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Dr Donald M. Bruce
Edinburgh, 28 February-1 March 2000
Society, Religion and Technology ProjectThe Society, Religion and Technology Project (SRT) is a unique unit dedicated to the assessment of the ethical and social issues arising out of current and future technologies. Set up in 1970 by the Church of Scotland, it has established a reputation for pioneering work on emerging technologies, and for the balance and perception of its multi-disciplinary approach. In 1993 it began a five year study into genetic engineering non-human species, which brought together leading Scottish experts in animal, plant and micro-organism genetics with specialists in ethics, sociology, risk assessment and regulation, animal welfare and public perception.
The working group's, report was published as the book "Engineering Genesis" (Bruce D. and Bruce A. (eds), Earthscan Publications, London, 1998) which has just been reprinted and updated. This has been acclaimed by several UK commentators and by leading figures in biotechnology as the most balanced and well informed study available on the subject. It was also the subject of a consultation in November 1999 at St. George's House, Windsor Castle, on "Genetics, Values and Risk", which was attended by several senior UK regulatory and policy advisors, including the chairman of the Advisory Committee on Releases to the Environment and the Chief Scientist of the Ministry of Agriculture Fisheries and Food. The Engineering Genesis study was chaired by the Director of the SRT Project, Dr Donald Bruce, who worked for 15 years in nuclear research and for the Health and Safety Executive as an inspector in nuclear safety and risk assessment. This work is being followed by new SRT expert studies on risk and values in technology and on technology and globalisation. |
Emphasis on Commercial Factors has masked Important Social Values
The SRT Project is concerned for the responsible and ethical use of genetic technology. In our analysis we have drawn particular attention to the disproportionate emphasis on commercial criteria in the policy making and regulatory structures which have hitherto directed food and crop applications of genetic engineering. In doing so they have notably failed to take proper account of wider public values and concerns. On several occasions during our study we drew the attention of both the UK Government and the EC of the likely consequences if wider public values were not given more attention. We forewarned of an impending crisis in the UK over genetically modified food if these concerns were not addressed. Unfortunately, our concerns have been amply borne out in the events of the past year.
The primary goal of the UK and other European governments in the early 1990's was to press for the rapid commercialisation of GM technology. The grounds of this were to enable European nations to capitalise on their high calibre research base in biotechnology, and thus to have a competitive stake in the expanding market that was forecast. This led to pressure to relax the precautionary regulatory regime in the EU, just at a time when the public were becoming more aware of the potential risks of such technologies. Voices expressing caution were somewhat dismissed and scientific models of risk assessment were assumed all that was necessary. The precautionary principle was seen, at best, as unnecessary in the light of scientific studies, and at worst as an emotional or irrational response. Commercial Considerations have thus largely been allowed to mask important social attitudes and values.
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The Social Failure of Substantial Equivalence and Labelling by Content
The doctrine of "substantial equivalence" was assumed to be sufficient, on the assumption that if a foodstuff produced by genetic modification was shown to be scientifically indistinguishable from a normal food, this would satisfy the public over safety. Similarly it was assumed that GM food labelling by testable content was all that was needed. Subsequent events have shown both assumptions to be seriously mistaken. In both cases, no account was taken of wider public evaluation of acceptableness, which takes a wider set of criteria into account than a scientific safety or risk assessment. For example, insufficient account was taken of basic ethical objections to switching genes among species that do not normally mate, or which saw it as "tinkering with nature" to an unacceptable degree. Similarly, substantial equivalence and labelling by content take no account of those many people who are concerned about the environmental risks while the GM crop is grown. Thus the two key concepts on which safety of GM foods were assessed proved largely irrelevant for a large section of the UK population. According to the consumer organisations it was this failure to have any real choice over GM foods that was the biggest factor in the UK public turning against GM foods.
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Changed Underlying Values about Risk
Risk is socially embedded. The present context in the UK is one characterised by an increasing risk aversion towards novel technologies, based on a number of value considerations. Amongst these is a deep theological and philosophical questioning of what is regarded as "unnatural", i.e. an inappropriate human intervention in nature. While it is easy to critique this if it were claimed as an absolute concept, as the embedded perception of a culture it has very great significance, which has to be taken with all seriousness. A noticeable paradigm shift is occurring. No longer can biotechnology rely on a public acceptance of the Enlightenment model of progress driven by a scientific conquering of the power of nature. Increasingly this is replaced by the notion of being part of nature and needing to work in harmony and balance with it. In our experience over the past year of talking to many diverse groups all over the UK, such concepts, which were formerly confined largely to Christian and environmental thinkers, are now emerging quite generally in public reactions. Agricultural biotechnology in particular needs to learn to treat this reaction not with scorn but with respect and seriousness, if it wishes to find public acceptance.
The safety and environmental impacts of genetically modified foods therefore now need to be conceived in a much wider frame of reference than the merely scientific assessment of risk. From our professional experience of nuclear energy regulation we know that a rigorous scientific risk assessment is of no consequence if the general public have lost their sense of trust of those in charge of the industry. This is now also the case over GM foods in the UK. If crop and food applications of this technology will only have a future if they are redirected to addressing significant human or environmental needs, and with the public's involvement and approval.
People are now more aware that harnessing and altering fundamental forces of nature like those inside the atom or the gene involve significant risks as well as potential benefits. There is a strong underlying public attitude that we have simply gone too fast in developing GM crops and foods, without taking account of the wider implications to safety and the environment. For many of the UK public, a measure of precaution is now viewed as a more appropriate response in biotechnology, instead of going ahead rapidly in order to stake a claim in a competitive commercial market.
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In this new context, new technologies like GM food have to satisfy an invisible social contract if they are to gain public acceptance. Our society is prepared to embrace technology as a provider of certain services it offered, and accepts a certain degree of risk and adaptation as a result, provided certain basic factors are not infringed. These factors can be identified as
In the case of GM food, several of these basic conditions are not immediately met by the current applications. The technology is unfamiliar and has no social embedding in the way that, for example, coal has. Pragmatically, it has not so far derived any products of tangible benefit to the consumer. Although there have been no significant accidents, GM crops are perceived to pose a threat to wildlife, biodiversity and human safety, comparable to that of introducing a non-indigenous species into a vulnerable ecosystem. The residual fear derived from the BSE crisis undermines confidence that the scientists or regulators could have taken all eventualities into account.
The situation which GM addresses is one which is not perceived to need improving. Gene therapy in medicine is perceived as righting something wrong. GM food, however, is seen as putting at risk something which is all right. Some see it almost inevitable that an accident will happen at some time. Others are less pessimistic, but nonetheless consider that we have rushed too quickly, driven by commercial goals or scientific naiveté, into developing novel technologies whose far reaching implications we do not sufficiently understand.
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What Level of Precaution?
A general moratorium on GM crops has little rational force unless there is a rather exact specification of the conditions which need to be satisfied in order for a decision to be made, one way or the other, about particular applications, at the end of the relevant period. It cannot be used as a smoke screen for opposition to GM in principle which no amount of data would ever satisfy. The main purpose of a moratorium is to give society a breathing space within which either to get used to the idea of the technology or else conclude that it does not want it. A more effective measure would probably be simply to remove from the market the two imported products whose widespread and indiscriminate use have caused most of the problem - soya and maize - until arrangements can be made for their segregation and labelling.
There is a more basic question of what is an appropriate level of precaution. The term "the precautionary principle" has, like "sustainable development", become devalued by becoming redefined by each group that uses it, according to their own lights. Originally it signified a prudent approach to risk regulation that takes account of potential accidents for which there are no or insufficient empirical data. For many in the environmental movement it has, however, become an expression that enshrines the philosophy that if there is the least doubt, the technology should not go ahead. At the other extreme, some North American risk assessors regard the precautionary principle as a wholly unnecessary and irrational approach, since it is not based on scientific data. Both these poles suffer from an extreme denial of the validity of any other view. Ironically, both also make equal and opposite misjudgements about the reliability of data. In practice, it is in the very nature of the ecological or safety risks of GM food that the assessor will never be in position of anything approaching certainty. Always one will have to make decisions based on inadequate data, and thus to use value judgement.
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Taking Society's View of Precaution Seriously
What is now apparent is that civil society demands to have its view of precaution taken seriously. It is no longer enough to assess GM food safety only against the criteria of the scientist, Government civil servant or professional risk assessor. This fact is not something to be regretted, as though somehow a retreat from the highest standards of scientific rationality. It is rather a recognition that, instead of assuming that only this one form of rationality was valid, other forms of rationality also have their place in decision making. Any society which wants to apply genetic engineering to something as basic as food needs equally to take account of what Max Weber pointed out almost a century ago. This is that there is another sort of rationality, not only a question of sociology or psychology, but based on people's ethical, philosophical and religious values. GM food only has a future in OECD countries if it accords with people's basic values like these. In the UK this is not currently the case. The question is whether the proponents of GM food can turn it from a technology currently geared primarily to commercial interests into one based on human and environmental interests, because those are the values that will count.
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Dr Donald Bruce
Society, Religion & Technology Project
Church of Scotland
121 George Street
Edinburgh EH2 4YN
Scotland
Tel.: +44 131-240 2250, Fax : +44 131-240 2239
srtp@srtp.org.uk
http://www.srtp.org.uk
