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Science, Ethics and Action in the Public Interest
Food Fights: Canadian regulators are under pressure to face the uncertainties of genetically modified food.
By Katherine Barrett
Reprinted courtesy of Alternatives Journal: Environmental Thought, policy and Action
Vol. 28 No1, Winter 2002.
In the fall of 2000, US newspapers reported that genetically modified (GM) corn not approved for human consumption had been found in taco shells, corn chips and other corn products  The corn, called "Starlink", was engineered with a toxin from bacteria that allows the plant to withstand attacks by insect pests. The US Environmental Protection Agency (EPA) had previously assessed Starlink for its potential to cause allergic reactions. They concluded that the GM protein involved was "tougher" than similar proteins already in the human food chain, that it did not readily break down in the gut, and therefore that it may pose a greater risk of allergic response. Consequently, US government regulators approved Starlink for animal feed but not for human use, a so-called "split" approval .
Despite this regulatory restriction, Starlink corn found its way to grocery store shelves and restaurant tables. Dozens of people reported allergic or other adverse reactions. Distributors began recalling over 300 corn products, but the enormous difficulty of extracting Starlink from seed stocks, grain elevators, shipping routes, food processing plants and supermarkets soon became apparent.
The amount of Starlink corn in Canada's food supply is not known. In March 2001, Agriculture Minister Lyle Vanclief admitted that although Starlink has not been approved in Canada "some of it did get into the animal feed system" and there was a "slim chance" it had entered the human food chain .
The Starlink case is a wake-up call for those who believe the risks of GM food can be easily predicted and controlled. The complexity of tracing and testing Starlink corn highlights key questions in the ongoing debate over GM food: does genetic modification pose increased risks of toxic and allergic reactions? Are particular populations, such as children, more susceptible? What are the potential environmental effects of GM organisms? How can we test for potential harms, and what standards should be used to determine adequate safety?
As the world's third largest producer of GM crops, Canada has huge stakes in the answers to such questions. Serious doubts about the adequacy of our current approach to food biotechnology regulation have been raised, most notably in the recent report of an independent expert panel of the Royal Society of Canada . Until these doubts are addressed, Canada is unlikely to build confidence in the safety of GM foods, or our ability to identify, test and prevent potentially negative health and environmental effects from food biotechnology.
Promotion Without Precaution
The rapid expansion of Canadian agricultural biotechnology is due in large part to the concerted efforts of industry and the federal government over the past 20 years. The first National Biotechnology Strategy, launched in 1983, aimed to provide program and policy support to encourage the commercial growth of biotechnology. Financial incentives for business and funding initiatives for research fostered a globally competitive biotechnology sector in Canada. In 1998, this strategy was renewed and renamed the Canadian Biotechnology Strategy.
Whereas strategies for promoting biotechnology were devised in 1983, procedures for evaluating associated health and environmental hazards were not established until the early 1990s. The first regulatory framework, announced in 1993, set ground rules for the "science-based" assessment of GM organisms. Rather than create new legislation specific to GM organisms, policies would build on laws already in place for conventional agricultural practices. This reflects a broader philosophy of the federal government "that genetically engineered organisms are not fundamentally different from traditionally derived organisms and can be assessed using well-defined and understood principles of risk assessment"  The federal regulatory framework appears in stark contrast to justifications for government promotion and investment that stress the innovative character of genetic modification techniques.
Reluctance to acknowledge that the process of genetic engineering may pose unique health and environmental hazards is, however, increasingly out of touch with world wide movements - from local organic food markets to international environmental agreements – that recognize the novel character and potential hazards of GM organisms. In current controversies, "genetic modification" usually refers to recombinant DNA techniques that are used to isolate one or more genes from a donor organism and transfer these genes into an unrelated organism. The recent Cartagena Protocol on Biosafety recognizes the distinctive qualities of GM organisms and establishes special rules for international trade in such organisms. This protocol clearly distinguishes the methods of traditional breeding from those that overcome natural reproductive barriers to create organisms with novel combinations of genetic material.7 Similarly, the Codex Alimentarius Commission, a UN body charged with establishing food safety standards, recognizes that products of recombinant DNA technology warrant specific regulatory oversight.
Public protests have also focused on the distinctive character and potential risks of GM foods and have resulted in wildly unstable markets. Canadian canola exports plummeted in the mid 1990s as many overseas buyers refused to import GM crops. The Canadian Wheat Board, a coalition of producers, currently opposes the commercialization of transgenic wheat until markets can be assured and processes for segregating GM and non-GM varieties are in place . Large manufacturers such as McCain Foods have recently adopted a no-GM policy . Recent polls and focus groups indicate that a majority of North Americans favour mandatory labelling of GM foods, and that many would use these labels to avoid consuming GM products . These stories of public scepticism and producer hesitancy - bolstered by the recent Starlink fiasco - are further supported by an increasing number of scientific reports that suggest organisms developed through recombinant DNA technology pose uncertain benefits and uncertain risks .
The above examples clearly demonstrate that the scientific, economic, political and cultural dimensions of the GM debate are closely tied. All point to the distinctive character of GM technology, and to the need for cautious and comprehensive regulations. But how cautious is cautious enough?
The Expert Panel's Report
The precautionary principle states that when a technology or activity threatens public health or the environment, measures to avoid adverse effects are warranted, even if there remains scientific uncertainty about the nature and extent of harm that may occur. In other words, the principle advises us to err on the side of caution when we are unsure if our actions will result in harm. Precaution, however, does not equal inaction. The term precautionary principle is translated from the German vorsorgeprinzip, a concept of environmental policy that means foresight, and emphasizes forward planning to anticipate and prevent harm before it occurs.
Although it has been incorporated into numerous international agreements as well as the national policies of several countries (including Canada), serious application of the precautionary principle remains a contentious idea. In negotiations leading to the adoption of the Cartagena Protocol, Canada and other major producers of GM crops lobbied against inclusion of the precautionary principle . In fact, the Canadian government has argued that current regulations are sufficiently sound and are "based on the latest and best scientific knowledge we have" .
Public resistance and wavering markets have prompted the Canadian government to test these assertions through more independent means. In January 2000, Health Canada, the Canadian Food Inspection Agency and Environment Canada commissioned an expert panel of the Royal Society of Canada to examine the scientific and regulatory capacity of federal agencies to ensure the safety of GM food.
The final report, entitled Elements of Precaution was released in January 2001, and is the first comprehensive review of food biotechnology in Canada by an independent, (i.e., non-government, non-industry) committee. The report focuses on the scientific aspects of GM food, examining the current state of knowledge and questioning our ability to predict GM risks. How, for example, can we test new GM foods for potential toxic or allergenic effects? What do we know about the environmental and health impacts of transgenic fish? How can we predict if a GM crop will become a invasive weed?
Based on this review, Elements of Precaution makes over 50 recommendations, many of which may have dismayed the federal agencies that commissioned the study. The report clearly demonstrates that GM foods pose potential health and environmental risks, and that our scientific knowledge about them remains incomplete and uncertain. Overall, the report advises that Canada adopt a more transparent and precautionary regulatory process for approving GM food.
What would a precautionary regulatory system for GM foods look like? How different would it be, in process and outcomes, from the current approval system in Canada? In the following section, I draw on the detailed scientific findings of the Royal Society report and suggest a framework for applying the precautionary principle to GM food .
Precaution In Practice
World wide protests over globalization and related issues are showing how citizens' views will eventually be heard - if not quietly through stakeholder consultations, then loudly and clearly through rapid exchange of information, persistent demands and direct actions. The Canadian government and other proponents of biotechnology would do well to listen, learn and respond.
Katherine Barrett has a PhD in botany from the University of British Columbia, and is currently project director with the Science and Environmental Health Network, and a research associate with the Polis Project on Ecological Governance at the University of Victoria.
 See "Firm looks for bushels of unapproved grain", Washington Post (October 19, 2000), p. A1; "Biotech critics cite unapproved corn in taco shells", Washington Post (September 18, 2000), p. A2.
 For an overview of the Starlink case see: Final Report, FIFRA, Scientific Advisory Panel Meeting; and W. Lin, G.K. Price, E. Allen, Starlink: Impacts on the US Corn Market and World Trade (2001)
 Reuters, Canada says banned GM corn fed to animals" March 17, 2001
 Royal Society of Canada, Elements of Precaution. Recommendations for the Regulation of Food Biotechnology in Canada" 2001
 Statistics from: C. James,. "Global Status of Commercialized Transgenic Crops in 2000," ISAAA, Briefs, 21 (2000). For a complete list of GM crops approved for release into the environment see "Status of Regulated Plants with Novel Traits in Canada"; For list of product in field testing see Detailed table for 2000 confined field trials
 Canadian Food Inspection Agency, Concerns and Issues about Biotechnology" (2001).
 The Cartagena Protocol on Biosafety uses the term "living modified organisms" rather than "genetically modified organisms".
 Canadian Wheat Board, "CWB Biotechnology Statement" (2001)
[9 ] McCain Food Limited, Frequently Asked Questions" (2001)
 For examples see US FDA, Report on Consumer Focus Groups on Biotechnology" (2000); <a href="http://http://strategis.ic.gc.ca/SSG/bh00258e.html">Public Opinion Research into Biotechnology Issues, Second Wave
 For example see L.L. Wolfenbarger, P.R. Phifer, "The Ecological Risks and Benefits of Genetically Engineered Plants", Science, 290 (2000), pp. 2088-93; J.J. Obrycki, et al., "Beyond Insecticidal Toxicity to Ecological Complexity", BioScience, 51:5 (2001), pp. 353-61; The EU-US Consultative Forum, Final Report (2000).
 United Nations Environment Program, Draft Report of Extraordinary Meeting of the COP for the Adoption of the Protocol on Biosafety to the CBD" (1999).
 L. Vanclief, "Food Safety Will Not be Compromised", London Free Press (June 25, 1999)
 For more information on the precautionary principle see C. Raffensperger and J. Ticker, "Protecting Public Health and the Environment: Implementing the Precautionary Principle", Washington DC, Island Press, 1999
 J. Tickner, "A Map Toward Precautionary Decision-Making", in Raffensperger and Ticker, ibid, pp162-86
 Agriculture and Agri-Food Canada, Centre Set to Bolster Canada's Organic Expertise", July12, 2001 press release; see also Agriculture and Agri-Food Canada, "Vanclief Announces Funding to Help Organic Growers Seize New Market Opportunities", June 8, 2001 press release.
 Elements of Precaution, note 4, p,95
 Final Report, note 2
 Elements of Precaution, note 4, p.59; and Final Report, note 2.
 Elements of Precaution, note 4, pp.164-65.
Reprinted courtesy of Alternatives Journal: Environmental Thought, policy and Action.
Vol. 28 No1, Winter 2002.
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