Science Can't Dictate Moral Actions

cubic tomato

“GMO labeling bill lacks a scientific justification” headlined The Boston Globe’s lead editorial on 7/30/14. Here is the first paragraph:

Advances in crop biotechnology over the past 20 years have multiplied the range of so-called genetically engineered foods in the average citizen’s diet. Despite reassurances from the international and US scientific community about the safety of genetically modified organisms (GMOs), the anti-GMO movement continues to gain ground, and has arrived at the state Legislature in the form of a proposal that would create new food-labeling regulations. But until there is a solid scientific reason to believe that genetically modified crops are unhealthy, a labeling requirement would only serve to confuse consumers.

This sounds more like a piece from the Agricultural Producers Monthly (if it should exist) than from the usually responsible Globe. Maybe this reflects the history of the new owner, John Henry, who made his fortune dealing with commodity futures. I can’t see this showing up under the previous owner, The New York Times.

The real issue here is risk, not science. GMOs have yet to achieve the grade of GRAS (generally regarded as safe) which allows the products to be exempt from the FDA labeling regulations. The FDA allows sale of products considered to be GRAS without any kind of warning label, but that does not apply here in any way. There is no general agreement that these products are safe, quite the opposite. GRAS designation comes from long uses of the products without signs of harm. It is far too early to make such a judgment about GMOs. Their safety has to be established on two fronts: safe in the consumer’s body and safe in the fields. I deliberately avoided using “proved” here because proof is the other aspect of the editorial that is misleading.

There may be no significant risk in producing and using these products, but there may be. There certainly is in use in the fields. Monsanto has a history of suing farmers next door to users of their GMO seeds in cases where the GMO traits have become mixed with the farmer’s stock through windblown transport. It doesn’t take a lot of science to demonstrate that these products may be risky; in this case the courts did it.

It is more difficult to “prove” that there is no harm in consuming GMO products. Science cannot “prove” a negative hypothesis simply because the scientists may have asked the wrong question and are consequently, looking in the wrong place. In the case of GMOs, science cannot show everything that happens when a gene is purposely replaced, but the same science is discovering that a single gene mutation can have profound effects on the body. There are between 20-25000 genes in human DNA and only a small number have been fully connected to their effects. That the number of genes remains only an estimate attests to the state of uncertainty about a complete understanding of the role of every gene, and suggests that any proof that playing around with them is safe is far off in the future. What we ingest can certainly modify the workings of our genes. This is the basis of genetically targeted drugs—magic bullets.

The argument in the headline is old and tired. Industry has argued for years that only “sound science” should be used as the basis for regulatory purposes, but know full well that scientists can never prove a negative. I got deeply in trouble back in my MIT days when I asked, during a meeting about a potential industry-sponsored project on science in regulation, “How would you feel if the results showed that less science, not more, would improve the regulatory process?” I got taken to the woodshed. The presumption that more science would benefit industry was palpable in the room. Successful or not more science delays the time until some regulation that restricts production might come forth. The potential bias in industry-sponsored research is so large that many journals demand that the source of funding is made clear. Relying on information from the producer in cases like this is notoriously suspect. We learned that lesson from the behavior of the tobacco industry.

The issue here is fundamentally not about science but about risk. It is the same issue concerning climate change and many of the other pieces of unsustainability. How long do we wait until we take action? The oceans have not inundated Manhattan Island yet, but they may. We deserve a better way of making decisions about risks that effect all of us as do both climate change and GMOs. If the issues are so complicated that the scientists cannot tell us with certainty that all is OK, then maybe we should use fact that itself as the argument on which we base our actions. This process has a name, the precautionary principle, and has been used in European regulations. Industry is not so strong there as here; it’s strength is the primary reason we haven’t become more serious about it. The costs of ignoring possibility can be great. Think of the misery and deaths from tobacco. (They are still at it) Climate change consequences could (I’m being deliberately cautious here.) incur pain and suffering and losses of investments in infrastructure far in excess of anything we have imagined. Not to worry, industry and the science/technology sectors have an associated argument. If it happens, we can fix the damage cheaper than it would be by acting too soon or mistakenly to prevent it.

Surprise, surprise! That’s the closing argument in the editorial.

But few bills [to label GMOs] would achieve so little while costing so much. A professor from Cornell University conducted a study, albeit sponsored by the food industry, predicting a GMO labeling law could increase food costs for a family of four in the Northeast by $224 to $800 per year, with an average of $500. As for Vermont, lawmakers estimate it would cost the Green Mountain State around $8 million just to defend the law..…That’s a steep price to give consumers virtually no useful information.