Ethical arguments against genetically modified foods

Dr. Gary Comstock

Philosophy and Religious Studies

Coordinator, Bioethics Program

Iowa State University

Two kinds of ethical arguments against GM foods

1. Extrinsic objections

GMOs are wrong because risks outweigh benefits.

2. Intrinsic objections

GMOs are wrong , no matter how great the benefits.

1. Extrinsic objections

A. Unsafe for consumers

“Frankenfoods”

2. Extrinsic objections

B. Unsafe for environments

“superweeds”

– Herbicide resistance - canola gene flows into weedy relatives

– Bt toxin kills monarch butterfly larvae

Extrinsic objections

C. Unfair to small farmers

“Rich get richer,

poor get poorer”

Vandana Shiva

Monocultures of the Mind

Ethical arguments against GM foods

1. Extrinsic objections

2. Intrinsic objections

GM foods are wrong no matter how great the benefits may be.

Intrinsic objections

GM foods are wrong because it’s wrong to:

1. Play God2. Invent world changing

technology3. Cross species boundaries4. Reproduce by nonsexual

means5. Disrupt integrity, beauty,

balance of nature6. Harm sentient beings

Genetic engineering

“ takes mankind into

realms that belong

to God and God

alone ”

- Prince Charles

Intrinsic objections

1. We should not play God

Intrinsic objections

1. Don’t play God

Counter-examples:

– High tech medicine

– God wants us to genetically engineer food

Intrinsic objections

2. We should not change the world through new technology

Intrinsic objections

2. No world-changing technology

Counter-example:Agriculture

Intrinsic objections

3. We should not cross natural species boundaries

Intrinsic objections

3. Don’t cross species

Counter-examples:

• Mules

• Hybrid wheat

Intrinsic objections

4. We should not use nonsexual means to reproduce

Intrinsic objections

4. Don’t reproduce nonsexually

Counter-examples:• GIFT and in vitro• Plant cuttings

Intrinsic objections to ag biotech

5. We should not disrupt the integrity, beauty and balance of creation

Intrinsic objections to ag biotech

5. Don’t disrupt nature

Problems:

• An extrinsic objection

• Is / ought problem

Intrinsic objections

6. We should not harm sentient beings

Intrinsic objections

6. Don’t harm sentient beings

Problems:• An extrinsic objection

• Meat-eaters accept harm to animals

Conclusion: Intrinsic objections are not sound

1. Playing God2. Invent world changing technology3. Cross species boundaries4. Reproduce nonsexually5. Disrupt integrity and beauty of nature6. Harm sentient beings

Extrinsic objections

• Unsafe for consumers? Food allergens, toxins

• Unsafe for environment?

– Unintended effects on nontarget organisms– Gene flow, development of resistant weeds

• Unfair to small farmers? Rich get richer, poor get poorer

Extrinsic objections

•Are valid concerns

•Demand scientific and political attention

Extrinsic objections

• Support: Regulatory oversight on case-by-case basis• Do not support: a ban on all GM crops

Ethical arguments FOR GM foods

Potential to improve:

– Diets in developing countries

– Efficiency of food production

– Safety and purity of food

– Agricultural sustainability

– Diversity of agro-ecosystems

Enhanced nutrition

Vitamin A Rice

Iron Enhanced Rice

Amino Acid Balance

Insect resistance

• Bt corn– Insect resistance from

Bacillus thuringiensis– Non-toxic to humans– Target insect: corn borer– 40% U.S. Corn crop Bt– Potential to reduce

insecticide use

Disease resistance

• Potatoes• Squash• Tomatoes• Corn• Rice• Canola• Soybeans• Grapes• Cantaloupes• Cucumbers

Genetic engineering in microbes: enzymes

• Recombinant Chymosin

– Enzyme used for cheese making

– Originally from calf stomach– Bovine gene expressed in

GRAS microbes– FDA approved 1990– Now used in 70% of U.S.

cheese

Recombinant amino acids

• Aspartame– Artificial sweetener– Made from aspartic acid

and phenylalanine– Used in 5,000 products

• Monosodium glutamate

Recombinant alpha amylase

• Used to make HFCS

• Gras status in 1995

• 10% U.S. corn crop processed into syrups

Ethical Issuesin Risk Communication:

Why ConsumersNeed Not Worry AboutGenetically Modified Crops

Steven R. ShaferMichael D. McElvaine

Alwynelle S. AhlOffice of Risk Assessment

& Cost-Benefit Analysis

RiskAssessment

HazardRisk

-Likelihood-Magnitude

Uncertainty

RiskManagement

Cost-BenefitAnalysis

RiskMitigation

Risk Communication

RISK ANALYSISRisk Analysis

Ethical questions for risk assessment involving agriculture should be asked in the context of the risk assessment paradigm itself…

• What can go wrong?

• How likely is it to occur?

• How bad will it be if the undesirable event does occur?

Variability and Uncertainty• Variability

– heterogeneity among measurements– estimate may be refined by increasing the number

of measurements

• Uncertainty– inaccuracy, incomplete knowledge– may be reduced by different types of observations– may indicate gaps to be addressed by research

Ethics in Risk Assessments and Risk Communication Involving Agriculture: Some

Principles

• Make sure all stakeholder voices are heard

• Ensure transparency of ideological positions in determination of resources at risk and endpoints

Ethics in Risk Assessments and Risk Communication Involving Agriculture: Some

Principles

Need to

– maintain a safe, nutritious, and plentiful food supply

– preserve ecosystems

– balance agricultural production and wise stewardship of the earth.

The Act of Congress establishing a US Department of Agriculture was signed by President Lincoln in 1862………….

“….to acquire and diffuse among the people of the United States useful information on subjects

connected with agriculture…….”

USDA Mission:

• ensuring a safe, affordable, nutritious, and accessible food supply

• caring for agricultural, forest, and range lands

• supporting sound development of rural communities

USDA Mission:

• providing economic opportunities for farm and rural residents

• expanding global markets for agricultural and forest products and services

• and working to reduce hunger in America and throughout the world.

Risk assessments in USDA

• Mandated by law and Executive Order for economically significant rules ($100 million)

• Risk assessments, cost-benefit analyses, and Environmental Impact Statements are part of the public record

• Open to public comment before proposed rules are implemented

Coordinated Framework for Regulation of Biotechnology

• Federal Register 51:23302-23350 (1986)

• Uses existing statutes to regulate products of biotechnology

• Reviews of products are risk-based, not based on the technology itself

• Can impose civil or criminal penalties for non-compliance

Regulatory Oversight in Biotechnologyhttp://www.aphis.usda.gov/biotechnology/index.html

• US Dept. of Agriculture

– Plant pests

– Plants

– Veterinary biologics

• US Food and Drug Administration

– food, feed

– food additives

– veterinary drugs, human drugs and medical devices

• US Environmental Protection Agency

– microbial/plant pesticides

– new uses of existing pesticides

– novel microorganisms

Regulation of Biotechnology:US Environmental Protection Agency

• Regulatory authority under three statutes– Toxic Substances Control Act (TSCA)

– Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

– Federal Food, Drug, and Cosmetic Act (FFDCA), Section 408

• Ensures the safe use of microbes and pesticides in the environment

• Includes regulation of GM plants that produce pesticidal substances not produced by the non-GM plant

Regulation of Biotechnology:US Food and Drug Administration

• Regulatory authority under Federal Food, Drug, and Cosmetic Act (FFDCA)

• Ensures the safety and labeling of the nation’s food supply (excluding meat and poultry), and of drugs

• Includes monitoring foods to enforce pesticide residue tolerances set by EPA

Regulation of Biotechnology:USDA Animal and Plant Health

Inspection Service

• Regulatory authority under two statutes– Federal Plant Pest Act (FPPA)

– Plant Quarantine Act

• Ensures protection of American agriculture against pests and diseases

Risk:Characteristic vs. Source

• The maximum exposure to many acetyl cholinesterase (AC) inhibiting insecticides (organophosphates, carbamates) considered acceptable under the FQPA is approximately 0.01 mg per kg body weight per day

• Solanaceous crops contain glycoalkaloids• Glycoalkaloids are AC inhibitors, and for crops like

potato and pepper, the aRfD is also 0.01 mg per kg per day

20-kg childaRfD = 0.01 mg/kg/d

Consumption

(g)

Residue

(mg/kg)

Exposure

(mg/kg)%aRfD

Small fry 70 38 0.1330 1330

Large fry 125 38 0.2375 2375

Super fry 170 38 0.3230 3230

Pepper 74 77 0.2849 2849

Eggplant 96 60 0.2880 2880

70-kg adultaRfD = 0.01 mg/kg/d

Consumption

(g)

Residue

(mg/kg)

Exposure

(mg/kg)

%aRfD

Small fry 70 38 0.0380 380

Large fry 125 38 0.0679 679

Super fry 170 38 0.0923 923

Pepper 74 77 0.0814 814

Eggplant 96 60 0.0823 823

Assume that a new variety of apple has been developed.

It has the ability to produce AC-inhibiting glycoalkaloids.It is resistant to many insect pests.

Which is the more risky?The gene for glycoalkaloid production was inserted from a crabapple by traditional methods.

The gene for glycoalkaloid

production was inserted

from a potato by genetic

modification.

Secretary Glickman’s principles to guide USDA biotech policies

• Arm’s length regulatory process

• Consumer acceptance

• Fairness to farmers

• Corporate citizenship

• Free and open trade

http://www.usda.gov/news/releases/1999/07/0285

Arm’s length regulatory process

• Separation of regulators from the regulated

• Regulatory agencies (APHIS, FSIS) separate from marketing assistance agency (AMS)

• Separate experts serve different functions

• Maximize transparency in regulations

Arm’s length regulatory process

• Establish regional pest management centers with EPA– investigate crop production, pest biology, pest

management, biotechnology– long-term studies– information resource

• Gather the best scientific information to support policy and regulation

Expertise on the USDA’sAdvisory Committee

on Agricultural Biotechnology• Recombinant DNA

- plants• Recombinant DNA

- animals• Recombinant DNA

- microbes• Ecology• Biodiversity

• Agricultural practices

• Silviculture &

Forest science

• Fisheries

• Food science

Expertise on the USDA’sAdvisory Committee

on Agricultural Biotechnology

• Human medicine

• Public health and epidemiology

• Occupational health

• Veterinary medicine• Weed science• Entomology• Nematology• Plant pathology

Expertise Advisory on the Committee onUSDA’s Ag Biotechnology

• Small farm advocacy

• Consumer advocacy and public attitudes

• Ethics / bioethics• Risk assessment

• Laws and regulations• Biotechnology

industry• Intellectual property• International trade

Why US consumers may feel protected by the US GMO regulatory structure

Political structure is inherently competitive

Basic separation of powers• Creation of laws by Congress

• Enforcement of laws by Executive Branch agencies

• Challenge of laws and regulations through the Judiciary

Why US consumers may feel protected by the US GMO regulatory structure

Political structure is inherently competitive– Separation of regulatory authority from

agencies that promote agriculture

– Administrative Procedures Act authorizes courts to review agency decisions for decisions that are arbitrary and capricious

– Freedom of Information Act demands public disclosure

Why US consumers may feel protected by the US GMO regulatory structure

• Political structure is inherently competitive - some implications– Regulatory agencies can be sued

for procedural deficiencies

– Regulatory agencies can be sued if they do not acquire, or if they fail to consider, relevant scientific information

Why US consumers may feel protected by the US regulatory approach for biotechnology

• Political structure is inherently competitive - some implications– Encourages transparency and

extensive scientific investigation (e.g., risk analysis) by the government

– Encourages private citizens to challenge the government

Why US consumers may feel protected by the USGMO regulatory structure

• Preference for experts in scientific analytic techniques helps define who participates in some aspects of regulatory decision-

making, but policy decisions are not limited to experts

Why US consumers may feel protected by the US GMO regulatory structure

–Scientific experts selected based on what they know, not who they are, or are affiliated with

–Non-experts provide input through public comment, elections, administrative hearings, initiation of laws, regulations, lawsuits

Conclusion

Intrinsic arguments against GMOs are not sound.

ConclusionsExtrinsic arguments against GMOs raise two valid concerns:

•Food safety•Environmental effects

Conclusions

In the U. S., regulatory agencies have years of experience testing GM foods for safety to the consumer.

Continued vigilance is necessary.

Conclusions

In the U.S., regulatory agencies have

responsibility to test GMOs for safety to the environment.

Continued vigilance is necessary.

Conclusions

Extrinsic objections

•Representvalid concerns

•Demand scientific and political vigilance

Conclusions

Extrinsic objections

• Necessary: Regulatory oversight on case-by-case basis

• Not necessary: A ban of GM foods

Acknowledgments

This presentation is based on:

Gary Comstock, “Is it unnatural to genetically engineer plants?” Weed Science 46 (1998): 647-651, at:

www.biotech.iastate.edu/Bioethics/gmosethics/weedscienceart.htm

Acknowledgments

Dr. Clark Ford (Food Science and Human Nutrition, Iowa State University) generously assisted with ideas, design, and web-based pictures, and allowed me to use slides from his presentation, Ethics and GMOs, at:

www.biotech.iastate.edu/Bioethics/gmosethics/

ford.pdf

Acknowledgments

Dr. Steven Shafer, U. S. Department of Agriculture, kindly allowed me to use slides from his presentation, “Why Consumers Need Not Worry About Genetically Modified Foods,” at:

www.biotech.iastate.edu/Bioethics/gmosethics/

USDA.pdf

Photo credits

Vandava Shiva: courtesy of Mt. Holyoke College

ens.lycos.com/ens/feb99/1999L-02-23-03.html

Creation of Adam: www.artprintcollection.com/html/michelangelo_

buonarroti-crea.html

Frankenfoods tomato: www.the-scientist.library.upenn.edu/yr1999/oct/palevitzp10_991011.html

Prince Charles:www.princeofwales.gov.uk/

Mule: www.sky.net/~nodell/

Plant cuttings:www.familyplay.com/activities/plantcut.html

Monarch larva: www.the-scientist.library.upenn.edu/yr1999/oct/lewis_p1_991011.html

Monarch butterfly: http://news.bbc.co.uk/hi/english/sci/tech/

newsid_681000/681208.stmFermenter:

www.nbsc.com/ferm_eq/custferm.htmNew Leaf:

www.monsanto.com/monsanto/investor/current/default.htm

Bt corn field:ens.lycos.com/ens/sep99/1999L-09-16-01.html

Ethical arguments against genetically modified foods

Dr. Gary Comstock

Philosophy and Religious Studies

Coordinator, Bioethics Program

Iowa State University