According to the main web page of the International Society for Biosafety Research, "the mission of ISBR is to promote the practice and application of science in the fields of agricultural biotechnology and environmental risk analysis. In particular, ISBR aims to encourage research which supports the safe and effective use of biotechnology in agriculture and food production and assists the development of the relevant policy and regulation." (http://isbr.info/)
We think that any reasonable person should agree with this goal, as far as "agricultural biotechnology" is defined appropriately, i.e. a broad and comprehensive approach, encompassing the whole "green" biotech area, older and newer techniques and methods, and centering on a scientifically defensible and risk-based consideration of the safety and environmental issues of each new product (crops, animals, microorganisms, and the byproducts). Such an approach should focus on the phenotypic traits of an organism, irrespective of the processes that breeders have used to obtain it. (McHughen 2016, Tagliabue 2017)
Yet, the ISBR main mission statement appears to conflict with actual practice, in that all the ISBR documents make reference to "genetically modified organisms", as if "GMOs" were the only group of agri-food products deriving from "agricultural biotechnology". That misconception feeds the popular myth that "GMOs" are in some way a meaningful category, ignoring, for example, the 3,000+ crop varieties obtained via physical/chemical mutagenesis (http://mvgs.iaea.org/) as well as untold numbers of plants obtained via wide crosses with embryo rescue (which are "transgenic" in fact, if not in name).
The biotechnology R&D community is well aware that the methods of artificial mutagenesis and wide crosses with embryo rescue have been excluded from regulation for purely political reasons. And it is well known that even the most traditional techniques can result in unsafe outputs: think, e.g., of the Lenape potato (http://boingboing.net/2013/03/25/the-case-of-the-poison-potato.html). Theoretically, any new plant variety may be quite unfriendly to an environment, e.g. invasive. Yet, for the most part, these elicit little concern if these potentially noxious organisms have been obtained via methods that don't fall into the legalistic (pseudo-)category of "GMO".
Why is this? And more to the point, why do groups such as ISBR perpetuate that meaningless dichotomy? We have never heard a satisfactory explanation of why so-called "GMOs", however defined, have been the subject of 40 years of excessive attention and regulation, while very similar products - e.g. herbicide-tolerant crops obtained by "conventional" techniques, such as the Clearfield varieties obtained by crossbreeding naturally occurring varieties (Tan et al. 2005) - are free from endless, redundant red tape, over-regulation, or even outright bans.
Similarly, if transgenesis is the (supposed) problem, why are naturally-occurring or manmade but "non-molecular transgenic plants" not of concern? Among the former is the well-known case of the sweet potato (Kyndt et al. 2015) with its natural transgenes, and dozens of other documented cases of organisms with natural transgenes (see the extensive lists in Tribe 2017). The latter include the many examples of intentional movement of genes from one species or genus to another. (Goodman et al. 1987)
As biologists, geneticists and scientific societies have pointed out countless times, scientifically this regulatory divide does not make sense. It is the persistent, pernicious error that one of us (K.A.) dubbed the "Genomic Misconception" (Ammann 2014). To explain the misconception, we refer to a seminal paper (preceded by many similar ones), by Nobel Laureate Werner Arber: "conjectural risks of genetic engineering must be of the same order as those for natural biological evolution and for conventional breeding methods. [...] There is no scientific reason to assume special long-term risks for GM crops." (Arber 2010, Abstract. For a reference list of many similar positions, see Tagliabue 2016, Miller and Conko 2004, endnotes to Chapter 3.)
With reference to the ongoing regulatory debates stimulated by the relatively new techniques of "gene editing," including TALENs, Zinc Finger Nuclease, and CRISPR-cas9, we oppose simplistic solutions that would: a) include all GE varieties in old or new regulatory law; or b) exclude all new-DNA-free new varieties from regulation. Rather we promote a stratified approach (such as described in detail in Conko et al. 2016. More discussions of such a stratified regulatory approach are in Nancy Podevin et al., Ricroch et al., Eriksson and Ammann 2017, Davison and Ammann 2017, with slightly different language.)
We would emphasize, however, that the objective of formulating more scientifically defensible and risk-based regulatory approaches cannot be merely redefining "GMO" to be more widely acceptable. Rather, they must be genuinely risk-based.
We welcome Alan Gray's answer to our letter concerning the 14th International Symposium on the Biosafety of Genetically Modified Organisms, organized by ISBR. Nevertheless, in most of the sessions, ISBR yet again reinvented the GMO-wheel. Thus, we are unpersuaded that ISBGMO is committed to dispensing with a focus on the pseudo-category of "GMO" – and all the mischief that that engenders – and to live up to the scope of its activity, which is nicely phrased at the very beginning of its mission statement (but is soon abandoned). Examining the scientific program of the June Mexico ISBGMO-meeting, we cannot discover any discussion of how to make regulation truly risk-based.
Some may feel that "GMOs," defined in some ingenious way, should be the subject of particular attention because there is much concern among the public regarding that pseudo-category. We disagree. We do not believe that that justifies contravening sound science in the formulation of public policy.
We cannot fully address this important issue in a short letter: Suffice to say here that various of the undersigned have authored articles in which it is shown that a misinterpreted concept of democracy opens the gates to the influence of detrimental ideologies and reduces science to popular whim. See, for example, Kuntz 2016, Miller 2004). Encouraging the perpetuation of the anti-scientific "GMO" meme is part of the contemporary attack on reason and on enlightened democratic values, a theme explored thoughtfully and at length (Taverne 2006).
We hope that in future more weight will be given by ISBR to the reality that genetic modification is a long-standing, seamless continuum of methods and technologies, and that risk-analysis and regulation must take that into account.
Henry Miller, Wesson Fellow, Hoover Institution, Stanford U., USA
Klaus Ammann – Prof. emeritus, U. of Bern, Neuchâtel, Switzerland, Founding member of ISBR
Marcel Kuntz – Prof. and Director of French National Centre for Scientific Research, Grenoble, France
The content of this letter has been endorsed by the following scientists:
Burachik, Moisés – International Life Sciences Institute, Argentina
Chassy Bruce – U. Illinois
Costantino Paolo – U. Roma La Sapienza
Davison John – Institut National de la Recherche Agronomique, France
de Andrade Eugénia – Instituto Nacional de Investigação Agrária e Veterinária, Portugal
DeGregori Thomas R. – U. Houston
Giddings L. Val – PhD, PrometheusAB, Inc.
Jany Klaus-Dieter – Wadi Intl U.
McHughen Alan – U.C. Riverside, Founding President of ISBR
Morandini Piero – U. Milano
Ricroch Agnès - French Academy of Agriculture
Rugini Eddo – U. della Tuscia, Italy
Sundström Jens – Swedish U. of Agricultural Sciences
Tribe David – U. Melbourne
Twardowski Tomasz – Polish Academy of Sciences
Vitale Alessandro – Consiglio Nazionale delle Ricerche, Italy
Wager Rob – U. Vancouver Island
Wojtaszek Przemyslaw – Adam Mickiewicz U., Poland
Teeri Teemu – U. Helsinki
Zilberman David – U. C. Berkeley
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