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SUBMISSION TO THE ROYAL COMMISSION ON GENETIC MODIFICATION

Ministry of Agriculture and Forestry

November 2000

1- Executive Summary

MAF's regulatory roles

  1. The Ministry of Agriculture and Forestry (MAF) was created in 1998 by merging the Ministry of Agriculture with the Ministry of Forestry. MAF exists to create opportunity for, and manage risk to, New Zealand and the food, fibre, forestry and associated industries. This encompasses economic, social and environmental goals. For example, MAF aims to improve the profitability of land-based industries, maintain vibrant rural communities, and protect New Zealand from unwanted pests. MAF's key roles are:
  • to provide policy advice on the trading environment, sustainable resources use and the regulation of product safety, biosecurity and related matters;
  • to administer the regulation of product safety, biosecurity and related matters; and
  • to provide services where government needs to be the provider.
  1. MAF has statutory responsibilities for:
  • preventing unauthorised organisms (including GM organisms) from entering the country, whether they are being imported or they are associated with other imported goods;
  • preventing non-living material that could pose a risk to animals or plants in New Zealand (e.g. stockfeeds) from entering the country (if there is a human health concern then the New Zealand Customs Service stops the product at the border and waits for advice on further action from the Ministry of
  • enforcing any controls set for the importation, development or field-testing of organisms (including GM organisms) in containment, and standards for containment facilities;
  • certifying that agriculture and forestry exports have met certain standards;
  • ensuring domestic food safety for animal products and dairy;
  • regulating agricultural chemicals and stockfeeds; and
  • overseeing animal welfare including codes of ethical conduct for research involving animals.

MAF is the New Zealand contact point for the Codex Alimentarius Commission, which sets international food standards to protect consumer health and ensure fair trade practices, and the World Trade Organisation's Committee on Sanitary and Phytosanitary

  1. It is critical for primary producers that consumers have confidence in the safety of their products. Confidence in the integrity and reputation of New Zealand's regulatory processes underpin our access to many overseas markets. It is also important to protect health and safety for the living and working environments of people in those sectors.
  2. It is impossible to have a perfect understanding of every situation and the amount of variation that exists. Like all other technologies, it is almost certain that genetic modification will have unforeseeable social, environmental or economic impacts. Current regulatory systems provide mechanisms for weighing up the risks and benefits of new technologies. In its regulatory activities, MAF uses risk management within limits set by the government, rather than attempting to eliminate all risks. MAF is careful to recommend actions that are known to deal with expected variations and confidently reduce risks to at least the levels desired.
  1. This submission distinguishes between genetically modified (GM) organisms and genetically modified (GM) products because they are treated differently by legislation.
  • GM organisms are organisms produced by genetic modification, e.g. GM soybeans.
  • GM products include every medicinal, commercial, chemical, and food product that (while not itself capable of replicating genetic material) is derived from, or is likely to be derived from, genetic modification. Both flour and oil from GM soybeans are GM products, but the oil usually contains no modified DNA or novel proteins because they are removed during processing.

Context

  1. Agriculture, horticulture and forestry are vitally important to New Zealand's economy, society and environment. They account for about 15 percent of New Zealand's gross domestic product, employ roughly 13 percent of the total labour force, and make up around 63 percent of the value of all merchandise exports. Assets in these industries represent the second-largest group of Maori-owned assets, and they make a large contribution to the economic, social and cultural welfare of Maori. The competitiveness of our land-based industries affects the whole economy, and since almost 60 percent of New Zealand's land area is occupied by farm land or plantation forest, they also have an important impact on the environment.
  1. Gene technology is being rapidly developed and implemented in agriculture, horticulture and forestry around the world. There are large quantities of commercial GM crops grown in the USA, Argentina and Canada, with smaller quantities grown in several other countries. Development of second and third generation GM crops, offering benefits to consumers or new traits not seen before in primary production, has already begun.
  2. Currently, all commercial agriculture, horticulture and forestry in New Zealand is non-GM but genetic modification is an important research tool for understanding how plants, trees and animals grow. Since 1988 there have been over 50 approvals for field trials of GM organisms including GM crops, trees and animals. There have been no applications or approvals to release any GM organisms into the environment in New Zealand.

Issues

  1. There are some issues and gaps in the existing regulatory system, including:
  • the legislation covering new organisms does not recognise the capacity for post-release controls under legislation administered by MAF;
  • ethical approvals are not required for research on animal foetuses less than halfway through term; and
  • stockfeeds that are GM products may not require safety assessments because there is no risk factor specific to genetic modification that would trigger the requirements.
  1. New Zealand enjoys one of the highest levels of biosecurity protection available anywhere in the world, but it is not perfect. Some factors will be beyond New Zealand's control. While it is illegal to import unapproved GM organisms into the country, border control alone could not prevent accidental or deliberate introductions of GM organisms. The experience with rabbit calicivirus highlighted the difficulty of preventing a deliberate introduction of an organism.
  2. Genetic modification, like other breeding processes, may have environmental risks and benefits and many of the concerns raised about GM plants also apply to other technologies. For example, herbicide resistant crops have been produced using conventional breeding. These risks and benefits are considered when assessing whether or not to release GM organisms into New Zealand. Since 1992, MAF has been involved in research into biological control of possums that includes the possibility of using genetic modification.
  3. The decision-making processes for genetic modification in New Zealand will have to balance conflicting ethical views and perceptions of risk. In the absence of a clear consensus for these issues, it will be difficult to know how to balance them against scientific evidence while at the same time maintaining consistency.
  4. New Zealand's primary industries rely on access to overseas markets. Access depends on operating within the trading framework provided by multilateral and bilateral commitments of New Zealand and its trading partners. New Zealand gains significant benefits from these trade commitments, particularly those that require risk assessments to be scientific and barriers to be the least trade restrictive possible. New Zealand's regulatory processes are highly regarded and play an important role in our trading relationships. New Zealand's regulatory regime for genetic modification may have implications for our trading relationships.
  5. Around 90 percent of New Zealand's agricultural produce and 70 percent of forestry production is exported so external consumer demands and regulatory requirements will play a major role in the profitability of these sectors. There are likely to be opportunities in both GM and non-GM markets. New Zealand could be seriously disadvantaged if its producers were locked out of a technology (GM or non-GM) that provided significant opportunities in the future.
  6. It will be critical to examine the extent to which GM and non-GM production can coexist in New Zealand. This will depend, to a large extent, on consumer confidence in the integrity of non-GM supplies and the separation of products. Pollination of non-GM crops by GM crops would not be an issue for crops of different species (e.g. GM corn and non-GM apples). For crops of the same species, different production and processing systems already coexist in New Zealand, particularly for market access to countries with different requirements. Buffer zones or separation could minimise cross-pollination, and a number of emerging technologies could potentially help to biologically isolate particular crops. A zero tolerance for unavoidable mixing would make it very difficult for both systems to coexist.

Conclusion

  1. MAF believes that it is important that the agriculture, horticulture and forestry sectors have access to the latest technology in order to remain internationally competitive. Gene technology is being rapidly developed and implemented around the world, and presents opportunities and risks that will need to be evaluated on a case-by-case basis. Those who could benefit from its application should have the choice to use it where it does not adversely affect others.
  2. New Zealand's isolation and border control activities ensure one of the world's highest levels of biosecurity protection, but the border is not impenetrable. While it is illegal to import unapproved GM organisms into the country, border control alone could not prevent accidental or deliberate introductions of GM organisms. MAF could take actions under the Biosecurity Act to manage any GM organisms that were declared to be `unwanted organisms'.

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Contact for Enquiries

Dr Sharon Adamson
Manager, Innovation Policy
Ministry of Agriculture and Forestry
PO Box 2526
Wellington
NEW ZEALAND

Phone: +64 4 894 0618
Fax: +64 4 4 894 0741
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