July 1999

This submission concentrates on the connection between animal testing and genetically modified food and organisms.

Food safety

"Labour will require that all GMFs for sale in New Zealand must be safety assessed"

The policy on who will carry out the assessing using whose data and methodologies has not been outlined.

Current regulations provide for the results of animal testing to be used in assessing the safety or otherwise of food. Extrapolations from animal studies to humans are so uncertain as to have no value. This is due to the differences in anatomy, physiology, metabolism and biochemistry between species. Doctors and scientists world-wide are speaking out about the dangers to human health of animal testing.

The current reliance on animal tests to prove the safety of a toxic product is an illusory farce. Rather than being instrumental in safeguarding our health, animal testing programmes have legitimised the continued production and use of millions of toxic chemicals.

Chemicals and pharmaceutical drugs are being pulled off shelves on what seems to be a weekly basis despite having tested 'safe' for humans based on studies on animals. The chemical companies and drug pushers currently use animal testing as their alibi to allow them to produce and market their dangerous products. Labour must ensure that the proponents of genetically-modified foods cannot use the same alibi to promote their potentially dangerous products.

Many non-animal technologies already exist which can screen toxic substances quickly, accurately, and cheaply, thereby preventing their production and distribution.

Labour needs to clearly signal that data involving results of tests on animals in assessing food safety for humans will carry zero weighting. Animal testing must not be used as an alibi for potentially dangerous food to be produced and distributed.

"Labour will require a recall plan to be developed so that food can be recalled from supply or use by consumers when that is in the interest of public health and safety."

Labour must ensure that when such food is recalled the producers and marketers are not able to successfully argue for the continuation or recommencement of supply based on results of animal tests. One of the best ways to prevent this is to give zero weighting to results of animal tests when deciding on whether or not to recall a product due to possible dangers to human health. A clear policy on this would stop producers and marketers successfully defending their potentially dangerous product on the grounds of ambiguity of animal testing.

For example when 2,4,5-T was coincidentally shown to have harmful effects in rabbits, Dow defended its continued production by arguing that "it is impossible to extrapolate from rabbits to humans".

"Labour will fund key research into the genetic modification of food to ensure that New Zealand's food meets the safety standards demanded by consumers and those set by our trading partners, and to ensure that New Zealand has the know-how to make its own decisions in this field."

Labour must not fund research involving animal testing in determining the safety or otherwise for humans of genetically modified food.

Labelling

Vegetarian and vegan diets are common for many New Zealanders. They have made these decisions for a variety of reasons: ethical, spiritual, health, animal welfare, environmental included.

Should a decision be made to allow the supply of genetically modified food it is essential that those foods that are presently compatible with a vegetarian or vegan diet be clearly labelled as to whether the product contains gene material from an animal or animals.

Royal Commission

The terms of reference for a Royal Commission must include:

• The effects of genetic modification on the organic production of food.
• The risks associated with genetic modification of animals to produce organs for xenotransplantation into humans.
• The economic costs and health risks of using genetically modified animals to produce pharmaceutical proteins.
• The scientific invalidity of using animal testing as an alibi to allow the production and marketing of genetically modified products for humans.

Independent Biotechnology Advisory Council

We have no confidence in the IBAC given that the convenor is New Zealand's most infamous defender and practitioner of vivisection, Peter Gluckman. His activities include taking court action against those who have opposing views and failing to show up for the hearing thus wasting taxpayers' funds and resources.

Food Assurance Authority

The FAA must be required to give zero weighting to all animal testing data and results when assessing the safety or otherwise of food for humans.

The FAA must be prohibited from conducting or commissioning research into food safety for humans that involves animal testing.

Environmental Risk Management Authority

ERMA must be required to reject all applications to import or breed genetically modified animals for the purposes of medical research.

ERMA must be prohibited from conducting or commissioning research involving animal testing into the safety or otherwise for humans of genetically modified organisms.

Recommended reading

• Animal Research Takes Lives - Humans and Animals Both Suffer, NZAVS, 1993, Bette Overell
• Submission in Support of NZAVS Petition to Abolish Vivisection, NZAVS, 1991
• Lethal Laws, Alix Fano, Zed Books 1998
• The LD50 Alibi, NZAVS, 1985