Wellington, 20 March 2000 / Lu/rs/clark203.doc
Transmitted by Fax to No. 04 - 4733579
Right Honourable Prime Minister
Ms Helen Clark
Parliament
Wellington
Kindly transmit urgently, since this matter concerns the present Cabinet
debate.
Royal Commission on Genetic Engineering; Moratorium on field trials
Dear Prime Minister,
Time is short. Therefore let me make this brief since you are right now in
a cabinet meeting, reportedly deliberating on a moratorium on Genetic
Engineering.
As independent scientists we have been actively involved in the promotion
of reliable GE knowledge, organising large public forum debates, etc..
Earlier this year we have sent a proposal for Criteria for the selection of
members for a Royal Commission on Genetic Engineering to the ministers
Marian Hobbs, Annette King and Sandra Lee (copy attached).
Regarding the possible variations of a moratorium we see it as our
scientific and moral duty to recommend a full-scale moratorium on any field
trials of genetically engineered organisms, plants and animals during the
time of the Royal Commission on Genetic Engineering.
In the course of our involvement with all GE issues we have come to
understand that
ˇ Safe containment of GE field trials is impossible.
ˇ GE organisms can lead to contamination and the creation of new organisms
with unknown and thus potentially dangerous properties.
ˇ Any unwanted (accidental) dispersion of genetically engineered organisms
in the environment cannot be "called back". The effects will be irreversible.
ˇ The real dangers of GEd organisms cannot be offset by potential
"benefits" of research outcomes. Such comparisons are scientifically flawed
and inadmissible. Similarly the non-scientific argument of "lagging behind
if a moratorium is installed" is unacceptable in a decision that may have
irreversible consequences for our environment.
ˇ In case of doubt the precautionary principle (Better Safe Than Sorry) has
to prevail and guide the decisions to be taken.
We thank you four your kind attention and look forward to the government's
announcements on the Royal Commission and a Moratorium.
With kind regards,
[signature]
Helmut E. Lubbers, trustee
ecology discovery foundation
new zealand (charitable trust)
Enclosures: "Criteria for the selection of members for a
Royal Commission on Genetic Engineering."
Criteria for the selection of members for a
Royal Commission on Genetic Engineering.
The public interest will be served best if the members of the Royal
Commission on Genetic Engineering are selected according to fair and
independent principles.
Committee members that are hand-picked in line with
the ideology of the government-of-the-day will deliver a biased outcome and
have difficulty finding the acceptance of the population.
The following is a set of criteria for committee members and the work of
the R.C. on GE that will contribute to a good process and a scientifically
and socially correct outcome.
Committee Members' Credentials
1. Members should:
1.1 be chosen from a range of socio-economic backgrounds, not just from
traditional organisations or industry groups,
1.2 have the intelligence and clarity of mind to understand complicated
issues, but not necessarily be a scientist, a geneticist or biologist,
1.3 have independent "third party" perspective and overview,
1.4 possess scientific and moral integrity and honesty (until recently at
least one IBAC scientist maintained publicly that GE is the same as
conventional breeding; a statement that serious scientists would not dare
to make),
1.5 be prepared to question all assumptions and axioms that underlie
wide-spread socio-economic and sociological paradigms,
1.6 be able to apply methodological and analytical rigour,
1.7 not have a 'superiority' attitude which can easily lead to ignoring
and/or discrediting arguments put forward by people who do not belong to
that specific élite group (of scientists, socio-economic class, old boys
network),
1.8 have no vested interests.
Evaluative guidelines
2. Time frame and moratorium:
2.1 the commission must be allowed sufficient time to reach a
scientifically correct conclusion,
2.2 a moratorium on field testing of any genetically modified organisms
(microorganisms, mammals, birds, plants, trees, fish) must be adopted until
such time that the Royal Commission reaches a conclusion,
2.3 a moratorium is required because of the precautionary principle: there
are sufficient scientific doubts and studies on irreversible worst-case
scenarios,
2.4 in the common interest of preserving a GE-free environment as long as
we are not absolutely convinced of the safety of genetically engineered
organisms for the web of life and for our foods we must resist pressures
from industry and avoid undue haste.
3. Accessibility:
- All meetings and reports must be open and fully accessible to all members
of the public.
4. Liability: awareness of
4.1 the limits of "liability"; even the best insurance cannot undo
possible irreversible harm to nature and/or society,
4.2 the limitations of liability towards organic farming and horticulture;
GE contamination can possibly not be undone and thereby ruin organic farmers.
5. Public opinion:
5.1 The issue is not alleviating public worries, as GE proponents and the
media frequently suggest, but the scientific assessment of risks,
dangers/safety and real benefits,
5.2 Panel discussions, Delphi, Talking Technology "methods" are not
acceptable as fact finding methods for assessing the danger or safety of GE.
6. Analytical rigour:
6.1 Critical and rational analysis of socio-economic benefits and
advantages that are claimed by GE proponents,
6.2 Distinguish between socio-economic and ecological-scientific arguments,
6.3 Distinguish between "potential" outcomes (expectations, hope, trust,
etc.) and scientific certainties (present state of the GE technology); i.e.
potential versus reality,
6.4 Distinguish between (potential, hopes) benefits in one area (medicine,
health) and the thrust of present applications in another field
(agriculture and fisheries),
6.5 Distinguish between generally accepted, current definitions and
"re-definitions"
Examples of re-definitions:
6.5.1 Normal: Genetically engineered; redefined: genetically modified,
genetically enhanced,
6.5.2 Normal: "Organic", as defined by the organic farming associations,
redefined: "organics compatible with genetically engineered agriculture"
(by non-organic representatives),
6.5.3 "Sustainable growth" (an oxymoron, no growth can continue for a very
long time) made palatable by including a condition in the definition (such
as "growth that does not consume more resources"),
6.6 Awareness of assumptions that may underlie superficially obvious
opinions,
6.7 Awareness of the socio-economic and religious framework and bias of
people,
6.8 Awareness of the questionable credibility of some sources of
information, such as FDA, think tanks, other regulatory authorities and
("independent") specialists, with a critical analysis of the validity of
their assertions on scientific examination and approval procedures before
these are used as evidence,
6.9 Attribute sufficient attention to other means of attaining the same or
better socio-economic outcomes as claimed by GE proponents, such as organic
agriculture, preventative health care,
6.10 Awareness of subconscious evaluative linguistic distortions that bias
opinion forming by words such as a "long" time, "already", "old" vs. "new",
"even", and other evaluative words,
6.11 Awareness of terminological bias, such as "genetically modified" or
"genetically enhanced" versus "genetically engineered",
6.12 Awareness of bias in the opinions and assessments by industry,
research and authorities,
6.13 Avoid undue simplifications, but simplify the root cause wherever
possible.
7. Sustainability:
7.1 GE biotech as a part of the whole socio-economic development picture
(framework),
7.2 GE biotech as a part of "sustainable development",
7.3 Acknowledge the precautionary principle (in case of risk, assume the
worst outcome will happen and do not take the risk if the worst outcome is
irreversible),
7.4 Risk - The correct understanding and application of the concepts,
theory and practice of risk. (The minimisation of risk should be the aim,
not "risk management". "Risk management" includes making non-explicit value
judgements about trade-offs between risks and benefits.)
8. Partisan interests:
8.1 awareness of (undue, undemocratic) interests and influence of other
countries, international organisations (possibly dominated by single
countries) and/or (international) corporations or their individual
representatives,
8.2 awareness of intimidation and scare-mongering pressures by countries,
organisations,
8.3 awareness of possible group pressure within the R.C.,
8.4 avoidance of compromises that contradict and conflict with scientific
rigour.
ecology discovery foundation
new zealand (charitable trust)
4 February 2000 Lu/rs
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