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Preserving the Safety of Our Food, the Health of Our Environment, and the Harmony of Our Relationship with Nature

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1. While human beings may rightfully improve the world through many types of technologies, the enterprise to restructure the genetic blueprints of earth?s plants and animals is so unprecedented, so invasive of the realm of the Creator, and potentially so irreversible that it warrants the most careful consideration and reverential restraint. Human intelligence should not undertake such a venture without sincere acknowledgement of its own limitations and full appreciation of the complexity and majesty of God?s design.

2. Accordingly, it is crucial to recognize the extent to which genetically engineering our food supply exceeds all previous technologies in disrupting natural boundaries. Bioengineering (through which bacterial, animal and even human genes are being fused into fruits and vegetables) is a radical departure from traditional breeding techniques and represents an unprecedented break with natural processes. (Nobel laureate biologist George Wald has termed it "the biggest break in nature that has occurred in human history." ) Even nuclear technology is substantially more congruent with natural processes, since sustained fusion and fission reactions both exist under natural conditions. In contrast, the systematic transfer of DNA between distant and dissimilar species does not occur through natural pathways but relies on invasive and forcible gene splicing techniques. Moreover, in traditional breeding, DNA is conveyed in the form of complete chromosomes. This means that genes are transferred in groups in which they are positioned according to a fixed sequence that harmonizes with the sequence of genes in the host cell. It is otherwise in genetic engineering, where isolated genes (or conglomerates of fragmented genetic material) are inserted randomly within the DNA strand of the host, thus reconfiguring its natural sequence in unpredictable ways.

3. Regrettably, neither the bioengineering industry nor the federal administrative agencies responsible for regulating its products acknowledge the actual character of this radical technology. Rather, they repeatedly claim (as in FDA publications) that it is merely an "extension at the molecular level" of traditional selective breeding; and Dr. Henry I. Miller, who for many years was director of the FDA's Office of Biotechnology, has recently asserted in a newspaper op-ed piece that there is "a seamless continuum" between the two processes. Because the federal agencies impute close kinship between forcible gene splicing and sexual reproduction, they claim substantial equivalence between their products. For instance, the current federal policy, published on June 26, 1986 as the Coordinated Framework for Regulation of Biotechnology, is based on the premise "...that products of recombinant DNA technology will not differ fundamentally from unmodified organisms or from conventional products." This policy is the cornerstone for the regulatory programs of the USDA, EPA, and FDA regarding genetically modified organisms, and it is clearly not neutral. FDA admits the policy aims "to foster" bioengineering ; and the USDA emphasizes its own efforts "to promote" global adoption of the policy in order "... to prevent ... trade barriers and ease the transfer of American products into international markets."

4. Based on these assumptions of substantial equivalence, and unduly influenced by their motive to promote bioengineering, the federal agencies are in large part abdicating their regulatory responsibilities as regards genetically modified organisms (GMO?s). For instance, the USDA, which is charged with assuring that genetically altered crops pose no ecological hazard, has progressively weakened its oversight procedures to the point where it has virtually eliminated federal permits for field testing. In 99% of the cases, the only requirement is that developers notify USDA of their impending test, and the agency conducts no review. So far, no proposed release of GMO?s has prompted either USDA or EPA to require a formal environmental impact statement under the provisions of the National Environmental Policy Act.

5. A more precautionary approach is warranted. Just as transporting foreign organisms across natural geographical barriers has frequently resulted in substantial (and unexpected) ecological harm, so transposing foreign genes across nature?s biological barriers can also yield unpredicted damage. For instance, through cross-pollination, superweeds can be created; and through use of viral DNA as vectors in the engineering process, superviruses could emerge. Further, the majority of bioengineered crops are made resistant to chemical herbicides, which will greatly increase the use of these environmentally damaging substances. Moreover, the negative effects of genetic engineering are in many respects irreversible. The extent of this irreversibility has been termed "awesome" by Erwin Chargaff, often referred to as the father of molecular biology. Accordingly, organizations such as the Sierra Club have called for much stricter regulations on release of GMO?s than the government requires, and the Union of Concerned Scientists has called for a moratorium on releases pending more rigorous testing and safeguards.

6. Besides allowing GMO?s to be released without adequate safety precautions, the federal government also permits them to be sold as food without proper testing. Because the FDA assumes genetically altered foods are substantially equivalent to their natural counterparts, it also assumes they are generally safe, and it does not require that such safety be established through the standard testing required of novel food additives.

7. This policy is scientifically unsound. Evidence increasingly indicates that the function of genes is significantly influenced by their chromosomal context and that when placed in a new one (through genetic manipulation), there are unexpected results. Not only can the function of the transposed gene be altered, so can the function of the surrounding host genes. Such disruptions can stem from the influence of the foreign genes themselves and also from the promoters and enhancers that commonly accompany them. Although these agents are added to maximize the expression of the foreign gene, they may unintentionally increase the expression of surrounding genes as well. These potential hazards have been noted by many experts and well-expressed in a statement by a group of 25 scientists that includes the Director of the Max Planck Institute and President of the Association of German Scientists; a professor of medical microbiology at the University of Leeds, UK; and a professor emeritus in the department of molecular and cell biology at the University of California, Berkeley. Their report, The Need for Greater Regulation and Control of Genetic Engineering, warns: "With genetic engineering, familiar foods could become metabolically dangerous or even toxic. Even if the transgene itself is not dangerous or toxic, it could upset complex biochemical networks and create new bioactive compounds or change the concentrations of those normally present. In addition, the properties in proteins may change in a new chemical environment because they may fold in new ways. Further, the potential toxic or carcinogenic effects could have substantial latency periods. Only rigorous, long-term tests can screen for such problems. But under current FDA policy, genetically engineered foods are marketed without such tests. Moreover, whatever testing does occur is largely left to the discretion of a food?s developer, which the Council for Responsible Genetics likens to letting the wolf guard the hen house.

8. In addition to the group of scientists mentioned above, many other eminent scientists and public interest groups have criticized FDA?s policy as overly lax (e.g. Union of Concerned Scientists, Environmental Defense Fund,); and an editorial in The New England Journal of Medicine (Vol. 334, Issue 11, 1996) observes that the policy "would appear to favor industry over consumer protection." Another forceful critique has been made by Consumers Union in written comments to the FDA that "disagree strongly" with the assumptions upon which its policy is based. In an attempt to reform this policy, CU urged the FDA to recognize that genetic engineering "...represents something that is fundamentally new and, as such, should be approached with caution, care and some humility as well as a healthy respect for how little science still knows about how this technology works."

9. Consumer Union?s plea for humility in the face of our vast ignorance about the intricacies of genetic interactions was made from a secular standpoint. From the standpoint of religion, the need for humility is far greater; and its virtual absence from the thinking of the bioengineers and their governmental promoters is a glaring defect that rightly undermines confidence in their actions. This is especially so for religions that view the myriad forms of life as purposeful creations of a supreme God. From such a perspective, the cross-breeding barriers are basic features of the divine plan, and limited human intelligence should be wary of disrupting them and should approach the intricate web of life with great reverence. At minimum, this entails that substantial caution should be exercised in any attempt to alter such a complex and delicate system, especially when it involves reconfiguring the genetic structure of numerous organisms. To presume that both the process and products of piecemeal gene splicing are essentially equivalent to those of sexual reproduction is to significantly discount the existence and importance of a divine plan. It is deeply disrespectful to trivialize the differences between forcible gene splicing across natural barriers and normal reproduction through God-given pathways, and it is highly arrogant to thoroughly sunder these natural barriers without adequate precaution.

10. The degree to which bioengineering (as currently conducted) involves disrespect for the Creator of life and an arrogant over-estimation of human capacity to assume such an awesome role is highlighted by a comparison with computer programming. When software engineers add code to an existing program, they test to see whether they have inadvertently disrupted its function. These tests include even those parts of the system that their intervention was not designed to affect. Given the nature of such systems, they recognize that the addition of even a small amount of new information can have unforeseen consequences. Further, the more that an unexpected change could endanger human life (as in the case of software for pace-makers, X-ray machines, and airplane guidance), the more rigorous the testing.

11. Compared to even the most elaborate man-made software system, the genetic program of a living organism is vastly more powerful, vastly more complex, and vastly less comprehended by limited human intelligence. Moreover, unanticipated side effects in reprogramming the genetic structure of the food supply could have disastrous consequences for human health. Accordingly, bioengineering of food should at minimum be conducted with the same standard of care that is followed when re-engineering life-critical computer software. For bioengineering, this standard entails long-term clinical feeding tests, since only such testing can monitor whether deleterious imbalances have been generated by the random insertion of foreign genes. Yet, the promoters of genetic engineering (in both the public and private sectors) have summarily assumed we can repattern the divinely created blueprints of life with far greater confidence than when revising a computer program created by the human brain, and scores of genetically reconfigured foods are being rushed to market absent the type of testing we routinely require when altering the work of our own hands. Moreover, not only does the FDA fail to subject genetically altered foods to the same standard of testing it mandates for life-critical medical software, it even fails to subject them to the less stringent standard imposed on novel food additives produced by conventional means. This reveals not only a reckless disregard of sound scientific practice, but a brazen disrespect for the Creator.

12. Given the unprecedented degree to which food bioengineering alters the integrity of God?s creation, and given the degree of irreverence with which it is being carried out, any devout individual has strong religious grounds for wishing to separate him or herself from this ethically questionable enterprise by avoiding its products. Moreover, the potential health hazards of genetically altered food provide additional grounds -- especially since the claims about the safety of such foods not only are based more on unconfirmed assumptions than empirical proof, but because the assumptions themselves are unsound from the standpoints of both science and religion. They ignore important biological facts while also failing to recognize that the genetic patterns which structure the various species -- and the crossbreeding barriers that preserve species integrity -- are basic features of a divine plan. Only by virtue of such deficient thinking do bioengineers presume they can sunder these natural boundaries and radically restructure the genetic programs of living organisms with greater certitude than when amending a man-made computer code.

13. In summary, religious individuals have strong grounds to reject the products of genetic engineering based not only on concern for personal safety but also on concern for the integrity of God's creation and the integrity of humanity's relationship with God. Such rejection has a religious dimension and is a religious right.

14. However, the FDA's failure to require labeling of genetically altered foods is effectively restricting Americans from exercising this right and subjects individuals to foods they have sound religious reasons to avoid. FDA policy thus appears to violate the First Amendment of the U.S. Constitution, which protects free exercise of religion. Further, because bioengineered foods have been implanted with genes (and resultant substances) that are foreign to them, FDA policy also appears to violate Section 403(i) of the Food, Drug and Cosmetic Act, which requires that added substances to a food be labeled, as well as Section 403(a), which prohibits "false or misleading" labeling and mandates disclosure of material facts. While this lack of labeling poses a serious problem for all citizens, it is most injurious to individuals who for either health or religious reasons must strictly avoid specific categories of foods (e.g. allergy sufferers; Jews, Muslims, devout vegetarians).

15. People concerned about maintaining the integrity of their food, the integrity of God's creation, and the integrity of their religious principles should avoid purchasing bioengineered foods and act to reform the government policy that restricts their freedom to do so -- while it waives rational restrictions on commercially altering the blueprints of life.


  • Wald, G. quoted in Kimbrell, A., The Human Body Shop: The Engineering and Marketing of Life, Harper Collins (1994) p. 159.
  • "Genetically Engineered Foods," FDA Consumer, Jan. - Feb. 1993, p. 12; See also 57 Federal Register 22984 May 29, 1992.
  • Miller, Henry, I. "Happy Earth Day, Mr.Rifkin," Washington Times, April 22, 1997. J. W. Glosser, chief administrator of the USDA's Animal and Plant Health Inspection Service, testifying before the House Subcommittee on Department operations, Research and Foreign Agriculture on Oversight of APHIS Programs, 17 July, 1988.
  • FDA Consumer, supra, p. 14.
  • Testimony of J.W. Glosser, supra.
  • The Gene Exchange, Fall, 1997, Union of Concerned Scientists.
  • The Need for Greater Regulation and Control of Genetic Engineering: A Statement by Scientists Concerned About Trends in the New Biotechnology. Third World Network, Penang, Malaysia (1995) p.18.
  • Consumer Alert, Council for Responsible Genetics, web site: www.essential .org Consumers Union?s Comments to U.S. Food and Drug Administration on Statement of Policy: Foods Derived From New Plant Varieties, August, 1992, p. 2.



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