PUBLIC HEALTH ASSOCIATION OF ASUSTRALIA POLICY ON:

GENETICALLY MODIFIED FOODS

The Public Health Association of Australia notes that:

1. Genetically modified (GM) or engineered (GE) foods are produced using ingredients derived from genetically modified organisms, including GM microbes (e.g. yeast), crops and animals. Ingredients that have been derived from animals fed GM feed (e.g. milk, eggs, meat and honey) are also regarded as GM food by some people.

2. The potential health, environmental, social, economic, ethical and political effects of these foods have made their introduction controversial^1-3.

3. Proponents of GM food argue that gene technology has the potential to be useful in enhancing the quality, safety, nutritional value and variety of food available for human consumption and to increase the efficiency of food production and processing^2,4.

4. Critics of GM food warn that DNA inserts may interfere with the normal functioning of the host’s genes, and that there is insufficient evidence that these foods are safe for the environment and for human consumption (e.g. the potential for the production of new allergens and antibiotic resistance in GM plants).

5. The global economic, social, ethical and political implications of GM foods are largely unknown. Some of the information which does exist points to deleterious effects on health, the environment and on the social and economic milieu, particularly in developing countries^5-7. There are particular concerns about genetic contamination of the environment (e.g. 10% of the maize crop in Mexico now contains GM residues despite a ban on the planting of GM maize in that country since 1998⁸), the considerable costs of segregation and testing of conventional and organic crops for contamination with GM for labelling purposes, particularly for poor economies⁷, and the effects of monopolistic seed supplies by holders of international patents.

6. The introduction of GM food in Australia preceded the development of appropriate regulatory frameworks. Two bodies currently oversee GM foods in Australia; the Office of the Gene Technology Regulator (OGTR) regulates GM animals and crops while Food Standards Australia New Zealand (FSANZ) regulates the food derived from them.

7. The primary objectives of FSANZ are to protect public health and safety and to ensure the provision of information to consumers on which to base decision making. However, in addition, it is required to take into consideration impacts on food industry and trade.

8. The standard that defines GM food requires pre-market approval and labelling and prohibits the sale of GM food unless the specific food is included in the standard. GM food labelling laws were introduced on 7 December 2001.

9. Some States and Territories have developed moratoria on the planting of GM crops.

10. The PHAA has raised concerns about the process and scientific adequacy of FSANZ’s GM food assessments¹⁰. In particular, the PHAA is concerned that FSANZ doesn't apply the precautionary principle appropriately, doesn't allow adequate time for public consideration of assessments, places too much reliance on unpublished safety data from applicant companies, accepts inadequate sample sizes, considers GM crops that have statistically significant differences in amino acid or fatty acid compositions to be “substantially equivalent” to non GM crops and considers some GM foods to be safe for human consumption, even though testing has shown adverse effects in animal studies.

11. Further, there appear to be no safety tests on humans, most safety tests on animals involve feeding an oral gavage of the new protein expected to be found in the GM food only (not the whole food) and the animal is followed for only 7-14 days. Safety testing of the whole food is rarely done, and then, the animals are followed for only 4 weeks and health tests are minimal. On this basis, many substances that are known to cause long-term health problems in people would be considered to be safe for human consumption.

12. There are no specific surveillance systems established to determine if there are any health effects in the population due to eating GM foods.

13. There is strong demand for thorough labelling of all GM food^1,11-14. Currently, GM food labelling does not cover foods that are: made from animals fed with GM feed (eg meat, milk, eggs, honey), highly refined foods (e.g. cooking oil, sugars, starches) prepared at bakeries, restaurants or takeaways, unintentionally contaminated by up to 1% per ingredient, processed and on supermarket shelves before 7 December 2001, contain processing aids or food additives using GM microbes, or contain GM flavours present at less than 0.1%.

The Public Health Association of Australia affirms the following principles:

14. The primary objectives of food regulation and monitoring are the protection of public health and safety and the provision of information (including labelling) to consumers to ensure informed decision making.

15. The precautionary principle states that: “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context, the proponent of the activity, rather than the public, should bear the burden of proof”¹⁵. This principle should be applied to the fullest extent possible in the safety assessments of GM food as it is not yet certain whether there are serious risks to the environment or to human health involved in producing or consuming GM foods or their products, especially in the long term.

16. The regulatory process should be more independent and transparent in particular to remove any perception of conflict of interest. Public health and consumer interests must have primacy in FSANZ and not be traded-off against commercial considerations.

17. GM foods cannot be considered to be safe without (i) thorough independent animal and human safety testing that has been published in peer-reviewed journals, (ii) and evidence of safety from surveillance systems designed to detect any human illnesses associated with exposure to GM foods.

The Public Health Association of Australia believes that the following steps should be taken:

18. No further GM foods should be approved for sale without comprehensive independent safety testing being undertaken and published in peer-reviewed journals. This testing must include human health trials. Currently-approved GM foods should be subject to review using the same independent safety testing. Should any food or ingredient not meet the highest safety levels, then it should be removed from sale.

19. A more thorough labelling system should be developed which includes foods that are currently omitted from labelling. These foods are described in paragraph 13.

20. A specific surveillance system should to be established to pick-up any short- or long-term human health effects from exposure to GM foods.

21. All levels of government should impose an immediate and indefinite freeze on:

· the growing of GM food crops for commercial purposes;

· the importation of GM foods and food components; and,

· the patenting of genetic resources for food.

22. The development between OGTR and FSANZ, of the statutory responsibility and capacity to undertake:

· independent research into the effects of GM foods, including health (human and animal), environmental, social, economic, ethical and political effects and the development of a comprehensive monitoring and surveillance system to track these effects;

· widespread public consultation about the development, production and patenting of GM foods;

· modification of the current regulatory system to control the production and sale of GM foods to reflect the findings of independent research and surveillance;

· modification of the current labelling system so that consumers can easily identify GM and non GM foods and foods with GM ingredients; and

· consideration of the effects of patenting of life forms.

The Public Health Association of Australia resolves to:

23. Advocate for thorough independent safety assessments of GM foods including full animal and human testing and monitoring to strengthen the public health components of the assessment system.

24. Advocate for the thorough labelling of all GM foods as described above.

25. Advocate for the introduction of a surveillance system that monitors the potential human health impacts of GM food.

26. Communicate with public health and consumer groups and various government authorities to enhance advocacy efforts.

27. Undertake its own review of some of the applicants’ safety documents housed at FSANZ and disseminate the results.

References:

1. First Australian Consensus Conference on Gene Technology in the Food Chain, 10-11 March 1999,

website at: [http://www.austmus.gov.au/consensus/02.htm] (March 1999).

2. Jones L. Genetically modified foods. BMJ 1999; 318:581-584.

3. Dixon B. The Paradoxes of genetically modified foods. BMJ 1999; 318: 547-548.

4. Position of the American Dietetic Association: Biotechnology and the future of food, c1994, website at:

[http://www.eatright.org].

5. Risks of genetic engineering, Union of Concerned Scientists, Cambridge, website at:

[http://www.ucsusa.org/agriculture/gen.risks.html], Australian GeneEthics Network, website at:

[http://zero.com.au/agen/body_index.html], Australian Consumers Association, website at:

[http://www.choice.com.au] and Consumers International, website at:

[http://193.128.6.150/consumers/index.html].

6. British Medical Association. The Impact of Genetic Modification on Agriculture, Food and Health: An

Interim Statement. London: BMA Print and Design Unit, 1999.

7. Co-existence in European Agriculture. A report prepared by the Institute for Prospective Studies, the

European Union Joint Research Centre, for the Commission of the European Union, January 2002.

8. Special report: Genetic Contamination. New Scientist 2002; No.2347:14-17.

9. Food Standards Code, ANZFA, Canberra, 1998.

10. Comments to ANZFA about Applications A346, A362 and A363 from the Food Legislation and

Regulation Advisory Group (FLRAG) of the Public Health Association of Australia (PHAA) on behalf

of the PHAA; Comments to ANZFA about Applications A372, A375, A378 and A379 from the Food

Legislation and Regulation Advisory Group (FLRAG) of the Public Health Association of Australia

(PHAA) on behalf of the PHAA, April 2001; The problem with the safety of Roundup Ready soybeans;

PHAA Media release “Public Health Concerns about GM Foods – reply to ANZFA”, 15 February 2002.

Website at http://www.pha.org.au.

11. Taylor Nelson Sofres poll on genetic engineering for Greenpeace, April 2002.

12. ‘FED:CSIRO study finds Aussies hungry for gene information’, AAP wire service, 31 March 1999.

13. Norton J, Wood G and Lawrence G. Public acceptance of genetically-engineered foods. Paper presented

at the Forum on Critical Issues in Transnational Agri-food Systems: The Millenium and Beyond, The

Australian Sociological Association Annual Conference, Queensland University of Technology,

Brisbane, December, 1998.

14. Mark Ragg, ‘Modified food must be labelled, say 93%’, The Sydney Morning Herald, Tuesday, 3 August, 1999.

15. The Precautionary Principle, Rachel’s Environment & Health Weekly no. 586, 19 February 1998 (www.psrast.org/precaut.htm).

Reference is: Anderson L (1999). Genetic Engineering, food and our environment. A brief guide. Scribe

Publications, Melbourne.

Adopted at the 1999 Annual General Meeting of the Public Health Association of Australia, amended at 2002 AGM and revised at 2003 AGM.