http://www.sierraclub.org/biotech/report.asp
Genetic Engineering at a Historic Crossroads
The Sierra Club Genetic Engineering Committee Report April 2000, revised
March 2001
Note: a list of definitions of important terms follows this report.
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* Historic turning point
* Medical uses
* Feeding the World's Hungry
* Terminator Technology
* The Genetic Engineering Committee
* An Educational Challenge
* Why is this important?
* Biodiversity and Endangered Species
* A Threat to Organic Farming
* Health issues
* The Precautionary Principle
* Regulatory process
* Proposed Legislation
* Moral and Religious Issues
* What you can do
* Definitions of Key Terms
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The last four years of the twentieth century witnessed the most rapid
adoption of a new technology in history. Since 1996, millions of acres of
farmland have been planted with genetically engineered (GE) crops‹mainly
corn, soybeans, and cotton. This means that genetically engineered organisms
(GEOs) are being released to the environment on a massive scale, an event
unprecedented in the 3.8 billion year history of life on this planet. This
technological upheaval happened virtually without public debate, while our
government played the role of enthusiastic promoter, rather than cautious
regulator, of this radically new and environmentally hazardous technology.
Genetic engineering is a new technology that combines genes from totally
unrelated species, in combinations not possible using conventional breeding
methods. Genes from an animal, say, a fish, can be put into a plant, a
strawberry for instance. In fact this is an actual example of an attempt to
"improve" strawberry plants. The fish gene is supposed to make the
strawberries more resistant to frost by causing the strawberry plant to
produce a form of antifreeze which the fish normally produces to endure cold
ocean conditions.
Over 60 percent of all processed foods purchased by U.S. consumers are
manufactured with GE ingredients. Some corn and potatoes have even been
genetically engineered to contain a gene from Bt bacteria which causes every
cell of the plants to produce an insecticidal toxin. Yet there is no
labeling of these or any GE foods as being genetically engineered, because
the U.S. Food and Drug Administration (FDA) considers the GEOs from which
these foods are made to be "substantially equivalent" to the non-genetically
engineered plant from which the GEOs are derived.
The doctrine of substantial equivalence is pure pretext and rationalization
with no basis in science. Yet, in a remarkable display of arrogance, the
supporters of genetic engineering accuse their critics of not basing their
objections on "sound science."
The FDA also uses this "substantial equivalence" rationalization as an
excuse to avoid any effective testing of GE foods to determine their safety.
Such testing might seriously delay or even prevent the introduction of GE
crops into the marketplace.
From the time in the early 1970s when advances in molecular biology led to
the development of the techniques we call genetic engineering, until the mid
1990s, the organisms produced by genetic engineering were nearly all
confined to laboratories or controlled factory settings. During this time
there were almost no releases of genetically engineered organisms to the
environment, as genetic engineering was used in basic research and to
produce medically useful substances such as insulin. The unrestrained
expansion of genetic engineering into agriculture during the past four years
changed all that. By 1999 almost 80 million acres of North American farmland
were planted with genetically engineered seed. This means massive releases
of GEOs to the environment are now taking place. Genetic engineering now
poses a very grave threat to the natural environment.
Historic turning point
We are now at a turning point in history. We can continue to allow the
virtually unrestricted release of genetically engineered organisms to the
environment, or we can bring this technology under strict control.
If we continue on our present path of unrestricted releases of GEOs, we will
eventually live in a genetically engineered world, as the genome of each
species now on earth is either deliberately altered by genetic engineering
or indirectly altered by inheritance of transgenes from a genetically
engineered organism. In such a world there would be nothing left of living
nature, as every species would have been deprived of its genetic integrity,
and every ecosystem would thereby have been irreversibly disrupted.
Of special concern to environmentalists should be the fact that trees are
now being genetically engineered, and that it is proposed that entire
forests be planted with these trees. One such proposal is for trees which
produce no seeds, but divert the energy from seed production to more rapid
growth of wood. A forest of such trees would wreak havoc on the food chain.
Other GE trees that do produce seeds could cross with native varieties and
damage forest ecosystems. Engineered trees which produced pollen (as might
happen despite scientists' attempts to create sterile subspecies) could
cross with native varieties miles away and damage forest ecosystems.
Fish, as well as other animals, are also being genetically engineered to
grow more rapidly. If they are released to the environment (fish culture
tanks often discharge during storm conditions), they may out-compete native
species and thereby disrupt ecosystems.
There is evidence that soil organisms may be adversely affected
bygenetically engineered crops. The Bt corn plant is engineered to contain a
bacterial gene that causes production of an insecticide in every cell of the
corn plant, including the edible corn ear and the roots. This toxin has been
found to persist in the soil for months.
The promoters of genetic engineering show no sign that they are willing or
able to impose limits on their applications of this new technology. It will
therefore be left to the institutions of civil society‹governments working
with non-governmental organizations representing the concerned public (such
as Sierra Club)‹to set limits to how much further genetic engineering will
be allowed to alter the earth's species.
Medical uses
Promoters of the use of genetic engineering outside the laboratory claim
that a moratorium or other controls on the planting of genetically
engineered organisms as agricultural crops would mean an end to the uses of
genetic engineering in the production of medically useful products. This is
untrue. As long as proper precautions are taken to assure that the
genetically engineered microorganisms used in production of pharmaceuticals
or in scientific experiments are not released to the environment, such uses
need not be prohibited. However, all applications of genetic engineering,
including medical uses, carry some risk. Medical applications of genetic
engineering should be approached with caution and not rushed to market. We
believe that simpler, more traditional strategies for problem solving should
always be considered when evaluating the production of transgenic organisms.
This is especially relevant with respect to agricultural applications, as
will be discussed in the topic below.
Feeding the world's hungry?
Medical uses of genetic engineering may be prudent, but agricultural
applications of GE are not. Yet the argument is being made by the biotech
industry that if the genetic engineering of farm crops is not allowed to
proceed, the poor people of the world will starve.
In fact there is more than enough food produced by conventional agriculture,
without genetic engineering, to feed all of the world's people. One cause of
hunger is the ineffective distribution of food. Genetic engineering may
actually lead to more food insecurity and hunger because in poor countries
it will lead to the planting of monoculture crops, highly vulnerable to
disease and pests, in the place of resilient, diverse range of crops, and it
will make farmers dependent on corporations that will demand payment for
basic inputs such as seed, chemicals, and fertilizers.
Terms of trade between developed and less developed nations have often
resulted in the best land in the poor countries being used to grow cash
crops for export rather than food for consumption at home. Issues of equity
and fairness have not been addressed by trade agreements. Certainly these
problems call out for redress, but their solution isn't to increase the
monopoly power of "life science" companies in the richest nations.
As Indian writer and activist Vandana Shiva summarized, "Millions of farmers
in third world countries want to breed and grow the crop varieties that
adapt to their diverse ecosystems. Plant biodiversity is essential for a
balanced diet. Yet numerous crops are pushed to extinction with the
introduction of GE crops."
Terminator technology
Any claim by the corporations promoting agricultural biotechnology that they
have the interests of the world's poor people at heart are refuted by the
facts in the case of Terminator seed technology. This technology would
protect the intellectual property interests of the seed company by making
the seeds from a genetically engineered crop plant sterile, unable to
germinate. Terminator would make it impossible for farmers to save seed from
a crop for planting the next year, and would force them to buy seed from the
supplier. In the third world, this inability to save seed could be a major,
perhaps fatal, burden on poor farmers. The Sierra Club's Genetic Engineering
Committee (GEC) believes that Terminator is a tool by which seed companies
are trying to engineer their monopoly power into the genetic code.
Adding insult to injury in the Terminator technology story is the fact that
our own tax dollars were used to develop Terminator. The U.S. Dept. of
Agriculture played a major role in the development of Terminator technology.
The USDA is actually part owner of the patent on this immoral technology.
The Genetic Engineering Committee
The Sierra Club's Genetic Engineering Committee (GEC) was formed in May 1999
to explore ways to mobilize the strength of Sierra Club, the largest
grassroots environmental organization in the U.S., for the work of public
education and regulatory reform that will be necessary to protect the
natural environment and human health from the threats posed by the release
of genetically engineered organisms.
An Educational Challenge
Genetic Engineering Committee members have found that the need for public
education is great. Because of inadequate reporting by the U.S. media, many
otherwise well educated people simply have not been told what genetic
engineering is. We hear statements like, "If there is a moratorium on
planting genetically engineered crops, doesn't that mean that no crops at
all will be planted?" And, "Aren't all farm crops these days genetically
engineered?"
The supporters of genetic engineering gladly fill this information vacuum
with false statements. They claim that the selective breeding of plants and
animals that has been done for centuries is genetic engineering. Supporters
claim that modern genetic engineering is nothing more than an improved, more
precise, high-tech form of conventional plant and animal breeding. Michael
Khoo, in a letter published last year in the Toronto Globe and Mail, called
this claim ". . . biotechnology's public-relations line that genetic
engineering is no different from traditional breeding." His letter
continued, "A potato can cross with a different strain of potato but, in 10
million years of evolution, it has never crossed with a chicken. Genetic
engineering shatters these natural species boundaries, with completely
unpredictable results. As a result of these risks, the British Medical
Association has recently called for an open-ended moratorium on GE
planting."
Gene transfers occur in conventional breeding, but these transfers can only
take place between individuals of the same species, or, in the case of
hybridization, between individuals of closely related species. This is
because conventional breeding relies on the normal reproductive processes of
the plants or animals. Plants can be conventionally bred only with plants of
the same species or, to make a hybrid, with closely related species. And
animals can only be bred with other animals of the same or, in some
instances, closely related species.
Genetic engineering is not bound by these limits in the possible exchanges
of genes that can be made to occur using its techniques, which include the
use of viruses as "vectors" to move foreign genes into host organisms. By
means of genetic engineering, genes can be transferred from a plant to an
animal; from an animal to a plant; from a bacteria to a plant, and between
numerous other combinations of donor and recipient organisms. There have
even been attempts to put human genes in plants and animals that are used as
human food.
Why is this important?
The changes caused by genetic engineering can be inherited by subsequent
generations of the affected organism, and, once released to the environment,
these organisms cannot be recalled‹they will continue to pass on their
spliced-in genes, or transgenes, to future generations. Many of the gene
changes may turn out to have unexpected secondary effects. Serious errors in
judgement might prove unrecallable as trillions of copies are broadcast via
pollen and seed. Wild relatives of crops will also be affected, with
possibly profound effects on the environment. For instance, genetically
engineered cereals may cross with various grasses. Once this process begins,
it will be for all practical purposes uncontrollable and unpredictable.
Biodiversity and endangered species
As environmentalists, one of our most basic concerns is the preservation of
species. We live in a time when the rate of species extinction has increased
drastically, primarily as a result of human activities. Now a new form of
human activity, genetic engineering, may pose the ultimate threat to the
survival of all species.
Many of those who are promoting genetic engineering give every indication
that they regard life as a form of information technology: that genes are
mere bundles of information to be transferred from one species to another on
the basis of expediency and potential corporate cash-flow; that the natural
barriers to genetic transfer that protect the integrity of species are mere
inconveniences to be overcome; and that the very concept of species is an
anachronism which it is now time to discard.
Because these principles are being put into application‹genetically
engineered organisms are now being made and released to the environment‹we
have to conclude that genetic engineering threatens the continued existence
of all species as life-forms that are distinct from one another.
Genetic engineering should be considered an environmentally dangerous
technology that is breaking down the barriers that have protected the
integrity of species for millions of years. There are probably good reasons
why it is impossible for a conventional plant breeder to combine plant genes
with animal genes. Those reasons have to do with the very survival of life
on earth, and we ignore them at our peril.
Another threat to biodiversity from genetic engineering is from toxins
produced by GE crops. The finding last May that Bt corn pollen might be a
threat to monarch butterflies provides an example. Genetically engineered Bt
crops have the gene spliced-in from the Bt bacteria that codes for the
production of the toxin that kills insect larvae. A Cornell study showed
that this toxin kills the larvae of certain species of moths and
butterflies. Other studies have indicated reduced viability of other
nontarget beneficial insects, such as ladybugs and lacewings. Bt toxin also
persists in the roots of the crops and in plant residues for a considerable
time after the crop is harvested, which may have major adverse consequences
for the millions of soil organisms that help maintain soil fertility.
Yet another threat to biodiversity is the out-crossing of herbicide
resistance traits to native plants. There is already evidence of
"superweeds" created by the spread of pollen carrying the herbicide
resistance trait.
A threat to organic farming
The standards established by organic farmers categorically exclude
genetically engineered crops from the organic food system. A problem arises
from pollen drift from fields of GE crops planted too close to organic
crops. The organic plants may become crossed with the GE plants and thereby
contaminated with the spliced-in gene (transgene) from the GE crop. Then the
crop grown next season from seed saved from what was an organic field will
no longer be acceptable as organic‹it will contain the transgene and will
have to be considered genetically engineered. And in the case of crops in
which the harvested portion of the plant is the seed, the presence of a
transgene will immediately, in the first generation, make the crop not
acceptable as organic. This problem of outflow of transgenes to organic
crops is considered by organic growers to be very serious.
Another negative impact on organic farming is the expected resistance that
insect pests will develop to Bt toxin. Organic farmers have been using Bt
bacteria applied to crops in a spray as an organic method of controlling
damaging insects. But genetically engineered Bt crops have the gene that
codes for Bt toxin production spliced-in. By applying Bt bacterial sprays
only occasionally, and because of the naturally limited quantity of the
toxin present in the bacteria, organic farmers have avoided pest resistance
problems. Now, with massive quantities of Bt toxin present in fields
throughout the growing season, most of the insects susceptible to the toxin
will be killed off, leaving a proportionately greater number of resistant
insects alive. These Bt-resistant survivors will pass resistance traits into
future generations. It is expected that resistance problems caused by
genetically engineered Bt crops will render Bt sprays useless to organic
farmers within a few years.
Health issues
While Sierra Club is an environmental organization, we are concerned also
with potential human health impacts of this new technology. Among the issues
are the possible spread of allergens, the invitation which herbicide
tolerant crops give to over-use of herbicides, possible adverse effects of
new toxins (such as the Bt endotoxin) on some people, and the emergence of
antibiotic resistance which may be fostered by the use of antibiotic
resistance genes in almost all transgenic crops. New genes also alter the
expression of native genes and so may change the nutritional benefits of
foods and may also result in the overproduction of previously low-level
natural toxins which exist in most foods. Health risks add to the
environmental reasons for exercising caution.
The Precautionary Principle
The Genetic Engineering Committee strongly supports application of the
precautionary principle to biotechnology issues and recognizes the limits
inherent in present systems of risk assessment. Here is cogent statement of
the precautionary principle from the Wingspread Consensus Statement on the
Precautionary Principle, Jan, 1998: "When an activity raises threats of harm
to the environment or human health, precautionary measures should be taken
even if some cause and effect relationships are not fully established
scientifically."
The participants at the conference said the following about risk assessment:
"We believe existing environmental regulations and other decisions,
particularly those based on risk assessment, have failed to protect
adequately human health and the environment, the larger system of which
humans are but a part."
Carolyn Raffensperger offered further commentary on risk assessment:
"Participants [at the Wingspread conference] noted that current policies
such as risk assessment and cost-benefit analysis give the benefit of the
doubt to new products and technologies, which may later prove harmful. And
when damage occurs, victims and their advocates have the difficult task of
proving that a product or activity was responsible." (email by Ms.
Raffensperger, 1/28/98)
The precautionary principle is of the greatest importance when the damage
from a new technology would be irreversible. This is the case with genetic
engineering. Once they are released into the environment, genetically
engineered organisms cannot be recalled. The Genetic Engineering Committee
believes that genetically engineered farm crops are wrongly given the
benefit of the doubt in the regulatory process, and that, under the
precautionary principle, they should not be released into the environment or
allowed to be part of the food supply.
The regulatory process
The federal government decided early in the development of genetically
engineered crops that this was a technology where U.S. producers had an
advantage which could be used to help them compete successfully in world
markets. It was decided during the first Bush administration that the
regulatory process for approval of GE crops would be streamlined. The
Clinton administration continued this policy, with both President Clinton
and Vice President Gore being strong supporters of agricultural
biotechnology.
The regulatory inadequacies in the case of Bt potatoes are illustrative. The
U.S. Food and Drug Administration (FDA) does not test the toxin in Bt
potatoes for safety as a food additive because the toxin is a pesticide and
therefore the U.S. Environmental Protection Agency (EPA) has the
responsibility to assure its safety. But the EPA tests only the Bt toxin,
not the potatoes containing the toxin. So no one tests Bt potatoes for their
safety as food, yet they become part of our food supply. The FDA does not
require labeling of Bt foods, because the agency is prohibited from
requiring any information about pesticides on food labels, and because they
consider GE foods to be substantially equivalent to conventional foods.
Meanwhile, the U.S. Dept. of Agriculture pursues a role primarily of
promotion of genetic engineering in agriculture, spending only a tiny
fraction of its budget on safety testing of biotech foods.
As for testing GE crops for environmental hazards, there has been no
environmental impact statement (EIS) done for a release of any genetically
engineered crop. This is in violation of the National Environmental Policy
Act (NEPA), which the EPA has the responsibility to administer.
Proposed Legislation
Laws are needed to require safety testing and labeling of GE crops. Also
needed are mandatory environmental impact statements for every ecosystem
into which any new GEO is to be introduced, and when applicable, involvement
with the U.S. Fish and Wildlife Service. Liability issues also need to be
addressed: clarification is needed as to who is responsible for the
downstream effects of a company's product, including damage to organic
producers and damage to the environment. Funding for agricultural research
and development should be directed towards sustainable methods, rather than
methods that perpetuate dependence on the chemical treadmill and
agricultural biotechnology.
Moral and Religious Issues
In the book My First Summer in the Sierra, by the Sierra Club's founder, it
becomes more clear with each page that John Muir regarded the study of
nature as an act of worship. Although Muir provides glorious images of
inanimate nature in the Sierra‹the mountains and rock formations; the
clouds, storms, and waterfalls‹most of the book is devoted to careful
descriptions of plants and wildlife, with frequent mention of how all these
living things are loved by their Creator. Muir tells us that to be in a
place like the Sierra Mountains is to be closer to God than is possible in
any human-built church.
Not all Club members will hold the same religious convictions that John Muir
held. But most of us probably share his belief that ethical principles are a
part of our relationship with nature; that there is a moral dimension to our
task of protecting nature. Those ethical principles lead us to respect and
protect the natural world.
To Muir, the more one knows about nature, the more one is inclined to
protect nature. Using our knowledge of living organisms in order to better
protect wild nature is the opposite of using that knowledge to bring living
things into the realm of human technology and human control.
There is not a shred of evidence that John Muir would have regarded the
release of genetically engineered organisms to the environment with anything
but shock and outrage. We can be certain that Muir would be fighting those
powerful corporate forces that are trying to control and commodify the very
basis of life. We can be certain that Muir would commit to this fight the
same energy and spirit that he gave to his last battle, the struggle to save
the Hetch-Hetchy Valley. We believe that Sierra Club today should commit
major resources to save what remains of living nature from this new
technology of genetic engineering.
Respectfully submitted,
The Sierra Club Genetic Engineering Committee
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What you can do‹
Write to your members of Congress urging them to support the bills discussed
above.
Start biotechnology committees within your own region.
Make sure the public understands what genetic engineering is. If a statement
appears in the media repeating the myth that genetic engineering is nothing
more than what conventional plant and animal breeders have been doing for
centuries, write a letter to the editor stating that genetic engineering is
a new and dangerous technology that combines genes of unrelated species. See
letter writing tips.
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Definitions of key terms:
Biotechnology - A term now widely used to mean genetic engineering. In a
larger sense, biotechnology is any use of biological processes to produce a
desired result. Thus, the use of yeast to bake bread is a form of
biotechnology which is not genetic engineering and which has been in use for
centuries.
Genome - The complete set of genes of an individual organism, or the
complete set of genes of all the individuals of a species.
Genetic engineering (GE) - The transfer of genes from one organism to
another organism in ways that are not possible using conventional breeding
methods. Genetic engineering bypasses the reproductive barriers that prevent
genetic transfers between unrelated species, thus allowing transfer of genes
from an organism of one species to another, completely unrelated species.
Genetic engineering also includes methods of gene deletion and gene
manipulation that are not possible using conventional breeding methods.
Genetically engineered organism (GEO) - Any living thing that has had its
genetic structure altered by genetic engineering. A genetically engineered
organism is also called a genetically modified organism (GMO), a genetically
altered organism, or in certain cases, a transgenic organism.
Recombinant DNA technology - The technique, also called gene splicing, that
made possible the first application of genetic engineering, in 1973. A
section of DNA molecule which constitutes a gene, the basic unit that
determines an inherited trait, is cut from the molecule and spliced into
another DNA molecule in another organism. The two organisms need not be of
the same species or even closely related. Thus, using recombinant DNA
techniques, genes from bacteria have been spliced into corn plants and DNA
from a fish has been spliced into strawberry plants. It is also possible to
splice plant DNA into an animal.
Transgene - A gene from one organism transferred into another (usually
unrelated) organism by means of genetic engineering.
Transgenic organism - An organism containing a transgene.
Vector - In the context of genetic engineering, a virus or plasmid used to
transfer genetic material into a cell.
----------
Photos: corn courtesy Warren Gretz, strawberries courtesy USDA, seeds
courtesy Warren Gretz, fish courtesy US Fish & Wildlife Service, farmer
courtesy http://www.imagesoftheworld.org
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