Responding to the UK government’s public consultation on gene editing

9 March 2021 — GMWatch

Quick guide for busy people

Here are some information/action points to help you respond to the DEFRA Consultation on the Regulation of Genetic Technologies. The response needs to be in by 17 March – the closing date of the consultation.

Please feel free to share the link to this page with others.

How to respond

Please see below a simple example email template which can be used to respond to the DEFRA Consultation on the Regulation of Genetic Technologies. Please enter your own details (instead of John Smith’s!) and customise the responses in your own words where possible, and then send the email to DEFRA at consultationreply@defra.gov.uk.

Please respond before 17 March 2021.

Three ways you can respond:
1) By email: Send an email as described in 1) above to consultationreply@defra.gov.uk
2) Online: Use the Citizen Space online form
The example answers in the email template can also help you answer the questions online on the citizen’s space online form.
3) Post a response to:
Consultation Coordinator
DEFRA
2nd Floor
Ross House
Kings Pool
1-2 Peasholme Green
York YO1 7PX

Submissions need to be received well before the deadline.

To submit a more detailed response, GM Freeze offers advice at: https://www.gmfreeze.org/gene-editing-consultation/

Gene-editing consultation – An introduction for people not familiar with the situation

The government is currently proposing to deregulate gene-edited crops and foods, so they will no longer be classified as genetically modified organisms (GMOs). This means that vital safety checks will be removed, and that these new experimental GMOs will not be required by law to be labelled for the consumer.

DEFRA, the Department of the Environment, Food and Rural Affairs, is now holding a public consultation on this proposal. This will close on Wednesday 17 March.

Scientists such as Dr Michael Antoniou consider that gene-edited foods could pose the same dangers as other GM foods. Contrary to the hype, the actual technology itself is not precise and leads to unintended consequences. There could be unexpected toxins and allergens, and safety checks are absolutely essential. Labelling is also essential, so that we can continue to choose what we eat.

It is vital that everyone who is concerned about protecting the safety of food, farming and the environment tells the government what they think by submitting a response. This can take just 5 minutes of your time, or you can submit a longer response.

Simple example email template for your response

Attention DEFRA: consultationreply@defra.gov.uk

Dear DEFRA,

I am submitting a response to the current Consultation on the Regulation of Genetic Technologies.

I am responding as an individual, and my contribution is NOT confidential.

I am particularly interested in crop cultivation, human foods, animal feed, animal breeding, and the environment.

Below are my answers to the questions itemised in the consultation webpage.

With best wishes

Your NAME
Your PROFESSIONAL OR OCCUPATIONAL POSITION (OPTIONAL) (e.g. Managing Director)
Your COUNTRY OF RESIDENCE
Your EMAIL ADDRESS

SECTION 2

Part 1, question 10: “Currently, organisms developed using genetic technologies such as GE are regulated as genetically modified organisms(GMOs) even if their genetic change(s) could have been produced through traditional breeding. Do you agree with this?”

YES, anything produced with gene editing should continue to be subject to present genetic modification regulations, and if anything, the regulations should be strengthened in all areas, including food, crops and the environment.

I do not agree with the assumption in this question, that GE crops and foods could have been produced by traditional breeding. There is no evidence that any gene-edited organism is the same as a traditional naturally-bred one. Gene-editing is an artificial laboratory-based procedure in which humans directly intervene in the genome to change it, with consequences that are not fully understood.

Part 1, question 11: “Do organisms produced by GE or other genetic technologies pose a similar, lesser or greater risk of harm to human health or the environment compared with their traditionally bred counterparts as a result of how they were produced?”

GREATER RISK. Plants, animals and micro-organisms produced by any kind of genetic engineering are more risky for human health and the environment than those created through traditional breeding, because of the way they were produced.

Research on gene-editing so far has shown how imprecise the technology is, and that it can give rise to unintended changes both at the intended site, and at other places in the genome. As a result in crop plants there could be unexpected toxins and allergens.

Gene-edited crops should continue to be regulated as under the current EU and UK regulation concerning GMOs, and these regulations should not be watered down in any way. Crops such as oilseed rape cross very easily with wild and cultivated relatives. Once GMOs are  released they cannot be recalled..

Part 1, question 12: “Are there any non-safety issues to consider (e.g. impacts on trade, consumer choice, intellectual property, regulatory, animal welfare or others),if organisms produced by GE or other genetic technologies, which could have been produced naturally or through traditional breeding methods, were not regulated as GMOs?”

YES, there are lots of non-safety issues to consider if organisms produced by gene editing or other genetic technologies were not regulated as GMOs. It would be hard to trade with countries that do treat them as GM (including in Europe) and having different rules in England vs Scotland, Wales and Northern Ireland would be very difficult to manage. I am concerned about the effects of gene editing on animal welfare and contamination of non-GM farms and food supplies.

Also, if gene-edited GMOs are not regulated and labelled, how would I know if they were in the food that I am buying? I would like all gene-edited GMO foods to be clearly labelled, so that I can maintain my right to choose whether or not to eat these foods.

Part 1, question 13: “What criteria should be used to determine whether an organism produced by gene editing or another genetic technology, could have been produced by traditional breeding or not?”

It does not matter whether an organism produced through gene editing could, in theory, have been produced by traditional breeding – the point is that it was not. All forms of genetic engineering, including gene-editing, should be strictly regulated, especially when it comes to our food.

SECTION 3

Part 2, question 14: “There are a number of existing, non-GM regulations that control the use of organisms and/or products derived from them. The GMO legislation applies additional controls when the organism or product has been developed using particular technologies. Do you think existing, non-GM legislation is sufficient to deal with all organisms irrespective of the way that they were produced or is additional legislation needed (in the following areas)?”

a) Cultivation of crop plants – NO, existing non-GM legislation is insufficient and additional regulation is needed.

b) Breeding farmed animals – NO, existing non-GM legislation is insufficient and additional regulation is needed.

c) Human food – NO, existing non-GM legislation is insufficient and additional regulation is needed.

d) Animal feed – NO, existing non-GM legislation is insufficient and additional regulation is needed.

e) Human and veterinary medicines – NO, existing non-GM legislation is insufficient and additional regulation is needed.

f) Other sectors/activities – NO, existing non-GM legislation is insufficient and additional regulation is needed.

Part 2, question 15: “Please describe what additional regulatory or non-regulatory measures you think are required to address these  insufficiencies (i.e. NO’s above), including any changes you think need to be made to existing non-GMO legislation. Please explain how any additional measures you identify should be triggered (for example: novelty, risk, other factors)?”

Existing GM regulations are a good starting point and should be triggered by the use of any form of genetic engineering, including gene-editing. In addition, risk assessment guidelines should be developed and strengthened to address the special risks of gene-editing technologies There should also be a proper assessment of the social, ethical and economic impacts of gene editing, including the use of patents. Ordinary people should have a proper say in what is allowed.

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