Discussion of Barbara Weber's paper, 28th October 1997

This talk was a brilliant example of focusing the risks solely on genetic engineering, but what has been said applies to many kinds of industrial processes and newly emergent technology. With respect to the albumin issue, there exists recent data showing that ovalbumin is very persistent in the stomach for at least 60 minutes. When it comes to food allergies we should be grateful that we have much more precision for screening and that we have a better knowledge of what we are doing. The relatively recent introduction of the kiwi fruit to Europe, with its hundreds of new proteins, gave rise to allergies here. If we were to apply such strict rules we would just have to stop not only GE but also the introduction of exotic fruits, new food processes and any progress whatsoever!

It is true that much of what we have done in the past should be scrutinised more carefully in future. This is the so called 'backlash' of new on traditional methods. But to ban GE would be going too far. A balance in risk perception is required for satisfactory progress.

In conventional crop production we have a process of adaptation which has taken hundreds of years. Granted we have also arrived at certain allergies this way, for instance with peanuts, but the peanut can be recognised for what it is whereas a transgenic soybean cannot. The soybean has 16 known allergies associated with it and if only five patients representing only three of these allergies are tested, it is not very reassuring. This could be taken to imply that a request is being made for 100% security with transgenic products whereas with other products no similar level of stringency is being demanded. However, this is far from justified, other novel foods deserve equally strict scrutiny.

Over a long period we have gained more experience with conventional products compared with transgenic products and transgenics take us the same direction in which we have made mistakes in the past. It is thus inappropriate to argue for a continuation of a technology which simply continues in the same direction as that associated with past mistakes. Against this, it can be argued that the traditional breeding methods, which introduce hundreds of potentially allergenic proteins, can be replaced with the greater precision of transgenesis. This, however, would be all well and good if one could direct the integration, location and number of copies of the inserted transgene. The transgene also has to be tailored with various promoter and termination sequences, but it is not known what the consequences are going to be once it is inserted. Normal breeding, the way that got us all here, now seems to be being cast as something bad in the light of the claimed precision of transgenesis. The superior precision claimed by the transgenicist when it comes to creating new varieties extends only to the gene sequence. The precise function is unknown.

To say that the risk assessment argument, based on suspected allergenicity, should be extended to every new exotic fruit variety introduced is questionable because these varieties are produced by interbreeding varieties or closely related species which are normal in evolution and have been used over years often hundreds of years of husbandry. In any case, if new varieties which are known to pose some allergenicity risk, are properly labelled, at least the consumer would be able to avoid them. This raises the question as to whether the varietal source of a food ingredient, say of tomato puree, should be identified on the packaging. The weakness of such a reductio ad absurdum question is shown by the fact that allergy to a particular tomato variety has not been reported.

The polls in Europe certainly show a public disapproval of foods produced by GE but the behaviour at the supermarket shelves does not reflect this. For instance when a batch of Toblerone was released containing illegally imported transgenic soya, many people made a special effort to secure a sample for themselves. People were curious. The same sort of phenomenon occurred at a recent public biotechnology exhibition. People avidly sampled the novel foods and conceded that it did them no harm. But is the consequence of this argument that we should ignore the polls and make such foods available in the shops? Conversely, have people been so brainwashed as to the alleged dangers of such novel foods that they are surprised that it seems just like normal food when they eat it? Are they being foolish? Can the millions of Americans who, without any fear, daily eat food derived from transgenic organisms be wrong? It is likely that the initial resistance encountered in Europe will change, whether we like it or not, as more and more of such foods appear on the shelves. This is not to say that the more this happens the more justified we are in reducing our vigilance over these new organisms and products, but we have to be realistic. That any consumer trend to buy GE foods is likely to be a matter of its price remaining low is undermined by the preparedness of growing numbers of people to buy organically produced foods which are usually more expensive, thus showing that quality is for them an overriding factor.

What is against clear labelling of products derived from transgenics? It should not be impossible to label foods which not only can be chemically proven to contain ingredients derived from transgenics, but also those which at some point in their production or distribution havebeen in contact with transgenics. This would be fully open and allow people to make their own decisions. People get very angry when it is claimed that this cannot be done.

In Switzerland, at least, people are erring on the safe side. Raw materials are analyzed for the presence of transgenics. According to a law that came in in July 1995, products containing transgenics or their derivatives will have to be labelled. However, it is beginning to look as though under the current Novel Foods Directive in Europe, most of the transgenic derived foods will not be labelled. At the present time, the EU is distinguishing between science-based and risk-related labelling requirements. The Directive will include the latter. A further labelling framework is under consideration in response to consumer information needs. On 25th July the European Commission put forward proposals for three categories in this respect: 1) certified non-GMOs - for instance for a food which has soya products in it, the producer has the burden of proof by DNA or protein testing that it is not transgenic; 2) may contain GMO(s) - for cases where there is circumstantial evidence that a GMO product is in it but it has not been established either way; 3) contains GMO(s). The big food processors have been invited to respond to these proposals. One has said that it would object to the first category of labelling as it would not help to further the technology. They would therefore not wish to invest in facilities for proving that products do not contain GMOs. The exact nature of the consumer information based labelling, whether based on the detectability of DNA or protein is further complicated by the issue of setting limits for the different categories. The increasing sensitivity of testing, such as by the polymerase chain reaction, will make slight contamination a problem. Even Greenpeace proposed a limit of 99% to qualify for non-GMO classification. The setting of limits arises from the need to preserve the possibility of a GE free food production line, just as is already the case for organic products. However, in doing so one must expect that by contamination, e.g with pollen, from transgenic sources traces of transgene are likely to be detectable. The 'may contain' categorisation is the worst option possible because all producers would opt for it and the consumers will not know what they are getting. While a certain as yet unknown percentage of the population will steadfastly avoid foods derived from GMOs, the option must be protected for them to chose such foods if they wish. As things stand it appears that this percentage is a large one.

There is also the general problem to be borne in mind that any labelling system is prone to providing as much disinformation as it provides information. There is no black and white situation. Many people think that such a labelling proposal may only be a transient solution because after several years when nearly all available products have been labelled and the acceptance resistance has been overcome then labelling will become redundant.

If producers leave it to the government to introduce labelling and thereby run the risk of having their product appear through the labelling as potentially dangerous, why do they not - if they are so proud of their products - label them themselves? This would be the free market at work. Certainly the form of the label is under discussion. Some food producers want something like 'this product was derived through modern biotechnology', but some governments feel that the labels should state 'this product has been obtained through genetic modification'. This shows that there is already activity by the major players involved. There has indeed been voluntary labelling too, for instance with Zeneca's tomato paste in UK supermarkets. The price was lower and consumers did indeed buy it. It was not boycotted.

This brings up the issue of euphemisms. There are several expressions available which mean almost the same thing. But the meaning of terms is being corrupted, for instance with the term 'vegetarian cheddar'. Another factor is how prominent the special labelling is. An example was cited of a ketchup eye-catchingly labelled as from 'genetically modified tomatoes', whereas another example was of products in Holland labelledin small writing 'this product has been enhanced through modern biotechnology'.

Demanding labelling could become a double-edged sword. If small producers always had to pay for DNA testing before they sell their crops, it could become an additional big handicap for them. They would be forced into larger cooperatives to fund the testing. Another factor to be borne in mind is the trend towards certain raw materials like lecithin, no longer being available in GMO free form.

If a product qualifies for non-GMO categorisation, and yet has been produced by conventional high input agriculture, should it be required to carry the label, say, 'this produced using 5 pounds per acre of so and so insecticide'? People may also like to know that their food contains toxins. However, this argument that the GMO producers and processors are beyond reproach because of the exemplary way they claim to conduct their risk assessment compared with the way it was done in former times is untenable. It falls down when we admit that perhaps we should have been more careful when, for example, organophosphates were used in the past. If the transgene derived products are to be labelled and at the same time shown in a positive light as regards inputs such as pesticides then, to be entirely fair, we must also identify products which are still produced with high pesticide use.

However, the claim that transgenic soybeans contain lower chemical residue levels was rebutted by findings in USA and Europe which show that herbicide levels are in fact higher because it is applied at a later stage in the growth cycle. Formerly it was not possible to apply glyphosate while the plants were growing.

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