This post is by Jonny Hazell, senior policy adviser at the Royal Society, writing in a personal capacity
So much commentary on the public debate around agricultural genetic technologies begins with the assertion “we need to talk about gene editing” [1]. Why? Did we talk about other plant breeding technologies, like x-ray mutagenesis or marker assisted selection? Should we have done? Unless there’s something inherently harmful about a technology, ie you cannot use it without creating something that poses a risk to human or environmental health, then surely the important thing to discuss is the problem the technology is being used to address and the consequences of the proposed solution.
The reason we are being urged to talk about gene editing is because the current UK regulatory framework for genetically modified organisms (GMOs) focuses on the technologies involved in developing new plant and animal varieties, not the characteristics and consequences of those varieties.
The government has just begun to consult on whether some gene editing applications should be excluded from this framework. This is significant as being designated as a GMO means a new plant or animal variety has to undergo much more rigorous safety testing before it can be approved for commercial use. The costs and uncertainties of this process (passing the safety tests is no guarantee of receiving an approval) have meant European plant breeding companies have all but given up on developing GMOs.
Historically, whether a new plant or animal variety was designated as a GMO was determined by whether it contained DNA from a separate species. Gene editing blurs this sharply drawn boundary as it can be used to both move genes between species but also accelerate evolution within a species. The uncertainty this caused for regulators working within the framework of the EU’s Directive on Genetically Modified Organisms was eventually resolved by a court ruling that said all gene editing products should be treated as GMOs. The UK government disagreed with this verdict at the time, hence the consultation on whether it should take a different approach to gene editing regulation.
The wrong way to look at it
Whilst UK plant breeding companies have welcomed this consultation, it seems destined to perpetuate the unhelpful discussion of whether the technology is good or bad. This is like asking are hammers good or bad? Good if you need to put up a picture, bad if they are being used to threaten you.
Rather than focus solely on the technology, we should pay much greater attention to what the technology has been used for. This was the approach taken by my employer, the Royal Society, in its 2018 public dialogue on genetic technologies. This used case studies on a range of possible uses for genetic technologies to shed light on the purposes which were supported or opposed. Perhaps unsurprisingly, it found that people approved of uses which helped to improve human health or reduce environmental damage, and resented uses that would help sustain agricultural practices they disapproved of, such as the intensive farming of salmon.
We need to know what the public thinks
To follow this approach through into regulation would mean taking into account whether a new plant or animal variety had characteristics that supported or undermined public priorities for our agricultural system. This, in turn, begs the question of whether we know what public priorities are. Thankfully, there is a wealth of research on this. The government has been directly asking people as part of a public dialogue for the National Food Strategy. Similarly, the Food, Farming and Countryside Commission, set up by the RSA, spent seven months touring the country getting public views on what they would like to see in a post-Brexit agricultural system. Finally, my own colleagues are in the midst of a public dialogue about landscapes and how different types of land should be used. This is not a comprehensive list, but rather an indication of the evidence the government could draw on, should it wish to include public priorities in its regulatory system for genetic technologies.
To some extent, the government is already showing what it thinks public priorities for the environment are through the outcomes it chooses to subsidise as part of the new Environmental Land Management scheme. We will also have another perspective on the same question from the Trade and Agriculture Commission when it recommends what the government’s red lines in future trade negotiations should be. Having a public discussion about the objectives revealed by these policy processes would be another way of ensuring that regulation for genetic technologies is aligned with public priorities.
So, rather than spending time debating whether genetic technologies are good or bad, wouldn’t it be better instead to discuss how we make sure they are used in the way people want?
[1] Although the more commonly used term, gene editing is a subset of possible genome editing interventions. A gene refers to a specific sequence of DNA that provides the genetic instructions to produce a protein. The genome refers to the total sequence of our DNA. Some uses of genome editing tools do not target genes themselves but other parts of the DNA sequence, hence genome editing is the more comprehensive term for all possible applications of the technology. In this blog gene editing has been used for simplicity and consistency with other blogs in the series.
