Assessing If Herbicide-Resistant GM Plants are Sustainable

THIRD WORLD NETWORK BIOSAFETY INFORMATION SERVICE 
 
Dear Friends and Colleagues 
 
Assessing If Herbicide-Resistant GM Plants are Sustainable 

Article 26 of the Cartagena Protoocl on Biosafety establishes the right of Parties to take socio-economic considerations into account when deciding on imports or domestic measures related to genetically modified organisms (GMOs). Many Parties have included socio-economic considerations in their national laws.  

The Norwegian Gene Technology Act of 1993 requires that Norwegian authorities consider, in addition to the risk assessment, whether the production and use of a genetically modified (GM) plant contribute to sustainable development, are of benefit to society and are ethically justifiable. As such, the Norwegian Biotechnology Advisory Board is responsible for making a holistic assessment of GM plants, and has a special responsibility for assessing sustainability, social benefit and ethical factors.  

It carried out a project on “Herbicide-resistant genetically modified plants and sustainability” in 2012/2013. The objective was to find relevant parameters that could be used to determine whether herbicide-resistant GM plants contributed to sustainable development in the areas of environment/ecology, economy and society.  

The project produced guiding questions for regulatory authorities considering applications for the approval of such plants as well as questions for the Norwegian authorities to answer such as what the consequences of approving many GM plants will be. The former is intended to ensure a more holistic assessment of the sum effects of individual decisions in various areas such as nutrition, food and regional development policy and should be considered with the question of whether the herbicide resistant crop will prevent conversion to other agricultural systems in the future.  

In prioritising the most important issues, the Board recommends that the authorities pay high attention to whether the cultivation and breeding of herbicide resistant crops or products may have serious undesirable effects on human or animal health, plants, the environment and society at large in both the short and long term. It highlights possible irreversible adverse effects as especially serious. 

The Summary of the report and its final chapter are reproduced below.
 
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HERBICIDE-RESISTANT GENETICALLY MODIFIED PLANTS AND SUSTAINABILITY 
The Norwegian Bio-technology Advisory Board
 
Summary 

The Norwegian Biotechnology Advisory Board carried out the project “Herbicide-resistant genetically modified plants and sustainability” in 2012/2013. The objective was to find relevant parameters that could be used to determine whether a plant that was genetically modified to tolerate a herbicide contributed to sustainable development in the areas of environment/ecology, economy and society. Using the parameters as a basis, we formulated questions that must be answered to enable the evaluation of applications for approval of these plants. In addition to the questions for applicants, there are questions the Norwegian authorities should reply to. We also discuss knowledge gaps. 

The questions concerning environment/ecology are grouped into three blocks. The first concerns the herbicide­resistant plant itself, and the topics are:  

– characterisation of the plant
– interaction between plant and environment
– gene flow
– preservation of biodiversity
– comparison with control plants 

The second block concerns the herbicide the plant has been modified to tolerate, and covers the following topics:  

– characterisation of the herbicide
– effects of a change in the spraying regime on
            – preservation of biodiversity
            – the time when spraying takes place
            – drifting of the herbicide with the wind
            – the type and amount of herbicide that is used
            – the effects of using more than one herbicide in the same area
– resistance of other plants to the herbicide 

The last block concerns soil, water, energy and climate. 
The questions on sustainable development in the areas of economy and society are grouped into the following main topics:  

– the right to sufficient, safe and healthy food
– animal health and welfare
– living conditions and profitability for the farmers who cultivate herbicide­resistant genetically modified crops
– living conditions and profitability in the production area
– rules for use of herbicides
– plant genetic resources for food and agriculture
– independent risk research
– free choice of agricultural system in the future 

The questions the authorities should answer are grouped under the following topics:  

– freedom of choice for Norwegian consumers
– ecological, economic and societal consequences in Norway
– plant genetic resources for food and agriculture
– independent risk research
– the consequences of approving many different genetically modified organisms
– Norway’s North-South policy, work to protect biodiversity and international role
– prioritisation of the most important issues 

Finally, we discuss factors that we believe to be particularly important for deciding whether herbicide­resistant genetically modified crops – hereafter called HR crops – can be said to contribute to sustainable development. 

 
How to decide on an application?  

When assessing whether an HR crop contributes to sustai­nable development, there is little doubt that different groups in society will rank the priority of the various ques tions differently. It is important to bear in mind that those who incur (the potential) costs will, as a rule, not be those who reap the greatest benefits of the use of HR crops. The answers to many questions will probably also differ from one region to another and from one country to another, because it is also a question of the balance of power in soci ety. In order to assess the usefulness of genetically modi­fied plants in relation to the various types of costs arising from their use, it is therefore reasonable to view all draw­ backs and benefits in an overall context, to ensure that nothing is given lower priority at the outset.  

A case-­by-­case assessment is important because a ques­tion may be given great weight in one case and less in another. Case­-by-­case assessments must be supplemented by continuous overall assessment, to ensure that the total effect of individual decisions does not counteract our soci­etal goals. The decision must also be weighed against other instruments for implementing the policy that has been adopted.  

The consequences that approval of an HR crop will have for health and the environment must also be considered in the context of sustainable development, in which case the perspective is global and longer term than the perspective in traditional health and environmental risk assessments. The precautionary principle is one of several principles encompassed by the concept of sustainable development. This principle is applicable if it has been documented that there is uncertainty regarding our scientific understanding of adverse health and environmental effects. The Biotechnology Advisory Board has recommended that it should not be applied in order to allow uncertainty concerning negative social impacts to be decisive in assessment of an application. This is because the precautionary principle has been defined very precisely in connection with health and environmental issues, and it is important to prevent the principle from becoming diluted.  

If an HR crop has no special advantages or disadvantages compared with non-genetically modified crops in terms of economic and social parameters, and does not entail any environmental, ecological or health risk, it may be asses sed as neutral and not negative. If, on the other hand, the HR crop offers certain benefits in terms of economic and social parameters, this can count as a positive factor, without such benefits being requirements that must be met. If we are to accept greater risk or approve an application des­pite our lack of understanding, the HR crop must have clear benefits that can be said to offset its drawbacks.  

Although all the questions must be seen in an overall con­ text, it may be easier to decide an application if some ques­ tions are defined as particularly important (see chapter 5.7). If certain questions are to be given priority, weight should be attached to whether the cultivation and breeding of the HR crop or products from the HR crop may be harm­ful to plants, animals, humans or ecosystems in the short or the long term. Particular importance should be attached to irreversible adverse effects.  

The Biotechnology Advisory Board is of the opinion that the following factors are particularly important in deter mining whether an HR crop may be said to contribute to sustainable development (the factors are not ranked in order of importance):  

Environment/ecology: 

whether cultivation or use of the HR crop might be harmful to non-­target organisms, especially pollinators (see questions 4 and 7a)

whether unexpected additive or synergistic effects might occur when more than one herbicide is used in the same area (see question 7f)

whether cultivation of the HR crop may lead to more resistant weeds, and whether measures have been taken to prevent this effect (see question 8)

whether the HR crop is easily dispersed in the form of seed or pollen (see question 3)
whether the HR crop contains a gene for resistance to antibiotics (see questions 1e and 3b)  
Economy and society: 

whether the herbicide to which the plant is resistant is prohibited in Norway because it poses a risk to health or the environment, and the herbicide has the same effects in the country of cultivation as in Norway (see questions 5a and 5b)

whether the herbicide is prohibited or to be phased out under international treaties (see question 5c)
whether there are long-term effects on the health of farmers (see question 3.1a)
whether farmers receive training and protective equipment for use of the herbicide (see question 3.1b)

whether the democratic rights of other farmers are violated, i.e. whether there are rules governing co­existence (how GMOs and non­GMOs may be cultivated in the same area) and compensation for unwanted gene dispersal (see questions 4.2a and 4.2c)

whether the plant is available for independent risk research (see question 7)
whether the plant is available for further plant breeding (see question 6c)
whether farmers will be free to choose cultivation systems (conventional, organic or GMO) in the future (see question 8)  

Employment, ownership rights and the economy of the country of cultivation, whether the HR crop is to be grown in Norway or elsewhere, are among the questions that should be given lowest priority. 

Some consequences may be so serious that the answer to one single question should constitute grounds for rejec ting the application. Cases in which this must be conside­red are when  

the HR crop contains a gene or genes for resistance to antibiotics (see questions 1e and 3b, environment/ecology)

the plant is not available for independent risk research (see question 7, economy and society, and question 4, questions for the Norwegian authorities)

the herbicide to which the plant is resistant is prohibited in Norway because it poses a risk to health and the environment, and the herbicide has the same effects in the country of cultivation as in Norway (see questions 5a and 5b, economy and society)

it has been decided in international treaties that the herbicide to which the plant is resistant should be prohibited (see question 5c, economy and society)  

The questions as to whether approval of a GMO application is compatible with the political objectives of Norway’s North­-South policy, the political objecti­ves for protection of biodiversity and Norway’s role as a leading example and bridge­builder, as well as with its food policy objectives, make it possible to carry out a more holistic assessment of the sum effects of individual decisions: what direction do we want to take, and what will be the overall effect of individual decisions regarding genetically modified plants on our objectives in areas such as nutrition, food and regional development policy? These questions should also be seen in conjunction with the question of whether the HR crop prevents conversion to other agricultural systems in the future. It is the sum total of the answers to these questions that determines whether a decision supports Norway’s policy objectives. 

Assessing If Herbicide-Resistant GM Plants are Sustainable

 

HERBICIDE-RESISTANT GENETICALLY MODIFIED PLANTS AND SUSTAINABILITY 
 
The Norwegian Bio-technology Advisory Board
 
Summary 

The Norwegian Biotechnology Advisory Board carried out the project “Herbicide-resistant genetically modified plants and sustainability” in 2012/2013. The objective was to find relevant parameters that could be used to determine whether a plant that was genetically modified to tolerate a herbicide contributed to sustainable development in the areas of environment/ecology, economy and society. Using the parameters as a basis, we formulated questions that must be answered to enable the evaluation of applications for approval of these plants. In addition to the questions for applicants, there are questions the Norwegian authorities should reply to. We also discuss knowledge gaps. 

The questions concerning environment/ecology are grouped into three blocks. The first concerns the herbicide­resistant plant itself, and the topics are:  

– characterisation of the plant
– interaction between plant and environment
– gene flow
– preservation of biodiversity
– comparison with control plants 

The second block concerns the herbicide the plant has been modified to tolerate, and covers the following topics:  

– characterisation of the herbicide
– effects of a change in the spraying regime on
            – preservation of biodiversity
            – the time when spraying takes place
            – drifting of the herbicide with the wind
            – the type and amount of herbicide that is used
            – the effects of using more than one herbicide in the same area
– resistance of other plants to the herbicide 

The last block concerns soil, water, energy and climate. 
The questions on sustainable development in the areas of economy and society are grouped into the following main topics:  

– the right to sufficient, safe and healthy food
– animal health and welfare
– living conditions and profitability for the farmers who cultivate herbicide­resistant genetically modified crops
– living conditions and profitability in the production area
– rules for use of herbicides
– plant genetic resources for food and agriculture
– independent risk research
– free choice of agricultural system in the future 

The questions the authorities should answer are grouped under the following topics:  

– freedom of choice for Norwegian consumers
– ecological, economic and societal consequences in Norway
– plant genetic resources for food and agriculture
– independent risk research
– the consequences of approving many different genetically modified organisms
– Norway’s North-South policy, work to protect biodiversity and international role
– prioritisation of the most important issues 

Finally, we discuss factors that we believe to be particularly important for deciding whether herbicide­resistant genetically modified crops – hereafter called HR crops – can be said to contribute to sustainable development. 

 
How to decide on an application?  

When assessing whether an HR crop contributes to sustai­nable development, there is little doubt that different groups in society will rank the priority of the various ques tions differently. It is important to bear in mind that those who incur (the potential) costs will, as a rule, not be those who reap the greatest benefits of the use of HR crops. The answers to many questions will probably also differ from one region to another and from one country to another, because it is also a question of the balance of power in soci ety. In order to assess the usefulness of genetically modi­fied plants in relation to the various types of costs arising from their use, it is therefore reasonable to view all draw­ backs and benefits in an overall context, to ensure that nothing is given lower priority at the outset.  

A case-­by-­case assessment is important because a ques­tion may be given great weight in one case and less in another. Case­-by-­case assessments must be supplemented by continuous overall assessment, to ensure that the total effect of individual decisions does not counteract our soci­etal goals. The decision must also be weighed against other instruments for implementing the policy that has been adopted.  

The consequences that approval of an HR crop will have for health and the environment must also be considered in the context of sustainable development, in which case the perspective is global and longer term than the perspective in traditional health and environmental risk assessments. The precautionary principle is one of several principles encompassed by the concept of sustainable development. This principle is applicable if it has been documented that there is uncertainty regarding our scientific understanding of adverse health and environmental effects. The Biotechnology Advisory Board has recommended that it should not be applied in order to allow uncertainty concerning negative social impacts to be decisive in assessment of an application. This is because the precautionary principle has been defined very precisely in connection with health and environmental issues, and it is important to prevent the principle from becoming diluted.  

If an HR crop has no special advantages or disadvantages compared with non-genetically modified crops in terms of economic and social parameters, and does not entail any environmental, ecological or health risk, it may be asses sed as neutral and not negative. If, on the other hand, the HR crop offers certain benefits in terms of economic and social parameters, this can count as a positive factor, without such benefits being requirements that must be met. If we are to accept greater risk or approve an application des­pite our lack of understanding, the HR crop must have clear benefits that can be said to offset its drawbacks.  

Although all the questions must be seen in an overall con­ text, it may be easier to decide an application if some ques­ tions are defined as particularly important (see chapter 5.7). If certain questions are to be given priority, weight should be attached to whether the cultivation and breeding of the HR crop or products from the HR crop may be harm­ful to plants, animals, humans or ecosystems in the short or the long term. Particular importance should be attached to irreversible adverse effects.  

The Biotechnology Advisory Board is of the opinion that the following factors are particularly important in deter mining whether an HR crop may be said to contribute to sustainable development (the factors are not ranked in order of importance):  

Environment/ecology: 

whether cultivation or use of the HR crop might be harmful to non-­target organisms, especially pollinators (see questions 4 and 7a)

whether unexpected additive or synergistic effects might occur when more than one herbicide is used in the same area (see question 7f)

whether cultivation of the HR crop may lead to more resistant weeds, and whether measures have been taken to prevent this effect (see question 8)

whether the HR crop is easily dispersed in the form of seed or pollen (see question 3)
whether the HR crop contains a gene for resistance to antibiotics (see questions 1e and 3b)  
Economy and society: 

whether the herbicide to which the plant is resistant is prohibited in Norway because it poses a risk to health or the environment, and the herbicide has the same effects in the country of cultivation as in Norway (see questions 5a and 5b)

whether the herbicide is prohibited or to be phased out under international treaties (see question 5c)
whether there are long-term effects on the health of farmers (see question 3.1a)
whether farmers receive training and protective equipment for use of the herbicide (see question 3.1b)

whether the democratic rights of other farmers are violated, i.e. whether there are rules governing co­existence (how GMOs and non­GMOs may be cultivated in the same area) and compensation for unwanted gene dispersal (see questions 4.2a and 4.2c)

whether the plant is available for independent risk research (see question 7)
whether the plant is available for further plant breeding (see question 6c)
whether farmers will be free to choose cultivation systems (conventional, organic or GMO) in the future (see question 8)  

Employment, ownership rights and the economy of the country of cultivation, whether the HR crop is to be grown in Norway or elsewhere, are among the questions that should be given lowest priority. 

Some consequences may be so serious that the answer to one single question should constitute grounds for rejec ting the application. Cases in which this must be conside­red are when  

the HR crop contains a gene or genes for resistance to antibiotics (see questions 1e and 3b, environment/ecology)

the plant is not available for independent risk research (see question 7, economy and society, and question 4, questions for the Norwegian authorities)

the herbicide to which the plant is resistant is prohibited in Norway because it poses a risk to health and the environment, and the herbicide has the same effects in the country of cultivation as in Norway (see questions 5a and 5b, economy and society)

it has been decided in international treaties that the herbicide to which the plant is resistant should be prohibited (see question 5c, economy and society)  

The questions as to whether approval of a GMO application is compatible with the political objectives of Norway’s North­-South policy, the political objecti­ves for protection of biodiversity and Norway’s role as a leading example and bridge­builder, as well as with its food policy objectives, make it possible to carry out a more holistic assessment of the sum effects of individual decisions: what direction do we want to take, and what will be the overall effect of individual decisions regarding genetically modified plants on our objectives in areas such as nutrition, food and regional development policy? These questions should also be seen in conjunction with the question of whether the HR crop prevents conversion to other agricultural systems in the future. It is the sum total of the answers to these questions that determines whether a decision supports Norway’s policy objectives. 

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