Biotechnology Policy [The following policies on Biotechnology have been adopted by the Sierra Club Board of Directors:]
GENETIC ENGINEERING is a rapidly evolving technology involving molecular modifications of the genetic code of living organisms. Sierra Club’s policy, herein updated, is concerned with the applications of this technology in farm crops, fish and non-human animals, trees and all wilderness species. Our policy is not intended to be applied to biomedical applications. Genes taken from one species and inserted into the genome of another, such as bacterial genes inserted into corn or soy, are one application. The resultant crop can be called a genetically modified organism (GMO) or genetically engineered (GE’d) or, as in the Cartagena Protocol on Biosafety to the Convention on Biological Diversity, a living modified organism (LMO).
Genes which have been transferred like this are called transgenes. When genes from different sources within the same species are moved, the process is called cisgenesis rather than transgenesis. In either case, the aim is to make heritable changes which can be passed down to succeeding generations. In both cases, there are risks, one of which is that if such organisms are introduced outside of laboratory confinement the ways in which they spread and their ultimate health and ecological effects may be impossible to predict and the genetically engineered organisms may be impossible to recall. More recently, it has become possible to directly edit genes and regulatory elements at the molecular level (for example, zinc finger technology and CRISPR-Cas9 techniques) which present new risks. Indeed, the annual worldwide threat assessment report of the U.S. intelligence community (2016) added gene editing to its list of “weapons of mass destruction.”
For purposes of this policy we define genetic engineering to include all direct molecular manipulation of the genetic structure of organisms or viruses.
A genetically engineered organism (GEO or GMO or LMO) is a single-celled or multicellular organism, the genetic structure of which has been altered by genetic engineering.
The accidental outflow of transgenes or altered genes from a genetically engineered organism to a natural organism, for example by pollen transfer or fish spawning, results in the production of an organism which, although it has not intentionally been genetically engineered, must be classified as a genetically engineered organism.
GENERAL STATEMENTS OF PRINCIPLE (further expanded in the guidelines, to follow)
The Sierra Club urges full public disclosure, discussion and evaluation of the potential hazards, the potential benefits, and policy options for genetic engineering research and the development and use of products from that research. We urge the development of adequate regulatory, legislative, and other controls and that these decisions be based on a reverence for nature and life, as well as socioeconomic equity.
We call for a ban on the planting of all genetically engineered crops and the release of all GEOs into the environment, including those now approved, pending improved regulatory procedures and safety testing. Releases should be delayed until extensive, rigorous research is done which determines the long-term environmental and health impacts of each GEO and there is public debate to ascertain the need for the use of each GEO intended for release into the environment.
We urge that where there are safer alternatives to the use of GEOs, these technologies should be given preference. For example, genetic engineering solutions should never be used to divert attention from the solutions to the problem of hunger that carry less biological risk (e.g., better distribution of food, land reform, sustainable soil conservation strategies, promotion of regional sustainability, reduced consumption of animal products, and stabilization of population).
GUIDELINES (1) TESTING OF GEOs.
There are health and environmental risks inherent in the release of GEOs during field testing and/or commercial planting. Government agencies must develop and enforce policies that require stepwise testing, with strict controls to prevent accidental and premature releases. The stepwise testing must include (as appropriate) contained testing in the laboratory and greenhouse. The results of each step must be made publicly available when tests are subject to approval processes. No field testing should be done until all guidelines in this policy are met.
(2) REGULATION OF GEO RELEASES.
Regulation of releases of genetically engineered organisms should ensure that potentially hazardous organisms are not released into the environment without sufficient safeguards and monitoring. Final evaluation should be made on the basis of the effects of genetic modifications, taking into account other factors, particularly the site where the organism will be released. Long-term as well as short-term impacts of GEOs must be evaluated, and a finding of environmental safety made before a release is approved. At a minimum, the evaluation must assess:
(a) the genetically engineered organism's role in the ecosystem (including its food and nutrients, its predators, parasites, and competitors, organisms with which it can exchange genetic material, and environmental limits to its growth);
(b) the impact of its release and potential use on ecosystems and genetic diversity;
(c) the effects of its potential use on sustainable agriculture, resource use, and cultural systems;
(d) the impacts of the organism and its products on human health; and
(e) the impacts of marker genes as well as genes of interest to producers. (Antibiotic resistance marker genes should not be used in GEOs released into the environment.)
All impacts from production to disposal should be assessed, as well as all paths of potential migration, and the scale of the release. Deleterious impacts on workers or on those living near production or release sites should also be considered. An emergency response plan must be in place in case of unforeseen outcomes.
If any government, organization or individual wishes to release, for any purpose, genetically engineered organisms into the environment of a foreign country, they should abide by the standards of the releasing party's home country as well as those of the host country. In the case of conflicting national standards, the standard more protective of the environment and human health should prevail.
Public agencies providing biosafety oversight must notify the public of proposed releases and provide a reasonable and timely opportunity for the public to comment on proposed releases. Notification should include, but not be limited to, the location of release sites. Public comment should be encouraged and receive response. Agencies should ensure public access to all information necessary to evaluate potential hazards even when such needed information otherwise qualifies as confidential business information. In addition, companies and institutions should not be permitted to withhold scientific testing data as trade secrets.
The Sierra Club supports the establishment of a repository for information on GEOs that have been approved for release. Such information must be available to the public.
(3) MONITORING OF GEOs.
Both deliberate and unintentional releases of genetically engineered organisms should be monitored through coordinated efforts of agencies, companies, and academic institutions in order to test predictions about the organisms' behavior, numbers, dispersal and environmental impact. The public should be involved in the design of these monitoring programs. Data from such programs must be made available to the public and widely distributed and publicized.
(4) LABELING AND SUBSTANTIAL EQUIVALENCE.
Foods produced from or containing GEOs may contain new substances or have purposeful or inadvertent compositional changes. All foods containing or produced with genetically engineered material must be labeled as such. The federal government should carefully regulate food produced from or containing genetically engineered organisms to ensure safety. The use of the concept of "substantial equivalence" in order to waive the need for both pre- and post-marketing testing and surveillance should be prohibited.
(5) LIABILITY.
Liability issues must be addressed and resolved prior to the release of every GEO. Manufacturers of GEOs should be fully liable for any environmental damage caused by the organisms they genetically engineer. The burden of proof of safety must be on the manufacturing company. At a minimum, these companies must be fully insured and able to reimburse:
(a) farmers whose crops are less saleable because of genetic contamination from GEOs;
(b) farmers using nonviable genetically engineered seeds; and
(c) for any human or animal suffering health dysfunction resulting from consumption of products that contain GEOs, where the conventional counterpart did not cause such health dysfunction.
(6) CONFLICT OF INTEREST.
Regulations should require that there be full public disclosure when there is potential conflict of interest with individuals:
(1) serving on biosafety committees;
(2) working for or advising government regulatory or research agencies involved in genetic engineering research or regulatory oversight.
(7) REGULATION OF GEOs/TRADE RULES WITHIN THE USA.
We support the right of states and localities to adopt regulations for genetically engineered organisms more stringent than federal regulations. We support efforts to ensure communication and, where appropriate, to coordinate oversight among federal, state, and local agencies. Federal and international trade policies and rules must not interfere with the right of states and localities to adopt more stringent measures.
(8) REGULATION OF GEOs / INTERNATIONAL TRADE RULES.
All nations should develop and enforce regulations governing experimental release and commercialization of genetically engineered organisms. We oppose any release or agricultural/industrial commercialization of GEOs until appropriate procedures are in place to protect human health, biodiversity, and cultural systems. Trade rules must not be used to override the right of each country to establish regulations based on its own level of risk and based on precautionary action in the absence of scientific certainty.
GEOs may have transboundary impacts and may also move both legally and illegally in international trade. No international trade agreements should infringe upon the rights of governments to apply the Precautionary Principle or to regulate import, export, or trade of genetically engineered species within their borders.
(9) INAPPROPRIATE USE OF GEOs.
We oppose any development or use of biological weapons and agents used for agricultural bioterrorism, including any use of genetic engineering for these purposes.
We oppose the introduction of any GEOs onto public lands or other open spaces that are protected chiefly for their natural characteristics.
We oppose activities that have the potential to adversely affect the viability of biodiversity and food security. Genetically engineered seed meant to enhance monocropping is an example of such an activity. Others include:
(a) Systems which combine the development of herbicide-tolerant crops with reliance on the manufacturer's proprietary herbicides to control competing plant species should not be instituted;
(b) Technologies that encourage corporate control over seeds should not be employed. Genetic restrictive use technology (commonly known as "terminator technology") is an example of such corporate control; and
(c) Policies that encourage further consolidation or monopolistic control of the food production system should be avoided.
(10) PATENTING of GEOs.
All humans, animals, plants, and microorganisms are products of nature.
No individual, institution or corporation should have the ability to claim ownership over species or varieties of living organisms. We oppose the granting of patent claims over organs, cells, genes, proteins, and other living matter whether naturally occurring, genetically engineered, or otherwise modified. The genetic code of humans, animals, plants and microorganisms has evolved over hundreds of millions of years and represents not only our natural world of today but also its past and future. We hold that respect for this natural treasure demands that no government should have power to grant patents or property rights over it. Just as civilized societies have decided that there can be no ownership of human beings (slaves), we believe that there should be no ownership of genetic code, which should continue to be the shared common heritage of all.
Indigenous peoples, their knowledge and resources are a target for the commodification of genetic resources. We recognize these peoples' sovereign rights to self-determination and territorial rights, and support their efforts to protect themselves, their lands and genetic resources from commodification and manipulation.
Patents over life forms are not necessary to conduct scientific and technological research, and, in fact, retard and limit access to benefits which may result from new information, treatments or products.
(11) BIOPROSPECTING.
Our national park system was established to conserve its scenery, natural and historic objects, and wildlife in such a manner that will leave them unimpaired for the enjoyment of future generations. This mandate protects all genetic resources within our national park system from commodification and manipulation. Accordingly, we oppose any individual, institution or corporation's ability to claim control and ownership over this diversity through the act of bioprospecting and/or through contractual agreements allowing access to such diversity for the purpose of commercial gain. We respect the rights of all peoples and governments to similarly designate and restrict exploitation of their own genetic resources.
Adopted by the Sierra Club Board of Directors, May 21, 2000, replaced the policy adopted September 18-19, 1993. Amended on April 21, 2016.
Special Guidelines Concerning Fish and Other Aquatic Life
Sierra Club's Biotechnology Policy, which, among other things, defines genetic engineering and genetically engineered organisms (GEOs), calls for the development of adequate regulatory, legislative and other controls, calls for a reverence for nature, and invokes the Precautionary Principle, is applicable in its entirety to genetically engineered (GE'd) fish, shellfish, and all other GE'd aquatic organisms, in freshwater or salt. The Guidelines relating to agricultural crops are also broadly applicable. The major issue is very similar: the uncontrolled release of GEOs. Thus, the points in the Guidelines about testing and regulation, monitoring, labeling, liability, application of the Precautionary Principle and other topics mentioned in the Guidelines are equally as important for GE'd fish and aquatic organisms, except where the language specifically refers to "farmers," "crops," or "seeds." We embrace the extension of those Guidelines to all aquatic life, whether the GEOs are intended for food, feed, sport, environmental management, artistic statement or pet store trade.
(1) We believe that GE'd fish and aquatic organisms are an even greater hazard to natural stocks and are even more difficult to properly evaluate and to monitor than GE'd crops, and therefore our primary position is to oppose releases of transgenic aquatic organisms out of doors, or where there is any chance of the organisms or their genetic code escaping into the general environment.
(2) Genetically engineered fish intended for fish farming, whether intended as human food or for other uses such as mosquito control, feed for other fish, or pet store trade, can't be adequately contained. Fish in inland ponds are often swept into steams by storms and can be transported by birds. Fish constrained by nets (such as nearshore netpens for salmon and offshore pens for tuna) have a high rate of escape into the wild. The same is true of other aquatic organisms. Eggs, sperm, larval and planktonic forms of GEOs present additional problems making containment impracticable in out-of-doors environments. The possibility that new or altered genes could wreak havoc with natural ecosystems is therefore great, and this type of genetic adulteration of nature may be irreversible once it occurs. It may lead to extinction of species or to the creation of new bioinvasive varieties. Therefore, we oppose the cultivation of any genetically engineered fish or other aquatic organisms outside of laboratory confinement (or equivalent complete confinement during industrial processes).
(3) We are opposed to genetically engineered sport fish, and to "genetic enhancement" of natural populations.
(4) We are opposed to the production of aquatic GEOs for export, even though the laws or regulations of the importing country may not prohibit it, excepting small and rigorously contained shipments intended solely for research. All exports must be made known to the customs authorities of the importing country in advance of shipment.
(5) Notwithstanding our strong belief that all releases should be prohibited at the present time, it is important that good regulatory mechanisms be established which give government the authority to study and to regulate production or release of transgenic fish. The Sierra Club's existing Guidelines apply here.
(6) We are opposed to release of sterile GE'd fish or other aquatic organisms, much as we are opposed to "Terminator" technology in plant crops, because (a) it would deprive small fish farmers of the opportunity to breed their own fish, (b) escaping sterile fish would reduce the breeding efficiency of wild populations, and (c) it would tend to turn the traditional property of the poor and disadvantaged into the intellectual property of the rich and advantaged. We also do not believe that sterility and reproduction are adequately understood in fish. Prediction is further impaired by the ability of some fish to change sex during their life cycle.
(7) The concepts in the paragraphs above, where written with regard to fish, are embraced and extended to include all uses of any transgenic organisms in aquaculture. Unicellular organisms and plants are included.
(8) Definitions and application. For the purposes of these Guidelines covering fish and aquatic life, amphibians and other life forms that are aquatic during part of their life cycle will be considered aquatic. We recognize that there may be difficulties in deciding whether some organisms such as brewer's yeast, a Pseudomonas bacterium, or a mosquito is to be considered aquatic. In such instances, the general principles of precaution, scientific evaluation of ecological and health risks, and ongoing surveillance will apply regardless of whether the GEO is aquatic or not. On a case-by-case basis, some exceptions to our broad policy may become acceptable (such as, possibly, the release of GE'd sterile mosquitoes as a means of malaria control), but that will not mean that these Guidelines are any less relevant to decisionmaking regarding any and all future releases.
Adopted by the Sustainable Planet Strategy Team, February 20, 2001.