Ethical arguments against genetically modified foods Dr. Gary Comstock Philosophy and Religious Studies Coordinator, Bioethics Program
Dec 18, 2015
Ethical arguments against genetically modified foods
Dr. Gary Comstock
Philosophy and Religious Studies
Coordinator, Bioethics Program
Iowa State University
Two kinds of ethical arguments against GM foods
1. Extrinsic objections
GMOs are wrong because risks outweigh benefits.
2. Intrinsic objections
GMOs are wrong , no matter how great the benefits.
1. Extrinsic objections
A. Unsafe for consumers
“Frankenfoods”
2. Extrinsic objections
B. Unsafe for environments
“superweeds”
– Herbicide resistance - canola gene flows into weedy relatives
– Bt toxin kills monarch butterfly larvae
Extrinsic objections
C. Unfair to small farmers
“Rich get richer,
poor get poorer”
Vandana Shiva
Monocultures of the Mind
Ethical arguments against GM foods
1. Extrinsic objections
2. Intrinsic objections
GM foods are wrong no matter how great the benefits may be.
Intrinsic objections
GM foods are wrong because it’s wrong to:
1. Play God2. Invent world changing
technology3. Cross species boundaries4. Reproduce by nonsexual
means5. Disrupt integrity, beauty,
balance of nature6. Harm sentient beings
Genetic engineering
“ takes mankind into
realms that belong
to God and God
alone ”
- Prince Charles
Intrinsic objections
1. We should not play God
Intrinsic objections
1. Don’t play God
Counter-examples:
– High tech medicine
– God wants us to genetically engineer food
Intrinsic objections
2. We should not change the world through new technology
Intrinsic objections
2. No world-changing technology
Counter-example:Agriculture
Intrinsic objections
3. We should not cross natural species boundaries
Intrinsic objections
3. Don’t cross species
Counter-examples:
• Mules
• Hybrid wheat
Intrinsic objections
4. We should not use nonsexual means to reproduce
Intrinsic objections
4. Don’t reproduce nonsexually
Counter-examples:• GIFT and in vitro• Plant cuttings
Intrinsic objections to ag biotech
5. We should not disrupt the integrity, beauty and balance of creation
Intrinsic objections to ag biotech
5. Don’t disrupt nature
Problems:
• An extrinsic objection
• Is / ought problem
Intrinsic objections
6. We should not harm sentient beings
Intrinsic objections
6. Don’t harm sentient beings
Problems:• An extrinsic objection
• Meat-eaters accept harm to animals
Conclusion: Intrinsic objections are not sound
1. Playing God2. Invent world changing technology3. Cross species boundaries4. Reproduce nonsexually5. Disrupt integrity and beauty of nature6. Harm sentient beings
Extrinsic objections
• Unsafe for consumers? Food allergens, toxins
• Unsafe for environment?
– Unintended effects on nontarget organisms– Gene flow, development of resistant weeds
• Unfair to small farmers? Rich get richer, poor get poorer
Extrinsic objections
•Are valid concerns
•Demand scientific and political attention
Extrinsic objections
• Support: Regulatory oversight on case-by-case basis• Do not support: a ban on all GM crops
Ethical arguments FOR GM foods
Potential to improve:
– Diets in developing countries
– Efficiency of food production
– Safety and purity of food
– Agricultural sustainability
– Diversity of agro-ecosystems
Enhanced nutrition
Vitamin A Rice
Iron Enhanced Rice
Amino Acid Balance
Insect resistance
• Bt corn– Insect resistance from
Bacillus thuringiensis– Non-toxic to humans– Target insect: corn borer– 40% U.S. Corn crop Bt– Potential to reduce
insecticide use
Disease resistance
• Potatoes• Squash• Tomatoes• Corn• Rice• Canola• Soybeans• Grapes• Cantaloupes• Cucumbers
Genetic engineering in microbes: enzymes
• Recombinant Chymosin
– Enzyme used for cheese making
– Originally from calf stomach– Bovine gene expressed in
GRAS microbes– FDA approved 1990– Now used in 70% of U.S.
cheese
Recombinant amino acids
• Aspartame– Artificial sweetener– Made from aspartic acid
and phenylalanine– Used in 5,000 products
• Monosodium glutamate
Recombinant alpha amylase
• Used to make HFCS
• Gras status in 1995
• 10% U.S. corn crop processed into syrups
Ethical Issuesin Risk Communication:
Why ConsumersNeed Not Worry AboutGenetically Modified Crops
Steven R. ShaferMichael D. McElvaine
Alwynelle S. AhlOffice of Risk Assessment
& Cost-Benefit Analysis
RiskAssessment
HazardRisk
-Likelihood-Magnitude
Uncertainty
RiskManagement
Cost-BenefitAnalysis
RiskMitigation
Risk Communication
RISK ANALYSISRisk Analysis
Ethical questions for risk assessment involving agriculture should be asked in the context of the risk assessment paradigm itself…
• What can go wrong?
• How likely is it to occur?
• How bad will it be if the undesirable event does occur?
Variability and Uncertainty• Variability
– heterogeneity among measurements– estimate may be refined by increasing the number
of measurements
• Uncertainty– inaccuracy, incomplete knowledge– may be reduced by different types of observations– may indicate gaps to be addressed by research
Ethics in Risk Assessments and Risk Communication Involving Agriculture: Some
Principles
• Make sure all stakeholder voices are heard
• Ensure transparency of ideological positions in determination of resources at risk and endpoints
Ethics in Risk Assessments and Risk Communication Involving Agriculture: Some
Principles
Need to
– maintain a safe, nutritious, and plentiful food supply
– preserve ecosystems
– balance agricultural production and wise stewardship of the earth.
The Act of Congress establishing a US Department of Agriculture was signed by President Lincoln in 1862………….
“….to acquire and diffuse among the people of the United States useful information on subjects
connected with agriculture…….”
USDA Mission:
• ensuring a safe, affordable, nutritious, and accessible food supply
• caring for agricultural, forest, and range lands
• supporting sound development of rural communities
USDA Mission:
• providing economic opportunities for farm and rural residents
• expanding global markets for agricultural and forest products and services
• and working to reduce hunger in America and throughout the world.
Risk assessments in USDA
• Mandated by law and Executive Order for economically significant rules ($100 million)
• Risk assessments, cost-benefit analyses, and Environmental Impact Statements are part of the public record
• Open to public comment before proposed rules are implemented
Coordinated Framework for Regulation of Biotechnology
• Federal Register 51:23302-23350 (1986)
• Uses existing statutes to regulate products of biotechnology
• Reviews of products are risk-based, not based on the technology itself
• Can impose civil or criminal penalties for non-compliance
Regulatory Oversight in Biotechnologyhttp://www.aphis.usda.gov/biotechnology/index.html
• US Dept. of Agriculture
– Plant pests
– Plants
– Veterinary biologics
• US Food and Drug Administration
– food, feed
– food additives
– veterinary drugs, human drugs and medical devices
• US Environmental Protection Agency
– microbial/plant pesticides
– new uses of existing pesticides
– novel microorganisms
Regulation of Biotechnology:US Environmental Protection Agency
• Regulatory authority under three statutes– Toxic Substances Control Act (TSCA)
– Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
– Federal Food, Drug, and Cosmetic Act (FFDCA), Section 408
• Ensures the safe use of microbes and pesticides in the environment
• Includes regulation of GM plants that produce pesticidal substances not produced by the non-GM plant
Regulation of Biotechnology:US Food and Drug Administration
• Regulatory authority under Federal Food, Drug, and Cosmetic Act (FFDCA)
• Ensures the safety and labeling of the nation’s food supply (excluding meat and poultry), and of drugs
• Includes monitoring foods to enforce pesticide residue tolerances set by EPA
Regulation of Biotechnology:USDA Animal and Plant Health
Inspection Service
• Regulatory authority under two statutes– Federal Plant Pest Act (FPPA)
– Plant Quarantine Act
• Ensures protection of American agriculture against pests and diseases
Risk:Characteristic vs. Source
• The maximum exposure to many acetyl cholinesterase (AC) inhibiting insecticides (organophosphates, carbamates) considered acceptable under the FQPA is approximately 0.01 mg per kg body weight per day
• Solanaceous crops contain glycoalkaloids• Glycoalkaloids are AC inhibitors, and for crops like
potato and pepper, the aRfD is also 0.01 mg per kg per day
20-kg childaRfD = 0.01 mg/kg/d
Consumption
(g)
Residue
(mg/kg)
Exposure
(mg/kg)%aRfD
Small fry 70 38 0.1330 1330
Large fry 125 38 0.2375 2375
Super fry 170 38 0.3230 3230
Pepper 74 77 0.2849 2849
Eggplant 96 60 0.2880 2880
70-kg adultaRfD = 0.01 mg/kg/d
Consumption
(g)
Residue
(mg/kg)
Exposure
(mg/kg)
%aRfD
Small fry 70 38 0.0380 380
Large fry 125 38 0.0679 679
Super fry 170 38 0.0923 923
Pepper 74 77 0.0814 814
Eggplant 96 60 0.0823 823
Assume that a new variety of apple has been developed.
It has the ability to produce AC-inhibiting glycoalkaloids.It is resistant to many insect pests.
Which is the more risky?The gene for glycoalkaloid production was inserted from a crabapple by traditional methods.
The gene for glycoalkaloid
production was inserted
from a potato by genetic
modification.
Secretary Glickman’s principles to guide USDA biotech policies
• Arm’s length regulatory process
• Consumer acceptance
• Fairness to farmers
• Corporate citizenship
• Free and open trade
http://www.usda.gov/news/releases/1999/07/0285
Arm’s length regulatory process
• Separation of regulators from the regulated
• Regulatory agencies (APHIS, FSIS) separate from marketing assistance agency (AMS)
• Separate experts serve different functions
• Maximize transparency in regulations
Arm’s length regulatory process
• Establish regional pest management centers with EPA– investigate crop production, pest biology, pest
management, biotechnology– long-term studies– information resource
• Gather the best scientific information to support policy and regulation
Expertise on the USDA’sAdvisory Committee
on Agricultural Biotechnology• Recombinant DNA
- plants• Recombinant DNA
- animals• Recombinant DNA
- microbes• Ecology• Biodiversity
• Agricultural practices
• Silviculture &
Forest science
• Fisheries
• Food science
Expertise on the USDA’sAdvisory Committee
on Agricultural Biotechnology
• Human medicine
• Public health and epidemiology
• Occupational health
• Veterinary medicine• Weed science• Entomology• Nematology• Plant pathology
Expertise Advisory on the Committee onUSDA’s Ag Biotechnology
• Small farm advocacy
• Consumer advocacy and public attitudes
• Ethics / bioethics• Risk assessment
• Laws and regulations• Biotechnology
industry• Intellectual property• International trade
Why US consumers may feel protected by the US GMO regulatory structure
Political structure is inherently competitive
Basic separation of powers• Creation of laws by Congress
• Enforcement of laws by Executive Branch agencies
• Challenge of laws and regulations through the Judiciary
Why US consumers may feel protected by the US GMO regulatory structure
Political structure is inherently competitive– Separation of regulatory authority from
agencies that promote agriculture
– Administrative Procedures Act authorizes courts to review agency decisions for decisions that are arbitrary and capricious
– Freedom of Information Act demands public disclosure
Why US consumers may feel protected by the US GMO regulatory structure
• Political structure is inherently competitive - some implications– Regulatory agencies can be sued
for procedural deficiencies
– Regulatory agencies can be sued if they do not acquire, or if they fail to consider, relevant scientific information
Why US consumers may feel protected by the US regulatory approach for biotechnology
• Political structure is inherently competitive - some implications– Encourages transparency and
extensive scientific investigation (e.g., risk analysis) by the government
– Encourages private citizens to challenge the government
Why US consumers may feel protected by the USGMO regulatory structure
• Preference for experts in scientific analytic techniques helps define who participates in some aspects of regulatory decision-
making, but policy decisions are not limited to experts
Why US consumers may feel protected by the US GMO regulatory structure
–Scientific experts selected based on what they know, not who they are, or are affiliated with
–Non-experts provide input through public comment, elections, administrative hearings, initiation of laws, regulations, lawsuits
Conclusion
Intrinsic arguments against GMOs are not sound.
ConclusionsExtrinsic arguments against GMOs raise two valid concerns:
•Food safety•Environmental effects
Conclusions
In the U. S., regulatory agencies have years of experience testing GM foods for safety to the consumer.
Continued vigilance is necessary.
Conclusions
In the U.S., regulatory agencies have
responsibility to test GMOs for safety to the environment.
Continued vigilance is necessary.
Conclusions
Extrinsic objections
•Representvalid concerns
•Demand scientific and political vigilance
Conclusions
Extrinsic objections
• Necessary: Regulatory oversight on case-by-case basis
• Not necessary: A ban of GM foods
Acknowledgments
This presentation is based on:
Gary Comstock, “Is it unnatural to genetically engineer plants?” Weed Science 46 (1998): 647-651, at:
www.biotech.iastate.edu/Bioethics/gmosethics/weedscienceart.htm
Acknowledgments
Dr. Clark Ford (Food Science and Human Nutrition, Iowa State University) generously assisted with ideas, design, and web-based pictures, and allowed me to use slides from his presentation, Ethics and GMOs, at:
www.biotech.iastate.edu/Bioethics/gmosethics/
ford.pdf
Acknowledgments
Dr. Steven Shafer, U. S. Department of Agriculture, kindly allowed me to use slides from his presentation, “Why Consumers Need Not Worry About Genetically Modified Foods,” at:
www.biotech.iastate.edu/Bioethics/gmosethics/
USDA.pdf
Photo credits
Vandava Shiva: courtesy of Mt. Holyoke College
ens.lycos.com/ens/feb99/1999L-02-23-03.html
Creation of Adam: www.artprintcollection.com/html/michelangelo_
buonarroti-crea.html
Frankenfoods tomato: www.the-scientist.library.upenn.edu/yr1999/oct/palevitzp10_991011.html
Prince Charles:www.princeofwales.gov.uk/
Mule: www.sky.net/~nodell/
Plant cuttings:www.familyplay.com/activities/plantcut.html
Monarch larva: www.the-scientist.library.upenn.edu/yr1999/oct/lewis_p1_991011.html
Monarch butterfly: http://news.bbc.co.uk/hi/english/sci/tech/
newsid_681000/681208.stmFermenter:
www.nbsc.com/ferm_eq/custferm.htmNew Leaf:
www.monsanto.com/monsanto/investor/current/default.htm
Bt corn field:ens.lycos.com/ens/sep99/1999L-09-16-01.html
Ethical arguments against genetically modified foods
Dr. Gary Comstock
Philosophy and Religious Studies
Coordinator, Bioethics Program
Iowa State University