Minimum international standards of regulation should be formulated by the United Nations to protect human and environmental safety. Individual countries would be required to enforce these minimum regulations through their own government agencies, but would be free to enforce more stringent standards should they wish to do so. In order to make these standards meaningful, it would first be necessary to define the terms "safety", "harmful", etc. as they pertain to genetically modified organisms.

Genetically modified organisms should be regulated during all steps of its process from manufacturer to consumer — field-testing, transportation, distribution and sale. More specifically, government monitored environmental release (also called field-testing) for genetically engineered crops is essential. Applicants for environmental release should provide full information about the plant, the new genes and their origin, the purpose and design of the experiment, and the precautions taken to prevent unintended cross-pollination with other plants. This can be achieved by bagging the flowers, growing the crops in cages that keep insects from carrying pollen out, removing the plants’ reproductive structures and isolating the plants from other crops. Once the crop has been harvested, any residual vegetative material must be allowed to dry down in the field and be incorporated again into the soil before the planting of new crops.

These field tests must necessarily be limited in terms of geography and time. They cannot predict all the effects of the large-scale introduction of a genetically engineered crop to diverse ecosystems. Such small-scale experiments, however, can provide useful information as long as that information is understood to be the result of a limited experiment and not unjustifiably extrapolated.

In assessing the results of these tests, scientists should actively look for harm, in the crop’s effects on insects, microorganisms, and other crops. They must never assume that genetically engineered crops are safe. It should be the responsibility of the manufacturer to demonstrate the safety of a genetically engineered organism, rather than the government’s responsibility to prove danger.

It must also be the responsibility of the government to "remove unsafe foods from the marketplace and make producers legally responsible for the safety and wholesomeness of the foods they market."^xxi All food containing genetically added substances must be proved by the manufacturer to be safe. Especially close attention should be shown to products that produce unexpected genetic effects, significantly alter levels of important nutrients, differ significantly in composition from substances currently found in foods, and those that may contain proteins causing allergenic responses.

This last criterion is particularly difficult to assess, as there is currently no way to predict the allergenicity of most proteins.^xxii For this reason, we recommend that the United Nations take active steps to improve scientific understanding of allergens and develop predictive tests for determining allergenicity. Foods that have been genetically engineered to contain proteins known to be allergenic, such as soybeans engineered with a Brazil nut gene, should not be marketed. And until such predictive tests have been developed, genetically engineered foods should be labeled as such, clearly stating the risk that it may contain unknown allergens.

In making the minimum regulations, the United Nations should assess safety as far as current science allows. The long-term health effects of genetically engineered organisms are still unknown, with no way to certainly determine them without the passage of time. It is unnecessary, however, to reject them completely. Standards should call for labeling of all genetically engineered products, even such products deemed "safe" according to regulations, in order to give consumers full disclosure and the right to choose.

11/30/99)

(accessed 11/28/99)