Risk Communication and Public Policy Issues Relevant to Gene Technology
In New Zealand as elsewhere, and notwithstanding international trade agreements and obligations, the ultimate decision on whether or not to accept new technology rests with the public. In August 1996, 16 lay New Zealanders evaluated the use of gene technology in plants during New Zealand's first Talking Technology Conference. The panel concluded that:
"We have to accept that plant biotechnology is a reality and it is better that it be conducted in an open environment where checks and controls can be put in place and the process open to public scrutiny."
"There is a deficiency in public awareness and education with regard to the technology and its effects, that needs to be addressed. The whole population has the right to be informed."
The New Zealand panel's conclusions are instructive - the public must be able to scrutinise the use of gene technology if it is to accept it. Further, consumers must be provided with sufficient information to effectively scrutinise the use of the technology, and to be able to make informed choices in the foods they purchase. There is currently a very large information gap between the public on the one hand and the developers and marketers of products derived from gene technology on the other. While regulation should prescribe the safety and appropriate labelling requirements for GMOs, manufacturers and marketers of these products do have a responsibility and interest in providing all relevant information to the public to enable consumers to make informed choices.
There are now a range of New Zealand bodies supplying information to the public on gene technology e.g. the Royal Society, the Gene Technology Information Trust, government departments and regulatory agencies, non-governmental organisations, research institutes, schools and universities. The combined efforts of these bodies should provide appropriate vehicles for disseminating information to all interested groups.
A recent international example points another way forward in the marketing of genetically modified foods and the role that industry can play in the consumer information process. In 1996, two of Britain’s leading food retail chains successfully marketed Britain's first genetically modified food - a puree produced from genetically modified tomatoes - by implementing a code of practice for how they would market GMFs. They informed the public on why the genetic modification was made, how the safety of the food was assessed, what the benefits were to consumers, and sold the identified genetically modified puree alongside its unmodified counterpart.
This example highlights that trade in the products of gene technology is not just about prescriptive regulatory controls. It also calls for effective risk communication between all interested groups. Indeed, risk communication is now recognised as an integral part of the science of risk analysis and the responsibility for communication is a shared responsibility between regulators, producers, marketers and public interest groups. A risk communication strategy for products of gene technology, for instance, needs to explain the basis of national or international regulation, taking into account:
- the international regulatory environment;
- the domestic regulatory environment; and
- public perceptions and concerns.
Such an integrated process is going to be important if we are to derive maximum benefit from agricultural gene technology.
Safety Evaluation
Safety evaluation is the most important regulatory requirement. If New Zealand is to promote and maintain consumer confidence we need to ensure that we have a sound process for evaluation of the safety of these products to people and the environment. The authors believe that New Zealand is well on its way to having an operational system for safety evaluation. Before any GMO can be introduced into New Zealand, it will have to undergo a safety evaluation by the newly established ERMA. If their safety evaluation has cleared the product, then it is clearly able to be imported into New Zealand, subject only to any quarantine or other phytosanitary requirements that MAF Regulatory Authority might stipulate.
The equivalent role for regulation of foods derived from gene technology falls on ANZFA.
II.Labelling Issues
There is broad agreement internationally that labelling of GMFs should be mandatorywhere:
- they are no longer substantially equivalent to their unmodified counterparts (e.g. a new variety of broccoli that has a higher level of a particular vitamin, or an oil that has less saturated fat);
- a specific health concern exists (e.g. the GMF contains a protein that may be allergenic to some).
These requirements prevent deceptive trade practices and alert consumers to any possible risks to which they would otherwise be unaware. We believe these are the critical regulatory requirements. They are consistent with the criteria by which Codex standards are commonly formulated and should be justifiable in terms of the SPS and TBT Agreements.
There have been calls in many countries, including New Zealand, for mandatory labelling of foods produced using gene technology to address ethical, environmental or cultural concerns, and to ensure consumers can have an informed choice in the foods they purchase. This requires careful consideration. As illustrated by the British example, labelling is but one component of what is required to offer consumers a truly informed choice. The issue here is not whether or not the consumer has a need or right to know but how this need is met and whether any regulatory controls that may be proposed are realistic in their application.
CONCLUSIONS
The various international agreements cited in this paper place strong emphasis on science and risk assessment as fundamental cornerstones of national measures relating to products of gene technology. As a signatory to the WTO SPS and TBT Agreements, New Zealand has a clear obligation to ensure that domestic regulatory measures affecting trade in these products are scientifically justified and based on an assessment of risk and do not constitute a disguised barrier to trade.
It is very important to ensure that we have a regulatory regime relating to biotechnology that enables us to capture the benefits of modern technology while ensuring the protection of the consumer and the environment. To achieve this, it is not sufficient to have a sound regulatory framework. We also need to generate public confidence through an effective risk communication process.
International regulation in this area is at a very early stage. New Zealand has a real opportunity to develop a regulatory regime that is strongly based on science and safety evaluation while addressing the issues of labelling and consumer information in a way that meets the needs of our society. The emphasis on safety, coupled with an open transparent process for exchange of information, are essential requirements when it comes to regulation of new technologies such as gene technology and food irradiation. A sound national framework could also offer us the best opportunity to influence thedirection and content of international standards and agreements currently being negotiated.
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