Home Page Link AgBioWorld Home Page
About AgBioWorld Donations Ag-Biotech News Declaration Supporting Agricultural Biotechnology Ag-biotech Info Experts on Agricultural Biotechnology Contact Links Subscribe to AgBioView Home Page

AgBioView Archives

A daily collection of news and commentaries on

Subscribe AgBioView Read Archives

Subscribe AgBioView Subscribe

Search AgBioWorld Search Site

Prakash Interviews

AgBioWorld Articles

Other Articles

Biotech and Religion

Media Contacts

Press Releases

Special Topics

Spanish Articles


A Brief for The Royal Commission on Genetic Modification of New Zealand

8 October 2000
Gary Comstock
Iowa State University

Ethically justifiable conclusions rest on two kinds of claims: (a) factual judgments, based on the best available scientific evidence and theories, and (b) ethical judgments, based on the best available moral principles and theories. Is it ethically justifiable to pursue genetically modified crops and foods? The decision rests ultimately with the citizens of New Zealand who will use their conscience and reason to decide on the ethical questions. However, as these citizens are, by and large, not scientists, they must, to one degree or other, rest their factual understanding of the matter on the opinions of scientific experts. Therefore, ethical responsibility in this decision devolves heavily upon scientists.

I. The ethical responsibilities of scientists

Science is a communal process devoted to the discovery of knowledge, and to open and honest communication of that knowledge. It rests on two classes of values.

Epistemological values are values by which scientists determine which knowledge-claims are better than others. The values include clarity, objectivity, capacity to explain a range of observations, and ability to generate accurate predictions. Claims that are internally inconsistent are jettisoned in favor of claims that are consistent, and fit with established theories. (At times, anomalous claims turn out to be justifiable, and an established theory is overthrown, but these occasions are rare in the history of science.) Epistemological values in science also include: fecundity, the ability to generate useful new hypotheses; simplicity, the ability to explain observations with the fewest number of additional assumptions or qualifications; and elegance.

Personal honesty and social responsibility represent a second class of values. If scientists are dishonest, untruthful, fraudulent, or excessively self-interested, the free flow of accurate information so essential to science will be thwarted. If a scientist plagiarizes the work of others or uses fabricated data, that scientist's work will become shrouded in suspicion and otherwise reliable data will not be trusted. If scientists exploit those who work under them, or discriminate on the basis of gender, race, class, or age, then the mechanisms of trust and collegiality under-girding science will be eroded.

The very institution of scientific discovery, therefore, is supported, indeed, permeated with moral values. This fact becomes important in different ways, depending upon the scientist's social role.

University scientists must be scrupulous in giving credit for their research to all who deserve credit; careful not to divulge proprietary information; and painstaking in maintaining objectivity, especially when funded by industry. Industry scientists must also maintain the highest standards of scientific objectivity, a particular challenge since their work may not be subject to peer-review procedures as strict as those faced by university scientists. Industry scientists must also be willing to defend results of their research that are not favorable to their employer's interests. Scientists employed by nongovernmental organizations face challenges, as well. Their objectivity must be maintained in the face of an organization's explicit advocacy agenda, and in spite of the fact that their research might provide results that might seriously undermine the organization's fund-raising attempts. All scientists face the challenges of communicating complex issues to a public that receives them through media channels that often are not equipped to communicate the qualifications and uncertainties attaching to much scientific information.

At its core, science is an expression of some of our most cherished values. The public largely trusts scientists, and scientists must in turn act as good stewards of this trust.

II. A method for addressing ethical issues

Ethical objections to GM typically center on the possibility of harm to persons or other living things. Harm may or may not be justified by outweighing benefits. Whether harms are justified is a question that ethicists try to answer by working methodically through a series of questions:

1. What is the harm envisaged? Describe briefly (a) the harm or potential harm; (b) who are the "stakeholders," that is, all of the persons and non-persons (animals, ecosystems, other nonhuman entities) who may be harmed; (c) the extent to which these stakeholders will be harmed; and (d) the distribution of harms (are those at risk of being harmed the same or different from those who may benefit?).

2. What information do we have? Sound ethical judgments go hand-in-hand with thorough understanding of the scientific facts. In a given case, we may need to ask: (a) Is the scientific information about harm being presented reliable, or is it fact, hearsay, or opinion? (b) What information do we not know that we should know before making the decision?

3. What are the options? In assessing the various courses of action, emphasize creative problem-solving, seeking to find "win-win" alternatives in which everyone's interests are protected. Here we must identify (a) what objectives each stakeholder wants to obtain; (b) how many methods are available by which to achieve those objectives; (c) what are the advantages and disadvantages of each alternative?

4. What ethical principles should guide us? There are at least three secular ethical traditions: a. Rights theory: Always act so that you treat human beings as autonomous individuals, and not as mere means to an end. b. Utilitarianism: Always act so that you maximize good consequences and minimize harmful consequences. c. Virtue theory: Always act so that you act the way a just, fair, good person would act.

Ethical theorists are divided about which of these three theories is best. We manage this uncertainty through the following procedure. Pick one of the three principles. Using it as a basis, determine its implications for the decision at hand. Then, adopt a second principle. Determine what it implies for the decision at hand. Repeat the procedure with the third principle. Should all three principles converge on the same conclusion, then we have good reasons for thinking our conclusion morally justifiable.

5. How do we reach moral closure? Does the decision we have reached allow all stakeholders either to participate in the decision or to have their views represented? If a compromise solution is deemed necessary in order to manage otherwise intractable differences, has the compromise been reached in way that has allowed all interested parties to have their interests articulated, understood, and considered? If so, then the decision is justifiable on ethical grounds.

III. Ethical issues involved in the use of genetic technology in agriculture

Discussions of the ethical dimensions of agricultural biotechnology are sometimes confused by a conflation of two quite different sorts of objections to GM technology: intrinsic and extrinsic. It is critical not only that we distinguish these two classes, but keep them distinct throughout the ensuing discussion of ethics. Extrinsic objections focus on the potential harms consequent upon the adoption of GMOs. Extrinsic objections hold that GM technology should not be pursued because of its anticipated results. Briefly stated, the extrinsic objections go as follows. GMOs may have disastrous effects on animals, ecosystems, and humans. Possible harms to humans include perpetuation of social inequities in modern agriculture, decreased food security for women and children on subsistence farms in developing countries, a growing gap between well capitalized economies in the Northern hemisphere and less capitalized peasant economies in the South, risks to the food security of future generations, and the promotion of reductionistic and exploitative science. Potential harms to ecosystems include possible environmental catastrophe, inevitable narrowing of germplasm diversity, and irreversible loss or degradation of air, soils, and waters. Potential harms to animals include unjustified pain to individuals used in research and production. These are valid concerns, and nation-states must have in place testing mechanisms and regulatory agencies to assess the likelihood, scope, and distribution of potential harms through a rigorous and well-funded risk assessment procedure. It is for this reason that I have said, above, that GM technology must be developed responsibly and with appropriate caution. However, these extrinsic objections cannot by themselves justify a moratorium, much less a permanent ban, on GM technology, because they admit the possibility that the harms may be minimal and outweighed by the benefits. How can one decide whether the potential harms outweigh potential benefits unless one conducts the research, field tests, and data analysis necessary to make a scientifically-informed assessment? In sum, extrinsic objections to GMOs raise important questions about GMOs, and New Zealand ought to have in place the organizations and research structures necessary to assess the questions. I believe, however, that this conclusion describes the status quo. There is, however, an entirely different sort of objection to GM technology, a sort of objection that, if it is sound, would indeed justify a permanent ban. Intrinsic objections allege that the process of making GMOs is objectionable in itself. This belief is defended in several ways, but almost all of the formulations are related to one central claim, the unnaturalness objection: It is unnatural to genetically engineer plants, animals, and foods (UE). If UE is true, then New Zealand ought not to engage in bioengineering, however unfortunate may be the consequences of halting the technology. Were a nation to accept UE as the conclusion of a sound argument, then much agricultural research would have to be terminated and potentially significant benefits from the technology sacrificed. A great deal is at stake. In my book, Vexing Nature? I identify fourteen ways in which UE has been defended. For present purposes, those fourteen objections can be summarized as follows:

(1) To engage in ag biotech is to play God. (2) To engage in ag biotech is to invent world-changing technology. (3) To engage in ag biotech is illegitimately to cross species boundaries. (4) To engage in ag biotech is to commodify life.

Let us consider each claim in turn.

(1) To engage in ag biotech is to play God.

In a western theological framework, humans are creatures, subjects of the Lord of the Universe, and it would be impious for them to arrogate to themselves roles and powers appropriate only for the Creator. Shifting genes around between individuals and species is taking on a task not appropriate for us, subordinate beings. Therefore, to engage in bioengineering is to play God. There are several problems with this argument. First, there are different interpretations of God. Absent the guidance of any specific religious tradition, it is logically possible that God could be a Being who wants to turn over to us all divine prerogatives; or explicitly wants to turn over to us at least the prerogative of engineering plants; or who doesn’t care what we do. If God is any of these beings, then the argument fails because playing God in this instance is not a bad thing. The argument seems to assume, however, that God is not like any of the gods just described. Assume that the orthodox Jewish and Christian view of God is correct, that God is the only personal, perfect, necessarily existing, all-loving, all-knowing, and all-powerful being. On this traditional western theistic view, finite humans should not aspire to infinite knowledge and power. To the extent that bioengineering is an attempt to control nature itself, the argument would go, bioengineering would be an unacceptable attempt to usurp God’s dominion. The problem with this argument is that not all traditional Jews and Christians think that this God would rule out genetic engineering. I am a practicing evangelical Christian and the chair of my local Church's Council. In my tradition, God is thought to endorse creativity, scientific and technological development, including genetic improvement. Other traditions have similar views. In the mystical writings of the Jewish Kabbalah, God is understood as One who expects humans to be co-creators, technicians working with God to improve the world. At least one Jewish philosopher, Baruch Brody, has suggested that biotechnology may be a vehicle ordained by God for the perfection of nature. Personally, I hesitate to think that humans can "perfect" nature. However, I have become convinced that GM might help humans to rectify some of the damage we have already done to nature. And I believe God may endorse such an aim. For humans are made in the divine image. God desires that we exercise the spark of divinity within us. Inquisitiveness in science is part of our nature. Creative impulses are not found only in the literary, musical, and plastic arts. They are part of molecular biology, cellular theory, ecology, and evolutionary genetics, too. It is unclear why the desire to investigate and manipulate the chemical bases of life should not be considered as much a manifestation of our god-like nature as the writing of poetry and the composition of sonatas. As a way of providing theological content for UE, then, argument (1) is unsatisfactory because ambiguous and contentious.

(2) To engage in ag biotech is to invent world-changing technology, an activity that should be reserved to God alone.

Let us consider (2) in conjunction with a similar objection (2a).

(2a) To engage in ag biotech is to arrogate historically unprecedented power to ourselves.

The argument here is not the strong one, that biotech gives us divine power, but the more modest one, that it gives us a power we have not had previously. But it would be counterintuitive to judge an action wrong simply because it has never been performed. On this view, it would have been wrong to prescribe a new herbal remedy for menstrual cramp, or to administer a new anaesthetic. But that seems absurd. More argumentation is needed to call historically unprecedented actions morally wrong. What is needed is to know to what extent our new powers will transform society, whether we have witnessed prior transformations of this sort, and whether those transitions are morally acceptable. We do not know how extensive the ag biotech revolution will be, but let us assume that it will be as dramatic as its greatest proponents assert. Have we ever witnessed comparable transitions? The change from hunting and gathering to agriculture was an astonishing transformation. With agriculture came not only an increase in the number of humans on the globe, but the first appearance of complex cultural activities: writing, philosophy, government, music, the arts, and architecture. What sort of power did people arrogate to themselves when they moved from hunting and gathering to agriculture? The power of civilization itself. Ag biotech is often oversold by its proponents. But suppose that they are right, that ag biotech brings us historically unprecedented powers. Is this a reason to oppose it? Not if we accept agriculture and its accompanying advances, for when we accepted agriculture we arrogated to ourselves historically unprecedented powers. In sum, the objections stated in (2) and (2a) are not convincing.

(3) To engage in ag biotech is illegitimately to cross species boundaries.

The problems with this argument are both theological and scientific. I will leave it to others to argue the scientific case that nature gives ample evidence of generally fluid boundaries between species. The argument assumes that species boundaries are distinct, rigid and unchanging while, in fact, species now appear to be messy, plastic and mutable. To proscribe the crossing of species borders on the grounds that it is unnatural seems scientifically indefensible. It is also difficult to see how (3) could be defended on theological grounds. None of the scriptural writings of the western religions proscribe genetic engineering, of course, because genetic engineering was undreamt of at the time the holy books were written. Now, one might argue that such a proscription may be derived from Jewish or Christian traditions of scriptural interpretation. Talmudic laws against mixing "kinds," for example, might be taken to ground a general prohibition against inserting genes from "unclean" species into clean species. Here’s one way the argument might go: For an observant Jew to do what scripture proscribes is morally wrong; Jewish oral and written law proscribe the mixing of kinds (e.g., eating milk and meat from the same plate; yoking donkeys and oxen together); bioengineering is the mixing of kinds; therefore, for a Jew to engage in bioengineering is morally wrong. But this argument fails to show that bioengineering is intrinsically objectionable in all of its forms for everyone. The argument might prohibit Jews from engaging in certain kinds of biotechnical activity but not all; it would not prohibit, for example, the transferring of genes within a species, nor, apparently, the transfer of genes from one clean species to another clean species. Incidentally, it is worth noting that the Orthodox community has accepted transgenesis in its food supply. Seventy percent of cheese produced in the United States is made using a GM product, chymosin. This cheese has been accepted as kosher by Orthodox rabbis. In conclusion, it is difficult to find a persuasive defense of (3) either on scientific or religious grounds.

(4) To engage in ag biotech is to commodify life.

The argument here is that genetic engineering treats life in a reductionistic manner, reducing living organisms to little more than machines. Life is sacred and not to be treated as a good of commercial value only, to be bought and sold to the highest bidder. Could we apply this principle uniformly? Would not objecting to the products of GM technology on these grounds also require that we object to the products of ordinary agriculture on the same grounds? Is not the very act of bartering or exchanging crops and animals for cash vivid testimony to the fact that every culture on earth has engaged in the commodification of life for centuries? If one accepts commercial trafficking in non-GM wheat and pigs, then why should we object to commercial trafficking in GM-wheat and GM-pigs? Why should it be wrong or us to treat DNA the way we have previously treated animals, plants, and viruses? While (4) may be true, it is not a sufficient reason to object to GM technology because our values and economic institutions have long accepted the commodification of life. In conclusion. None of the four major formulations of the unnaturalness objection (UE) to ag biotech seem sound. Whereas I once was tempted to believe that GM technology is morally objectionable I have, after years of study, come to reverse myself. I changed my mind in large part because I became convinced that intrinsic objections to agricultural biotechnology cannot be sustained.

IV. Religion and ethics

Religious traditions provide an answer to the question, "How, overall, should I live my life?" Secular ethical traditions provide an answer to the question, "What is the right thing to do?" When in a pluralistic society a particular religion's answers come into genuine conflict with the answers arrived at through secular ethical deliberation, we must ask how deep is the conflict. If the conflict is so deep that honoring the religion's views would entail dishonoring another religion's views, then we have a difficult decision to make. In such cases, the conclusions of secular ethical deliberation must over-ride the answers of the religion in question. The reason is that granting privileged status to one religion will inevitably discriminate against another religion. Individuals must be allowed to follow their conscience in matters theological. But if one religion is allowed to enforce its values on others in a way that restricts the others' ability to pursue their values, then individual religious freedom has not been protected. Moral theorists refer to this feature of non-religious ethical deliberation as the over-ridingness of ethics. If a parent refuses a life-saving medical procedure for a minor child on religious grounds, the state is justified in over-riding the parent's religious beliefs in order to protect what secular ethics regards as a value higher than religious freedom: the life of a child. The over-ridingness of ethics applies to our discussion only if a religious group claims the right to halt GM technology on purely religious grounds. The problem here is the confessional problem, of one group attempting to enforce its beliefs on others. I mean no disrespect to religion; as I have noted, I am a religious person, and I value religious traditions other than my own. Religious traditions have been the repositories and incubators of virtuous behavior. Yet each of our traditions must in a global society learn to co-exist peacefully with competing religions, and with non-religious traditions and institutions. If someone objects to GM technology on purely religious grounds, we must ask on what authority they speak for their tradition, whether there are other, conflicting, views within their tradition, and whether acting on their views will entail disrespecting the views of people from other religions. It is, of course, the right of each tradition to decide its attitude about genetic engineering. But in the absence of other good reasons, we must not allow someone to ban GM technology for narrowly sectarian reasons alone. To allow such an action would be to disrespect the views of people who believe, on equally sincere religious grounds, that GM technology is not necessarily inconsistent with God's desires for us.

V. Minority views

When in a pluralistic society the views of a particular minority come into genuine conflict with the views of the majority, we must ask a number of questions: How deep is the conflict? How has the minority been treated in the past? If the minority has been exploited, have reparations been made? If the conflict is so deep that honoring the minority's views would entail overriding the majority's views, then we have a difficult decision to make. In such cases, the conclusions of the state must be just, taking into account the question of past exploitation and subsequent reparations, or lack thereof. This is a question of justice. The question of justice would arise in the discussion of GM technology if the majority favored GM technology, while the minority claimed the right to halt GM technology. If the minority cited religious arguments to halt GMOs, yet the majority believed that halting GMOs would result in loss of human life, then the state faces a decision very similar to the one discussed in the prior section. In this case, secular policy decisions may be justified in over-riding the minority's religious arguments insofar as society deems the value of human life higher than the value of religious freedom. However, should the minority cite past oppression as the reason that their values ought to predominate over the majority's, then a different question must be addressed. Here, the relevant issues have to do with the nature of past exploitation; its scope and depth; and the sufficiency of efforts, have there been any, to rectify the injustice and compensate victims. If the problem is acute, long-standing, and has not been addressed, then imposing the will of the majority would seem a sign of an unjust society insensitive to its past misdeeds. If, on the other hand, the problem has been carefully addressed by both sides and, for example, just treaties arrived at through fair procedures have been put in place, are being enforced, are rectifying past wrongs, and are preventing new forms of exploitation, then the minority's arguments would seem to be far weaker. This conclusion would be especially compelling if it could be shown that the lives of other disadvantaged peoples might be put at risk by honoring a particular minority's wish to ban GMOs.

VI. Conclusion

Earlier I described a method for reaching ethically sound judgments. It was on the basis of that method that I personally came to change my mind about the moral acceptability of GM crops. Ten years ago, I wrote what has been called the first philosophical objection to agricultural biotechnology, a paper called "The Case Against bGH." I then wrote a series of papers objecting to GM herbicide resistant crops, transgenic animals, and, indeed, all of agricultural biotechnology. On further reflection, however, my opinion changed as I took further account of three considerations: (a) the rights of people in various countries to choose to adopt GM technology (human rights principle); (b) the balance of benefits over harms to consumers and the environment from GM technology (utilitarian principle); and (c) the wisdom of encouraging discovery, innovation, and careful regulation of GM technology (virtue theory). I have come to believe that the three major ethical traditions converge on a common answer to the question before the Royal Commission. That answer fits with my own theological beliefs. The answer is that New Zealand should continue to research, develop and use the technology responsibly and with appropriate caution.


I have profited from a method ("Ethics Assessment") devised by Dr. Courtney Campbell, Philosophy Department, Oregon State University.

2 Baruch Brody, private communication.

3. William McNeill, "Gains and Losses: An Historical Perspective on Farming," The 1989 Iowa Humanities Lecture, National Endowment for the Humanities and Iowa Humanities Board, Oakdale Campus, Iowa City, Iowa, p. 5. 4. Richard L. Willham, "The Legacy of the Stockman," Department of Animal Science, Iowa State University, Ames, Iowa, 1985, p. 61.

5 Dr. Jonathan Gressel, observation at the annual meeting of the Weed Science Society of America.

6. Cf. Dorothy Nelkin and M. S. Lindee, The DNA Mystique: The Gene as Cultural Icon (New York: Freeman, 1995). References

Comstock, Gary. Life Science Ethics (Ames: Iowa State University Press, forthcoming).

__________ . Vexing Nature? On the ethical case against agricultural biotechnology (Boston/Dordrecht: Kluwer Academic Publishers, forthcoming).

__________ . "The Rights of Animals and Family Farmers," Between the Species 7 (Summer 1992): 153-156.

__________ . "The Case Against bGH," Agriculture and Human Values 5 (Summer 1988): 36-52.

__________ . "Genetically Engineered Herbicide Resistance, Part One," Journal of Agricultural Ethics 2 (1989): 263-306, and "Part Two," 3 (1990): 114-146.

__________ . "The Costs and Benefits of bGH May Not Be Distributed Fairly," Journal of Agricultural and Environmental Ethics 4 (1991): 121-130.

__________ . "Pigs and Piety: A Theocentric Perspective on Food Animals," Between the Species 8 (Summer 1992): 121-135.

__________ . "Should We Genetically Engineer Hogs?" Between the Species 8 (Fall 1992): 196-202.

__________ . "The Moral Irrelevance of Autonomy," Between the Species 8 (Winter 1992): 15-27.

__________ . "Do Agriculturalists Need a New, an Ecocentric, Ethic?" Agriculture and Human Values 12 (Winter 1995): 2-16.

__________ . "Is it Unnatural to Genetically Engineer Plants?" Weed Science 46 (1998): 647-651.

__________ . "Research with Transgenic Animals: Obligations and Issues" The Journal of BioLaw and Business 2 (Autumn 1998): 51-54.

Reiss, Michael, and Roger Straughan. Improving Nature: The Science and Ethics of Genetic Engineering (Cambridge: Cambridge University Press, 1996).

Shrader-Frechette, Kristin. Risk and Rationality: Philosophical Foundations for Populist Reforms (Berkeley: University of California Press, 1991).

Thompson, Paul. "Pragmatism and Policy: The Case of Water," in Eric Katz and Andrew Light, eds, Environmental Pragmatism (London: Routledge, 1996), pp. 187-208.

__________ . Designing Animals: Ethical Issues for Genetic Engineers," Journal of Dairy Science, 75 (1992): 2296.

__________ . Food Biotechnology in Ethical Perspective (London: Blackie, 1997).