http://www.sierraclub.org/policy/conservation/biotech.asp
Sierra Club Conservation Policies
Biotechnology
The following policies on Biotechnology have been adopted by the Sierra Club
Board of Directors:
GENETIC ENGINEERING is a new technology which, unlike traditional breeding
methods, allows the transfer of genetic material from one organism into a
host organism of an unrelated species, thus bypassing the natural
reproductive barriers between species. The genetic manipulation resulting
from genes inserted by genetic engineering cannot be recalled; the altered
characteristics will be passed on to future generations and continue to be
reproduced in the environment.
Genetic engineering became possible with the advent of recombinant DNA
technology, which for the first time allowed for the transfer, using
laboratory procedures, of DNA from one species into the DNA of an unrelated
species. For purposes of this policy, however, we define genetic engineering
to include all direct molecular manipulation of the genetic structure of
organisms or viruses, including additions of foreign genes (transgenes),
gene alterations, duplications, or deletions.
Genetic engineering is not, as many of its supporters claim, merely a more
efficient form of traditional plant and animal breeding. There is a clear
boundary between traditional breeding methods and the radically new
technology of genetic engineering.
A GENETICALLY ENGINEERED ORGANISM (GEO) is a single-celled or multicellular
organism, the genetic structure of which has been altered by genetic
engineering, resulting in genetic changes that could not be achieved using
conventional breeding methods. (The terms "GEO," "genetically modified
organism" and "genetically altered organism" all have the same meaning.)
The accidental outflow of transgenes or altered genes from a genetically
engineered organism to a natural organism, by pollen transfer or by other
means, results in the production of an organism which, although it has not
intentionally been genetically engineered, must be classified as a
genetically engineered organism.
GENERAL STATEMENTS OF PRINCIPLE (further expanded in the guidelines, to
follow)
The Sierra Club urges full public disclosure, discussion and evaluation of
the potential hazards, the potential benefits, and policy options for
genetic engineering research and the development and use of products from
that research. We urge the development of adequate regulatory, legislative,
and other controls and that these decisions be based on a reverence for
nature and life, as well as socioeconomic equity.
We call for acting in accordance with the Precautionary Principle, meaning
that when an activity raises the possibility of serious or irreversible harm
to the environment or living creatures, precautionary measures that prevent
the possibility of harm shall be taken even if the causal line between the
activity and the possible harm has not been proven.
In accordance with this Precautionary Principle, we call for a moratorium on
the planting of all genetically engineered crops and the release of all GEOs
into the environment, including those now approved. Releases should be
delayed until extensive, rigorous research is done which determines the
long-term environmental and health impacts of each GEO and there is public
debate to ascertain the need for the use of each GEO intended for release
into the environment.
We urge that where there are safer alternatives to the use of GEOs, these
technologies should be given preference. For example, genetic engineering
solutions should never be used to divert attention from the solutions to the
problem of hunger that carry less biological risk (e.g., better distribution
of food, land reform, sustainable soil conservation strategies, promotion of
regional sustainability, reduced consumption of animal products, and
stabilization of population).
GUIDELINES
(1) TESTING OF GEOs. There are health and environmental risks inherent in
the release of GEOs during field testing and/or commercial planting.
Government agencies must develop and enforce policies that require stepwise
testing, with strict controls to prevent accidental and premature releases.
The stepwise testing must include (as appropriate) contained testing in the
laboratory and greenhouse. The results of each step must be made publicly
available when tests are subject to approval processes. No field testing
should be done until all guidelines in this policy are met.
(2) REGULATION OF GEO RELEASES. Regulation of releases of genetically
engineered organisms should ensure that potentially hazardous organisms are
not released into the environment without sufficient safeguards and
monitoring. Final evaluation should be made on the basis of the effects of
genetic modifications, taking into account other factors, particularly the
site where the organism will be released. Long-term as well as short-term
impacts of GEOs must be evaluated, and a finding of environmental safety
made before a release is approved. At a minimum, the evaluation must assess:
(a) the genetically engineered organism's role in the ecosystem (including
its food and nutrients, its predators, parasites, and competitors, organisms
with which it can exchange genetic material, and environmental limits to its
growth);
(b) the impact of its release and potential use on ecosystems and genetic
diversity;
(c) the effects of its potential use on sustainable agriculture, resource
use, and cultural systems;
(d) the impacts of the organism and its products on human health; and
(e) the impacts of marker genes as well as genes of interest to producers.
(Antibiotic resistance marker genes should not be used in GEOs released into
the environment.)
All impacts from production to disposal should be assessed, as well as all
paths of potential migration, and the scale of the release. Deleterious
impacts on workers or on those living near production or release sites
should also be considered. An emergency response plan must be in place in
case of unforeseen outcomes.
If any government, organization or individual wishes to release, for any
purpose, genetically engineered organisms into the environment of a foreign
country, they should abide by the standards of the releasing party's home
country as well as those of the host country. In the case of conflicting
national standards, the standard more protective of the environment and
human health should prevail.
Public agencies providing biosafety oversight must notify the public of
proposed releases and provide a reasonable and timely opportunity for the
public to comment on proposed releases. Notification should include, but not
be limited to, the location of release sites. Public comment should be
encouraged and receive response. Agencies should ensure public access to all
information necessary to evaluate potential hazards even when such needed
information otherwise qualifies as confidential business information. In
addition, companies and institutions should not be permitted to withhold
scientific testing data as trade secrets.
The Sierra Club supports the establishment of a repository for information
on GEOs that have been approved for release. Such information must be
available to the public.
(3) MONITORING OF GEOs. Both deliberate and unintentional releases of
genetically engineered organisms should be monitored through coordinated
efforts of agencies, companies, and academic institutions in order to test
predictions about the organisms' behavior, numbers, dispersal and
environmental impact. The public should be involved in the design of these
monitoring programs. Data from such programs must be made available to the
public and widely distributed and publicized.
(4) LABELING AND SUBSTANTIAL EQUIVALENCE. Foods produced from or containing
GEOs may contain new substances or have purposeful or inadvertent
compositional changes. All foods containing or produced with genetically
engineered material must be labeled as such. The federal government should
carefully regulate food produced from or containing genetically engineered
organisms to ensure safety. The use of the concept of "substantial
equivalence" in order to waive the need for both pre- and post-marketing
testing and surveillance should be prohibited.
(5) LIABILITY. Liability issues must be addressed and resolved prior to the
release of every GEO. Manufacturers of GEOs should be fully liable for any
environmental damage caused by the organisms they genetically engineer. The
burden of proof of safety must be on the manufacturing company. At a
minimum, these companies must be fully insured and able to reimburse:
(a) farmers whose crops are less saleable because of genetic contamination
from GEOs;
(b) farmers using nonviable genetically engineered seeds; and
(c) for any human or animal suffering health dysfunction resulting from
consumption of products that contain GEOs, where the conventional
counterpart did not cause such health dysfunction.
(6) CONFLICT OF INTEREST. Regulations should require that there be full
public disclosure when there is potential conflict of interest with
individuals: (1) serving on biosafety committees; (2) working for or
advising government regulatory or research agencies involved in genetic
engineering research or regulatory oversight.
(7) REGULATION OF GEOs/TRADE RULES WITHIN THE USA. We support the right of
states and localities to adopt regulations for genetically engineered
organisms more stringent than federal regulations. We support efforts to
ensure communication and, where appropriate, to coordinate oversight among
federal, state, and local agencies. Federal and international trade policies
and rules must not interfere with the right of states and localities to
adopt more stringent measures.
(8) REGULATION OF GEOs / INTERNATIONAL TRADE RULES. All nations should
develop and enforce regulations governing experimental release and
commercialization of genetically engineered organisms. We oppose any release
or agricultural/industrial commercialization of GEOs until appropriate
procedures are in place to protect human health, biodiversity, and cultural
systems. Trade rules must not be used to override the right of each country
to establish regulations based on its own level of risk and based on
precautionary action in the absence of scientific certainty.
GEOs may have transboundary impacts. They also may move in international
trade. To address these international aspects, governments must complete and
ratify the Convention on Biological Diversity negotiations and complete a
biosafety protocol establishing adequate minimum standards for regulation of
the risk of GEOs, in particular introductions through trade and possible
transboundary effects. At a minimum, a biosafety protocol must:
(a) provide for assistance to developing countries to help them build
regulatory capacity;
(b) support the implementation of the Precautionary Principle; and
(c) not be subordinated to trade rules.
Members of multilateral trade institutions such as the WTO must work to
ensure that trade rules recognize and do not interfere with the
implementation of the Precautionary Principle.
(9) INAPPROPRIATE USE OF GEOs. We oppose any development or use of
biological weapons and agents used for agricultural bioterrorism, including
any use of genetic engineering for these purposes.
We oppose the introduction of any GEOs onto public lands or other open
spaces that are protected chiefly for their natural characteristics.
We oppose activities that have the potential to adversely affect the
viability of biodiversity and food security. Genetically engineered seed
meant to enhance monocropping is an example of such an activity. Others
include:
(a) Systems which combine the development of herbicide-tolerant crops with
reliance on the manufacturer's proprietary herbicides to control competing
plant species should not be instituted;
(b) Technologies that encourage corporate control over seeds should not be
employed. Genetic restrictive use technology (commonly known as "terminator
technology") is an example of such corporate control; and
(c) Policies that encourage further consolidation or monopolistic control of
the food production system should be avoided.
(10) PATENTING of GEOs. All humans, animals, plants, and microorganisms are
products of nature.
No individual, institution or corporation should have the ability to claim
ownership over species or varieties of living organisms. We oppose the
granting of patent claims over organs, cells, genes, proteins, and other
living matter whether naturally occurring, genetically engineered, or
otherwise modified. The genetic code of humans, animals, plants and
microorganisms has evolved over hundreds of millions of years and represents
not only our natural world of today but also its past and future. We hold
that respect for this natural treasure demands that no government should
have power to grant patents or property rights over it. Just as civilized
societies have decided that there can be no ownership of human beings
(slaves), we believe that there should be no ownership of genetic code,
which should continue to be the shared common heritage of all.
Indigenous peoples, their knowledge and resources are the primary target for
the commodification of genetic resources. We recognize these peoples'
sovereign rights to self-determination and territorial rights, and support
their efforts to protect themselves, their lands and genetic resources from
commodification and manipulation.
Patents over life forms are not necessary to conduct scientific and
technological research, and, in fact, retard and limit access to benefits
which may result from new information, treatments or products.
(11) BIOPROSPECTING. Our national park system was established to conserve
its scenery, natural and historic objects, and wildlife in such a manner
that will leave them unimpaired for the enjoyment of future generations.
This mandate protects all genetic resources within our national park system
from commodification and manipulation. Accordingly, we oppose any
individual, institution or corporation's ability to claim control and
ownership over this diversity through the act of bioprospecting and/or
through contractual agreements allowing access to such diversity for the
purpose of commercial gain. We respect the rights of all peoples and
governments to similarly designate and restrict exploitation of their own
genetic resources.
Adopted by the Sierra Club Board of Directors, May 21, 2000, replaced the
policy adopted September 18-19, 1993.
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Special Guidelines Concerning Fish and Other Aquatic Life
Sierra Club's Biotechnology Policy, which, among other things, defines
genetic engineering and genetically engineered organisms (GEOs), calls for
the development of adequate regulatory, legislative and other controls,
calls for a reverence for nature, and invokes the Precautionary Principle,
is applicable in its entirety to genetically engineered (GE'd) fish,
shellfish, and all other GE'd aquatic organisms, in freshwater or salt.
The Guidelines relating to agricultural crops are also broadly applicable.
The major issue is very similar: the uncontrolled release of GEOs. Thus, the
points in the Guidelines about testing and regulation, monitoring, labeling,
liability, application of the Precautionary Principle and other topics
mentioned in the Guidelines are equally as important for GE'd fish and
aquatic organisms, except where the language specifically refers to
"farmers," "crops," or "seeds." We embrace the extension of those Guidelines
to all aquatic life, whether the GEOs are intended for food, feed, sport,
environmental management, artistic statement or pet store trade.
(1) We believe that GE'd fish and aquatic organisms are an even greater
hazard to natural stocks and are even more difficult to properly evaluate
and to monitor than GE'd crops, and therefore our primary position is to
oppose releases of transgenic aquatic organisms out of doors, or where there
is any chance of the organisms or their genetic code escaping into the
general environment.
(2) Genetically engineered fish intended for fish farming, whether intended
as human food or for other uses such as mosquito control, feed for other
fish, or pet store trade, can't be adequately contained. Fish in inland
ponds are often swept into steams by storms and can be transported by birds.
Fish constrained by nets (such as nearshore netpens for salmon and offshore
pens for tuna) have a high rate of escape into the wild. The same is true of
other aquatic organisms. Eggs, sperm, larval and planktonic forms of GEOs
present additional problems making containment impracticable in out-of-doors
environments. The possibility that new or altered genes could wreak havoc
with natural ecosystems is therefore great, and this type of genetic
adulteration of nature may be irreversible once it occurs. It may lead to
extinction of species or to the creation of new bioinvasive varieties.
Therefore, we oppose the cultivation of any genetically engineered fish or
other aquatic organisms outside of laboratory confinement (or equivalent
complete confinement during industrial processes).
(3) We are opposed to genetically engineered sport fish, and to "genetic
enhancement" of natural populations.
(4) We are opposed to the production of aquatic GEOs for export, even though
the laws or regulations of the importing country may not prohibit it,
excepting small and rigorously contained shipments intended solely for
research. All exports must be made known to the customs authorities of the
importing country in advance of shipment.
(5) Notwithstanding our strong belief that all releases should be prohibited
at the present time, it is important that good regulatory mechanisms be
established which give government the authority to study and to regulate
production or release of transgenic fish. The Sierra Club's existing
Guidelines apply here.
(6) We are opposed to release of sterile GE'd fish or other aquatic
organisms, much as we are opposed to "Terminator" technology in plant crops,
because (a) it would deprive small fish farmers of the opportunity to breed
their own fish, (b) escaping sterile fish would reduce the breeding
efficiency of wild populations, and (c) it would tend to turn the
traditional property of the poor and disadvantaged into the intellectual
property of the rich and advantaged. We also do not believe that sterility
and reproduction are adequately understood in fish. Prediction is further
impaired by the ability of some fish to change sex during their life cycle.
(7) The concepts in the paragraphs above, where written with regard to fish,
are embraced and extended to include all uses of any transgenic organisms in
aquaculture. Unicellular organisms and plants are included.
(8) Definitions and application. For the purposes of these Guidelines
covering fish and aquatic life, amphibians and other life forms that are
aquatic during part of their life cycle will be considered aquatic. We
recognize that there may be difficulties in deciding whether some organisms
such as brewer's yeast, a Pseudomonas bacterium, or a mosquito is to be
considered aquatic. In such instances, the general principles of precaution,
scientific evaluation of ecological and health risks, and ongoing
surveillance will apply regardless of whether the GEO is aquatic or not. On
a case-by-case basis, some exceptions to our broad policy may become
acceptable (such as, possibly, the release of GE'd sterile mosquitoes as a
means of malaria control), but that will not mean that these Guidelines are
any less relevant to decisionmaking regarding any and all future releases.
Adopted by the Sustainable Planet Strategy Team, February 20, 2001.
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