Introduction
Genetically Modified Organisms (GMOs) are the modification of organisms by the direct incorporation or deletion of one or more genes to introduce or alter a specific characteristic(s). GMOs were once easily classified into two main categories of cisgenic or transgenic. Cisgenesis is when DNA is inserted from same or closely related species, while transgenesis involves foreign DNA. GMO crops were typically bred for the following two reasons:
However, that is no longer the case, with an increasing number of novel gene editing techniques now commercially feasible, increasing the GMO pool that influences other aspects of production such as ripening, shelf life, yields or by inhibiting the action of certain genes. In addition, GMOs are increasingly being referenced differently which can cause confusion; such terms include bioengineering, gene modification (GM), gene editing, gene engineering, new breeding techniques and more.
Deregulation of gene technology methods creates a situation where producers and consumers are unable to verify that a product has been genetically modified without significant economic costs. There is also the ethical concern where CRISPR and other genetic engineering can be and have been used on human embryos[1]. Should this technology be required, Australian Organic Limited (AOL) is committed to the position that gene technology methods remain regulated and under the control and guidance of the Government to ensure the safety and continued free choice of consumers as to what they consume.
Potential Negative Effects of GMOs
As Dr. G.D.W Smith once so eloquently said:
“The safety of GM food is false… Yes, the DNA of all living organisms is made up of just four nucleosides, and yes, virtually all proteins are made up from just 20 amino acids. But this does not imply that everything containing these basic building blocks is without risk to human beings. The same units, arranged in different ways, are contained in the smallpox virus, bubonic plague and influenza, deadly nightshade and other poisonous plants, creatures such as poisonous jellyfish, scorpions, deadly snakes, sharks – and people who talk absolute nonsense”[2].
To date, there have been no long-term epidemiological studies investigating potential effects of GMO food on human health. However, there are countless animal studies linking GMOs with innumerable negative effects on organs, the reproductive systems, induced blood, hormonal and immunological alterations, toxicity in multiple organs as well as increased tumours and mortality[3][4][5]. Many studies show signs of toxicity in the liver and kidney, the major detoxifying organs. These organs are often the first to show evidence of chronic disease[6], however often these effects are disregarded as biologically insignificant when they don’t cause animal mortality. Most animal feeding studies on GMOs are short to medium-term in length, too brief to show long-term (chronic) effects such as organ failure, cancer, or reproductive problems. In contrast, for new product pesticide approval, they must undergo minimum 2-year trials and mammal reproductive tests before being allowed on the market. GMOs don’t require this, even when they are engineered to contain the same (often multiple) toxic components such as insecticides, leading to further questions regarding GMO safety.
In addition to the potential toxic effects of GMO components, changes in farming practices linked to the use of GMOs may result in even higher toxic residues. For example, higher levels of crop contamination with the herbicide Roundup (glyphosate) are an inevitable result of using genetically modified Roundup-ready crops[7]. The genetic modification transformation process may also produce mutagenic effects that can disrupt or alter gene structure, disturb normal gene regulatory processes, or cause effects at other levels of biological structure and function. These effects can result in unintended changes in composition, including new toxins or allergens and/or disturbed nutritional value. Should GMOs be required for use within the food industry, further long term, intergenerational and human studies should be conducted[8]. AOL remains firmly against GMOs in all agricultural contexts.
Legislation and Regulation of GMOs in Australia
In Australia, the Gene Technology Act 2000 is the key source of regulation of gene technology and its uses. The government established the legislation:
“to protect the public and safety of people and to protect the environment from risks associated with gene technology…by identifying and assessing risks posed by, or as a result of, gene technology, and by managing any risks through the regulation of certain dealings with genetically modified organisms (GMOs)”.
Since then, the legislative instruments have expanded to include the Gene Technology Regulations 2001, as well as Amendments to the original Act introduced in 2006, 2007, 2009, 2011, 2015 and 2019.
State Government Moratoriums on GMOs
Since the introduction of the Gene Technology Act 2000, states across Australia (apart for Queensland) had introduced moratoriums on the growing of GM crops within their jurisdictions.
However, as of July 2021, Tasmania is now the only state in Australia which holds a moratorium on GM crops. The removal of these moratoriums reduces the amount of regulatory oversight on GMOs and adds to the risks faced by organic operators from contamination from GMOs. This is particularly relevant when considering the requirements of the National Standard for Organic and Bio-Dynamic Produce (National Standard).
GMOs under the Australian National Standard
In Australia, the National Standard expressly states that the use of GMOs is not compatible with the principles of organic and bio-dynamic agriculture. Section 1.3 of the National Standard is the key section and states products with GMOs “are not compatible with the principles of organic and bio-dynamic agriculture”[9].
Inclusion of GMOs results in the removal of organic status for operators. For producers, the ability to prove that goods meet the National Standard is paramount to being able to export products overseas as certified organic. If goods fail to meet the requirements of the National Standard, they will cannot be exported overseas.
The potential implications and risks associated with this technology cannot be overstated. Removal of moratoriums increase the underlying risk of cross pollination with organic crops, which may lead to negative effects on human and animal health. It is the opinion of AOL that all gene technology should continue to require constant pre-market safety assessment, monitoring, approval and continue to be clearly labelled and segregated as “genetically modified”.
Who oversees GMOs and food safety in Australia?
Food Standards Australia & New Zealand (FSANZ) is the agency that oversees food regulation policy, including residues in food, classification, and GMOs. Recently, there have been submission requests from FSANZ to deregulate GMOs and exclude certain genetically modified foods from pre-market safety assessment and approval. These new breeding techniques can make the same genetic changes as older genetic modification techniques, however, can also be used to make the same genetic changes as conventional breeding or natural occurrence.
New breeding techniques include but are not limited to:
| Techniques | Example of Technology | Capacity for genetic change and mutation |
| Genome editing | A group of techniques that make precise changes (edits) at targeted locations in the genome of an organism. CRISPR technology is a form of genome editing. | CRISPR technology can also result in frameshift mutations that have a high probability of disturbing protein structure and function. New studies suggest CRISPR technology can lead to unexpected genetic changes that increased the growth of cancer cells[10]. May involve foreign DNA and could be classified under transgenesis. |
| GM rootstock grafting | A GM plant is used as the rootstock onto which a non-GM plant is grafted. Grafting is a very old technology, but using GM rootstocks is a more recent development. | May involve foreign DNA and could be classified under transgenesis. |
| Cisgenesis | DNA from the same or a closely related species is inserted into the genome of an organism without changing the inserted DNA sequence or arrangement. | Altering to protein structure and function. Can produce variable frequencies and severities of unintended effects[11]. |
| Intragenesis | Similar to cisgenesis, except the DNA is changed from its original form, often to include additional pieces of DNA from the same or a closely related species, and/or rearranged in some way before being inserted in the genome. | The transfer of DNA fragments with the potential to create novel genes that could not arise in nature[12]. Can produce variable frequencies and severities of unintended effects[13]. May involve foreign DNA and could be classified under transgenesis. |
AOL sees no scientific or legal reasoning to exempt any genomic techniques from labelling, traceability, and risk assessment. It is the opinion of AOL that genetically modified foods should encapsulate all gene technology that does not arise from conventional breeding techniques. The labelling of gene editing and genetically modified foods should reflect the associated risk and capacity for potential genetic changes, rather than their advocated use. Deregulation of gene technology methods creates a situation where producers and consumers are unable to verify that a product has been genetically modified without significant economic costs. There is also the ethical concern where CRISPR and other gene editing techniques have been used on human embryos overseas[14]. Should this technology be required, AOL is adamant that it remains regulated and under the control and guidance of the Government to ensure the safety, regulatory labelling and continued free choice of consumers as to what they choose to eat.
Potential market access impacts of GMOs
Australian organic produce is currently exported to over 80 countries globally[15]. The USA is currently Australia’s largest international market and represents 33% of current organic exports. All Australian producers must be certified to the United States Department of Agriculture’s (USDA) National Organic Program standard to export their product to the USA. The use of genetic engineering, or GMOs, is prohibited in USDA organic products. Organic farmers must show that they aren’t growing GM foods. Equally, processors must show this in terms of non-GMO ingredients.
Testing for GMOs is a costly and time-consuming process. Should certain genetic modification techniques no longer require labelling regulation within Australia, there could be numerous negative ramifications for the organic industry in terms of lost market access to the USA. This is also the case for:
Legislation from other countries
Australia must maintain equal or superior GMO regulations and regimes compared to other countries for the organic market to prosper. As noted above, key markets for Australian organic producers have highlighted their concerns with the use of GMOs within their own markets. Regulation within Australia, at a Federal and State level, is needed not only for novel traits, but also for the process of DNA interference itself. Altering the definition of GMOs and potentially deregulating techniques that are not classified as conventional breeding puts the Australian organic Industry at risk and must be prevented. For many gene editing techniques, there are no options to thoroughly test for this in an economically feasible way and ensure Australian organic integrity remains intact. This would lead to the loss of international equivalency and market access.
Conclusion
Humans have manipulated genes since the dawn of civilisation. The importance of selective breeding in the domestication of cereal crops and livestock in the evolution and continual development of humans cannot be understated. Genetic engineering is behind many modern life-saving vaccines. There is no denying the potential use of controlled gene editing to address complex human disease and save lives. However, this technology must undergo stricter and lengthier testing and safety evaluations to minimise potential risk within the agricultural industry and to human health.
The genetic modification of crops does not reduce the potential negative effects of the unsustainable farming practices on the environment and climate. Genetically modified crops have not increased the efficiency of photosynthesis, nor do they produce more energy from the same amount of sunlight. Genetically modified crops are covered by patents which monopolise the seed market and can have negative economic consequences in the agricultural sector.
AOL will continue to advocate for all GMOs (new and old) to remain subject to risk assessment, traceability and labelling to ensure farmer choice, consumer choice and the safeguarding of animal and human health and the environment. Should conventional farmers choose genetically modified foods, all products should continue to go through pre-market safety assessment, approval, labelling and separation to prevent potential contamination of organic goods.
AOL remains passionate about protecting and cultivating the Australian organic industry through market access opportunities and consideration of consumer’s best interests.
[1] Rothschild, J. Ethical considerations of gene editing and genetic selection. J Gen Fam Med. 2020; 21: 37-47. https://doi.org/10.1002/jgf2.321.
[2] Smith GDW. Is GM food good for you? Letter to the editor of the Sunday Times [unpublished]. 2004.
[3] Dona A, Arvanitoyannis IS. Health risks of genetically modified foods. Crit Rev Food Sci Nutr. 2009;49:164–75. doi:10.1080/10408390701855993.
[4] Pusztai A. Can science give us the tools for recognizing possible health risks of GM food? Nutr Health. 2002;16:73-84.
[5] Hines FA. Memorandum to Linda Kahl on the Flavr Savr tomato (Pathology Review PR–152; FDA Number FMF– 000526): Pathology Branch’s evaluation of rats with stomach lesions from three four-week oral (gavage) toxicity studies (IRDC Study Nos. 677–002, 677–004, and 677–005) and an Expert Panel’s report. US Department of Health &Human Services; 1993. Available at: http://www.biointegrity.org/FDAdocs/17/view1.html.
[6] Séralini GE, de Vendomois JS, Cellier D, et al. How subchronic and chronic health effects can be neglected for GMOs, pesticides or chemicals. Int J Biol Sci. 2009;5:438-43.
[7] Séralini GE, Clair E, Mesnage R, et al. [RETRACTED:] Long term toxicity of a Roundup herbicide and a Roundup tolerant genetically modified maize. Food Chem Toxicol. 2012;50:4221-4231.
[8] Fagan, J., Antoniou, M., Robinson, C., 2014. GMO Myths and Truths. Earth Open Source. Available At: http://livingnongmo.org/wp-content/uploads/2014/11/GMO-Myths-and-Truths-edition2.pdf.
[9] Australian Government, National Standard for Organic and Bio-Dynamic Produce,, Department of Agriculture and Water Resources, 2016, https://www.awe.gov.au/sites/default/files/sitecollectiondocuments/aqis/exporting/food/organic/national-standard-edition-3-7.pdf.
[10] Geng, Keyi, et al. “Target-enriched nanopore sequencing and de novo assembly reveals co-occurrences of complex on-target genomic rearrangements induced by CRISPR-Cas9 in human cells.” Genome Research 32.10 (2022): 1876-1891.
[11] EFSA Panel on Genetically Modified Organisms (GMO). “Scientific opinion addressing the safety assessment of plants developed through cisgenesis and intragenesis.” EFSA Journal 10.2 (2012): 2561.
[12] Holme, Inger Bæksted, Toni Wendt, and Preben Bach Holm. “Intragenesis and cisgenesis as alternatives to transgenic crop development.” Plant Biotechnology Journal 11.4 (2013): 395-407.
[13] EFSA Panel on Genetically Modified Organisms (GMO). “Scientific opinion addressing the safety assessment of plants developed through cisgenesis and intragenesis.” EFSA Journal 10.2 (2012): 2561.
[14] Rothschild J. Ethical considerations of gene editing and genetic selection. J Gen Fam Med. 2020;21(3):37-47. Published 2020 May 29. doi:10.1002/jgf2.321
[15] The University of Melbourne, Euromonitor International, Mobium Group, NielsenIQ, Australian Organic Market Report 2021 (Australian Organic Limited, 2021). https://austorganic.com/resources-and-research/publications/market-report-2021.
[16] The University of Melbourne, Euromonitor International, Mobium Group, NielsenIQ, Australian Organic Market Report 2021 (Australian Organic Limited, 2021). Available through following link: Australian Organic Market Report 2021 (austorganic.com).
Australian Organic Limited (AOL) is the peak body for the organic industry.
AOL acknowledges the Traditional Custodians of the land on which we operate, the Turrbal and Yuggera people. We extend our respect to Elders past, present and emerging.