Review of the Gene Technology Act 2000

Western Graingrowers submission to the Review of the Gene Technology Act 2000 (GT Act)

Page last updated: 30 September 2011


The Pastoralists and Graziers Association of WA (Inc) (PGA) is a non-profit industry organisation established in 1907, which represents primary producers in both the pastoral and agricultural regions in Western Australia.

Western Graingrowers, the grains committee of PGA, represents progressive Western Australian grain growers who produce a substantial portion of the Western Australian grain harvest every year.

Having access to new technology, including GM, is a very important to our membership. This organisation has worked diligently since 1996 to allow Western Australian farmers access to GM technology, and important tool in the production toolbox. Several of our members planted GM canola in Western Australia's first commercial year of GM production (2010-11) and have witnessed first-hand the benefits delivered by such technology.

Allowing farmers the freedom of choice in their methods of production and in which products they use is central to the continuing success of Australian agricultural in feeding the world.

PGA and Western Graingrowers welcome the opportunity to comment on this review of the Gene Technology Act (2000).

Executive Summary

In 1798, Robert Malthus penned this doomsday tome in which he predicted mass starvation due to the "fact" that food production would not keep pace with the increasing world populations.

Since then, many "Malthusians" (as these doomsayers have come to be known) have attempted to strike fear into the hearts and minds of average citizens. The general theme is that humans are a blight on the earth, are somehow not a part of nature, and in taking actions to ensure propagation of our species, we are making the entire world "unsustainable".

Reality has proven quite the contrary in every instance. Thanks to human ingenuity and inventiveness, per capita food production has increased at the same time the world's population has doubled.

Graph of food production per capita index 1961 - 2005 GRAPH OF FOOD PRODUCTION PER CAPITA INDEX 1961-2005

In a speech delivered on 10 July 2000 entitled "Is There Enough Food?" Nobel Laureate Dr. Norman Borlaug stated:

I believe that we have the agricultural technology - either already available or well advanced in the research pipeline- to feed those 8.3 billion people anticipated [by 2025]. The pertinent question today is whether farmers and ranchers will be permitted to use that technology.

Extremists in the environmental movements from the rich nations seem to be doing everything they can to stop scientific progress in its tracks. Small but vociferous, highly effective and well funded Luddites are predicting doom and provoking fear, slowing the application of new technology, whether it be transgenics, biotechnology or more conventional methods of agricultural science. Witness the campaign against genetically modified crops called "Frankenstein Food" by activists in Great Britain and elsewhere in Europe.

I am particularly alarmed by those elitists who seek to deny small-scale farmers in the third world, especially in sub-Saharan Africa, access to conventionally improved seeds, fertilizers and crop protection chemicals that have allowed affluent nations the luxury of plentiful, and inexpensive foodstuff which, in turn, has accelerated their economic development.

While the affluent nations can certainly afford to pay more for food produced by so-called "organic" methods, the one billion chronically undernourished people of the low income, food deficient nations cannot. (There is not enough "organic fertilizer" to produce the food today's population of six billion requires. If we attempt to produce the equivalent of the 80 million tons of nutrient nitrogen from manure needed for such a task, world cattle production would have to increase five or six billion head.)

Of course we must be environmentally responsible. I have always subscribed to what, in the old days, we called "integrated crop-management" and is today called "sustainability" - utilizing the land for the greatest good for the greatest number of people over the longest period of time.

But today's extremist thinking is dangerously misguided. Most worrisome, it preys upon a "knowledge gap" about the complexities of biology among the general public in the affluent societies - now thoroughly urban and removed from any relationship to the land - that grows ever greater with the rapid advances in genetics and plant bio-technology.

No doubt, one of the other great challenges of the coming century is a renewal and broadening of scientific education - particularly in primary, secondary and early college levels - that keeps pace with the times. Nowhere is it more important for knowledge to confront fear born or ignorance than in this basic activity of mankind - the production of food.

The acceptance and adoption of new technology by society has always been incremental, Refinements and use over time often see technology that was initially resisted, eventually accepted.

Reasonable caution based on reason and science involves careful cost-benefit analysis and an assessment of risk within a logical framework. The cost of not approving something or of taking a product off the market is weighed against evidence. How many people might die of disease or malnutrition or starvation because we cannot say with 100% certainty that a certain product will not cause ill effects at some point in the future? While people prefer life to death, health to sickness, nourishment to starvation, abundance to poverty, there will be no place for the so-called precautionary principle.

The object of the Gene Technology Act is:
to protect the health and safety of people, and to protect the environment, by identifying risks posed by or as a result of gene technology, and by managing those risks through regulating certain dealings with GMOs.

The weight of evidence demonstrated that the risk of GM crops posing serious risks to human health and safety is close to zero, and that, contrary to damaging it, the use of GM crops allows us to better care for our environment.

We fully endorse the aims of the Act, and encourage the continuation of a science-based and evidence-based approach free from alarmism and scaremongering in order to deliver on the stated aims.

Commentary on Specific Issues

Emerging trends and international developments in biotechnology and its regulation

By far the most important trend in the biotechnology world as it related to agriculture and food production is the rapid uptake of GM crop technology and the absence of any single verified report of adverse human health or safety impacts.

From 1996 to 2010, a 15 year period, the world's farmers grew over a billion hectares of GM crops. It took ten years for the first 500,000, but only 5 years for the next 500,000 hectares, to be sown. Farmers have experienced the benefits of GM technology in their cropping rotations and have made approximately 100 million individual choices to seed GM crops.1

At the same time, no human deaths or illnesses due to consumption or use of GM products have been reported.

Our organisation endorses a risk-based regulatory environment. The amount of regulatory oversight should be proportional to the amount of risk involved.

As a basis of comparison, the New South Wales Food Authority2 reports:
  • About 5.4 million Australians contract food poisoning each year and most cases can be prevented.
  • This results, on average: in 120 deaths, 1.2 million visits to doctors, 300,000 prescriptions for antibiotics, and 2.1 million days of lost work.
  • The estimated annual cost of food poisoning in Australia is $1.25 billion.

Recent news reports of 33 deaths3 in Germany likely due to the consumption of contaminated organic bean sprouts highlight the very real risks of food safety that continue to plague industries and countries which reject modern technology in favour of obsolete "natural" practices.

While this is hard evidence of real problems that currently affect human health and the economy exists, there appears to be disproportionate oversight of GM technology where health and environmental problems have proved imaginary.

The efficiency and effectiveness of the operation of the Act consistently across the national scheme for the gene technology regulation in Australia

The Act should not be changed to make it more susceptible to the activities of pressure groups who pay little respect to the need to increase food production on a given area of land. Many within these groups are informed by organisations that have declared policies of reducing human population on earth, and therefore value an absence of food as a means to achieving that goal.

The price of regulatory oversight is paid by consumers through a higher cost of the product or service being regulated. In many cases, though, the real cost is immeasurable. It is the absence of competition in provision of technological products or services because the costs of regulatory approvals are too onerous for all but the largest of existing companies. In many respects, from an Australian point of view, the Act is self-defeating. We endorse the continuation of reliance upon evidence and the scientific method in regulation of gene technology.

The interface between the Act and other systems (e.g. other Acts and schemes)

The existence of the GT Act (2000) alone has not paved the way for farmers to access the technologies that have been approved as safe for human health and the environment.

It was disappointing in the extreme to have the Office of the Gene Technology Regulator approve GM canola only to have our state legislature, on politically expedient grounds, pass a moratorium on GM crop production. After an 8-year delay, an exemption for GM canola was granted in Western Australia, allowing commercial plantings to proceed in the 2010-11 crop year.

Well funded and highly organised pressure groups have had undue influence in stopping or slowing adoption of this technology. They have successfully delayed progress in the Australian grains industry for 15 years. In those years, whilst the Australian canola industry stagnated, the Canadian industry more than doubled production4 - from about 5 million tonnes in 1996 to over 12 million tonnes in 2009.
In some seasons, Canadian farmers actually increased their year-on-year volume of canola production by more than Australia's entire canola crop. If we continue to impede development and uptake of technology in Australia. we're making it possible for Canadians and other farmers in the world to displace all of our export canola from the market at no additional cost. That is but one crop.

Fortunately, the cotton industry was established before governments had time to suppress the development of GM cotton in Australia. There would be no cotton industry in Australia today had cotton farmers been forced to use only obsolete technology. Cottonseed oil is consumed in large volumes in Australia (particularly in the fast food industry) and it has been since the introduction of GM crops -- once again, without a single adverse health incident.

Across the world, wherever farmers have been allowed to trial the performance of GM technology, they largely subsequently choose to integrate it into their farming business at higher rates. Indeed, the adoption of GM crop technology has been higher than that of any other new technology in agriculture.

In Western Australia, where, for many years, the State Government was successful in preventing even the establishment of trials (so that GM crops' performance could be observed under experimental conditions), now that the technology has become commercially available, the largest problem confronting the industry has been inadequate supplies of seed at a cost farmers can afford and with varieties adapted to WA conditions.

Non-GM canola has been effectively segregated in the states growing GM canola, and the claims of marketing advantages have not eventuated in states with moratoria in place.

A clear pathway to commercialization of new seed varieties is vital to the continued development and uptake of GM technology in Australia. It is imperative that the "rules of the game" do not change randomly in the absence of real evidence reviewed within the application of the scientific method. Arbitrary and haphazard changes in the GT Act will do nothing to provide the certainty needed to achieve the objective of the Act.

Key Points:

  1. The amount of regulatory oversight should be proportional to the amount of risk involved.
  2. We endorse the continuation of reliance upon evidence and the scientific method in regulation of gene technology.
  3. The precautionary principle should not be incorporated into any regulatory regime. Application of the precautionary principle will destroy our ability to advance in agricultural development and use. The precautionary principle is antithesis of the scientific method. Had it been implemented at any point in past human history, we would not enjoy our current safe, healthy and nutritious food supply.
  4. GM researchers, developers, manufacturers, wholesalers and retailers must have certainty in the realm of regulations, and consumers (including farmers) will benefit from that certainty.


The world's population is currently about 6.5 billion people, and is estimated to reach 9 billion by 2050. Increased food requirements cannot be met on existing arable land without the continued use of existing technologies and the development of new and improved ones.

Contrary to what is commonly promulgated, the use of GM technology has allowed for increased food production and environment improvement with zero evidence of negative impact on human health or safety. In the absence of a regulatory and political environment which encourages and rewards the continual development and uptake of technological inventions and innovations, Australian farmers will be hampered in their competitiveness and ability to maximise food production. "Sustainability" by any definition will fail.

Responsible, science-based oversight of straight-forward, clear, measurable and unchanging rules will allow us to continue to feed the world while improving our environment.

Thank you for the opportunity to make a submission. We welcome any questions or requests for clarification you might have.

The Pastoralists and Graziers Association of WA (Inc)
14 June 2011

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