ngin - Norfolk Genetic Information Network

6 September 2002


Thanks to Paul Cawthorne for forwarding these interesting points from Dave Leal, an Oxford ethicist, on the issue of GM food labelling.

Leal is responding to the arguments advanced against labelling by Michael Reiss, biologist and priest in the Church of England and the chair of EuropaBio's External Advisory Group on Ethics. Reiss has also long sat on the UK Advisory Committee on Novel Foods and Processes.
from Paul Cawthorne <

Jonathan - I wondered if this reflective response to a recent piece arguing against mandatory GM labelling by Michael Reiss in Nature Biotechnology was worth circulating for those who want their thinking stretched or just to give Agbioview something else to rebut, Paul C

----- Original Message -----
From: Dave Leal <
To: Paul Cawthorne <
Sent: Wednesday, September 04, 2002 12:01 AM
Subject: Re: Fw: CumminsGram: ethics of GM-food labelling

Dear Paul,
I have had a chance to read the Reiss piece.  I think it very interesting, and it has certainly provoked me to a little thinking.
'Substantial similarity' is a scientific phrase, which had better mean (if it means anything) that two substances are chemically indistinguishable.   It ought not to mean what it will sound to a layman like it means (pretty   much the same), because 'pretty much the same' is not enough.  I recall an   amusing tutorial with an undergraduate on sugar cane and sugar beet, and   whether if the sugar in the packet is chemically indistinguishable when   sourced from beet or from cane, whether the sourcing should be labelled.   (What 'chemically indistinguishable' will amount to is an interesting   question -- molecular equivalence, or as far down as ensuring that no   rogue isotopes of atoms of elements vary between samples?)  Not that   'indistinguishable' is a term of scientific (in this case   chemico-analytic) epistemology.  It will mean 'indistinguishable *in   practice*'.  What is indistinguishable in practice might actually be   different, and that in important respects.  There will, *always*, be the   possibility of such a gap being used to provoke doubts; and perhaps   rightly.  In any event, the gap needs to be noted.
Now, take 'substantial similarity' as meaning absolute chemical   equivalence, not just 'roughly the same'.  What would using this as an   argument against compulsory labelling suggest?  It would suggest that what   is at issue is consumer choice in relation to the a product's origin   should not matter where there is no difference in chemical composition of   the substances left unlabelled (and thus not disciminable by the   consumer).  Presumably that amounts to a belief that chemical equivalence   implies equivalence at some other level, and my guess is that that will be   one of: (a) nutritional value, and (b) safety.  I am (sadly) a product of   enlightenment science to a sufficient degree to say that I accept the causal beliefs which lie behind this: same chemical stuff, same nutrition, same risks.
But would that be the only reason to label?  Of course not.  Take the   Hindus-versus-Macdonalds case in the US.  Imagine that MacDs were to claim   that their chips cooked in beef dripping were, at the point of sale,   substantially equivalent to those cooked in vegetable oils.  And let's say   that this is in fact true, even though we know it's not.  Is this a   defence?  Of course not.  The Hindu chips-and-veggie-burger-buyer wants to   know that the product is cow-free, and does *not* mean by that concern   that he wants to know if it is substantially equivalent to something else.   Anyone who is against GM technology for whatever reason (and there are   good general questions about the support of technological society per se   which might make us regard GM as a worrying instance -- Ellul, Heidegger)   will want to know that the product he purchases is non-GM.  (I want to be   sure that the measles element of the MMR vaccine my son will be offered   has no linkage to a line of production with its origins in cells obtained   from a 'spare embryo' or from foetal tissue[as German measles was]; if it does, the vaccine will   be refused.  Satisfying me that it is substantially similar to a vaccine   generated in morally legitimate fashion is not relevant at all.)
So Michael Reiss is being too quick in telling the public what they want,   not because it can never be right to tell the public 'what you *really*   want is...' (again, for my sins, I can be as patronizing as the next   philosopher when I care to be), but because he hasn't a clue what the   public really want, or rather of the range of concerns which the public   might bring to the situation.  Given that this range of concerns is   probably unanticipatable -- I regard the autism link to MMR as of marginal   concern, but will still reject the jab for quite different reasons --   paternalistic 'well, you're asking for this but what you *really* want is   that' moves must be rejected.
On these grounds, then, labelling makes sense.  It is a separate question whether labelling should be voluntary or compulsory, and the free market   versus compulsion question is a real one.  It is solved simply enough, by pointing out that those who live in large cities can afford to be   complacent about markets.  Those who live in villages or small country towns will have little by way of choice in regard to shopping, and if one was the only Hindu in town one's hope that the burger chain would come clean about the history of the products they sell may well be forlorn.   If there is a legitimate reason for anyone to be told about GM products -- and there are a number of reasons why people might want to know -- labelling needs to be compulsory, or some people who are already   disadvantaged in terms of choice will suffer further discrimination.
 (An aside: Muller 'yoghurts' are allowed to be labelled as yoghurts, but   are thickened with pork gelatine, so in my book are not yoghurts.  The   label says 'yoghurt' in large letters -- there is an admission of the   gelatine in small print, but to my mind this is a denial of what it says   in large letters.  A peach yoghurt is a vegetarian-friendly thing; a   Muller one is not.  *How* we label is often as interesting as *whether* we   label.)
  Speaking of discrimination, the second of the three reasons (practicality,   fairness and cost) which are listed as objections to the proposals for   compulsory labelling early in the article is bemusing.  On course, the   labelling will discriminate.  That is the point of labelling.  And it will   enable customers to discriminate; that is also the point.  The issue is,   are GM products any *ground* for discrimination?  Unless the politicians are to decide for the public that some of their grounds for objection are   illegitimate -- which seems thankfully unlikely (for that would be to take   paternalism to a new and rather frightening level) -- compulsory labelling   appears inevitable.  What *that* would do is to offer a chance to compare takeup of products for those who have a choice (noting that GM products could always be sold at a loss to poor people initially to boost sales,   and make them appear a success; as with organic products, non-GM might   come to look like a rich person's sport).
It's worth ending these comments by saying that it is always unwise to remark too dogmatically on the lack of appreciable difference between two products. Wasn't it Sir John Krebs who made a dogmatic assertion a year or two back that there were no health benefits in organic food compared with non-organic?  And then there was the survey that showed the differential health benefits of organic over non-organic soups (not sure how widely that was publicised; my brother works in the food industry), and Krebs looks a fool for having made a dogmatic assertion ahead of the   evidence.  I suspect that the safety-fear aspect will lead most who can afford it away from GM products.  We'll not be (wittingly) using them.  I am slightly worried about using fear as the basis of arguments, though, on Christian grounds; but I do remain a GM skeptic.
Sorry, that may be rather random -- but do feel free to share with others if you think it could generate useful debate.
As ever,
  Dr Dave Leal
  Brasenose College
  OX1 4AJ
  Tel:   01865 793747
  Fax:   01865 2-77822

ngin bulletin archive