UK Genetic Technology Bill is not fit for purpose

EXCERPT: A joint statement signed by 90 international scientists and policy experts has criticised the government for the use of what is essentially a marketing slogan – “precision breeding” – in the bill’s title and text. The statement contends the term is “technically and scientifically inaccurate” and “misleads Parliament, regulators, and the public” and should be deleted from the bill.
---

The Genetic Technology Bill is not fit for purpose

Pat Thomas
Reaction, September 26, 2022
https://reaction.life/the-genetic-technology-bill-is-not-fit-for-purpose/
[links to sources at this URL]

The Genetic Technology (Precision Breeding) Bill is set to return to Parliament soon to complete its Commons phase. The bill, which removes most regulatory controls from gene edited crops and foods in England, is making swift progress but is mired in controversy.

As drafted, it has raised multiple concerns about its scope, about the legality of some of its provisions, and, given public demand to see genetically engineered food regulated and labelled, about democracy.

The government has, nevertheless, pursued its deregulatory agenda with relentless energy, oblivious to anything beyond “deliver, deliver, deliver”. It has brooked no criticism, addressed no questions, and, thanks to its still healthy majority, strong-armed the bill through its early stages unamended. All of which gives the impression that everything is fine. Nothing to see here. Move along.

Except that’s not true. Storm clouds are brewing and government intransigence means it is increasingly falling to those outside of government to raise issues of legitimate concern.

Momentum behind these concerns is growing.

“Not fit for purpose”

In June, the Regulatory Policy Committee, for the second time, rejected the government’s business case for the bill, as laid out in its impact assessment (IA). The RPC, the independent better regulation watchdog, has branded the IA ”weak” and “not fit for purpose”. It notes that the government:
* has not adequately considered the full range of potential impacts arising from its invention of a new kind of GMO – the so-called “precision bred organism”
* has not sufficiently considered the full range of impacts upon small and medium businesses
* has not made a detailed assessment of the competition, innovation, consumer and environmental impacts
* needs to be clearer about the impact of removing labelling and traceability requirements
* needs to revisit assumptions relating to the impact on devolved administrations.  

It also cautions that most of the evidence regarding risk “is drawn from interested parties, or based on scientific trials, that do not replicate real-world conditions”. Such a narrative could, it says, “impede research, development and evaluation of an important new technology.”

A need to make amends

Also in June, a coalition of 36 UK civil society groups published a joint statement that cautioned: “We are concerned that too few MPs have grasped the full implications of the bill and that, as a result, it could pass into law without the full debate and major revisions it requires. We urge our parliamentarians to take steps to prevent this from happening.”

Thus far, no such steps have been taken and it remains unclear how many MPs who are debating and voting on the bill have even read it.

Environmental issues

If they had, they might be surprised to find the bill does not simply remove regulatory control from “precision bred” plants and animals but, through clever word play, removes such control from nearly all types of genetically engineered crops and foods, including those resulting from the insertion of foreign genetic material. Its scope is also not strictly limited to agriculture but quietly extends to wild and free-living flora and fauna which could also be “precision bred” without any formal assessment or post-release monitoring.

This is an ethical concern. It is also an environmental one.

Crucially, although the bill claims, in its very first paragraphs, that its provisions “will not have the effect of reducing the level of environmental protection provided for by any existing environmental law”, those provisions also require no environmental assessment or monitoring that might ensure the truth of that statement.

Censure from the scientific community

This month, several more concerns have been raised.

A joint statement signed by 90 international scientists and policy experts has criticised the government for the use of what is essentially a marketing slogan – “precision breeding” – in the bill’s title and text.

The statement contends the term is “technically and scientifically inaccurate” and “misleads Parliament, regulators, and the public” and should be deleted from the bill.

London-based molecular geneticist Dr Michael Antoniou, who helped coordinate the letter, explains that the term “precision breeding” is being used “to give gene editing the appearance of controllability, predictability, familiarity, and therefore safety, implying that biosafety controls can be loosened or abolished”, something the growing number of signatories consider to be a “dangerous development”.

Issues of commerce and trade

Echoing the RPC’s concerns, the organic sector has just published a joint letter to Secretary of State for the Environment, Ranil Jayawardena, raising the as yet unaddressed issue of co-existence, and the need for traceability throughout the food chain to ensure organic and non-GM farms and businesses can maintain their values-based and commercially valuable ‘GMO free’ status.

Concern about the bill has also been raised in a joint letter by civil society groups in the UK and EU which alleges the bill breaches the non-regression clause of the UK-EU Trade and Cooperation Agreement and asks the European Commission to take action. At the same time Scotland and Wales have affirmed they will not grow England’s gene edited crops or sell its gene edited foods, while Northern Ireland farmers and retailers, aligned with EU rules, cannot legally grow or sell them. No surprise then that a recent poll in New Scientist found that no supermarket was willing to say it would stock gene edited food. All of which suggests the RPC’s judgement is spot on.

A bill full of holes

Objections to the Genetic Technology Bill are not merely ideological but arise from the fact that it is full of holes, vague language and half-baked ideas.

It takes an issue overflowing with complexity, one that extends well beyond the narrow tramlines of laboratory science into ethics, environment, animal welfare, consumer choice, food culture, food sovereignty, equity and transparency, and abandons all the tricky detail to a future time and possibly a future government.

Many of its proposed regulations have been left to undebated ‘negative procedure’ secondary legislation. Even those under the ‘affirmative procedure’, which in theory can be debated, will, as the Secondary Legislation Scrutiny Committee points out, not benefit from any meaningful debate.

Finding – or forcing – a place?

In his new book, The Genetic Age: Our Perilous Quest to Edit Life, renowned popular science writer and Professor of Zoology at the University of Manchester, Mathew Cobb, concludes that while genetically engineered crops may well be safe, they have utterly failed to fulfil their promises of higher yields, lower pesticide use, improved biodiversity, better nutrition and, crucially, public buy-in.

This is largely a failure of the science itself. Hiding behind marketing slogans and removing regulation is not the way to help genetic technologies fulfil that promise. Indeed, given how much we still don’t know about genetics, it may bring unforeseen risks.

Cobb goes so far as to suggest that a single-minded focus on genetic technologies as THE solution is crude, ignores the complexity and interconnectedness of the problems we face and can draw attention away from other effective and less controversial solutions.

Environmental collapse, a global pandemic, climate change, war and economic downturn have sharpened our focus on the challenges that we are facing in producing food that doesn’t cost the earth. The fragility of our farming and food systems leaves no room for hype, no room for overblown promises and no room for grand experiments.

We have a responsibility, as critics of the bill are clearly saying, to ensure that any technologies intended to “fix the food system” are subject to high standards and clear criteria, not just scientifically but ethically, socially, environmentally and economically.

It’s a high bar, but if government truly believes in the transformative nature of agricultural genetic engineering then that is where the bar needs to be set – even if it means pausing the bill, or starting again – because real innovation always involves real risk.


Pat Thomas is a Founder/Director of Beyond GM/A Bigger Conversation

__________________________________________________________