EU law-makers are struggling with the
thorny question of how to regulate genetically edited organisms, or
even whether to regulate them
at all [1].
Their problem is
mushrooming under an onslaught of diverse 'New Breeding Techniques'
pouring out of laboratories. These techniques are genetic editing
with a handful of old-style gene insertions thrown in [2].
Why should a body
which has taken so much care and time deliberating and implementing
regulations on genetic modification, be struggling with what seems to
be no more than a set of variations on the same GM theme?
Consider the
definitions of 'genetic modification' or 'GM'.
Our (layman's)
definition of 'GM' is anything involving humanly-conceived,
humanly-contrived molecular spanners, nuts and bolts to change life.
Geneticist, Ricarda
Steinbrecher's definition of 'GM' is a laboratory technique that can
change the genetic material (usually DNA) of a living organism
without breeding.
In response to the
apparent confusion in both journalistic and scientific blogs about
what GM actually is, Senior Greenpeace scientists Janet Cotter
defined a GMO as containing "a novel arrangement of genetic
material that either does not occur in nature, or has been obtained
by a process that does not occur in nature". (See below)
The
United Nations agreement on GMOs (Cartagena Protocol) defines
genetically modified organisms as a life-form which "possesses a
novel combination of genetic material obtained through the ..
application ... of in vitro
nucleic acid techniques".*
*Note.
DNA and its related molecule 'RNA' are composed of nucleic acid
chemical units; 'in vitro' refers to techniques performed in
laboratories.
EU Directive
2001/18 defines a genetically modified organism as a life form in
which "the genetic material has been altered in a way that does
not occur naturally by mating and/or natural recombination".
In all these
definitions the simple meaning of the words clearly encompasses all
form of artificial genetic change, be it 'modification',
'engineering', 'editing', 'transformation' or any unintelligible
abbreviation which happen to have been introduced into use [2].
Janet Cotter further clarified what GM is and isn't:
- the presence of foreign genes does not define a GMO
- in a GMO, genetic material is directly altered by humans
- horizontal gene transfer isn't GM, it's a process of natural evolution
- biotechnology is not genetic modification, but merely encompasses it
- the breeding process is not used to alter traits in a GMO
- GM isn't a 'pseudo-catgegory' of breeding techniques
- defining the term, GM, is very practical and totally possible both scientifically and legally.
So,
why is the EU struggling?
A major source of the problem no doubt
comes from America, which despite being the founding father of GM
commercialisation, has no clear definition of the term 'GMO', and
correspondingly no GM-specific regulations (the US is not a signatory
to the Cartagena Protocol). Its concept of 'GM' can therefore be
configured and reconfigured by the biotech lobby as its commercial
needs arise.
Note especially, that someone somewhere has cleverly introduced the
inaccurate and confusing term 'New Breeding Techniques' for what, by
any accepted definition, are 'New GM Techniques' which specifically
exclude breeding.
That
particular someone somewhere was likely a biotech industry bod or a
pro-GM scientist, someone with an interest in avoiding regulation
which would interfere with their profits, someone whose capacity to
re-define 'GM' as 'non-GM' is as well-honed as their ability to
reconfigure natural DNA to unnatural DNA, someone with a knack for
posing regulators questions that don't
need to be asked and supplying make-believe answers to those
unnecessary questions.
Thus, EU regulators are tied in knots over the question of whether
genetic modification is still genetic modification when you call it
'genetic editing' and include it in a new sort of breeding category
which doesn't involve breeding.
All
this time, the questions which everyone should
be
asking are: are these GM techniques (any of them) safe
to eat or safe
to allow into the environment?
The make-believe answer to this question is that genetic editing is
precise and isn't GM, therefore it's safe. In real-life, genetic
editing raises all the same concerns of inherent unpredictability as
the old-style GM crops which Europeans have already rejected.
While
the intention of genetic editing techniques is to make precise DNA
alterations in precise locations in the genome, the change may happen
in the wrong place or can evolve over time into something different.
And, the new DNA can certainly express in unpredictable ways and can
(some would say will)
interact unpredictably with the wider genome, the cell, the whole
organism, and the environment.
It has to be pointed out that while genetic editing is promoted as
inducing a small change in existing DNA, rather than the insertion of
a large sequence of DNA, it can (and will) be used repeatedly to
achieve substantial changes in one or in multiple genes, resulting in
increasingly unnatural organisms.
All the same potential for novel or increased toxins, allergens,
anti-nutrients, pathogens and nutritional disturbances exist in any
genetically edited food crop.
Despite the smart arguments being put forward by pro-GM advocates,
genetically edited organisms are GMOs.
It
seems the EU would actually have to amend its Directive to
exclude
genetically edited organisms, rather than exclude them for being
outwith the scope of its existing laws.
TAKE ACTION
Tell
your MEP that all
products
of 'New Breeding Techniques', MUST be required to undergo a full GM
safety assessment and be labelled, for the simple, important reason
that "just because gene-edited organisms don't contain foreign
DNA, this doesn't make them safe" (Steinbrecher)
[1] EU STRUGGLING WITH GEdOs - February, 2015
[2] SMART BREEDING TOOL - OR HIDDEN GM? - January 2016
SOURCES:
- Jan Cotter & Ricarda Steinbrecher, GM 2.0? 'Gene-editing' produces GMOs that must be regulated as GMOs, The Ecologist, 13.01.16
- What's a GMO? GM Watch , January 2016
- Nathanael Johnson, It's practically impossible to define "GMOs", Grist 26.12.15
- Giovanni Tagliabue, The meaningless pseudo-category of "GMOs", EMBO Press, 11.11.15
Photo credit: Corporate Europe Observatory on Flickr
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