The publication last week of an interesting new report 'Engineering nutrition: GM crops for global justice?' was rather overshadowed by news of the findings of the UK's GM public debate.

The Food Ethics Council (FEC) report shows why GM crops are bad news for the world's poor and hungry, demolishing arguments that GM foods are a moral crusade to feed the poor. It argues that contrary to U.S. claims, the E.U.'s caution on GM crops is unlikely to harm the world's poor and it is not 'immoral'. The new report argues that the E.U. should maintain a moratorium on GM crops until regulation is reformed to take public concerns more seriously.

Significantly, the report also rejects claims that it is in the interests of the world's poor to spend more public money on GM research. Future food security research should be driven by the needs of farmers and consumers, rather than those of international business and the scientific establishment.

This point is of critical relevance. Plant biotech institutes are increasingly running short of corporate cash and so are seeking to underwrite their reseach direction by using developing-country-related project proposals to try and lever additional support from the public purse and from major charitable foundations.

Below are excerpts from the FEC report + the summary and recommendations. The full report can be downloaded from
http://www.foodethicscouncil.org/gmnutrition.htm

The FEC is an independent group of scientists, academics and consumer representatives set up to review ethical issues in food and farming and to make recommendations for change.

EXCERPTS:

"Hungry people have become trumps in a game of high stakes, where the main players sit in Washington and Brussels." (7)

"... although three of the major organisations behind Golden Rice pledge to involve stakeholders, key strategic decisions are consistently performed in private, by bureaucrats and scientists... However, it is important that stakeholders are involved early in the research process because spending at an early stage can lock subsequent decision-makers into pursuing the same course of action... At the worst, they will be offered products in ways that they cannot refuse..." (16-17)

"We question whether a science that depends on privatising public goods to sell at premium prices can make a realistic promise to generate food security, which depends on public goods." (19)

"The litmus test for new public-private links is whether they tip [the existing public-private relationship] towards the provision of more public goods. Building PPPs into the agricultural research infrastructure appears to do the opposite, institutionalising a framework in which public goods are only produced as 'loss leaders' for commercial products. They are strategic freebies from a public-private research complex that increasingly needs to turn a profit. Public goods that offer no marketing kick-backs will not be produced." (22)

"The unsubstantiated promise that genetic engineering will 'improve' crops has been treated as an excuse to short-cut stakeholder participation in striving for food security. Great changes are needed in the relationships between public and private institutions if the agricultural research system is to contribute more to alleviating hunger. The widespread enthusiasm for PPPs is a sign of just how little these relationships are changing right now." (23)

"... reforms to EU and US agricultural and trade policies could have a far greater effect on international food security than any foreseeable technology. The argument that GM crops will contribute to food security does not only distract from these urgently needed changes. In some instances, it has been deployed to further precisely the kinds of unfair international trading relationships that contribute to food insecurity in the first place. International food security is being used as lever to promote the business interests of rich countries, rather than being valued as an end in itself." (24)

"Jules Pretty, at the University of Essex, has documented numerous instances in which community agricultural projects have drastically increased incomes and food security, as well as rehabilitating social life and the surrounding environment.  Seen from this perspective, single nutrient solutions such as Golden Rice are simplistic attempts to grapple with highly complex problems."
 
"governments often prefer incurring research and technology costs to investing in public health. Public health or development spending on problems such as vitamin A deficiency is thought of as a straight cost, rather than as an investment with obvious economic returns. By contrast, research spending is seen as pump-priming, so that spending on a technological solution to vitamin A deficiency is expected to have knock-on economic benefits. For instance, the European Commission contributed to the Golden Rice project under a programme that justifies biotechnology research spending on the grounds of boosting EU international economic competitiveness, not addressing hunger"

"The human right to food, and the injustice that many policies in rich countries exacerbate hunger in poor countries, provide a strong ethical case for considerably increasing public health and international development spending irrespective of value-for-money."

"Unless policy-makers commit now to reforming risk regulation, agricultural research and agricultural policy, a just, secure and sustainable food system will remain nothing more than a promise."
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Summary and recommendations

This report challenges the dominant view of the scientific establishment that the future of agriculture lies with genetic modification technologies. Europeans who reject genetically modified (GM) crops are being told that their worries are irrational and that they are denying the potential benefits of these crops to hungry people in poor countries.  Whilst sweeping claims that GM crops will 'feed the world' are now made less frequently than they were in the 1990s, an influential set of scientists and development professionals maintains that specific GM crops could contribute to food security. Indeed, they argue that there is a moral case for greater public sector investment in GM research because, without it, there would be little incentive for scientists to develop 'pro-poor' GM technology. They criticise blanket policy responses to GM crops, such as the moratorium that the European Union (EU) put in place in 1999, arguing that the pros and cons of GM crops must be judged case by case.

We believe that, although there are some substantial differences between GM crops, a general moratorium on their use is not only prudent but an ethical requirement. Governments of wealthy countries certainly have a duty to invest more in building international food security and food justice, but research funding should not be earmarked for GM crop development. Instead, it should be directed at projects that involve small-scale farmers and other stakeholders, from the planning phase right through to implementation. We also identify reasons why technological 'solutions' to food insecurity are often favoured in science and policy at the expense of alternatives that are potentially both more effective and more just. Our report is not a field study intended to determine, once and for all, whether GM crops are good or bad for food security. It aims to be a constructive critique of assumptions taken for granted by many scientists, policy-makers and business people.

We begin with a brief overview of current arguments promoting GM crops for food security, in which we identify commonly held, but questionable, assumptions about: (1) the evaluation of new technologies by regulators; (2) the research process; and (3) the ownership of research and technology. The three main sections of the report analyse each of these areas in turn, drawing on the example of 'Golden Rice', a strain genetically altered to contain extra ß-carotene.

 Regulation

Proponents of GM crops argue that EU regulations should be eased in the interests of food security in poor countries. They claim that the EU rules are based on a triple abuse of the precautionary principle that: requires the proponents of GM technology to prove 'zero risk', which is technically impossible; ignores the different risks and potential benefits of specific GM crops, by imposing a temporary ban on all GM crop approvals; and underplays the risks of not using GM crops. The proponents insist that GM crops should be assessed case by case.

In contrast, we argue that there are compelling practical reasons for a robust interpretation of the precautionary principle, which would justify a moratorium under specific circumstances. The precautionary principle deliberately shifts the burden of proof onto the proponents of a potentially harmful course of action. The standard of evidence that they must provide in order to prove safety depends on the social acceptability of the risks involved. If the acceptability of a risk common to different GM crops was low, yet the relevant field of risk assessment was characterised by high levels of uncertainty, then a moratorium would be the logical regulatory outcome.

We believe that a moratorium on GM crop approvals in the EU and elsewhere is an ethical requirement, though not simply for the reason just described. Risk acceptability is as important in precautionary regulation as the level of risk, yet the prevailing 'risk management' approach to regulation takes the acceptability of some potential harms for granted. For instance, regulation is currently not equipped to evaluate social or economic harms that might arise from a GM crop. Until publicly trusted mechanisms are put in place to make explicit these inevitable judgements about risk acceptability, it is essential to maintain a moratorium on approvals of GM crops because of the evident disagreement over the acceptability of their associated risks.

We recommend that:
* The UK government and the European Commission research and develop mechanisms for evaluating the social acceptability of risks, that are widely trusted by members of the public including scientists.
* The UK government and the European Commission press for the concept of risk acceptability to be pivotal in international agreements that have a precautionary element.
* Until trusted mechanisms for evaluating risk acceptability are in place, governments place moratoria on highly controversial technologies such as GM crops.
 
 Research

The proponents of GM crops for food security are not just against a moratorium - they also recommend governments to invest greater resources in GM-related research. They argue that the potential benefits of GM crops will otherwise pass by the poorest people in society, unfairly benefiting the rich.

We agree that governments should invest more in projects to promote food security. However, in earmarking these additional resources for GM-related research, the proponents endorse a model of food insecurity that favours technological solutions and denies the people affected by new technology a genuine choice over its use.

The criteria against which potential solutions to food insecurity are evaluated affect how the problem is understood. By taking cost-effectiveness for granted as the primary measure for comparing food security strategies, the GM proponents, and some of their critics, define food security in terms of narrow range of quantifiable variables. Technologies designed to meet the specified criteria may therefore perform well on paper even though in practice, because food insecurity is highly complex, they are not necessarily more effective than multidimensional strategies based on already-available knowledge and tools.

Although proponents argue that farmers and consumers should be allowed to choose whether or not to use GM crops, and accept that end-users should participate in research, the limits that they place on stakeholder involvement deny these groups a genuine say. Early-stage research investment decisions taken in private, which depend on judgements about the interests and needs of different stakeholders, can lock subsequent decision-makers into the chosen course of action. If research sponsors are to meet their self-avowed responsibilities to enhance choice for end-users, it is crucial that the concerns of those stakeholders are built into research at the earliest possible stage.

We recommend that:
* Policy approaches to alleviating hidden hunger and food insecurity involve the communities affected in defining the problem and in evaluating potential solutions.
* Food security strategies be assessed for their beneficial effect on the whole diet, taking into account the social dimensions of food insecurity.
* Food justice and food security at all levels be valued in policy as goals in themselves.
* The UK government and the European Commission invest greater resources in food security research that is driven by the demands of communities affected by food insecurity.
* Research be funded into effective means of incorporating non-specialists and stakeholders into high-level strategic science planning, ensuring that these means are also acceptable to the scientific community.
* A greater proportion of research funding is invested in cross-disciplinary programmes, in order to encourage broader approaches to addressing food security problems.

 Ownership

Private firms dominate agricultural research, particularly in biotechnology, where the private sector accounts for around 80% of spending world-wide. This skewed public-private ratio has affected the direction of research, and the kinds of technology made available. Many proponents of GM technology are concerned by this private sector dominance, arguing that the result will be GM crops produced for the benefit of rich farmers and consumers who can afford to pay a premium for them, rather than for the poor and indebted people who are commonly food insecure.

In particular, these GM proponents are concerned that privately-owned patents on basic GM-related research tools will put GM crops beyond the means of poor farmers or even gridlock the research process entirely. Several high-profile initiatives are now under way that attempt to redress this situation by brokering partnerships between public sector researchers and private patent owners.

Patenting is a means of privatising knowledge that would otherwise be publicly available, on the assumption that this process will stimulate innovation and benefit the public in the long run. Over the past 20 years, patenting has been encouraged in the public sector to generate research revenue in an economic climate of retrenchment. We argue that the deal between inventors and society has been overdrawn in agriculture, and it should be renegotiated. Agricultural research should be exempt from patenting and similar forms of 'intellectual property' (IP) protection, nationally and internationally, wherever it is shown to limit the provision of public goods. The public sector should not be required to buy back from private owners a monopoly privilege granted in the public interest.

Effective food security promotion relies on genuine public goods that can be shared and copied freely. If GM crops cannot be developed without patenting or public-private partnerships (PPPs), then that is less a reason to endorse such institutions as an indictment of the pro-poor potential of GM technology.

We recommend that:
* IP protection applied to plants or animals should not allow the owner to prevent users from re-using or developing their product.
* Non-exclusionary incentives for agricultural innovation, such as cash rewards or prizes, are introduced instead of IP.
* International IP rules be balanced by introducing comparable anti-trust and liability rules, and by enforcing other agreements on plant biodiversity and genetic resources.
* The rights of farmers to save, share and adapt seed, and to have affordable access to technology that promotes food security, overrule the privileges granted to inventors in national and international law.
* Because 'intellectual property rights' are actually intellectually-based monopoly privileges, they should be named and treated accordingly.
* Co-operation and community involvement should come before competitiveness as the catch-phrases for public sector research in the EU.
* The European Commission dedicate a portion of its research budget to fund Public Good Projects, which require that research is non-commercial and spins-off into non-profit entities rather than firms.
* PPPs are only pursued in exceptional circumstances, and are not viewed as necessary to food security.
* There is wider reform of the public sector research system, including additional state funding, to ensure that the provision of genuine public goods is its primary mission.