ICC submission on genetic engineering - (Practical Dreamers Drop-In Centre)

Interchurch Commission on
Genetic Engineering

Submission

to the Royal Commission
on Genetic Modification

November 2000


	Submission Description Christians seeking to discern God's way as it relates to research into, and applications of, genetic modification of any living matter and its effect on the integrity of the whole of creation. Submission Executive Summary
1.	The Interchurch Commission on Genetic Engineering (ICC) represents the Anglican, Methodist and Presbyterian churches of Aotearoa/New Zealand. These mainstream churches have together approximately 1.2 million adherents. The ICC members include people with scientific, ethical, cultural and theological qualifications and expertise. The submission presented here is the outcome of the deliberations of the ICC, reports from 12 regional meetings and other consultations, the findings from a Symposium on the ethics of GE in Wellington in August 2000¹, and dialogue with church members and others. This document has as its philosophical basis, the eight ethical foundations described in the Preamble.
2.	There is public concern regarding the use of GM technologies and GM products in New Zealand. Spiritual concerns raised (Preamble and Section B (j)(v)) include a sense of humility. Do we have the 'right' to manipulate 'God's world' in this way? There is belief that we have a duty of care to the environment in which we live, and which we will leave for future generations, and a concern that we do not violate species integrity or biodiversity. The Church has a strong sense of responsibility for others and there is a commitment to ensuring that research and applications of GM technology should be made with real consideration for the needs of all people, especially the poorer countries and the disadvantaged throughout the world. Environmental issues (Section B(j)(ii)) also include the requirement that GM crops should only be used if their dissemination and physiology is substantially understood and controlled, and that the rights of others, e.g. organic farmers, are respected. We note that other people outside the church express similar concerns.
3.	Ethical concerns include the need for autonomy and the rights of all to give or withhold informed consent regarding GM. This is coupled with a fear of the unknown and a concern that there is insufficient information and understanding for people to make good decisions. There is also a conviction (Section B (b)) that the outcome of GM research and field trials is uncertain, that scientists do not 'know it all' and that there should be more research into possible long-term effects of GM products and technologies.
4.	The Churches support a bi-cultural stance and recognise the importance of the Treaty partnership. This is reflected in recognition of the Crown's responsibilities under the Treaty of Waitangi (Section B (g)) and the assertion that ERMA should listen to Maori concerns and these concerns must not be overlooked in their final decision-making (Section B (n)).
5.	The Church has concerns (Section B(d), B(h)B(j)(iii)) about the globalisation agenda of organisations such as the World Trade Organisation and the OECD, both from the point of view of a threat to our sovereignty, and the effect on poorer countries. We do not support the patenting of human genes (Section B(F)) and are particularly concerned about the possibility of exploitation of Maori or other groups in New Zealand who may be the subject of research.

6.	ICC Recommendations We ask that the Royal Commission make the following recommendations to the government: i. That an independent NZ Genetic Modification Ethics Council be set up specifically to address the ethical and spiritual concerns being raised by many New Zealanders, in relation to all GM research and applications. As new situations and ethical dilemmas will arise with new applications, this requires an ongoing process. ii. That moneys be allocated from the current public good science funding to carry out research into the ethical and spiritual implications of GM technology in New Zealand. iii. That the terms of reference of ERMA be reviewed to ensure that appropriate notice is taken of the recommendations of Maori. iv. That measures be taken to ensure that the New Zealand public is given accurate and sufficient information regarding GM, GMOs and GM products to allow it to make informed decisions to accept or reject GM technologies, including GM food. Where products are acceptable to a significant section of New Zealanders, wherever possible products alternative to GM products be available to safeguard the right of all consumers to choose. v. That the patenting of human genes be illegal in New Zealand. vi. That recognition be given to the widespread intuitive unease regarding the transfer of human genes to other species, especially to higher animals. We do not know the full implications of this sentiment for public policy. However, the transfer of human genes into higher animals should only be approved where highly focussed benefit is expected and after consultation in depth with the NZ community.

	Preamble
7.	The Interchurch Commission was formed to express balanced and considered Christian views on the issues surrounding Genetic Modification research, crops, foods and other products in Aotearoa-New Zealand. The seven commissioners represent the Anglican, Methodist and Presbyterian churches. As an Interchurch Commission we have identified eight ethical foundations on which a response on behalf of the churches can be based. These would be differently expressed by different groups within the churches, but carry the same implications. These insights have emerged from our consultations with groups of interested church people throughout the country, and from the personal enquiries we have made in our own worship settings. These eight foundational categories are as follows:
8.	1. Humility before the Creator is a fundamental attitude which allows Christians to realise that they are part of something far greater than themselves. This inspires reverence in us for that greater being of which we are no more than a tiny part, as is expressed in passages such as Genesis². "In the beginning God created the heavens and the earth", and Jesus' reaffirmation of the first great law -- "You shall love the Lord your God with all your heart, with all your soul, with all your strength, and with all your mind"³ .
9.	2. Responsibility for/to the whole of creation is another fundamental attitude. This responsibility is not only for what we may think we have power over, but also to that which gives us that power. We come from the earth, we are rooted in (or arise from) it, so that we have a two-fold responsibility, to the Creator and to creation. We find this expressed in Genesis⁴ as humankind is "made in the image of God" and "given dominion over the creation" and in the New Testament, that "the creation itself will be delivered from corruption into liberty when we responsibly take up our inheritance in Christ"⁵.
10.	3. Our being and all of creation is grounded in God. Traditionally that grounding is seen to be in the fact that we are called into being by God⁶, and this is related to the creating and sustaining activity of God through Christ.
11.	4. The truth of God is eternal, which contrasts with the fact that our knowledge in all areas is limited by time and history. We find this powerfully expressed in Job⁷ where God asks: "Where were you when I laid the foundations of the earth?" This thought is also found in later writing when we are warned that "we are in danger of becoming fools where we most profess to be wise"⁸.
12.	5. We are called into community with the faithful in Christ, and with all creatures who share the creation with us. We are taught that the proper attitude here is love and that it is good and pleasant when families dwell together in unity⁹. This ideal model includes harmony throughout creation. Love is the underlying principle here. Love is said to be the highest of the fruits of holiness. In expressing this love, the Church has concerns for the humble and needy people of the earth and does not condone the exploitation of their potential productivity, or the takeover of their traditional farming methods and their specialised knowledge of their own environment.
13.	6. We are not in complete control of our own fates in this world, there are forces at work greater than us. Today this is interpreted in many ways, the world has its natural catastrophes and accidents but the power and the riches and resources accumulated by some countries, some consortia and some companies are seen as dangerous, or mistrusted by many, on the evidence of their actions. This frequently-expressed position relates to our concerns for the disadvantaged in the world, as in point 5 above.
14.	7. The reality of sin is an undeniable strand in the faith of the Church. From Psalm 53's vision of our own sheep-like tendency to stray, we are reminded that evil comes from within and we lose ourselves in debased thoughts¹⁰. This is harsh judgement, but the history of greed, ambition and the misuse of power by many who set out to be guardians and leaders among human beings gives powerful testimony to the existence in all humans of a propensity for self-interest that allows us to be controlled by forces or motives we know are not good.
15.	8. Faith and hope are ever-renewable and powerful motivators for Christians. For the scientist, the company or the country working with GM, hope can guide and motivate so that decisions are made for good rather than evil.
16.	It is in the light of this framework that we intend to present our case in relation to genetic engineering. We will try, as far as possible, to make our submission from the position of faith but able to be shared by a number of concerned individuals whatever their personal religious or secular orientation. Our use of biblical references is an attempt to resonate with the traditions and narratives of the Church of which we are a part. We recognise that the faithful come in many colours and interpret these strands in different ways, while yet retaining the fundamental attitudes that are expressed. Our submission in its entirety will seek to give expression to the foundational categories identified above.

	Submission by Section
	Section A Recommendations
	The Warrant has set the Commission the task of receiving representations upon, inquiring into, investigating, and reporting on the items set out in Section A (1) and (2) below.
	Section A (1) A (1) the strategic options available to enable New Zealand to address, now and in the future, genetic modification, genetically modified organisms, and products.
	Section A (1) Summary Response
17.	The strategic options available to New Zealand regarding the use of GM are to become GM free, to have a total or selective moratorium on the use of GM technology or to continue to utilise GM technology. We see some advantages in a selective moratorium in that it would allow further research on environmental and safety issues and time to consider more adequately the ethical, spiritual and cultural issues. We advocate that strategies include co-operative ventures to ensure justice and equity within and without New Zealand, and to allow consultation with all groups who are involved in or are the subjects of research. Strategies for reviewing GM proposals are also discussed and it is recommended that strategies include an allocation from the existing public good science funding pool for the development of an ethical and spiritual framework.
	A (1) Response
18.	The strategic options adopted to enable New Zealand to address GM issues must demonstrate a commitment to spiritual values, ethical standards, justice and equity for all, safety and scientific value.
	Strategic options
19.	1. No GM, GMOs or GM products. One strategic option is for NZ to become and to promote itself as an "eco-nation" in which GM foods and products are not imported and GM research is not carried out. However New Zealand already has well advanced scientific research, is host to modified organisms and already has GM ingredients in the food supply. Curtailment of this work would mean a loss of expertise, intellectual property and economic opportunity and loss of benefits such as in the health-related industries.
20.	2. Moratoria on genetic modification. A total moratorium would have many of the disadvantages of Option 1. From opinions presented to the Interchurch Commission there was a wide variation in the level of confidence the scientific community was prepared to place in the integrity and safety of genetic modification processes and outcomes. Opinions ranged from very confident to 'we know so little'. Deficiencies in the knowledge base relating to the make-up and behaviour of the non-coding regions of DNA sometimes called 'junk' DNA was one frequently-cited example. A selective moratorium may be a more acceptable option, recognising public concern in some areas. To date no commercial release of GMOs has been approved in New Zealand. It may be that under a selective moratorium commercial release of GMOs at this time would not be permitted and that there would be more research on environmental and safety issues before commercial trials are approved. The ICC believe that NZ would benefit from more research into the possible long-term effects of GMOs. Clearly therefore ongoing research into benefits, risks and applications of GMOs should be valued and encouraged. There is a need for regulations which include accountability of those responsible for the commercial release of any GMOs for any adverse outcomes e.g. environmental contamination, and a monitoring system will need to be set up. A moratorium in recognition of spiritual imperatives: The partnership between the Crown representing all New Zealanders and the Hapu and Iwi of Maori so implicit in the Treaty of Waitangi requires the upholding of the spiritual values of Maori and all other New Zealanders. A moratorium on the development and exploitation of GM could be put in place until such time as the Treaty partners have agreed to procedures that ensure the scientific community and its corporate or Crown agencies adhere to explicit principles which honour the spiritual beliefs and Taonga (treasures) of the people, in particular Maori as Tangata Whenua. The role of the Crown in achieving a spiritual understanding of the processes and the ground upon which the practice and exploitation of genetic modification is built is unusual in an avowedly secular society. The Treaty partnership however does not make this distinction and encompasses the totality of life with all its taonga. The unwritten, but reported, Article Four in the Treaty of Waitangi enshrines freedom of belief in all its diversity as a recognised part of the life and being of all New Zealanders. A moratorium for the purpose of establishing an agreement on spiritual principles and practices to be observed by the GM scientific/industrial complex would ensure the deep seated spiritual feelings of the peoples of this country would not be trampled upon, damaged or ignored, sometimes to the peril of the present and following generations.
21.	3. Continue to Utilise Genetic Modification Technology. This technology at various stages of its development has been utilised in New Zealand for many years and NZ has been at the forefront of some GM research. If we are to utilise GM, GMOs and GM products in New Zealand, we should do so in the recognition that New Zealand should put in place the ethical and legal structures which will help create a climate in which New Zealand's use of the technology will: 1. Promote the view that all organisms are part of the whole of creation and that modification solely for the benefit of humankind may not necessarily be in the best interests of the created whole. 2. Ensure that there is opportunity for the continuation of GM-free agriculture by those farmers who believe their methodology is both economically and biologically sustainable and of benefit to the whole. 3. Provide ethical guidelines for investment in GM science which will return the benefits primarily to the nation where the research is carried out. Longitudinal studies will be needed to promote the biological safety of the processes and the final product. Safety will include the effects on other organisms, in addition to the effects on humans. 4. Provide the opportunity for informed choice e.g. regarding the use of GM foods and pharmaceuticals and provide alternative products produced by conventional means. Note: The Interchurch Commission notes the work of the Bench Mark Project¹¹ of a coalition of US, Canadian, UK and European Churches who are developing 'Principles for Global Corporate Responsibility'. Such a code will if adopted require Trans-national Companies to be accountable for the impact of their policies and activities on the human and natural communities where they operate and through this process of accountability to become responsible partners in the maintenance of life in all its diversity.
22.	4. Co-operative Ventures. We as the Interchurch Commission advocate the strategic option of co-operative ventures with people who are in need, having in mind the expectation that GM research can be designed to help poor countries who do not have the resources to carry out research relevant to their needs without assistance, as well as to meet our own needs. Closely related to this is the importance of cultural sensitivity and that within New Zealand and elsewhere research and applications should be planned in consultation with those groups who are to be involved in and benefit from the research.
23.	5. Strategies for Reviewing GM Proposals. Research involving genetic modification of organisms should continue to be assessed and monitored by ERMA or an equivalent body. However, as the ICC we are concerned that while ERMA considers scientific and safety issues, and carries out consultation on cultural matters, not enough consideration is given to ethical and spiritual matters. Therefore New Zealand's strategy needs to attend to these matters and requires that assessment of research looks at the larger picture of the likely outcomes in terms of the application to which results will be applied, the ethical issues involved, justice and equity in terms of who will benefit and spiritual issues, particularly in terms of species diversity, care of and responsibility for the environment and the concept that respect for the spiritual values of a community is essential for the health of that community.
24.	ERMA alone is unlikely to be able to accomplish all this and it is probable that the strategy would require another system be set up in addition to ERMA. The ICC has no wish to hinder "good" research and recognises that scientists sometimes find it time-consuming and frustrating to cope with the requirements of ERMA, and we advocate that in looking at the essential parameters we have outlined, scientists be allowed to contribute to working out the practicalities of how to accomplish appropriate review through an acceptable process.
25.	Regarding strategic options relating to importing GM products such as food, pharmaceuticals and in the future nutriceuticals, there is the same need to consider ethical issues of informed consent, autonomy and choice, and justice and equity with regard to access. This strategy requires adequate labelling of products, but informed decision by the New Zealand community, either to accept or reject the importation of a product, is not possible if there is not an understanding of the issues in the community. Therefore future strategies should include information which will enable consumers of GM products to make an informed decision and where GM products are accepted by the community as a whole, wherever possible there should be available alternatives to GM products.
26.	6. Allocation of resources for risk and ethical assessment. The ICC suggests that in allocating public moneys for scientific research, there should be a significant investment in the researching, development and communication of an ethical framework into which GM science, release and application should fit. This investment should come from the existing public good science funding pool and be seen as a logical extension and application of GM research in New Zealand.

	Section A (2) any changes considered desirable to the current legislative, regulatory, policy, or institutional arrangements for addressing, in New Zealand genetic modification, genetically modified organisms, and products
	Section A (2) Summary Response
27.	It is recommended that the terms of reference for ERMA be reviewed to ensure that adequate respect is given to the Maori point of view and that there is adequate representation of Maori. In preparation for possible future commercial release of GMOs guidelines should be drawn up to require moral, legal and financial responsibility from responsible bodies for any undesirable environmental or other outcomes. Steps should be taken to ensure that ANZFA decisions respect cultural diversity and the rights of indigenous people in New Zealand and Australia. It is advocated that an independent New Zealand GM Ethics Council be set up to look at research into the ethical and spiritual issues relevant to research, production and applications of GM, GMOs and GM products.
	A (2) Response
28.	Relevant bodies which address concerns related to genetic modification, genetically modified organisms and products include the following: Environmental Risk Management Authority (ERMA) (Works under HSNO) Hazardous Substances and Noxious Organisms Act. (HSNO) MAF Biosecurity Act Australia New Zealand Food Authority (ANZFA) National Ethics Committee on Assisted Human Reproduction (NECAHR) Standing Committee on Therapeutic Trials (SCOTT) Gene Technology Advisory Committee (GTAC) (sub-committee of Health Research Council Ethics Committee)
29.	We wish to make the following comments on some of these bodies: ERMA. We have concerns about ERMA's model of risk and benefit and query whether the committee takes adequate account of the Maori viewpoint, and whether ethical matters are given sufficient consideration (see Section B(j)(iv)) We believe that ERMA needs very clear guidelines available to researchers as to what matters must be considered, while at the same time considering research applications on a case by case basis. Regarding the future possibilities of commercial release of GMOs, there is a requirement for regulations regarding moral, legal and financial liability and accountability both from those responsible for the production and release of the GMOs and for the body responsible for approving the release. It is suggested that responsibility for these regulations could be part of the terms of reference of ERMA, so that liability statements would be part of applications for field release or commercial release of GMOs.
30.	ANZFA. The ICC ask that regulations relating to the release of GM foods and ingredients into the NZ food supply and the labelling of these foods be applied so as to ensure respect is shown to cultural diversity in NZ. Since ANZFA is a joint New Zealand and Australian body, we ask that the needs and identity of the indigenous people of Australia are also respected.
31.	New Zealand GM Ethics Council. It is suggested that an Ethics Council be set up to look at ethical issues related to research into, productions and applications of GM, GMOs and GM products. This body would produce guidelines, have a regulatory role in reviewing proposals for research and release of GMOs from an ethical and spiritual point of view, and would provide an advisory role for researchers, business and the wider community.
32.	New Zealand has been in the forefront internationally in the development of health ethics committees and in many ways these could provide a model for the development of a GM Ethics Council with terms of reference covering crops, foods and health issues, including research, production, applications and products.
33.	The ICC is aware of the high cost of compliance, both in time and financially, for those carrying out GM research in New Zealand, and would encourage improvement of the situation by the development of guidelines and adequate resources for the efficient review of proposals. At the same time the concerns of all New Zealanders must be respected and scientific validity, ethical, cultural and spiritual issues must be addressed.

	Section B Relevant Matters The Warrant has set the Commission the task of receiving representations upon, inquiring into, and investigating, the matters set out in Section B (a) - (n) below.
	Section B (a) B (a) where, how, and for what purpose genetic modification, genetically modified organisms, and products are being used in New Zealand at present. Section B (a) Summary Response
34.	The ICC acknowledges that there is a wide range of applications currently being researched and GM products being utilised in NZ. Other submitters will provide details here. In the rest of this submission we will on occasion refer to specific applications where this information helps to illustrate the point we are making.
	B(a) Response
	Section B (b) B (b) the evidence (including the scientific evidence), and the level of uncertainty, about the present and possible future use, in New Zealand, of genetic modification, genetically modified organisms, and products. Section B (b) Summary
35.	There is a high degree of uncertainty regarding GM technology in New Zealand. In particular there is a fear of unknown long-term outcomes and a feeling of powerlessness. This is particularly evident regarding GM foods, and regarding the transfer of genes across species. B (b) Response:
36.	We have become aware through regional meetings throughout NZ, a public symposium¹, media searches and consultations that many Church members are uncertain and concerned about the present and possible future applications of GM technology in NZ.
37.	We consider there is a need to have more information available to the public, even though some evidence is available¹² to suggest that public concern in relation to genetic engineering increases the more people know. I.e. the communication of more scientific information to the public will not necessarily alleviate public fears. Clearly there are deep-seated and fundamental ethical concerns to be addressed with the general public, and it cannot be assumed that all New Zealanders would accept GM 'if only they understood it better.' In New Zealand there is fear of the unknown long-term effects of certain genetic engineering applications. As an Interchurch Commission we have become aware of the fear of the unknown and of the feelings of powerlessness being experienced by people, in relation to preventing current and future applications of genetic engineering technology which are offensive to them on spiritual grounds. For example, Maori opposition to transferring human genetic information into cattle embryos (at Ruakura) was not considered sufficiently important to prevent the trial from proceeding. The overall benefits for the whole community were considered to over-rule Maori concerns. Such concerns are not alleviated by provision of more and more scientific data or concepts. Maori are not reassured for example by the scientific information that it is synthetic copies of human DNA that are used, rather than actual human DNA extracted from human tissue.
38.	Medical benefits of pharmaceuticals produced by genetic technology e.g. insulin are potentially acceptable to all people including Maori. Research into a gene encoding stomach cancer was undertaken in a joint project between a Bay of Plenty Maori family and the Cancer Genetics Laboratory at the University of Otago¹³. The isolaton of a gene which is responsible for pre-disposition to stomach cancer has led to the identification and understanding of the condition which would not have been possible otherwise. In this instance, GM was used in the development of a diagnostic tool and any financial benefits and proceeds from the outcomes of the research will be shared equally between the Maori family involved and University. It is significant to note that in this instance there was full consultation between the researchers and those involved, specific health benefits will accrue to the Maori involved and any proceeds will be shared.
	Section B (c) B (c) the risks of, and the benefits to be derived from, the use or avoidance of genetic modification, genetically modified organisms, and products in New Zealand, including: (i) the groups of persons who are likely to be advantaged by each of those benefits (ii) the groups of persons who are likely to be disadvantaged by each of those risks. Section B (c) Summary Response
39.	The benefits of the use of GM technology in New Zealand may include less use of pesticides, safer and possibly cheaper pharmaceuticals and economic advantages if GMOs or GM products are developed or utilised here. The disadvantages may include unexpected adverse effects, environmental damage, people feeling they have a lack of choice, spiritual and cultural damage to those who find GM technology offensive, the risk of losing ownership of genetic information, and the risk of damaging the organic foods industry.
40.	The benefits of avoidance of GM technology may be the belief that New Zealand has a 'clean green' image, assisting our tourist trade and affecting our own image of ourselves, and the knowledge for many that their concerns have been recognised. The risks of avoidance of GM technology is that New Zealand could lose the creativity of many scientists, and therefore problems unique to New Zealand and its fauna and flora would not be researched. If avoidance excluded the importation of GM products there could be major risks for those who are dependent on GM pharmaceuticals. B (c) Response The use of genetic modification, genetically modified organisms, and products in New Zealand.
41.	Benefits: In GM crops, there may be less use of pesticide if tox genes are put into plants, crops may be resistant to herbicides, produce may be produced out of season, produce may be longer-lasting or of better quality or flavour. Pharmaceuticals produced by GM may be safer, more available and cheaper than traditional products.
42.	Risks: Should genetic engineering and the production of certain foodstuffs and pharmaceuticals in NZ become commonplace, there is the risk of people not having a choice concerning what they eat or with what drugs they are treated. There are risks of the consumption of GM products/crops having unpredicted adverse effects. There is a risk of NZ losing our natural "clean and green" image, should genetic engineering of food crops become established in New Zealand. There is some concern that this could prevent our filling a lucrative niche market internationally, and prevent potential economic benefits from being realised. There are risks associated with field testing of genetically modified crops (public suspicion of science in this regard is high) such as the possible transfer of genes put into GM plants into neighbouring plants. Inherent in the widespread adoption of transgenic practices using higher life forms, lies the risk of spiritual damage to those who find such practices offensive or unacceptable on ethical, spiritual or theological grounds, including many Maori and others who consider it contravenes their religious beliefs. An example is the claim of Ngati Wairere that the insertion of human genetic material into cattle at Ruakura will lead to spiritual distress and death within their iwi/community, through the disruption caused to whakapapa and mauri. Whilst the scientific connection between cause and effect may not be apparent, nevertheless the risk is perceived as a very real one by those directly affected. It should be noted that Ruakura Agricultural Research Centre is based on Ngati Wairere ancestral land. There is the risk of losing ownership of genetic information and the question of patenting of genes. There is the risk of technologies developed with good intentions being highjacked for the production of GMO's for use as biological warfare agents. Organic growers in New Zealand are at risk of their crops being contaminated by GM crops and are directly disadvantaged by any move away from New Zealand agriculture being perceived to be GE free. The New Zealand economy is closely linked with the ecology of our land. There are therefore economic risks inherent in the release of any inadequately-tested GMOs into the wider environment. There is a risk of genes from New Zealand indigenous fauna and flora being patented by off-shore companies.
43.	(i) Those likely to be advantaged: Multi-national agricultural and pharmaceutical companies, recipients of genetically engineered pharmaceuticals, some farmers (perhaps) through reduced pesticide use, agricultural exporters (possibly), those involved in the risk assessment industry, those who benefit from GMO detoxification of soil and cleaning up of oil-slicks by GMO's. (ii) Those likely to be disadvantaged: Producers of organic crops, those, including many Maori, who find GM spiritually unacceptable, producers and consumers if there are unexpected side effects.
	The avoidance of genetic modification, genetically modified crops and products in New Zealand.
44.	Benefits: Maintenance of New Zealand's clean green image, which is beneficial to our tourist trade, and gives many New Zealanders a sense of pride in their country. The knowledge for many, including Maori, that their concerns have been understood and accepted, and their cultural objections respected. It is recognised that not all Maori have the same views.
45.	Risks: There is a risk of New Zealand losing the creativity of many talented scientists, should genetic engineering activities be restricted or the regulatory controls over genetic engineering intensified. There is frustration already over the amount of regulation of scientific activity already in place. Eg consultation was experienced as being too burdensome to proceed with attempts to carry out research on dying Pohutukawa trees in Northland. It is seen as undesirable to lose the knowledge base and to remove the incentive for New Zealanders to develop a career in biological science. There is a need for research to be carried out in New Zealand in order to address the many issues which are of particular significance to New Zealand e.g. possum control. There could be major risks for those who are dependent on GM pharmaceuticals, particularly as in some cases the conventional product is not readily available, or may be unsafe because of contamination from its source.
46.	Persons likely to be advantaged: Those who feel that New Zealand's clean green image is paramount and is destroyed by GM. Those who have spiritual concerns about GM technology.
47.	Persons likely to be disadvantaged: Scientists who would be unable to pursue their career in New Zealand, the people of New Zealand whose economy would be affected by this. If avoidance were to be extended to the importation of GM products, those who rely on medical products which are produced by GM could be severely disadvantaged.
	Section B (d) B (d) the international legal obligations of New Zealand in relation to genetic modification, genetically modified organisms, and products. Section B (d) Summary Response
48.	There is concern in New Zealand that we may be obliged through membership of such bodies as WTO to accept products which we do not wish to accept. We would want to avoid being legally obliged to implement specific applications of GM technology, and would see this as a threat to our sovereignty.
	B (d) Response:
49.	Many members of our Churches have significant concerns in relation to the globalisation agenda of the World Trade Organisation. We see many examples of unaccountable trans-national corporations who have economic profit for themselves as their main inspiration and commitment. Whole ecosystems have been ravaged and destroyed, and biological diversity decreased. We would want NZ to avoid being legally obliged to participate in international agreements which require us to implement specific applications of genetic modification, as this would be a threat to our sovereignty. There is concern that the issues relevant to the fundamentally important area of GM could be taken over by multi-national companies which are not primarily concerned with the welfare of all New Zealanders.

	Section B (e)
	B (e) the liability issues involved, or likely to be involved, now or in the future, in relation to the use, in New Zealand, of genetic modification, genetically modified organisms, and products.
	Section B (e) Summary Response
50.	The ICC considers that liability for the use of GM pharmaceuticals would be similar to that now in place for medical products, in particular for trial drugs. Liability would be more complex for GM crops or GMOs, but we consider that the regulatory bodies which approve research, field trials and commercial releases would be in part responsible for injury to consumers or damage to the environment, as would the companies/individuals/institutes who carry out the work. This would include responsibility for spread of GMOs in such a way as to cause damage to organic crops.
	B (e) Response
51.	We have a responsibility to protect the vulnerable and to ensure that there are disincentives in place to prevent exploitation and to protect those likely to be potentially at risk from application of certain GE technologies. The indemnity for consumers of GM pharmaceutical products would presumably be similar to that for any persons receiving medical treatment, and companies conducting research trials would be required to carry full indemnity for participants. Areas of less definable risk would be those affected by the growing of GM plants near other crops or of those experiencing side-effects which are believed to be the result of eating GM foods. Government bodies approving the use of GM products or GMOs and companies responsible for their manufacture or use would be expected to be accountable for any adverse effects, to individuals or to the environment, which result and would be liable, financially and legally.
	Section B (f) B (f) the intellectual property issues involved, or likely to be involved, now or in the future, in relation to the use in New Zealand of genetic modification, genetically modified organisms, and products. Section B (f) Summary Response.
52.	The ICC is against the patenting of human genes, but accepts the patenting of specific applications using genetic information. All research should be carried out after consultation with those who are the subject of the research or have an interest in the research, and who should share in the benefits of any financial or business outcome of the research. Neither Maori nor any other group in New Zealand should be exploited, and particular care should be accorded privacy and confidentiality issues. B (f) Response
53.	We are against the patenting of human genes and agree with the statement of the Conference of European Churches (CEC) church and society commission in opposing any attempt to establish ownership of what must be regarded as belonging to all humanity. We affirm the statement of the CEC's bioethics working group that there is "no objection to the patenting of a specific application using genetic information" but we are opposed to "the patenting of a gene sequence as such, independent of the specific application." We affirm turning down patents for human genetic material, on spiritual grounds (We belong to God).
54.	We are particularly concerned about the possibility of exploitation of Maori or any other group within New Zealand. We recommend a commitment to working together in partnership with communities who are the subject of research. Consultation with all who may have an interest in the research must begin at the planning stages and research should only be undertaken if it is likely to benefit such groups and is carried out in co-operation with those who are the subject of research. Any patents or business arrangements taken out as a result of research within New Zealand should be such as to share the benefits of research both financially and in other ways with those involved in the research and those who are the subject of the research, with economic benefits allocated in a just and equitable manner. Particular care should be accorded to privacy and confidentiality issues, and as appropriate to cultural attitude regarding ownership of information.
55.	A key principle of the United Nations Convention on Biological Diversity¹⁴ is that each country owns its own genetic resources. This carries with it an obligation to grant access to those genetic resources and also requires that intellectual property rights be respected. The genetic resources of New Zealand inherent in our indigenous flora and fauna belong to all New Zealanders under the partnership Treaty, and any granting of access to those resources must be done in accordance with Treaty obligations. Section B (g) B (g) the Crown's responsibilities under the Treaty of Waitangi in relation to genetic modification, genetically modified organisms, and products. Section B (g) Summary Response.
56.	It is the responsibility of the Crown to listen to the traditional views of Maori groups concerning GE issues. Treaty principles require that any genetic engineering of indigenous flora and fauna be planned and executed in genuine and meaningful co-operation with Maori. The Treaty of Waitangi also protects the rights of non-Maori and the cultural and spiritual values of both parties to the Treaty need to be respected. B (g) Response
57.	It is the responsibility of the Crown to listen to the traditional views of Maori groups concerning GE issues and to establish an ethical framework within which these views can be respected and taken into account. The Anglican, Methodist and Presbyterian Churches in New Zealand all have a deep commitment to honouring the Treaty of Waitangi. The Treaty of Waitangi is at the heart of our Church identity in this land. Because we are Christians in Aotearoa-NZ, which was established on the basis of a power-sharing partnership, the context in which we discuss genetic modification is uniquely distinctive.
58.	The Treaty of Waitangi also protects the rights of non-Maori, and the cultural and spiritual values of both parties to the treaty need to be protected. The Crown is the representative partner to the Treaty for all non-Maori, who should ensure that their rights are fairly represented by their treaty partner advocate, which is the Crown. The Treaty has established a partnership which we seek to honour in every area of life, for example, in the Methodist Church at Conference level, no major decision can proceed without the support of both partners (Taha Maori and Tau Iwi). The Crown has a responsibility to give real expression to treaty principles through establishing a new process whereby Maori views in relation to genetic modification, genetically modified organisms and products can be treated with greater respect than has thus far been the case. We acknowledge that there will often be more than one Maori voice on these issues, as there will be with Pakeha views.
59.	The Anglican, Methodist and Presbyterian Churches of NZ affirm the tino rangatiratanga of the Tangata Whenua of Aotearoa. We urge the Government to listen to the spiritual issues pertaining to Genetic Modification from the Maori perspective. We also have become aware of the possibility of viewing other non-human species (indigenous fauna and flora) through their relationship with the Tangata Whenua. Treaty principles therefore should require that any genetic engineering of indigenous flora and fauna be planned and executed in genuine and meaningful co-operation with Maori.
60.	ERMA does not have a spiritual mandate and has recently contracted another group to give them spiritual input. We warn against tokenism towards Maori. Having only one Maori spokesperson on ERMA for example, is inadequate (and some would say insulting). As Churches we wish to affirm the vital contribution Maori spirituality (protected under the Treaty of Waitangi) can make towards spirituality for all New Zealanders.
61.	The extent to which Maori spiritual concerns in relation to GE are genuinely heard will indicate the depth of our commitment as a nation, to the Treaty upon which our nation is founded.
62.	The Crown, having genuinely heard the concerns of the Tangata Whenua is also committed to the well-being of the whole nation, and will need great wisdom in making decisions which will be the best ones for all people in this land. We remind the government that economic and scientific goals are not the only desirable ends. Striving for physical and spiritual health is another crucial goal. Without respect for spirituality, we lose our "heart". What good does it do if we gain the whole world, but lose our "soul"?¹⁵.
63.	The Maori people of our land are the guardians of our indigenous spirituality. Under the treaty we are committed to hearing and valuing Maori spiritual perspectives. Maori members of our Churches would affirm the sacredness of all life, including the sacredness of DNA. The Treaty of Waitangi enables us all to adopt a more holistic approach to issues of genetic modification, through the respect it challenges us to exhibit towards each other's views.

	Section B (h) B (h) the global developments and issues that may influence the manner in which New Zealand may use, or limit the use of, genetic modification, genetically modified organisms, and products. Section B (h) Summary Response
64.	Global developments include changes in global climate, reduction in arable land and a trend toward monocultures. Other issues worldwide are the high level of poverty, hunger and malnutrition and the prevalence of disease in many poorer countries. Research in New Zealand and elsewhere should take into account these needs and large corporate companies and the profit motive should not dominate the direction of research. B (h) Response
65.	We are aware that we live in a world where poverty, hunger and malnutrition are widespread. We are aware of changes to global climate patterns and the reduction in arable land and the trend towards "mono-cropping". All these and other issues impinge directly upon New Zealand's stance on GM, GMOs and GM products. In relation to examining each potential application of GE technology in NZ, we need to ask whether proceeding to adopt such technology will assist with maintaining the integrity and well-being of God's creation. The Vitamin A 'golden grain' rice has been promoted as one application which may improve the nutritional status of millions of people. Such developments however need to be examined and critiqued alongside alternative potentially cheaper, less ecologically uncertain, and more culturally and ethically appropriate means of addressing nutritional deficiencies. Working towards a more just distribution of wealth and food internationally may, overall, be more significant in bringing relief to world hunger and poverty, than genetic engineering. New Zealand is in a unique location geographically and spiritually to make a significant contribution to global well-being, as has been evidence by our internationally well-known commitment to remaining a nuclear-weapons free zone.
66.	Research should take into account the needs of the world as a whole, including that of poor countries, and that large corporate companies and the profit motive should not determine the direction of research. Research should be planned to maximise benefits to humanity and to protect the environment, including in the long-term, so that benefits should far outweigh any risks and that justice and equity in terms of who will benefit should be part of the decision-making in approving research to be done in NZ. Section B (i) B (i) the opportunities that may be open to New Zealand from the use or avoidance of genetic modification, genetically modified organisms, and products. Section B (i) Summary Response
67.	Opportunities from the use of GM, GMOs and GM products in New Zealand are to improve the health of New Zealanders, to protect the environment and to safeguard indigenous flora and fauna by the development of technologies designed to control introduced pests. There is also the opportunity to devise standards and regulations regarding labelling of GM foods and their testing, and so to take a leading position globally in these areas. We also have the opportunity to research, develop and implement guidelines to prevent contamination of the environment by GMOs and GMO products.
68.	Opportunities from the avoidance of GM, GMOs and GM products. We have the opportunity to be GM food free in New Zealand, which would respect the wishes and cultural values of many people. We have the opportunity to create an organic farming system independent of GM agriculture or horticulture. In being GM-free, we would keep faith with those who believe it is inherently unacceptable to transfer genes across species barriers and therefore alter the nature of a species. B (i) Response
69.	Use of genetic modification, genetically modified organisms and products. As an Interchurch Commission we believe that scientific endeavour is part of the ongoing creativity of God and that we need to look at what are the wise applications of genetic modification in NZ.
70.	We believe that there are opportunities for improving the health of New Zealanders by the use of well-tested and proven GM pharmaceuticals, and this should include ensuring access for all members of the community.
71.	There are opportunities to protect the environment and safeguard our native flora and fauna e.g. by the use of GM to develop methods to control possums.
72.	We have the opportunity to accept or reject the importation and use of GM foods in New Zealand. Acceptance of GM foods would give us the opportunity to insist on labelling and proof of adequate testing of GM foods and the opportunity to take a leading position globally in these areas.
73.	We have the opportunity to use GMOs in agriculture and horticulture, and in doing so to set in place safeguards for the environment, and in particular to research and implement regulations which would prevent the contamination of the environment by GMOs and GM products. Avoidance of genetic modification, genetically modified organisms and products.
74.	We have the opportunity to be GM food free in NZ, which would enable us to take a leading position globally, and to respect the wishes of many New Zealanders.
75.	We have the opportunity to decide not to use GM in agriculture or horticulture, and to therefore maintain our "clean and green image" and perhaps more importantly keep faith with those who believe that it is not spiritually acceptable to alter species. We recognise that the principle of not crossing species barriers conflicts with the use of GM pharmaceuticals, but also that the benefits compared to possible risks in this area makes this acceptable to most people, including those who are concerned about species barriers.
76.	We have the opportunity to create an organic farming system in NZ and to maintain this without the use of GM agriculture or horticulture in NZ, which would make it easier to maintain organic farming in such a way that it is globally acceptable.

	Section B (j) B (j) the main areas of public interest in genetic modification, genetically modified organisms, and products, including those related to: (i) human health (including biomedical, food safety, and consumer choice) (ii) environmental matters (including biodiversity, biosecurity issues, and the health of ecosystems) (iii) economic matters (including research and innovation, business development, primary production, and exports) (iv) cultural and ethical concerns (v) spiritual concerns. Section B (j) Summary Response
77.	In human health, there is public concern that adequate information is supplied regarding pharmaceuticals and food, that there is an opportunity to give informed consent, and that there is an awareness of ethical, cultural and spiritual concerns. Short and long-term safety is an overwhelming concern for many consumers. Regarding environmental matters, there is concern to maintain the integrity and biodiversity of species and to preserve the option of organic farming for those who believe it has considerable merit. Economically there is wide concern as to who is going to benefit from GM technology and that the profit motive will overrule the needs of New Zealanders and of the disadvantaged of the world. Ethical concerns relate to informed choices, justice and equity, benefits outweighing risks, and privacy and confidentiality. Cultural concerns relate to the principles of Treaty partnership and have been addressed under Section B(g).
78.	The ICC has added the heading 'spiritual concerns' (Section B (j)(v) which are distinct from ethical and cultural concerns. They include a sense of stewardship of the earth, a sense of awe at the study of creation through science, humility in the face of the vastness of the universe, a sense of community and therefore a responsibility for one another. There is a spiritual concern that our actions are often guided by self-interest and that a sense of hope should motivate proper use of GM science. These have also been expressed in our preamble at the beginning of this submission, and they are implicit to the entirety of our submission. B(j) Response
79.	For the Interchurch Commission, our 'public' are the members of the three churches whom we represent. The main areas of public interest of which we have become aware are: B (j) (i): human health:
80.	The need for information and consultation. This is common to all areas of GM applications, both food and pharmaceuticals. There is considerable concern for short and long term safety in both these areas and a sense of danger from unforeseen outcomes. The need for awareness and consideration of spiritual concerns. The need for cultural awareness so that no-one is put in the position of having to receive medical treatment which is unacceptable for cultural reasons. B (j)(ii) environmental matters.
81.	Possible contamination of neighbouring crops or other plants by GM crops, and the unintentional spread of GM plants or other organisms throughout the environment. Related to this is a concern that organic farmers may find their crops affected by neighbouring GM crops and therefore their credibility as organic farmers would be threatened. Spiritual awareness and a need for a respect for God's creation. This is related to a concern for retaining integrity and biodiversity of species, a mainstream ecological view. B (j)(iii) economic matters
82.	There is a widely expressed concern as to who is to benefit from GM applications and that the profit motive and the requirements of corporate international companies will outweigh the needs of New Zealand, of the poor countries of the world, and of the needs of creation. There was some concern expressed about the effect on scientists if it became too difficult to carry out GM research in New Zealand and the economic effect this would have, as well as the personal effect on the scientists concerned. Questions were raised as to the costs of GM foods and other products and whether these would be cheaper or more expensive. There was a feeling that in the long-term GM medicines may be cheaper than conventional medicines. B (j)(iv) cultural and ethical concerns.
83.	The ICC provides the following general comments and references to some recent writings regarding the ethics associated with Genetic Engineering.
84.	(a) Barbara Nicholas¹⁶ has drawn attention to the limitations of traditional ethics, when it comes to gene technology. She writes: "We could reduce ethics to utilitarian or pragmatic calculations of risks and benefits, but gene technology pushes us to examine the wider frameworks within which we construct our ethics -- what does it mean to be human? How do we create meaning and value? Against what "horizon" do we understand the choices that we can now make? Gene technology is requiring that we construct a new ethics, building on what is recognised as of central importance to us, but taking into account the new possibilities that are now with us. "We cannot put new wine into old wineskins -- the results could be disastrous."
85.	(b) In April 2000 the Church of England's Ethical Investment Advisory Group (in Britain) issued a Press Release calling for the creation of a clear ethical framework for applications of crop genetic modification, whether experimental or commercial. (The Church Commissioners for England own 52,000 hectares of tenanted farmland.) Until further research has been conducted into the ecological risks, the Church of England has decided that new agricultural leases will contain a clause excluding the planting of GM crops on Church land. They state that public acceptance rests on there being a transparent, independent and robust ethical framework forming part of the regulatory process, and that not all that can be done, should be done.
86.	(c) Evans¹⁷ writes: "Ethical review of genetics research and practice has to scrutinise both its methodology and its impact generally in relation to fundamental moral considerations. We need to look at not only the realisability of worthwhile objectives, but also the impact of genetics on the values that inform human relationships like autonomy, kindness, not causing harm, dignity, truthfulness and justice". As an Interchurch Commission, we would agree.
87.	(d) In Christian ethics, genetic engineering has generally been discussed anthropocentrically as a problem of biomedical ethics and, to a lesser degree, agricultural benefits for humans, but it is also a problem of ecological ethics for humans vis-à-vis all other creatures. Like most sophisticated technologies, this one promises both potential blessings and curses, both power for good and power for evil. And the key word here is power, for genetic engineering is in large measure a question of the ethics of using and abusing power¹⁸. Under the headings Section B(j)(iv) we submit the following cultural and ethical concerns:
88.	(i) Informed consent. 'Who should decide if the risk is worth it?' A basic principle of biomedical ethics is that of 'informed consent.' The principle requires that whenever a medical or experimental procedure is to be undertaken, the persons to be affected by this procedure are made aware of the risks involved and voluntarily accept those risks in agreeing to the procedure¹⁹.
89.	As an Interchurch Commission we advocate that in the area of Genetic Modification ethical concerns similarly include the need for consumers to be able to make informed choices either to accept or reject a procedure or product. It was widely realised by those with whom we consulted that there is need for greater education and information if this is to be possible. Informed consent also implies lack of coercion and there is concern that this may be difficult when there is no conventional alternative to a GM product. The need to be able to make an informed decision applies to the New Zealand community as a whole, as well as to individuals. It is important to realise that an informed decision should not be taken to imply that if sufficient information and education is provided the community will give consent to all forms of GM.
90.	(ii) Justice and equity are essential Christian values, and in the area of GM products it is necessary to ensure that benefits are available to all. The Church affirms God's preferential concern for the poor, and so GM research must attend to the needs of the poor countries. It is also emphasised that GM technology must not be imposed on any culture.
91.	(iii) Benefits must outweigh the risks. Risks in this sense include the risk of emotional and spiritual harm as well as physiological harm. In some areas e.g. GM medicines, this was seen by many as outweighing principles such as not crossing species barriers e.g. in the production of medically active human proteins in other organisms in the manufacture of GM products of proven or potential benefit for sufferers of diabetes, cystic fibrosis and multiple sclerosis. However, for some people, while there was an acceptance of human proteins being produced in bacteria and yeast, the unease with the production of human proteins in higher animals such as sheep or cattle outweighed the potential benefits. Safety of pharmaceutical products is an ethical concern and it is recognised that in some instances there is greater safety in GM medical products e.g. where the alternative involves the risk of contamination from blood products. It is the task of bio-ethicists and theologians to provide a vision which will ensure that transgenic technology, if it is to be utilised at all, is applied in a wholesome and creative manner, to alleviate suffering and to assist with the establishment of a greater degree of well-being worldwide. Guidelines need to be prepared which will expand this vision to ensure that genetic engineering is not used to damage any component of creation²⁰.
92.	(iv) Cultural concerns relate to the principles of Treaty partnership and have been addressed under Section B(g). We add here that Harry et al²¹ believe that genetic research ethics, to date, have failed to adequately address the concerns of indigenous peoples. They conclude "It has become evident that this new area of science and technology poses new challenges with regard to existing ethical practices." As an Interchurch Commission, we consider the recently published primer and resource guide "Indigenous Peoples, Genes and Genetics"²¹ includes a very helpful introduction to the technology and is worthy of widespread circulation. B (j)(v) spiritual concerns.
93.	The ICC has added an additional heading 'spiritual concerns.' This is in addition to and distinct from ethical and cultural concerns. The tenets which give rise to spiritual concerns are described in the Preamble at the beginning of this submission.
94.	The 'public' for the ICC have expressed the following spiritual interests and concerns:
95.	(i). There is broad agreement with the tendency of the indigenous peoples to have an attitude of reverence to that which has given us birth. The world as we have it has a history of eons of time in comparison to which the human race is a mere flicker, but we hold the destiny of creation in our ever more powerful technologically-equipped hands. The Being of which we are a small part encloses us and nurtures us in ways we barely understand. There is a strong sense of stewardship of the earth and a concern therefore that in careless manipulation of the flora and fauna of New Zealand we may inflict permanent and unpredicted damage on our environment.
96.	(ii) There is a sense that we have an awesome responsibility on account of the power we have fashioned for ourselves. We can alter the future of the biosphere in a myriad ways, some of which are more contained than others. We are so capable because science has delivered this capability to manipulate the origins of ourselves and other creatures but we need to curb our natural hubris in this area and think of the awe with which we should approach a delicate balance which has been slowly evolving to its present state since before recorded time. We are not the autonomous masters of a world which belongs to us for our exclusive use. Rather, we are the inheritors of something that we have received as a precious gift in which many interwoven forces are bound up. We must be responsible in the use of the power we have and not get led astray by what seems a good idea at present, unless we understand significantly what its impact on our inheritance will be. To do less is to be negligent with a trust which we hold from all those who have gone before and for all those who will follow us.
97.	(iii) There is a general belief that the distinctions between species, although not absolute, are very deep-seated and represent major biological divides that define us as beings. There is a sense of awe at the conservative basis of embryonic development, in which there is a very delicate balance of many factors and a slight modification may have a profound effect. There is a concern that transgenic studies and the potential modification of our own gene pool by transgenic engineering threaten inter-species boundaries in ways which threaten the distinctness on which much of our thought and attitudes are based. Many hold to the belief that roots, origins or lineages have their own integrity and contain the basis of our belonging to families, groups, societies, and our own history. We have a responsibility to keep the treasure we have been given intact for future generations. There is also fear that as a result of manipulating the human genome we may come to see ourselves as commodities able to be manufactured to requirements rather than unique beings whose creation involves a certain mystery. It is recognised that some pain and suffering may in the future be ameliorated by genetic intervention, but there is a real fear of GM being used in the future to make 'designer babies' or to carry out an unnatural selection of unborn children for particular traits.
98.	(iv) There is a strong awareness that our knowledge is partial and our ability to predict the future is also partial. We see in a glass darkly and sometimes miss the interconnectedness of all things. Sometimes this makes a mockery of our sense of what is good to do and what should be approached with doubt and caution. There is a fear that decisions may be made which are irreversible and which we may regret. Choices are in order here but they need to be adequately informed and that puts a high threshold on the degree of scientific certainty we need to proceed with assurance.
99.	It is generally considered that medical Genetic Engineering is better understood, and the anticipated results are more predictable, than with other applications of GE. The use of GE material for medical purposes under strictly controlled laboratory conditions and for circumscribed therapeutic indications is therefore regarded quite differently from the wider field trials which might be used in the agricultural setting, with the potentially ramifying implications that such use might have for the environment in general. The benefit of GM products in medicine is readily seen, and while there is obviously a profit motive in the development of pharmaceuticals, the development of GM pharmaceuticals is seen by most as more motivated by caring and designed to promote the well-being of consumers than are other applications.
100.	(v). The Church is very aware that we are part of a community in which care for one another is indispensable. There is knowledge that we are co-dependent and bound together not only with other members of the human race but with other organisms in the biosphere. Much of the knowledge delivered by science is a part of the technological endeavour by which we extend our control over nature. This is nowhere more obvious than in genetic engineering and it is unclear to much of the Church whether this attitude of manipulation and alteration to suit our own narrow purposes is an appropriate one for us to adopt. The Church has particular empathy for people with disabilities, who frequently feel their worth is brought into question in the light of investigations about pre-birth, or even pre-implantation, diagnosis of genetically inherited differences, with possible consequences of abortion or selection. On the other hand it is recognised there is suffering brought about by genetic diseases which can and will be alleviated if we isolate the genetic origins of such diseases. Here our efforts are fashioned in love and concern for the integrity and life of the individuals whose origins are being studied, such as in the research on the stomach cancer gene which has been carried out in the Bay of Plenty.
101.	(vi) All consultations within the Church revealed a fear of the power of 'Multinationals' and 'Corporate Companies' to control and dominate what is done in the field of GE. It is widely believed that we are substantially controlled by supra-individual even supra-national forces which may have little to do with attitudes of care and the integrity of communities of human beings. The rise of genetic technology in the hands of these powerful agencies is therefore a cause for concern and a reason to impose real and robust safeguards into the use of genetics in the New Zealand setting. This concern was related to the sense of being part of a worldwide community and of owing a duty of care to those in poor countries, whose livelihood, and indeed existence, may be affected by the use of GM technology which does not take into account the well-being of those who are most affected. While it was agreed that in some instances there may be beneficial outcomes in helping food production in poor countries, even in such a situation it is considered that the principles of autonomy and informed consent (or refusal) by the whole community must prevail.
102.	(vii) The Church recognises that self-interest is a driving force in much of what we do, including in the use of GM, and it is recognised that there is a human propensity to do what is less than good for reasons which the church has called sin. It is a sad testimony of history that self interest and less than ethical reasons will often foster the rise of injustice, exploitation, and abuse at the expense of the general population. We need to be alert to this possibility if we adopt even a limited range of genetic technologies into New Zealand.
	Section B (k) B (k) the key strategic issues drawing on ethical, cultural, environmental, social, and economic risks and benefits arising from the use of genetic modification, genetically modified organisms, and products. Section B (k) Summary Response
103.	The key strategic issues as seen by the ICC are respect for autonomy for all individuals, respect for the environment, respect for the integrity of species, justice and equity to ensure that all will benefit from any applications of GM technology and the recognition of scientific endeavours as an expression of human creativity. B (k) Response
104.	The key strategic issues as seen by the Inter-church Commission and from consultation with church members are:
105.	The need for respect for autonomy so that consumers will have a choice, particularly in the areas of GM foods. This includes a need for adequate and clear labelling to enable potential consumers, both as individuals or communities, to accept or reject GM products.
106.	Respect for the environment so that changes introduced into organisms will not be disseminated throughout the environment, or impact on the environment in other unforeseen ways.
107.	Respect for the integrity of species, so that cross-species transfer of genes will not be made without there being a major benefit for a significant portion of humankind.
108.	Justice and equity to ensure that all will have the opportunity, if they wish, to benefit from use made of GM applications. This includes concern for the use of GM applications outside New Zealand, and that effort and funding will not be diverted into GM research and development at the expense of other measures which could improve the production and distribution of food in poor countries.
109.	Recognition and upholding of scientific endeavours in GM research, as this is an expression of human creativity. Section B (l) B (l) the international implications, in relation to both New Zealand's binding international obligations and New Zealand's foreign and trade policy, of any measures that New Zealand might take with regard to genetic modification, genetically modified organisms, and products, including the costs and risks associated with particular options. Section B (l) Summary Response B (l) Response
110.	If there are international obligations which NZ is required to fulfil, the principle of our sovereignity should take precedence in allowing us to act according to the ethical, spiritual and cultural values of New Zealanders.

	Section B (m) B (m) The range of strategic outcomes for the future application or avoidance of genetic modification, genetically modified organisms, and products in New Zealand. Section B (m) Summary Response
111.	Desirable strategic outcomes from the use of GM technology in New Zealand could include improved understanding within our community as we work through accepting one another's cultural and spiritual needs, maintenance and protection of the environment and improved health in wise use of GM products.
112.	Adverse strategic outcome might include harm to the spiritual health of those who are left no option but to accept technologies which they find culturally unacceptable, adverse results from unpredicted risks from GM foods or other products, damage to the environment by e.g. alteration of the balance by the indiscriminate use of insecticide genes in plants. In particular, there are wider ecological implications in the decay cycle of GM crops and possible effects on soil/water/biota. B (m) Response
113.	Desirable strategic outcomes from the future application of GM, GMOs and GM products in New Zealand could include: Improved understanding between groups in the community as we respect one another's spiritual and cultural needs. Protection and maintenance of the environment of New Zealand for future generations, by the use of GM technology for the control of pests which have an adverse effect on our fauna and flora. Improved health of New Zealanders from the use of tested and proven GM health products.
114.	Adverse outcomes could include non-beneficial effects in the environment e.g. promulgation of plants with herbicide resistance may lead to weeds becoming tolerant to herbicides, growth of plants containing insecticide genes may affect desirable insects. The spiritual and emotional health of those who feel that they are forced to accept technologies, including GM foods and pharmaceuticals, which they find culturally or ethically offensive, could be adversely affected. Section B (n) B(n) whether the statutory and regulatory processes controlling genetic modification, genetically modified organisms, and products in New Zealand are adequate to address the strategic outcomes that, in your opinion, are desirable, and whether any legislative, regulatory, policy, or other changes are needed to enable New Zealand to achieve these outcomes. Section B (n) Summary Response
115.	It is recognised that considerable time is allocated by ERMA to listening to the viewpoint of Maori, but Terms of Reference of ERMA should be reviewed to ensure that the viewpoint of Maori is not only heard but is taken into account. ERMA's regulations should be enlarged to take into account the regulations which should be in place before the commercial release of GMOs is approved. There is a need for regulations which govern the conditions of commercial release as they may affect the environment, and there has to be adequate regulation for legal and financial responsibility for damage to the environment or injury to consumers. It is suggested that an independent NZ GM Ethics Council be set up and this is addressed in Section A(2). B (n) Response
116.	Statutory and regulatory processes associated with genetic modification include the following:
117.	ERMA ERMA, operating under HSNO, is responsible for approving GM research and field trials. ERMA does not appear to include in its brief looking at such ethical issues as who will benefit and what is the expected outcome in terms of cost to consumers. Approval by ERMA should include an agreement that companies/organizations/researchers be liable morally, legally and financially for damage to the environment and to consumers of GM products (Liability agreements for non public good research as required by Regional Health Ethics committees and the ARCI would be a guide here). It seems unclear how much ERMA is obliged to take account of consultation with Maori and this needs to be reviewed to ensure there is true consultation and Maori concerns cannot be overlooked. It is recognised that there are difficulties in that not all Maori will have the same requirements and opinions.
118.	Commercial release. To date there has not been a commercial release of GMOs in New Zealand. When proponents of a field trial progress to the stage of applying for commercial release, further safeguards will be needed. Under the present position, a commercial release would be unconditional and without safeguards. A system should be set up now, before the position arises, to define monitoring of commercial releases, regulations re safeguards of the environment and consumers, and requiring liability clauses regarding harm to the environment or to consumers.
119.	NECAHR. Assisted human reproduction research and innovative treatment is subject to ethical review by NECAHR. This committee is presently under the Minister of Health, but will be in statute when an ART becomes law.
120.	GTAC. This committee provides advice to accredited ethics committees regarding proposals which include the introduction of nucleic acids (generally manipulated or synthesised in the laboratory) or GM micro-organisms, viruses or cells into human subjects for gene therapy or cell marking, or Proposals in which the introduction of nucleic acids (generally manipulated or synthesised in the laboratory) or genetically manipulated micro-organisms, viruses or cells is designed to stimulate an immune response against the subject's own cells as in the treatment of certain cancers.
121.	In advising on gene therapy, it is necessary for GTAC to respect the difference seen between somatic gene therapy and inherited gene therapy. Currently no approval has been given for gene therapy of reproductive cells. In our experience there are concerns ethically and spiritually about changing a person's DNA, whether the change is inherited or not, but the concerns are greater if the change is inherited. On the other hand, there is also recognition that it may be a 'good thing' to correct a faulty gene and therefore treat a person's illness. The question is raised as to whether GTAC has input from Maori and from laypersons in the general public to facilitate discussion of ethical and cultural issues.
122.	GM Ethics Council We have suggested in Section A(2) that an independent New Zealand Genetics Modification Ethics Council be set up to look into the ethical issues related to GM technology. There should also be a mechanism for ongoing ethical review of GM applications. It may be that a GM Council would both produce guidelines and review GM applications. This is discussed under Section A(2).

	Members of the Interchurch Commission Dr Audrey Jarvis, Chairperson Dr Vivienne Burrows Rev. Dr Joseph Bush Dr Chris Downs Professor Grant Gillett Rev. Greg Hughson Ms Maree Pene Support persons for the Commission Richard Davis Stephanie McIntyre Rev. Jim Greenaway References: 1. Will the ENZ Justify the Genes? Symposium on the ethics of Genetic Engineering. Wellington August 2000. Proc. Pub.Capital City Forum, Wellington. 2. Genesis.1:1 3. Luke 10:27 4. Genesis. 1:26 5. Romans 8:20 6. Psalm 149;14 7. Job 38:4 8. Romans 1:21,22 9. Psalm 133 10. Psalm 53 11. Ecumenical Council for Corporate Responsibility (1998). Principles for global responsibility. ECCR. PO Box 4317, Bishop's Stortford. CM22. UK 12. Smaglik, P. (2000) Educated US public get more wary of genetic engineering. Nature 405: 988. 13. Guilford, P., Hopkins, J., Harraway, J., McLeod, M., McLeod, N., Harawira, P., Taite, H., Scoular, R., Miller, A. and Reeve, A.E. (1998) E-cadherin germline mutations in familial gastric cancer. Nature 392: 402-405 14. Calhoun, D. (2000) Who owns plants and who owns genes? in Designer Genes: The NZ guide to the issues and facts and theories about genetic engineering, p119. Pub. Dark Horse, Wellington. 15. Matthew 16:22 16. Nicholas, B. (1997) "Gene Technology and Ethics: New Wine in Old Wineskins. Otago Bioethics Report 6: (3),10-13 . 17. Evans, D. (2000) ."Ethics and Genetics" in Designer Genes : The NZ guide to the issues and facts and theories about genetic engineering, p 27. Pub. Dark Horse, Wellington. 18. Nash, J.A. (1991) Genetic powers Excerpted from LOVING NATURE: Ecological Integrity and Christian Responsibility, James A. Nash (Abingdon Press, Nashville in cooperation with The Churches' Center for Theology and Public Policy, Washington, DC1991),pp.59-63. http://www.pq.godzone.net.nz/ge/jamesnash.html 19. Bush, J. (1999). Rhetoric and risk in Genetic Modification. Crosslink, November 1999, http://www.pq.godzone.net.nz/ge/gebush.htm 20. Hughson, G.A. (1993) Theogenethics and the Integrity of Creation. Methodist Theological Review 2: pp 12-17 http://www.pq.godzone.net.nz/theogen.html 21. Harry, D., Howard, S. and Shelton, B L (2000). Indigenous Peoples, genes and genetics. What indigenous people should know about biocolonialism: A primer and Resource Guide In "Indigenous Peoples Council on Biocolonialism, May 2000

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Interchurch Commission onGenetic Engineering

Submission

to the Royal Commissionon Genetic Modification

November 2000

Submission Description

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ICC Recommendations

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Section A Recommendations

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A (1) Response

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A (2) Response

Section B Relevant Matters

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B (b) Response:

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Section B (d) Summary Response

B (d) Response:

Section B (e) Summary Response

B (e) Response

Section B (f) Summary Response.

B (f) Response

Section B (g) Summary Response.

B (g) Response

Section B (h) Summary Response

B (h) Response

Section B (i) Summary Response

B (i) Response

Section B (j) Summary Response

Section B (k) Summary Response

B (k) Response

Summary Response

Section B (m) Summary Response

B (m) Response

Section B (n) Summary Response

B (n) Response

Members of the Interchurch Commission

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References:

Interchurch Commission on
Genetic Engineering

to the Royal Commission
on Genetic Modification