Today the House of Lords has published their report into GM Insects. I am astonished at how little they appear to have learned from the past in this report. This blog is my quick attempt to illustrate where the failures lie.
The inquiry chair, Lord Selborne, certainly should know better, he chaired our multi-stakeholder Responsible Nano Code initiative a few years ago which explored with stakeholders how to develop technology responsibly – in this instance nanotech, but the issues more generally around ‘Responsible Innovation’ are much the same and pretty much entirely fail to be applied here.
The report leads with the sentiment that we have a ‘moral duty’ to support the technology, to save lives, and equally prominently, because the UK is a leader in this area and it is in the public interest to avoid losing its ‘world leading talent’.. They bemoan unnecessary regulation holding back progress and public engagement is mentioned in the context of gaining public acceptability for the technology. Consideration of how to minimise negative impacts is barely mentioned at all.
Focus of critics
Commentators such as Jack Stilgoe and Sarah Hartley are scathing about the report, pointing out it’s ‘lopsided’ approach which focuses intensely on the potential positives without giving adequate emphasis to the potential impacts of the technology – describing it as ‘representing an unsophisticated form of moral blackmail’.
How could they make the same mistakes all over again?
In my view, it is perfectly feasible to make a case for a quite politically brave ‘moral duty’ to consider even controversial approaches to address complex and difficult problems; however it needs to be accompanied by a clear pathway to understanding and mitigating the many potential risks, whilst, crucially, remaining open minded and respectful of all views and considerations. This is where they have failed with this report, pretty much mirroring the failures of the past approach to GM plants.
Here for me are the lessons not learned:
1 Seeming to prioritise commercial goals ahead of due diligence on impacts
One of the fundamental lessons from the GM controversy was that commercial benefit appeared to (or did) trump safety and was prioritised over other issues. In this instance, by giving the weight and prominence they have in the report to the importance of benefit to science in the UK, and in fact to one small company, they have seemingly fallen straight into the same trap.
The very first page of the report leads with this and it seems the rationale for the report was based on this: “Against this background, the presence of a pioneering company based in the UK, and the world class research being conducted in our universities and
institutes, we decided to pursue an inquiry into GM insects. Primarily, we
set out to:
• explore the potential of GM insect technologies to control human and
livestock diseases and crop pests; and
• establish whether the regulatory environment was conducive to the
development and deployment of GM insect technologies”
That appears to me to be a very strange starting point for an ‘independent’ Inquiry. No mention of exploration of potential social, environmental, ethical, cultural or economic impacts, hazards and risks – the cornerstones of Responsible Innovation.
2 Have they sorted the hype from the reality – is it the Gartner Curve in action?
Many will know about the Garner Hype Cycle, I use it here with tongue-in-cheek as technology innovation isn’t really quite this neat, but to make a point. The hypothesis is that technology has a pathway as follows:
1 A technology trigger (OK, what can we genetically modify next? I know, Insects, what could we do with that? I know, let’s cure malaria)
2 A peak of inflated expectations (This technology is awesome, we will wipe out malaria, eliminate pesticides, get rid of expensive pests – it would be morally wrong for you not to give us the cash, we only need a few billion)
That’s where we are now and the rhetoric and rather breathless excitement in the report makes me think the Lords have swallowed the hype a bit too uncritically!
“The conceivable prize is enormous and the opportunity must not be squandered. Our concern is that unless there is change, and an injection of momentum and urgency, it will be.” Oh dear!!
The Chief Science Advisor for DfID’s Chris Whitty’s notes of caution on the speculative nature of the technology, its efficacy for malaria, and the importance of not diverting funds from other potential solutions appears to get a bit lost in the enthusiasm.
What follows is:
3 Trough of Disillusionment (So where are these results we have paid for, what do you mean it won’t work in all cases, have you done the risk assessment, what are the uncertainties, what do you mean people are against it, you really haven’t delivered what you promised)
4 Slope of Enlightenment (OK, so I see you have got evidence of what works and what doesn’t, it’s not going to do that, but it is useful for this. OK that’s interesting, this is beginning to look quite useful)
5 Plateau of Productivity (OK, this has contributed to A & B the impacts have been X & Y, this has a useful place in C & D)
Because of cock ups in steps 1 & 2, technologies can stop at 3 and never reach 5. That is what Responsible Innovation is all about. Not letting the science run the show, considering values and mitigating impacts as much as possible in advance and not over-selling it’s potential so much that the Trough of Disillusionment is inevitable.
3 Rows about Regulation
The long section bemoaning the regulatory regime in Europe is a well worn path for those involved in this area. I have some sympathy with the need to clarify the best approach to regulation and make it fit for purpose, for this and many technologies, particularly allowing a comparative approach considering benefits, risks and impacts of different solutions to be considered alongside each other. I have participated in a few interesting sessions on this recently and it is much needed.
However, the chippy & confrontational language used here is part of the problem and part of the reason why some countries dig in their heels. It is naive to expect that ‘the independence of the risk assessment process to be distinct from political decision making in the EU’ in this instance. The example of Spain refusing to permit a field trial, is seen as surprising.
Are regulators, politicians, publics, supposed to take the word and evidence provided by one small British company, in a complex area, with a speculative technology, unclear regulation, in a highly charged sector, with a very sceptical electorate? I don’t think it’s surprising that they don’t. If you go about introducing a technology quite as sensitive, and if it goes wrong potentially damaging, as this, with so little precaution and humility as is shown here, you will meet resistance. I appreciate that in other countries, where attitudes to the technology are different, where civil societies may be less engaged or heard, or the benefits may be more keenly felt, may have a different view.
4 Consideration of potential hazards, risks, impacts, dis-benefits and uncertainties is missing
Even the most zealous exponent of genetic modification would, one would expect, pause for thought at the proposition of Genetically modified insects and consider vary carefully the potential negative impacts of the technology on other organisms, the environment and eco systems.
In the upfront summary of the Lords report the potential for these negative impacts is not mentioned once. Not once. How bizarre is that given what we are talking about!
The Introduction follows the same line, and the recommendation that there is a GM field Trial does not mention, which in my view is pivotal and should be in the same section, their considered view that the current evidence of risks and remaining uncertainties makes this a credible option and outline what has been done to give them confidence.
Risk is only mentioned in relation to the protocols for regulation. Interesting that there are 142 paragraphs exploring benefit and considering regulation and none at all on what needs to be done to understand and mitigate risks and potential negative wider impacts.
5 Patronising attitudes to the public’s ‘anxieties’
Potential risks are mentioned in relation to the public’s ‘variety of anxieties’. Which include concerns about:
- horizontal gene transfer within the environment;
- potential impact on ecosystems;
- effects on predator/prey relationships and the food chain;
- evolution of more virulent strains of particular pathogens following GM control;
- a general feeling that GMOs are unsafe and create risks for individuals and the environment;
- the potential for unknown and unintended consequences;
- questions about intellectual property, patenting and excessive corporate involvement; and
- lack of confidence in scientists, companies and governments to understand and appropriately regulate the myriad possible implications of GMOs.
I may be over-sensitive, but the public is portrayed here as being almost slightly eccentric for worrying about these areas. Who is not worried about these issues in relation to GM insects I wonder!?
They “recognise, however, and wish to emphasise, that as these technologies develop, consideration of the ethical and safety concerns that surround GM insect technologies will be vital in order to inspire and maintain public confidence.”
Frankly, sod public confidence, these issues are the minimum that should be considered and solid evidence of safety & analysis delivered to underpin the development of this technology and certainly they should be adequately addressed and widely communicated before an open field trial is held, which the report is adamant should happen
This is not about public confidence, it is about the responsibilities associated with innovating in a complex area with the potential for very damaging downsides. It will follow quite swiftly that the public will fail to have confidence in a technology and a governance system that fails to give the highest priority to these issues.
In terms of public engagement, the ideas are basic, perfunctory and not thought through. There is brief mention of public engagement with the countries where the technology being used, for sales and marketing purposes.
I think personally that we, the stakeholder involvement advocates, are partly to blame for these approaches, we haven’t done a good enough job demonstrating the ‘business case’ for the involvement of society in more fundamental ways than market research and PR. We need to get our act together on that, and someone needs to pay to have it done.
When I read Jack Stilgoe and Sarah Hartley’s piece in the Guardian I thought perhaps they were being a bit over the top. But reading the report, I am not sure if it is competent enough to be considered ‘moral blackmail’. It’s a narrow-minded, knee jerk job, which has singularly failed to learn the lessons of the past, and fails to consider with any substance the issues of Responsible Innovation which are required for any technology, but in particular for this very complex new area.
I will close with the insightful advice from another member of the Lords, Baroness Onora O’Neill (who I wish had been on this panel,) She said:
“Once again, the slightly plaintive question “How can we restore trust?” is on everyone’s lips….the answer is pretty obvious. First, be trustworthy. Second provide others with good evidence that you are trustworthy”.
If the Lords had that as a starting point, they would have done a much better job. If I was Oxitec I would be livid. This may damage their chances of success quite significantly.
NB: Here is our submission to the Lords Inquiry Responsible Innovation and Genetically Modified Insects, using as its starting point our draft Principles for Responsible Innovation.