The Grand Old Craft of Gene-Editing: a Consultation

The technique called CRISPR (pronounced ‘crisper’, and standing for ‘clustered regularly inter-spaced short palindromic repeats’) has made genetic interventions suddenly much cheaper, quicker, and more accurate. It’s a very recent research product, the subject of 2020’s Nobel Prize in Chemistry, but already it’s boosting ambitions in the world of genetic engineering. One such ambition is, of course, the re-designing of food-plants and food-animals to fit our supposed preferences as producers and consumers. The UK’s Department of Food, Environment and Rural Affairs (Defra) wishes to enable our prompt enjoyment of these benefits by abolishing some of the restrictions and regulations to which we were formerly bound by membership of the European Community. To this end, Defra is at present inviting comments and opinions through a public consultation titled ‘The regulation of genetic technologies’. That consultation is the subject of this post, first by way of preface to it, then with some advice on how to participate, if there’s still time, or how to respond in other ways.

What Defra is most immediately wanting to de-regulate (it has some longer-term ambitions as well) is ‘gene-editing’, a term which it uses in the restricted sense of favourably altering the genetic make-up of an organism without adding any alien material (as opposed to ‘GM’, meaning genetically modified, though the terms are not officially delimited in this way, as far as I can find). It claims that this sort of alteration has been the goal of “traditional breeding” as practised by “farmers and growers” for “centuries”. You note the reassuring vocabulary. In fact when George Eustice, the Secretary of State at Defra, announced the consultation during an address to the Oxford Farming Conference in January, he used the gnarled old phrase “mother nature”.

Defra must be hoping that this sort of language will help to gain the confidence of those of us who simply shy away Egypt, 1200 bc, ploughing from any attempt to understand the scientific complexities of genetics. It’s nothing to be alarmed about, you see, just a newer way of putting the right boar to the right sows, part of the age-old pattern of man in the landscape (comforting mental picture of man with straw in mouth watching pigs copulate, while an ox-drawn plough goes by).

But if that doesn’t persuade you to let Defra go ahead unchallenged, the consultation itself may well do so. Ostensibly it’s offered to the general public. A two-page introduction to its subject matter is laid out in easy-to-manage panels, with helpful Q&A section, some reassurance about “frankenfoods”, and so on. But the questionnaire itself asks people for “not just their opinions” but also “supporting facts and reasoning”. You’ll be asked, for instance, what criteria you would propose for determining whether a gene-edited organism could indeed have been produced by traditional methods. How many members of the public, even after we’ve spelled our way through the two-page dummies’ introduction, could give a useful answer to that?

However, please don’t be put off. The questionnaire is very short, a total of six questions to deal with, and you can always leave out the “reasoning”. Then, this is a subject of enormous importance to agriculture and the animals and land roped into it. (It’s also important of course to medicine; already it has been involved in a science-scandal, because in 2018 a Chinese geneticist used CRISPR technology to gene-edit human babies. Alarming as that is, I would say that it’s the one area, our own species, where we do have some slight entitlement or at least good reason to wish to make changes.) In short, it’s something that we have to know about sooner or later. Moreover, there are great commercial interests at stake, and the consultation has brought them into sunlit view again: all the agri-business and agri-tech companies that hustle farming into its high-tech future, with their logos and their ‘visions’ (“to search and deliver practical solutions with real payback”, etc.). These will be pressing for an easier, shorter and more profitable route from lab to saleable foodstuff.

As the Soil Association (SA), which promotes organic farming and high animal welfare standards, has said, the more of us that complete this questionnaire “the more chance we have of showing the Government that UK citizens will not running otmoor pigaccept the terms of their proposal, and of preserving the integrity and trust of a farming future built on agro-ecological approaches.” In fact the Soil Association web-site is suggesting sample answers to help the amateur (as are two other organisations: see links in the notes). The SA’s answers are quite long and, rather unhelpfully, are numbered differently from the questions themselves, but of course they have authority. I shall offer some shorter, though less expert, suggestions in a moment.

Defra’s rule is that the ‘safety’ of a genetically engineered organism, plant or animal, should be judged by its resultant characteristics and not by the method of its creation: human safety, that is, which is a concern that Defra is naturally keen to deal with convincingly. So what will be the aimed-at results of gene-editing? The animals and plants, so Defra proposes, will be “stronger and healthier, and more resistant to disease”. The go-ahead farmers’ and technologists’ collective Agri-TechE (I haven’t made the name up) puts things more motivationally, asserting that their members “share a vision of increasing the productivity, profitability and sustainability [that all-purpose merit] of agriculture.” Perennial aims in farming, of course, but over the last hundred or so years, the science input has enabled them to bring into being, forpigs-2 the animals, the nightmare of factory farming, and there is no indication in Defra’s texts of any intention to revise that model as part of its so-called “green Brexit”. On the contrary, it’s clear that gene-editing, by making the animals more “resistant to disease”, will better enable them to survive and be productive (be “healthier”) in the inherently unsanitary conditions of over-crowding and stress which that system imposes upon them. It will help to make ruthless high-tech livestock farming pay.

Defra gives examples of four pioneer countries that have decided to de-regulate gene-editing, and it’s hardly an inspiring list: Australia, Japan, Argentina, and Brazil – all big exporters of animal foods, with little state interest in animal welfare (Japan’s lab-animal numbers are probably second only to the USA’s). I notice that Agri-TechE makes this same unconvincing point, but wisely omits Brazil from the list – presumably judging it to be more of a scare than an encouragement. In the USA, which Defra doesn’t seem to mention, responsibility for gene-edited farm animals was taken away from the Food and Drugs Administration on the last day of President Trump’s tenure and given to the more commercially-minded Department of Agriculture. It was a change which had been, according to the news service Politico, “a long-sought priority for the livestock industry and big businesses”. It seems that things hadn’t been moving fast enough for them under the FDA’s regulations. Even so, one notable advance had already been made: the ‘GalSafe’ pig, gene-edited to remove its ‘alpha-gal sugars’ to which some people are allergic. This advance in food-production, says Forbes magazine online, “will allow the 34,000 AGS sufferers in the nation the ability to finally eat pork.” Science: making the world better!

*                       *                       *                     *                      *

Here, anyway, are the questions posed in the consultation (abbreviated by me in places), with my comments and suggested answers, in case you would like to make an assisted submission. Of course you can give different or briefer answers, with minimum or no “reasoning”, and you can do the whole thing usefully in a few minutes. Or you can simply e-mail Defra at consultationreply@defra.gov.uk, putting ‘regulation of genetic technologies: consultation’ in the subject line.

Note that I’ve included in the first answer an absolute objection to genetic engineering of animals on principle, but have had to assume in subsequent answers that the best hope will be to protect them as well as possible, rather than to ban the practice. I’m afraid that the closing date is 17 March, which leaves little time (or none at all, if you’re reading this on a later date). As I mentioned, it’s a very short questionnaire, but if the time is too limited, or if it has already lapsed, an alternative is to write to your MP on this subject. That’s something worth doing anyway.

Part 1. Qu.10 [The first nine questions are about name, etc.]:  Currently, GE organisms are regulated in the same way as other GMOs, even if they could have been produced using traditional breeding methods. Do you agree? Yes. Who is to say with certainty that the particular changes could ever have been produced traditionally? Nor can it be assumed that such changes will be good ones except for those making them; in the case of farm animals, the ‘improvements’ will very likely be aimed at facilitating intensive conditions and higher productivity, at the expense of the animals’ well-being (a much more important consideration than mere ‘health’). I therefore state here that I strongly object to the genetic engineering of animals in principle.

 Qu.11 Do organisms produced by genetic technologies pose a similar or greater risk to human health or the environment than do their traditionally bred counterparts? Greater. Gene technologies are new and relatively untried; the changes they introduce are abrupt and unpredictable. A cautionary analogy is the introduction of alien species into new countries, usually done for simple ‘beneficial’ purposes but often with unexpected destructive results.

 Qu.12 Are there any other non-safety issues to consider, if GE organisms are not regulated in the same way as GMOs? [which they are under present EU law, as transcribed into the UK’s Environmental Protection Act 1990]? Yes. This technology seriously threatens the welfare of the animals affected, whose interests there will be no financial inducement to promote, provided they can be kept viable and made more productive. Given that the EU and the non-English UK nations show no signs of agreeing with Defra’s policy, trade with them may well be lost. Such trade in live animals as there may be will increasingly favour countries that have poor animal welfare rules and standards. Also, there is no mention, in the background material, of the patenting of organisms, and the effect this will presumably have of increasing the corporate grip on food-production.

 Qu.13 What criteria should be used to determine whether an organism produced by gene-editing or other genetic technology could have been produced traditionally? This is a highly technical question, and should surely have been presented as a choice of possibilities. In fact traditional breeding can never reliably produce single alterations such as GE aims at; the ‘tradition’ argument is beside the point.

 Part 2. [The last two questions now refer to “broad reform of legislation governing organisms produced using genetic technologies”. This is the longer-term aim I spoke of: i.e. to loosen regulation of genetic engineering of plants and animals in general.]

 Qu.14 Are the existing pre-GMO regulations that happen to cover gene-engineered organisms sufficient, or are the additional supervisions, specifically of GMO’s, a necessary supplement? [Tick-boxes for particular aspects are provided: I recommend ‘No’ to all of them. A panel for the “evidence” then follows.] Genetic engineering is developing very rapidly, and demands dedicated ethical and other checks which keep up with it. Moreover, innovation does not belong to the scientists or the users; it is a matter affecting all citizens, and their government should represent them vigilantly at every stage.

 Qu.15 If you’ve answered ‘no’ in any of the boxes in qu.14, what additional measures do you consider necessary? [This is an unreasonable question, since one would have to be familiar with all the regulations governing GM and non-GM organisms to answer it wisely, but here goes.] The present supervision provided under the 1990 Act makes a good basis for regulating all genetically engineered organisms. It is impossible to say how these might need adjusting in the light of what the consultation calls “novel organisms” in future. However, in the case of animals, if these are indeed to be genetically engineered at all, there should be a check-list of indicators to ensure that the well-being of the animals (not just their satisfactory ‘health’, which is quite compatible with serious suffering) is protected. Since much of the preparatory research will presumably have been done under the Animals (Scientific Procedures) Act 1986, that legislation might be adapted in order to assess the proposed purposes and experiences of the farm-animals subjected to this sort of genetic alteration.

Notes and references:

The consultation document is here: https://consult.defra.gov.uk/agri-food-chain-directorate/the-regulation-of-genetic-technologies/

There are two related Defra texts: the two-page introduction mentioned above, https://consult.defra.gov.uk/agri-food-chain-directorate/the-regulation-of-genetic-technologies/supporting_documents/Gene%20Editing%20Explainer.pdfand a longer ‘consultation document’ of 14 pages, which provides a preview of the questionnaire and some advice on how to complete it: https://consult.defra.gov.uk/agri-food-chain-directorate/the-regulation-of-genetic-technologies/supporting_documents/20210106%20Gene%20editing%20consultation%20document%20FINAL.pdf

The Soil Association’s advice is here: https://www.soilassociation.org/causes-campaigns/stop-genetic-modification/consultation-on-gene-editing/.  Advice is also given by two campaigning groups: Beyond GM (https://beyond-gm.org/how-to-respond-to-the-uk-consultation/) and GM Freeze (https://www.gmfreeze.org/gene-editing-consultation/).

The subject was quite helpfully discussed on BBC radio 4’s Farming Today programme for 6th March (6 minutes in), here: https://www.bbc.co.uk/programmes/m000sxxd

Other references: Agri-TechE’s web-site, a treasury of modern agri-speak, is here: https://www.agri-tech-e.co.uk/.  The “green Brexit” was promised in Defra’s publication titled Health and Harmony: the Future for Food, Farming and the Environment in a Green Brexit’. The article in Politico about control over gene-editing of farm animals in the USA is here: https://www.politico.com/news/2021/01/19/fda-hhs-genertically-modified-animals-460486. The Forbes piece is here: https://www.forbes.com/sites/jordanstrickler/2021/01/15/fda-and-usda-spar-over-genetically-engineered-animals/.

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