6 September 2002
ETHICS OF GM-FOOD LABELLING
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 <Paul@cawthorne52.fsnet.co.uk
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 <dave.leal@brasenose.oxford.ac.uk
To: Paul Cawthorne <Paul@cawthorne52.fsnet.co.uk
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,
Dave
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Dr Dave Leal
Brasenose College
OXFORD
OX1 4AJ
Tel: 01865 793747
Fax: 01865 2-77822
email: dave.leal@bnc.ox.ac.uk
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