The environmental ethics of agbiotech

The most frequently raised issue with agricultural biotechnology has been the potential for GMOs to cause long-term disruption of natural ecological relationships, necessary for sustainable, productive agriculture, and the health of the planet itself. The concern is shared by proponents and opponents of agbiotech; the Earth must be treated in ways that ensures the welfare of present people and future generations. It would appear that both believers in the legitimacy of agbiotech (to the extent they have thought about it) and environmental critics hold if not espouse a utilitarian ethic in this regard. The question is what does the "greatest good for the greatest number" mean to each of these parties.

Some environmentalists object to agbiotech simply because they have deemed the products of agricultural biotechnology "unnatural." I will discuss "naturalness" in more detail below, but the claim can be understood to mean that the nature of the products, or the ways they have been produced are such that ecosystemic health, and by implication the health and welfare of present and future human beings (and perhaps animals), will be threatened. Many critics are unwilling to accept an argument that agbiotech products, despite their test-tube origins, might actually improve health and well-being by positively altering the environment. Rather, the complaints are that GMOs have had and will have (and maybe must have) specific negative consequences in the environment. For example, GM herbicide-resistant crops and their herbicide "partners" are indicted for killing microflora in the soil—to the detriment of long-term soil fertility and hence food security (see Lappe and Bailey, 1998). GM insect-repellent plants are been blamed for endangering beneficial insect species, thereby disrupting ecosystems in ways bound to negatively affect people (Rice, 1999). Critics point to potential (long-term) negative human welfare effects, whereas proponents stress positive welfare consequences: herbicide tolerance means fewer agricultural chemicals in use, ultimately reducing food prices; insect-repellent plants similarly reduce costs of chemical applications and hence decrease farmer costs.

The urgency of many environment-based criticisms stems from the number of GM products slated to be deliberately released into the environment. Although the rate of increase in patents for such products has slowed, the number remains high (Halweil, 2000). No environmental catastrophe has occurred because of GM products now on the market. Yet, it remains a contention of critics such as Greenpeace, the California-based Center for Ethics and Toxics, the Union of Concerned Scientists, and others that GMOs have the potential for causing serious ecological harm. These organizations and others have devoted considerable time and energy to showing how biotechnology products might behave in ecosystems, whether in a farmer's field or in the larger environment, with negative welfare implications. However, "mainstream" research and testing performed by governmental agencies responsible for monitoring and regulating products with potential environmental consequences have repeatedly stressed environmental safety (and agricultural/welfare benefits) (see, for example, Sears et al., 2001). It is clear that much research is being conducted on environmental safety issues associated with GMOs, and different and contrary if not contradictory answers are being generated about their safety. This is controversial, but it is not an ethical controversy per se. Although, as some would have it, agbiotech puts the "ethics" of scientists and agencies who judge GMOs to be environmentally safe against the "ethics" of those whose scientific analyses suggest otherwise, the issue is really the soundness of the science used in establishing environmental acceptability (and preferability).

I see much of the environmental ethics of agbiotech as more of an apparent controversy than a real ethical one: it is more a case of disagreement over scientific interpretations and details, not ethical principle. Again, it would appear that researchers and activists working on assessing environmental impacts share an assumption or belief that "affecting natural systems negatively is ethically wrong," because of the welfare effects. Critics maintain that ecological diversity or soil fertility will be lost, negatively effecting present and future people. Proponents see improved gains in productivity and profitability (and reduced price). The difference is that the opposing sides have different views about what "the greater social good" means, and the means to achieve it. More important, they have different views about safety.

Proponents and critics of agbiotech seem to agree that all science can provide are its "best" conclusions at any point in time, and that there are gaps in scientific knowledge of how ecosystems behave, especially over the long run. Indeed, even the best scientific analysis of a new product is almost by definition incomplete. The question both sides pose is when are the results of scientific testing regarding environmental safety "good enough?" On the one hand, there are those in the scientific establishment, in biotechnology companies, and in government, who think that we can do the necessary tests and arrive at answers that are "good enough" to justify the release/marketing of a product. On the other hand, there are those who think that when doubts or uncertainties remain, we should continue testing until no more doubts remain.

This is the premise behind the call for scientists and regulators to adopt the so-called "precautionary approach" employed in environmental safety regulation in the European Union. Caution demands either near certainty in our environmental assessments, or at least serious consideration of "worst-case scenarios" (see Raffensburger and Tickner, 1999). US scientists and governmental agencies have not embraced the precautionary approach or precautionary principle. The standard view is that the kinds of rigorous chemical and biological testing of biotechnology products that "environmental risk assessment" mandates provide (and have provided) adequate grounds for asserting that some biotechnology products are safe.

A common definition of "safe" is "acceptable risk" (see Fischoff, 1981). Determining safety usually involves a two-stage process. First, scientific risk analysis is applied to a product. Risk analysis involves the identification of hazards or harms associated with the product, assessment of what effects a product has given different levels of consumption, and assessment of possible effects on different categories of agents, e.g. children, normally healthy adults, etc. (Wotecki, 1998). The goal of the process is a judgment concerning the "probability of harm"—how likely is it that this product will produce any negative health effects.

The second and crucial stage in the evaluation of environmental safety is deciding whether possible/probable harms are acceptable, and according to what standards. One such standard is "no detectable adverse effects." For example, if a chemical shows a low (though not zero) probability of harm over variable doses and different populations, and if there is some benefit in its use, applying the "no detectable adverse effects" standard means that the product is judged safe (i.e. the risks are acceptable). Alternatively, risk assessment may determine that for some populations, or at some dose, or in the presence of another substance, the probability of harm may be somewhat high. One might assume that risks would be unacceptable. However, another standard, "risk necessary to achieve benefit," might allow the product to be determined safe—though with conditions such as appropriate labeling, or applicator certification required.

Despite the apparent rigor in environmental risk assessment, opponents of GMOs fix on the fact that "safety" is a value judgment rather than a scientific certainty. As such, judgments of safety are to be treated with suspicion. This perspective leads some to believe that critics are anti-science, or worse, anti-rational and "emotional" (Rollin, 1995; Vanacht, 2000). However, the critics' points imply a deeper ethical indictment of risk assessment, and especially scientists' ethics, despite the latter's apparent assent to a "do no harm to the environment" principle. This concerns sincerity and honesty: How committed are scientists and regulators to environmental safety? How diligent are scientists and regulators in applying rigorous tests to determine safety? How careful are they to alert farmers to use agbiotech products appropriately? Each of these matters has bearing on the ethical acceptability of agbiotech, but are not typically the focus of the debate about the environmental ethics of agbiotech. They are relevant in terms of the institutional context of agbiotech's development and deployment, and I will return to this.

In sum, once we set aside those arguments that assert GMOs are environmentally unacceptable simply because they are GMOs, the environmental-ethical acceptability of GMOs rests on a judgment that these products are safe. This judgment rests, in turn, on someone having subjected particular GMOs to a battery of scientific tests. If we believe in the integrity of scientists and governmental agencies, and hold that environmental risk assessment as currently practiced is "good enough," then we ought to be able to conclude that GMOs overall are not ethically unacceptable. The issues are really whether our current standards for determining safety adequately assure our acting ethically responsibly toward the environment, and scientists and others responsible for safety determinations perform their tasks competently and ethically. Presumably, the goal of safety standards is welfare preservation and enhancement, a goal held by pro-agbiotech types and those opposed. Perhaps the issue, ultimately, is whether the testing/regulatory system in place (and those that populate it) performs in ways consistent with environmental safety and human welfare. The same can probably be said with regard to nanotechnology.

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