STEWARDING: GENE EDITING TECHNOLOGY

Regulators and government departments that are keen on deregulation haven't meaningfully address the potential risk from scalability, when governments and industries commercially release new technology into the environment. There's a big reluctance in regulatory circles to discuss what companies don't know when they release a new organism. Off-target and unintended mutations can be almost impossible to detect as they are not predictable. They do happen and they will happen. As releases into the environment increase, so will the likelihood of modified organisms that might carry an effect that presents harm to the surrounding environment. The risks will therefore scale up as development and release of the technology, scales up. Case by case analysis is also difficult - because of the extraordinary difficulty to identify a potential unintended change. Companies aren't likely to spend months and years testing for such elements, when they have already invested large amounts in product development.

September 2024: Food Standards Australia New Zealand (FSANZ) P1055 2nd Consultation proposal to deregulate (perhaps up to 94%) of GMOs by changing the definition - FSANZ Submission PDF or scrollable on Substack. We consider that mainstream media have inadequately discussed the biosecurity risk presented by scalable GMO technology. Worryingly, neither Australian or New Zealand media discussed the P1055 FSANZ consultation to inform the public that a 'paradigm shift' in GMO/GE regulation, from process-based to outcomes-based was being proposed by the food safety authority. If the public do not know, they cannot comment.

February 2025: Submission to the Health Select Committee on the Gene Technology Bill 2024. PSGR’s submission is in two parts (PDF):

Part I: Deficient Policy Formulation: details ways in which the Bill’s drafters have drafted text to narrowly restrict Regulatory powers and prevent wider regulatory scrutiny. This not only leaves New Zealand vulnerable to slow moving problems, it would result in the Regulator having insufficient scope and inadequate information in emergency situations that would enable the Regulator to assure the health and safety of people.
Part II: Recommendations including critical analysis of Bill text: Makes in-depth recommendations and outlines problems and gaps in the Bill text.

March 2025: Presentation to the Health Subcommittee, on behalf of the Physicians and Scientists for Global Responsibility (PSGR) (2:30:00-2:40:00). PSGR’s presentation concerned the Gene Technology Bill that is currently before that select committee.

April 2025: Release of paper - PSGR (2025) When powerful agencies hijack democratic systems. Part I: The case of gene technology regulatory reform. Bruning, J.R., Dommisse, E.. Physicians & Scientists for Global Responsibility New Zealand. ISBN 978-1-0670678-0-9

PSGR emailed New Zealand's Chief Ombudsman to request a formal Inquiry:

'The Physicians and Scientists for Global Responsibility (PSGR) are writing to request that the Ombudsman convene an Inquiry into conduct of the Ministry of Business, Innovation, and Employment (MBIE) and the Hon. Judith Collins, Kings Counsel and Attorney-General, in regard to their work on gene technology regulatory reform over the period 2023-2025. That the Ombudsman consider evidence that this body of persons acted improperly in their duties, directly undermining public law conventions, in order to expedite policies and laws in favour of the deregulation of gene editing technology.'

PSGR also emailed Members of Parliament (see also accompanying press release)- because:

'PSGR believe that there is significant evidence that actions of the Ministry of Business, Innovation, and Employment (MBIE) officials and the Minister in charge, Judith Collins may have undermined good process to drive outcomes that would severely restrict the capacity of the new gene technology regulator to safely regulate gene edited technologies and organisms.'

There is evidence that most gene edited organisms could evade pre-market risk assessment and avoid being labelled a GMO/GE product. A European study showed that 94% of current GM/GE plant applications affected by the European GE (new genomic techniques) proposal would not be classified as a GMO. For more information please scan our Fact Checking 101 page and consider reading our 2023 review paper which outlines where New Zealand stands currently on biotechnology and gene editing.

New Zealand has a low tolerance for unwanted and invasive species. Wilding or volunteer GMO species are a massive problem in north and south America. It is not easy to estimate how highly scalable GMO technologies could themselves become a biosecurity risk for future generations. This was not considered in FSANZ 2024 consultation and we are yet to see a risk assessment for the gene technology reform process by the Ministry of Business, Innovation and Employment, who are currently attempting to deregulate many gene editing techniques and organisms.

If you think it is 'over the top' that PSGR state that MBIE are working to deregulate gene editing techniques and organisms, our recent paper PSGR (2025) When powerful agencies hijack democratic systems. Part I: The case of gene technology regulatory reform reveals how MBIE's problem definition, shown in their Regulatory Impact Statement was focussing on - not the safety of GMOs - but the deregulation of them. MBIE then commenced to use scientists they funded to produce GMOs and gene edited organisms, and people and organisms with biotech investments or partnerships to develop biotech - to act as the 'experts' for the consultation for the new regulations and laws.

PSGR's new paper (April 2025) shows the paper trail and reveals the extraordinary conflicts of interest at play.

If you are interested in why GMO/GE organisms require a different regulatory approach from conventionally bred plants, we recommend you listen to this interview with Professor Jack Heineman on the risk that arises when we scale up technologies.

'Where harm can accumulate at scale transition, that's precisely where regulation is a solution to mitigate risks.'

PSGR (2025) When powerful agencies hijack democratic systems. Part I: The case of gene technology regulatory reform. Bruning, J.R., Dommisse, E.. Physicians & Scientists for Global Responsibility New Zealand. ISBN 978-1-0670678-0-9

Stewarding: New gene editing techniques & organisms

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