2008 Letter to Councils

7 February 2008

The Councillors and CEOs of all Regional, District and City Councils in New Zealand

LONG TERM COUNCIL CUMMUNITY PLANS 2008

The Trustees thank Councils for their generally positive responses to our submission in 2006 and ask that you please take into consideration the following:

Genetic Engineering Technology

We remind Councils of their need to monitor developments in genetic engineering technology and the potential impacts of GE on their local community and environment.

Currently, this particularly includes the Food Standards Australia New Zealand (FSANZ) approval of Application A549 High Lysine Corn (LY038). Shipments and handling present the opportunity for co-mingling with corn imported for human food production. FSANZ acknowledge this can occur. Where whole seed is imported, there is the potential for co-mingling and/or contamination of conventional varieties of corn seed grown commercially as food crops. Such contamination is of concern for local communities, growers and exporters.

Further, AgResearch has indicated that it will apply later this year to in the future move genetically engineered stock around the country. This will require the approval of the Environmental Risk Management Authority (ERMA). PSRG maintain that the effects of waste matter from transgenic stock, in water tables and on soil fauna, have not been adequately evaluated.

We ask that Councils please monitor applications and approvals on the following sites:

FSANZ http://www.foodstandards.govt.nz and ERMA http://www.ermanz.govt.nz.

Synthetic Biology

The potential products of Synthetic Biology are of concern. We refer you to the copy of our letter to government and the reply received. While we accept that development, testing and regulation are the responsibility of the New Zealand government, we do urge Councils and Health Boards to keep a watching brief. No country is known to have precise, unambiguous legislation in place. When these novel products are in production, rigorous impact studies must be undertaken by independent researchers.

PSRG is concerned by claims made by the proponents of Synthetic Biology who wish to design and construct unique and novel artificial life forms that do not exist in nature. Synthetic Biology is a broad redefinition and expansion of biotechnology and can be distinguished from current genetic engineering in its emphasis on developing foundational technologies that take the engineering of biology further. It raises serious questions concerning biosecurity, biosafety and bioethics, human, animal and environmental health, intellectual property, and the absence of clearly defined, rigorous safety testing and precise, unambiguous regulation.

Developers propose using genetic engineering on a massive scale to redesign existing biological systems to perform specific tasks. Such developments may include novel systems to produce food and energy, pesticides and fertilizers, health products and weapons of war. The results of releasing self-replicating, novel systems into the environment are not known.

Nanotechnology

Nanotechnology refers to techniques used to engineer structures, materials and systems that operate at a scale of 100 nanometres (nm) or less, the scale of atoms and molecules. One nanometre measures one-billionth of a metre. It can potentially pass through skin into the bloodstream, enter an individual cell, and pass through the blood-brain barrier and into the placenta. Nanoparticles cannot be easily monitored.

The development of this technology is of further concern. We refer you to the copy of our letter to government and the reply received. While we accept that development, testing and regulation is the responsibility of the New Zealand government, we do urge Councils and Health Boards to keep a watching brief. No country is known to have in place clearly defined, rigorous safety testing and precise, unambiguous legislation. Few toxicological studies have been carried out and where they have been performed on animals and fish, adverse reactions have been observed, including fatalities.

Items of proposed development, which may affect your community, include feed, fuels, seeds and packaging. Already in use in New Zealand are dental fillings, cleaning materials, possibly food additives, and potentially more, all with no known testing carried out. It is claimed that there are now over 400 nano-products being marketed worldwide. It is unknown how many are in New Zealand, and importers and manufacturers are reluctant to acknowledge the fact that they are using nanotechnology, claiming that this would inhibit their competitiveness.

Nano-particulates in waste matter could pose serious problems for Councils. We do not know what happens when nanoparticles are ground up, incinerated or go into a landfill, or when they are released into the atmosphere, ground water or soil, although studies have shown that they can move in unexpected ways through soil and potentially carry other substances with them. Airborne nanoparticles could potentially travel vast distances. Nano-particulate matter behaves differently from normal bulk materials. For example, aluminium, as used in the manufacture of soft drink cans, are capable of spontaneous combustion at the nano-scale.

We ask that Councils regularly access the NZ government websites to monitor how Genetic Engineering, Synthetic Biology and Nanotechnology may affect their community, exporters, environment and tourist industry. For your convenience we give some relevant sites here:

Food Standards http://www.foodstandards.govt.nz

ERMA http://www.ermanz.govt.nz

Ministry of Research, Science and Technology www.morst.govt.nz

for the Environment www.mfe.govt.nz

Biosecurity www.biosecurity.govt.nz

Bioethics http://www.bioethics.org.nz

Crop and Food http://www.crop.cri.nz

HortResearch http://www.hortresearch.co.nz

Crown Forestry http://www.maf.govt.nz

Health http://www.moh.govt.nz

Economic Development http://www.med.govt.nz

Industrial Research http://www.irl.cri.nz

Landcare http://www.landcareresearch.co.nz

Investment NZ http://www.investmentnz.govt.nz

For your convenience, we also list some relevant websites:

BIO - Biotechnology Industry Organisation www.bio.org

Environmental Health Perspectives www.ehponline.org

Synthetic Biology Net www.syntheticbiology.net

Synthetic Genomics www.syntheticgenomics.com

Synthetic Biology Organisation http://syntheticbiology.org

Centre for Responsible Nanotechnology www.crnano.org

ETC Group Reports on Nanotechnology and Synthetic Biology www.etcgroup.org

NIST Center for Neutron Research: www.ncnr.nist.gov

US Department of Commerce’s Technology Administration www.technology.gov

Foresight Nanotech Institute www.foresight.org

The European Strategy for Nanotechnology and the Nanotechnology Action Plan

http://cordis.europa.eu.

NSTI - Nano Science and Technology Institute www.nsti.org.

NOISH - National Institute for Occupational Health and Safety www.cdc.gov/niosh/topics/nanotech

MTB Europe: www.mtbeurope.info/news/2007/701005.htm

NIA - Nanotech Industries Association www.nanotechia.co.uk

Nanotechnology Now http://nanotech-now.com

National Science Foundation www.nsf.gov

Technology Administration www.technology.gov

Developments are reported in:

Nature www.nature.com, .

Science News Online www.sciencenews.org

The Virtual Journal of Nanoscale Science & Technology www.vjnano.org

Science Magazine www.sciencemag.org

PSRG will not be presenting this submission in person.

PSRG asks Councils to take the socially responsible step to put safety before industry profit and protect its community from the potential risks of Genetically Engineered Organisms, and the products of Nanotechnology and Synthetic Biology.

The Trustees of PSRG would appreciate receiving an acknowledgement of receipt of this communication and a statement of Council’s position on these issues. We would also appreciate having periodic reports on any changes to Council’s position. Thank you.

The Trustees look forward to hearing from you.

Signed on behalf of the Trustees of PSRG

Jean Anderson - Secretary

The Trustees of Physicians and Scientists for Responsible Genetics -

Paul G Butler, BSc, MB, ChB, Dip. Obst. (Auckland), FRNZCGP General Practitioner, Trustee PSRG, AUCKLAND

John R Clearwater, BSc, MSc, PhD, Principal Scientist, Clearwater Research and Consulting, Trustee PSRG, AUCKLAND

Bernard J Conlon, MB, BCh, BAO, DCH, DRCOG, DGM, MRCGP (UK), FRNZCGP, General Practitioner, Trustee PSRG, MURUPARA

Elvira Dommisse, BSc(Hons), PhD, Former Research Scientist, Trustee PSRG, CHRISTCHURCH

Michael E Godfrey, MBBS, FACAM, FACNEM, Director, Bay of Plenty Environmental Health Clinic, Trustee PSRG, TAURANGA

Neil Macgregor, BSc, MSc, PhD, Soil Microbiologist, Institute of Natural Resources, Massey University, Trustee PSRG, PALMERSTON NORTH

Peter R Wills, BSc, PhD, Associate Professor, University of Auckland, Trustee PSRG, AUCKLAND

Robert G Anderson, BSc, PhD, Lecturer retired, Trustee PSRG, TAURANGA

Jean Anderson, Businesswoman retired, Trustee PSRG, TAURANGA.

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