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Conko and Miller Op-Ed in The Wall Street Journal Europe<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />
One of the theoretical concerns raised about foods derived from gene-spliced, or genetically modified, plants is that consumers might experience allergic reactions to them. A panel of consultants to the United Nations' Food and Agriculture Organization and World Health Organization has proposed a protocol for the testing of such foods. Intended to guide testing in order to determine the allergenic potential of GM foods, the protocol poses questions -- such as, is the source of the introduced gene allergenic, and does the gene product resemble known allergens -- in a neat little flow chart.
Considered in a vacuum, this seems a reasonable approach. However, it ignores the realities of the development and commercialization of new plant varieties, and the way that foods derived from them traditionally are regulated. Or to be more precise, the way that they are unregulated.
New plant varieties used for food are not a new phenomenon. Dozens are produced through hybridization and other traditional methods of genetic improvement and enter the marketplace and food supply each year, without any governmental review or special labeling. A technique in use since the 1950s, induced-mutation breeding involves exposing crop plants to ionizing radiation or toxic chemicals to induce random genetic mutations. These treatments most often kill the plants (or seeds) or cause detrimental genetic changes. But on rare occasions, the result is a desirable mutation. For example, a mutation might produce a new trait in the plant that is agronomically useful, such as altered height, more seeds or larger fruit.
In these cases, breeders have knowledge of neither the exact nature of the genetic mutation that produced the useful trait, nor of what other mutations have occurred in the plant, including those that could alter the ability to cause allergic reactions. Yet the approximately 1,400 mutation-bred plant varieties from a range of different species that have been marketed in Europe and the U.S. over the last half century have been subject to no formal pre-market regulation whatever. Several, including two varieties of squash and one each of potato and celery, were found to contain dangerous levels of endogenous toxins and were subsequently banned from commerce.
Since the 1930s plant breeders have performed "wide crosses," hybridizations in which large numbers of genes are moved from one species or one genus to another to create a plant variety that does not and cannot exist in nature. Common commercial varieties derived from wide crosses include tomato, potato, oat, rice, wheat, maize, black currant, pumpkin and cotton. For example, Triticum agropyrotriticum is a relatively new manmade "species" that resulted from combining genes from bread wheat and a grass sometimes called quackgrass or couchgrass. Possessing all the chromosomes of wheat and also one entire genome from the quackgrass, T. agropyrotriticum has been independently produced in the former Soviet Union, Canada, the U.S., France, Germany and China. It is grown for both animal feed and human food.
At least in theory, several kinds of problems could result from such a genetic construction, which introduces tens of thousands of foreign genes more or less at random into an established plant variety. These include the potential for increased invasiveness of the plant in the field, and the possibility that quackgrass-derived proteins could be toxic or allergenic. But regulators have never shown the slightest concern about these possibilities. Instead of focusing regulatory attention on those products that raise risk-related issues such as allergenicity or toxicity (a "product-based" approach), their preferred regulatory trigger is merely the use of GM techniques (a "technique-based" approach).
The testing protocol for allergenicity is important because it imposes a microcosm of other standards and requirements that will, if current trends continue, be unique to GM products. These trends are contrary, however, to a broad and long-standing scientific consensus that GM techniques are a refinement, or improvement, of earlier techniques. An authoritative report last year from the Institute of Food Technologists, concluded that "the science that underlies [GM] foods does not support more stringent safety standards than those that apply to conventional foods," and that the evaluation of GM food and food ingredients "does not require a fundamental change in established principles of food safety; nor does it require a different standard of safety, even though, in fact, more information and a higher standard of safety are being required" by regulatory bodies.
By doing so, regulators arguably have adopted an approach in which there is inverse proportionality to risk. The more precisely crafted and more predictable gene-spliced organisms are subjected to far more stringent regulation than more crudely crafted organisms. (The FAO/WHO allergenicity protocol is a perfect example: No traditional food derived from a "conventionally modified" plant variety could pass such a testing regime.) This violates a cardinal principle of regulation: The degree of regulatory scrutiny should be commensurate with risk.
Like many other regulatory approaches that circumscribe only GM products, the FAO/WHO allergenicity protocol is compromised by adopting a scope that makes no scientific sense. The use of GM, a stunning refinement of older, less precise techniques, generates less uncertainty about possible untoward effects. But for GM techniques, and the foods derived from them, both the fact and degree of regulation are determined by the production methods. In effect, discriminatory regulation imposes upon them a huge, punitive tax. That is enough to doom even this superior technology.
The ultimate irony is that one of the more promising applications of GM to new food will be to reduce the allergenicity of common foods, by deleting the genes that produce the offending proteins. This would be an important achievement: More than 20 million Americans report allergies to peanuts, for example, and about 125 deaths a year are attributed to food allergy. However, until people break out in an itchy rash when confronted by flawed public policy, we're unlikely to have GM regulation that promotes such breakthroughs.
Copyright © 2001 The Wall Street Journal Europe