals which are
fed the non-engineered counter-part.  Statistics can be applied.
All the results should be subject to close scrutiny by watch-dog
groups (like PIRG) and subject to peer-review.  The results, good
& bad, should be made public knowledge.

Item #2 is difficult.  It is possible to imagine many ways in which
a disaster could occur and it will take *reasonable* judgement by
people knowledgeable in the field to assign probabilities to
possible events.  If someone is not knowledgable in the field, I
find it hard to see how it can be *proved* to them that the
chances of disaster are insignificant.  We can't prove that these
chances are zero, since some uncertainty will always remain.
Whichever way the assessment points, there will be someone individuals
who will dissagree and protest.  The best we can hope for is, e.g.,
a 90-95% concensus among the scientists & statisticians involved in
the studies.  The fear of this new unknown cannot be completely
assuaged, except by familiarity, which we can't have until it's
actually been used for some years.  Again, scrutiny by public
interest groups and peer-review are necessary & results should be
made public.

In both these studies, it will have to be understood by the public
interest groups that outright obstructionism is not acceptable, and
that a certain amount of trust must be placed on the scientists
involoved.  As I said, the best we can hope for is 90-95% consensus
among scientists, but we, at first, pick a wide and diverse group
of scientists so that any conflict-of-interest or bias is diluted 

Similarly, on the part of the (proponent) scientists, it will have to
be understood that public interest groups serve a vital and important
role, and that their questions and concerns can't be just dismissed
because 'they don't understand the science.'  With time, if jargon is
avoided, non-scientists can understand quite a bit.  Just saying that
'it's never happened before' or 'I don't see how that's possible' is
*not* an acceptable reason for dismissing a risk.  At least some
attempt must be made for explaining why an event is unlikely, or no
more likely than it is without the engineered crop.  Again, the onus
is on the proponents to 'prove' (to within reasonable limits) safety.

Now, given that these conditions are satisfied (except to a few 
individuals who oppose the technology 'on principle') the question
remains why we should use the technology when there is presumably
a non-zero (but not statistically significant) risk.  Well what are
the benefits?  Given current crop technology, without engineered
plants, it is possible to feed everyone in the world.  The reason
why people go hungry is primarily because either the existing
technology is not used world-wide or because the current system for
'distributing' food is imperfect.  For a less developed country that
can ill afford $$$ farm machinery, fertilizers, pesticides, training,
parts, fuel, etc., engineered crops may be a great boon - I hope so.
For developed countries, where food production is already adequate to
meet there own needs, there is still a potential for less environmental
impact through reduced use of pesticides, reduced need for water,
reduced need for cultivated land (i.e., more land could be left
natural) etc.  Yes, I know that some crops are engineered so that
*more* herbicides can be used, and that is probably not a good idea,
but it is not central to the general issue of safety and benefit.
Many farmers are learning that judicious use of herbicides and
pesticides saves them money and is good for the environment, I expect
that this will extend to engineered crops.

The final, but not least significant, benefit is economic.  Some folks
stand to make $$$ from this technology, and I think that here is the
crux.  Why should we except any, no matter how insignificant risk, 
just so someone can get rich?  Well, personally, I'm not against
capitalism, and if we were to eliminate all technologies/industries 
which make a profit while causing some public risk, we wouldn't have
much of an economy left and I think that, on average, the public would
suffer from the reduced standard of living.  (You're sitting in front
of a CRT screen right now.  Are there some risks?  Did someone profit
from the sale of that screen?  Do you want to give it up?)

So I would say that there are 'marginal but significant' benefits to
engineered crops which should be pursued if, and only if, a
reasonable level of safety can be assured.  Note that I am not
suggesting that these safety evaluations or the informing of the 
public be left completely to the private sector or to 'market forces'.

Now we come to the issue of labeling.  There are two cases: 1) both
the engineered crop and its non-engineered counterpart pose no
significant risk to the public (and the public has been so informed);
2) both the engineered crop & its counterpart pose real, but similar
risks which are deamed acceptable (as in the case of products
containing wheat gluten to which some individuals are allergic).
Note that I am taking as given that a crop will *not* be marketed if
its risk is greater than the non-engineered counterpart.  In both
of these case, simply labeling a crop "genetically modified" provides
no safety information and does not serve the public interest.  In
fact, it can hurt the public because enforcement would take tax dollars
away from, either the public, or other activities which mitigate real
risks, like the risk of being confronted by a violent criminal with a
gun.  Such a label would satisfy individuals who want to avoid
engineered crops because they aren't convinced of the safety, even
though there has been complete public disclosure as I described at
the beginning.  *But*, I still maintane that if engineered crops are
marketed, then non-engineered crops will be so labelled *voluntarily*
(just as 'organically grown' is labelled - by default you know that
if doesn't say 'organically grown', then it wasn't) so a legal mandate
is not necessary, even for those who are not convinced of the publicly
disseminated safety information.  Now in case (2) at the start of this
paragraph, there may be cause to provide safety labelling for *both*
engineered and non-engineered crops since both pose some risk, but
this isn't the type of labelling that's at issue.

In closing:  the safety evaluation I describe would be long and
painful.  I think that, for the first 'few' engineered crops, such
would be appropriate.  Once a 'track record' is established, some
'standard' procedures could be determined so that the process is not
so resouirce intensive, but still provides reasonable safety assurance.

O.K.  Let me duck behind my barricade.

Paul Schlosser
(all personal opinion with a reasonably cool head)

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