The NAS and Science: Three Views

The NAS and Science: Three Views Henry Miller raises a serious question about recommendations made in two recent National Research Council reports on plants produced with recombinant DNA techniques.1 Unfortunately, Fred Gould and Jennifer Kuzma do not supply a satisfactory response.2 Gould and Kuzma argue that, "taken to its simplest logical conclusion," prior National Research Council findings that "the 'product, not process' is the major concern" would leave only two options: "regulate all plant varieties or regulate none." Nothing could be farther from the truth. A third and more appropriate option is a tiered regulatory framework that applies heightened scrutiny only to plant varieties with unfamiliar phenotypes and phenotypes judged to have high-risk properties, regardless of how they were produced. The 1989 NRC report3 to which Miller refers even suggests ways in which plant varieties could be stratified vertically into risk categories, rather than defaulting to the scientifically unsupportable judgment that all products of rDNA technology should be subject to heightened scrutiny. For further guidance, the NRC committee members could have looked to the International Plant Protection Convention standards for introduction of "exotic" plant species, the US Department of Agriculture regulations for plant pests, or the US Food and Drug Administration rules on foods derived from new plant varieties. Each example sets out comprehensive, yet easy to understand guidelines for identifying plant species or new varieties that would reasonably be judged to have high-risk properties. Even the framework for evaluating rDNA-engineered plants proposed by Rissler and Mellon4 (the former of whom served as a reviewer for both the 2000 and 2002 NRC reports), could just as easily be applied for the evaluation of all high-risk plant varieties, while excluding low-risk varieties from federal oversight. Gould and Kuzma report that "both committees concluded that it [is] premature and impractical to regulate conventionally bred plants." This conclusion must come as a surprise to governments worldwide that have been regulating high-risk varieties of conventionally bred plants for many years. Gregory Conko Director, Food Safety Policy Competitive Enterprise Institute Suite 1250 1001 Connecticut Ave. NW Washington, DC 20036 gconko@cei.org *** Gould's and Kuzma's statement--"regulate all plant varieties or regulate none"--ignores the reality that sound regulatory regimes must consider all products and apply different degrees of oversight and safeguards based on the perceived risks of a product. In other words, apply a principle of proportionality. Thus, we regulate trucks more stringently than cars, not because they were assembled via a different manufacturing process or from different materials, but because trucks are heavier and can cause greater potential damage. Similar reasoning follows for the more stringent regulation of cars compared to bicycles. As Daniel Bush, president of the American Society of Plant Biologists, recently noted, traditional breeding practices "such as selection from crosses of wild relatives into commercial species can carry far greater inherent risks than [gene-splicing]." Gould and Kuzma cite the enormous costs of "regulating every conventionally bred plant variety" as justification for their antiscientific conclusion. But again, they ignore the many examples of graduated, risk-based, scientifically defensible regulatory frameworks based on "product, not process," including some that are applicable to plants and other organisms. By ignoring these elementary principles and scientific realities simply because the current regulatory regime "does focus on transgenic plants," the Academy abdicated its responsibility to provide unbiased and accurate analysis. The losers include everyone who values science as the basis for public policy. The only winners are those who wish to use excessive regulation to limit the wider application of the new biotechnology and the freedom to perform research. Alex Avery Director of Research Hudson Institute, Center for Global Food Issues Churchville, Va. aavery@rica.net www.cgfi.org *** Miller's article goes to the heart of many of the myths about transgenic crops and their regulation--and how those myths spread and gain legitimacy. We know now that the NAS and NRC are partly responsible. Most economists would agree that the role of regulation is to protect the public from harm, be it economic harm from monopoly power or the hazards of a consumer product. A first principle of this process is that the extent and intensity of regulation should be in proportion to the plausible harm of the product or activity. Miller's trenchant criticism of the recent reports on biotechnology regulation from the NAS and NRC cogently demonstrates that they not only violate this principle but contradict a series of previous analyses of transgenic crops performed by the Academy itself and others. It is clear from these studies--which reflect a broad, long-standing consensus--that, in fact, the construction of new plant varieties by recombinant DNA is both the most precise and predictable form of plant breeding ever devised; therefore, it is also likely to be the safest. Equally important, the NAS/NRC's endorsement of flawed science as the basis for regressive public policy encourages regulation that stifles innovation and commerce. Miller's insightful analysis implies that politics now trumps bona fide scientific expertise and judgment in the recent policy recommendations of the NRC committees. But the underlying causes remain murky. In recent years, we have seen journals and societies make concessions to a kind of moral equivalence, giving some legitimacy to the most mendacious and insidious of antitechnology groups and individuals. The 1999 publication of the Pusztai article by The Lancet5 and the more recent publication of the Chapela article in Nature6 are instructive. Such low-quality research was published because if not, "it will be claimed there is a conspiracy to suppress information," in the words of The Lancet's editor. The marketplace of ideas--as evidenced by what is exhibited in high-prestige venues--seems now to extend to experiments that are poorly designed, inadequately controlled, and inconclusive. The proponents of flawed ideas and bad experiments should be free to promote them, of course, but the scientific establishment has the solemn responsibility to separate the wheat from the chaff. Lately, it seems to be unable to distinguish which is which. Thomas R. DeGregori, PhD Professor of Economics University of Houston Houston, Texas 77204-5019 trdegreg@uh.eduwww.uh.edu/~trdegreg References 1. H.I. Miller, "Nescience, not science, from the Academy," The Scientist, 16[19]:12-4, Sept. 30, 2002. 2. F. Gould and J. Kuzma, "The Academy responds," The Scientist, 16[20]:12, Oct. 14, 2002. 3. National Research Council, Field Testing Genetically Modified Organisms: Framework for Decisions, Washington, DC: National Academy Press, 1989. 4. J. Rissler, M. Mellon. The Ecological Risks of Engineered Crops, Cambridge, Mass.: MIT Press, 1996. 5. S.W.B. Ewen, A. Pusztai, "Health risks of genetically modified foods, The Lancet, 354:684, 1999. 6. D. Quist, I.H. Chapela, "Transgenic DNA introgressed into traditional maize landraces in Oaxaca, Mexico," Nature, 414:541-3, 2001.

The NAS and Science: Three Views

The NAS and Science: Three Views

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