Advocates Urge Caution and Transparency in Gene Editing Policy

By: Thomas Gremillion, CFA Director of Food Policy

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Four consumer and environmental groups, including CFA, submitted comments on the U. S. Department of Agriculture’s (USDA) Agricultural Innovation Agenda earlier this month. The comments express support for the Department’s stated goal of increasing agricultural production in a sustainable manner to meet the needs of the global population in 2050 “while cutting the environmental footprint of U.S. agriculture in half,” but they urge the Department to take a more proactive stance on the genetic engineering in the food system.

The comments focus on the Department’s “genome design” agenda, with the groups maintaining that “gene editing can play a positive role in U.S. agriculture in the future,” but that it is not a “silver bullet” for the future of agriculture. “To achieve USDA’s goal of increased production to meet the needs of the global population with a decreased environmental footprint, there also needs to be broader investment and innovation in conservation, research, food access, and other key areas in addition to gene editing,” according to the letter.

The letter lays out four key points the USDA should consider while developing its Agricultural Innovation Agenda.

1. USDA Should Establish Policies that Make Gene Editing Technology Accessible to a Broad Range of Developers and Ensure it is Utilized for Societal Benefits.

“Consumer acceptance and social license for the new generation of gene edited products will be better achieved if developers ensure that gene editing technologies are accessible for use by a wide variety of public, private, and NGO institutions,” the letter states. To accomplish this, USDA should invest in academics, NGOs, and small businesses, and should ensure that any intellectual property that results from these partnerships be available to others.

The letter also stresses that USDA will need to establish policies that promote the use of gene editing to maximize societal benefit. “Specifically, USDA should prioritize funding for beneficial gene editing applications in fruits, vegetables, orphan crops, and other underfunded crop and animal applications that have not historically received public and private investment to develop varieties with improved genetics,” it states.

2. USDA Needs to Ensure Transparency about Which Gene Editing Applications are in Use in Food, Agriculture, and the Environment, and Ensure Access to Independent Information about the Benefits and Impacts of Those Products.

Transparency will be essential if agricultural innovation using gene editing techniques is to be adopted by farmers, used by companies in the food chain, and purchased by consumers, the letter argues. To provide this information, USDA should: establish a national registry of all gene edited products intended for agriculture and environmental use; make sure there is information about gene edited products already in commerce; and support research to establish methodologies to quantify, characterize, and compare benefits, impacts, and efficacy of new plant and animal varieties made with gene editing. Establishing policies that promote transparency can build public trust and will allow the U.S. to use, and expand, gene editing.

3. To Realize the Full Benefits of Gene Editing and to Manage its Potential Risks, USDA Must Put in Place Science-Based, Transparent, and Participatory Regulations that Ensure Product Safety.

“USDA needs to assess the potential risks of gene edited products before they are released to farmers using a regulatory system that is based on the best scientific evidence available,” the groups write. However, the groups also highlight that this regulatory process “…should not be so onerous as to preclude the participation of smaller institutions or public entities in the development of beneficial gene edited products, but thorough enough to ensure all products are adequately assessed for safety.”

4. USDA’s Recently Issued SECURE Rule Does Not Establish a Science-Based Regulatory System and Should be Revised.

Lastly, the groups argue that the current regulations around genetically engineered organisms “…do not establish a science-based regulatory system that adequately ensures safety for all gene edited products” and should therefore be revised or withdrawn. One key issue with the current regulations is that “…many gene edited applications are not regulated because they fall within an exemption or could be encompassed by a future exemption.”

In short, “USDA also needs to eliminate the regulatory provisions that allow developers to self-determine that their products meet an exemption and are not regulated. Those provisions set up an inherent conflict of interest because developers have financial incentives to determine themselves exempt,” the letter states.

“New gene editing tools have the potential to help solve some of the toughest challenges facing our food system,” said Thomas Gremillion, CFA Director of Food Policy. “But without meaningful public sector oversight, consumers will avoid products made with these technologies, and with good reason. Consumers have a right to information about what food products are made using gene editing and other genetic engineering technology, and to an independent safety determination of those products by federal regulators.”

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