Thursday, March 25, 2010

The Political Framing of Genetic Engineering

One of the things that interests me so much about the GE debate is that it is one of the few issues which sets the scientific establishment and left-wing activists at odds with each other. Typically, with issues like global warming, conservation, and evolution, we see the scientific community butting heads with conservatives. (Evolution is a somewhat less relevant issue, as it arguably has few to zero policy applications, but it’s scientific denialism at the most basic level and so I thought it worth mentioning.)

But liberals, in general, are thought of as the champions of reason and rationalism. We aren’t as afraid of all that book-learnin’, and we are generally disturbed when politics or corporations or religious institutions put restrictions on scientific freedom.

I don’t mean to say that GE opponents are eschewing reason, or that there are not serious, rational, legitimate reasons to be cautious with GE technology. But it’s worth pointing out, I think, that this is one of a few areas where science is marching ahead, and it is (generally) liberals who call for moderation.

How, then, does this effect the framing of the issue? When GE cautionaries attempt to sell their point of view to the general public, how do they go about it?

Ellen Kanner writes for the Huffington Post about food issues, and in one of her recent columns I found what seemed like a fairly average treatment of the GE issue. Not overly alarmist or egregiously sloppy, but not especially rigorous either. She begins her appeal to her audience with an extended metaphor that relates farmers who purchase GMO seeds to “Jack and the Beanstalk”.

What kind of magic were these beans? It depends on who's telling the story. A biotech company like Monsanto would boast about the beans' quick growing time, the fantastic yield -- c'mon, golden eggs -- painting a happily ever after scenario.

On the other hand, there's the unintended consequences. These aren't spoken of much, but Jack the consumer might have been duped, was almost an ogre's midnight snack, who knows just how happy an ending it really is?

I have to take issue with her comparison at a semantic level: the things she mentions in the second paragraph are not “unintended consequences”. They are hypotheticals. They never actually occur in the story. Unintended consequences might be the interruption of the soil by the beanstalk’s humongous root system. Or perhaps the extermination of nonmagical beanstalks, because of the magic vine’s hyper-competitive abilities. Things that, while not mentioned by the fable, are nonetheless easy to infer. In order to have Jack eaten by the ogre, on the other hand, one must change the fundamental trajectory of the narrative.

Although, Kanner is not actually stating that Jack was eaten, is she? She is just suggesting that in some alternate universe it might have possibly occurred. This distinction is subtle. To someone reading quickly, it might not register. The part that registers—the scary message that sticks in your mind—is: Jack was almost eaten. Who knows?

Once she segues into discussing the actual issue, the article is full of similar suggestions.

Even if they deliver…all the benefits Monsanto promises, there are still unknowns and unintended consequences in every color but green.

First of all, I will assume that Kanner is using “green” as a kind of catch-all term for non-manipulated crops, because otherwise the sentence makes no sense. Even when GE has resulted in a literal color change (like that rice they are feeding to African children), it’s not like the grain was green to begin with. Secondly—she does not list the unknowns. Nowhere in the article is there a discussion of just what these consequences are, or what they could possibly be. This could be because the consequences are well-trodden ground, familiar to everyone, and do not need to be revisited. Yet in many of the liberal articles I encountered, the dangers of GE crops seemed to be taken for granted. The issue is how to protect yourself.

Kanner goes on to advise people to “eat defensively. Pass on processed products, where GMOs tend to lurk.” The word “lurk” is troubling in itself, loaded with negative connotations of deceit and mistrust. It could be a reflection of how consumers perceive themselves to have been treated by biotech companies. It could be a little blip of fearmongering. “Defensively” offers a window into the larger problem with this kind of perspective. Kanner’s article focuses almost exclusively on the potential threats that GE foods make to individual human health.

I brainstormed a little and, based on the wide range of articles I’ve encountered, came up with four categories of potential danger from GE food:

  1. Dangers to human health. I’m still not totally clear on what these are. The only references I could find were on explicitly anti-GMO sites.
  2. Dangers to the environment. (Rapid evolution of resistance, gene transfer, invasion of GE plants into wilderness)
  3. Dangers to farming. (Perpetuation of unsustainable techniques, binding of farmers to biotech companies, high cost)
  4. Dangers to scientific inquiry. (Commercial science patents limit research science opportunities, $$ from big corporations determines directions of research)

I’m sure I missed some, so feel free to add on. (also I’d like to have links in there to articles on each individual danger.) But to me it seems that of these four, the dangers to human health are the least understood, and least certain.

They are also the most personal. When trying to sell your cause to the average person, the most direct way is to say: You might be in danger. Your babies might be in danger. They are putting unknown things into your children. While the knowledge needed to understand how GE plants disrupt ecosystems, or how biotech companies exploit farmers, can feel complex and distant, this pitch provokes a visceral response.

This framing might not even be conscious. It seems to stem from the same basic desire that causes people to want to preserve wilderness and exterminate nonnative species. Nature is something pristine. We sully it with our interference. One could argue that agriculture has been, from day one, nothing but interference—but for most of history there has been a kind of rhythm to it. Just as fossil fuels have sped up our lifestyle to an injurious degree, so GE speeds up our interactions with nature until they become…unnatural.

It’s an overly romantic view, if not explicitly a bad one. Add to that all of the irate blog posts I encountered that described food as a “sacred” experience and talked about our “contract with Mother Earth”—wait. I do not mean to belittle this viewpoint. I believe that emotion and a recognition of the sacred occupy a vital place in our culture, and should be even more prominent than they currently are. But it worries me somewhat when opposition to concrete, scientific issues originates in these gut-level reactions, rather than a careful evaluation of the facts.

The more complex problems seem to originate from shoddy application and regulation of the science. But the gut-level resistance seems aimed at the actual scientific technique, which doesn’t make much sense. That kind of resistance ends up limiting scientific inquiry, which brings us back to one of the dangers we are trying to avoid.

I’m beginning to ramble, and so I’ll close now. But, some other things I wanted to (& will, hopefully) write about:

  • The right-wing framing of genetic engineering. I put on my Hazmat suit and went poking around the National Review site, the American Enterprise Institute, and RedState.com. (AEI is one of the few conservative publications I can stand to look at without breaking out in hives. NR and RS I knew about because they are made fun of so often by Wonkette. Anyone know any other ones?) I found…surprisingly little. Some of what I did find was pretty hilarious. Some of it seemed strongly opposed to GE, though for different reasons. Mostly, however, this seems to be an issue that occupies the left and the center. The right has more important things to deal with, like teabagging.
  • Michael Specter, who has this really interesting book called Denialism that devotes a chapter to the GE debate. Why people oppose it, fear it, what the truth is.
  • GE vs. GMO. The implications of terminology.
  • The development of pesticide resistance in weeds and pests that interact with GE crops. How does this compare with how resistance develops in places that use traditional pesticide applications?
  • The Union of Concerned Scientists report stating that GE crops do not significantly increase yields.
  • All that pain free livestock stuff. I can’t even wrap my head around that. What does that mean?!?!

Wednesday, March 24, 2010

"Guidelines": Affective Long Term Regulation?

Our decision to follow genetic engineering policy began with a New York Times Op-Ed Sophia shared with us. The piece, “Not Grass Fed, but at Least Pain-Free,” advocated the genetic engineering of livestock to inhibit unpleasant feelings in relation to pain. Frustrated by the postulation of such genetic engineering as a solution to the ills of factory farming, I sought to determine what legislation governed genetically engineered food animals. Upon further research, I discovered that there was, in fact, very little legislation on the subject.

 

The following article discusses the guidelines for regulation of genetically engineered animals established by the Food and Drug Administration (FDA) on January 15, 2009 (the same as those discussed in Sophia’s 3/25 response): http://www.reuters.com/article/idUSTRE50E6VQ20090115. The FDA will regulate genetically engineered animals under the Federal Food, Drug and Cosmetic Act. The measure defines a drug as “anything that changes the ‘structure or any function’ of a person or animal. The framework requires producers to describe the DNA inserted into the animals, how it behaves in the animal, and its impact on the animal’s health. The product must also be demonstrated not to differ from traditional foods. This framework would require labeling only for significant changes in the food. Consumer groups, in particular, are outraged by the lack of labeling.

           

The guidelines were subject to a sixty-day period of public comment, which seems to have been well publicized as I found several news articles covering the opening for public comment. In response to some of the 28,000 comments, FDA officials said the new guidelines “would provide a ‘rigorous and predictable science-based framework’ to review genetically engineered animals in a timely and transparent manner.” The new guidelines will exempt some genetically engineered animals (those used for research, not those designed for consumption) from the regulation process, but oblige the FDA to make public any intentions of exemption.

 

The article frames the legislation as “[bringing] the decades-old technology of genetic engineering for animals one step closer to the dinner table.” Such phrasing emphasizes the topic’s place at the center of the general public’s private lives. The dinner table, after all, serves as the ideological center of the American family, the place where families gather to share in nourishment and stories. Regardless of how the dinner table actually plays out in individual households, its invocation calls upon family values and encourages the public to become involved in the debate.

 

Much of the fear surrounding genetic engineering arises from the mysterious nature of both the science and the regulation. Although FDA officials claim increased transparency, their public discussions have not covered the process undergone by producers of genetically engineered animals. A news release on the FDA’s website does not cover the specifics of the process, nor the standards that must be met (see http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/2009/ucm109066.htm). Instead, the press release focuses on defining genetically engineered animals and suggesting potential benefits. The actual guidelines are not very accessible to the general public either, as the document (meant for producers rather than consumers) is somewhat lengthy and not particularly readable (http://www.fda.gov/downloads/AnimalVeterinary/GuidanceComplianceEnforcement/GuidanceforIndustry/UCM113903.pdf).

 

What seems to be missing from both the Reuters article and the FDA press release is a discussion of what the term “guidelines” means in the first place. To quote the FDA’s official document, “Guidance for Industry: Regulation of Genetically Engineered Animals Containing Heritable Recombinant DNA Constructs”: “This guidance represents the Food and Drug Administration’s (FDA’s) current thinking on this topic. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public” (2). The non-binding nature of these guidelines worries me. As with the EPA and other governmental institutions, each president nominates certain individuals to head the FDA. As we have seen with regard to the Endangered Species Act (ESA), these nominations can have far-reaching consequences: President George W. Bush’s nomination for Assistant Secretary of the Interior for Fish, Wildlife and Parks, Julie MacDonald, doctored scientific reports to convey less dire need for the protection of certain species. During Bush’s time in office, species awaiting review were left to sit for much longer than the maximum allotted time. The ESA is federal legislation, yet has been interpreted and implemented (or not) very differently in different administrations. The new FDA guidelines on genetically engineered animals do not even carry the weight of law, but simply reflect the “current thinking” of the administration. “Current thinking” is, inherently, subject to change; what is “current” now may not have been accepted ten years ago and may not be accepted ten years from now. What is to stop the FDA from completely disregarding these guidelines (which imply flexibility in their very name) on genetically engineered animals if federal legislation (which is much more difficult to change and requires certain actions to be taken) is not even properly followed?

 

GM Livstock: It's What's for Dinner?

(http://www.grist.org/article/and3/)

In January 2009 the Los Angeles Times brought the issue of genetically modified livestock into the public arena . The article was published in response to a recent decision placing genetically modified (GM) livestock and animal products under the same Food and Drug Association (FDA) umbrella regulating GM crops and livestock growth hormones/ antibiotics. Throughout her piece author Jill Adams presents a brief background of the GM animal debate and uses it to frame the her discussion of changes in GM animal regulation.

Incentives for genetically modifying animals come from a wide variety of backgrounds including increased meat production, healthier livestock, and decreased environmental impacts. Advocates attest that direct genetic modification is only a direct approach to the ends reached through traditional artificial selection and breeding. The ability to engineer non-species genes is only an added bonus.

Genetic engineering is accomplished by inserting selected DNA fragments into an organism's genome during early developmental. As the organism develops, each successive cell contains the insertion. Modification may alter the expression of pre-existing genes, as in the case of enhanced salmon growth hormone, or introduce new metabolic pathways such as the transformation of omega-6 fatty acids into omega-3 fatty acids in pigs.

Turning to the FDA's regulatory decision, Adams reveals that genetic modification will be regulated as a synthetic livestock drug. This decision places GM under a pre-existing framework and requires little FDA reorganization. Before approval, companies are required to prove their modification's animal, consumer, and environmental safety.

Despite strong support, several organizations have presented concerns about placing GM under the FDA. Although drugs and genetic modification may be utilized for the same affect, genes can have drastically different long-term impacts. Drugs are (primarily) contained to an individual, but genetic changes are passed to progeny and have the potential to impact non-domestic populations.

Critics are concerned not only about GM animals themselves but also the regulatory process. FDA regulation gives companies the ability to control public access to their information. This operates in strict contrast to EPA regulation which emphasizes transparency and public participation. Further complicating GM transparency is labeling controversy. Companies are not required to label products and instead are only utilized to emphasize a selling point such as leaner meat or "natural" unmodified products.

Class Connections:

This article demonstrates the impact values can have on environmental policy making. By situating GM animal discussions within the opaque FDA, it places corporate desires over consumer needs. Doing so emphasizes the values of consumption, economics, and efficiency. Instead of attempting to work with the public to create an open and co-operative approach to GMO management, regulation was shoved into best existing infrastructure. While classifying genetic modification as a new type of drug may be efficient, the FDA is not the organization best suited for the task. FDA officials who have limited experience with human health aspects of GMO's often know even less about the environmental impacts. Without EPA input, environmentalism, public opinion/ freedom of information, and thorough investigation are forced to take a back seat.

Failure to consider the wide-ranging impacts of GMO's portrays a retrospective definition of the "environment". Over the decades environment has evolved to mean not just wilderness but also human impact and environmental justice issues (Taylor). By viewing the natural world as something separate from human society, the FDA does not acknowledge the potential for GMO's to interact with native ecosystems. Interbreeding between genetically engineered and wild individual may lead to genetic modification in native populations. So far, genetic transfer has led to the creation of pesticide resistant "super weeds" but also has the potential to further endanger threatened species such as Alaskan salmon (Smithson).

Disregarding these negative impacts directly embodies two of Dave Foreman's "wilderness foe" archetypes: immaturity and cornucopians. The immaturity mindset "reject(s) efforts from society to make them behave responsibly toward Nature" and fails to see the consequences of their actions (Foreman). Instead of working to ensure that new GMO technology is environmentally-friendly, the FDA does not contract EPA help and ignores the issue completely. The FDA can further be described as cornucopians who "see all as economics" (Foreman). In addressing GM animals the primary concern has not been public health, environmental safety, or transparency but rather efficiency and company involvement. This is particularly embodied in provisions allowing companies to limit public access to their plans; they want to get GM animals into the market as fast as possible, public opinion and environmental impacts aside.

My Thoughts:

After reading through this article I was struck by the fact that although this policy went into affect over a year ago it has been received relatively little attention. Media silence screams that there must be problems. There is no way something as controversial and integral as food policy should be changed so drastically without public input.

Even if GMO regulation is not going to be moved from the FDA to EPA, transparency and public input is vitally important. While this change will slow GM animal approval, it is worth taking that extra time to make sure we get it right.

Just today an article about the discovery of "super-bugs" was published (link below). If these are the impacts we know I hate to think about those waiting to be discovered. Introducing technological advances as radical as GM livestock should operate under the precautionary principle. All avenues of possible harm should be thoroughly explored before they are introduced into the food stream and ecosystems. Opening the policy and authorization process up will enable concerned citizens and scientific specialists to have their voices heard.

Works Cited:
Forman, Dave. "All Kinds of Wilderness Foes." Wild Earth Winter 1996: 1-4.

Smithson, Shelley. "Genetically Modified Animals Could Make It to Your Plate with Minimal Testingand No Public Input." Grist. 30 July 2003. Web. .

Taylor, Dorceta E. Race, Class, Gender, and American Environmentalism. April 2002.

http://www.grist.org/article/first-came-superweeds-and-now-come-the-superbugs/