Responsible Research and Innovation: A Concept Worse than the Precautionary Principle
A debate over biotechnology previews the regulatory innovation that could stop innovation
"Should we be grateful or should we be warned?" asked the Cato Institute's Marion Tupy as he opened Wednesday's debate on "GMOs and the Future of the Global Food Supply." The participants were Monsanto Chief Technology Officer Robert Fraley, a World Food Prize laureate; and Jennifer Kuzma, a professor in the Genetic Engineering and Society Cluster at North Carolina State University.
Fraley's non-confrontational talk noted that 2016 marks the 20th anniversary of the first commercially available biotech-enhanced crops. He pointed out that world population is likely to grow from 7.4 billion to 9.5 billion by 2050 and all those people will all want to eat—and to eat better diets. Food demand is projected to double, and more people will be dining on steaks, chops, and poultry. This food will have to be wrested from a more challenging environment, as the globe warms and water becomes relatively scarcer. Fraley argued that genetically enhanced crops will play an important role in meeting that demand.
The U.S. regulatory system applied to genetically enhanced crops was cobbled together in the mid-1980s. The Food and Drug Administration determines that the food derived from biotech crops is safe to eat; the U.S. Department of Agriculture establishes that it is safe to grow; and the Environmental Protection Agency decides that it is safe for the environment. "In the nearly 20 years that these products have been on the market," Fraley declared, "they have delivered numerous benefits to growers and the environment and have not had a single documented instance of harm to human or animal health."
The benefits of modern biotech crops include increasing the incomes of farmers in both developed and developing countries, reducing pesticide use, boosting yields and thus preserving more land for nature, using less water, preventing soil erosion by requiring less tillage, and even reducing carbon dioxide emissions. A 2014 PLOS One meta-analysis of 147 different studies reported that the widespread adoption of these crops "has reduced chemical pesticide use by 37%, increased crop yields by 22%, and increased farmer profits by 68%."
Fraley also pointed out that modern biotech crops constitute "the most thoroughly reviewed food product in the world." A 2013 comprehensive review of 10 years of biotech crop safety research—encompassing 1,783 separate studies—found that "the scientific research conducted so far has not detected any significant hazards directly connected with the use of [genetically engineered] crops; however, the debate is still intense." Fraley also cited research suggesting that improvements in farm productivity, including biotech enhancements, have brought humanity to the point of peak farmland. If current trends continue, as much as 146 million hectares could be restored to nature by 2060; an area nearly two and half times the size of France.
Fraley admitted that Monsanto had screwed up when introducing their new crops. They focused on explaining to farmers the benefits of the crops, but largely failed to talk to consumers. Fraley didn't say so, but this omission by biotech developers provided an opportunity for anti-technology activists, especially those in Europe, to spread misinformation about the new biotechnology. Fraley did note that even the right-leaning French president Nicholas Sarkozy cynically went along with banning biotech corn in 2008 to secure support from the Green Party.
Finally, Fraley suggested that the audience would be surprised to hear that Monsanto actually favored labeling foods made with ingredients from biotech crops. The company is opposed to state-by-state labeling laws and favors a national system. The company has no problem with voluntary labels and specifically cited the USDA's organic products program and the NON-GMO Project as good examples of labeling. Fraley's appreciation of the NON-GMO Project is not reciprocated. The group favors mandatory labels and opposes recent congressional legislation that would pre-empt state GMO labeling laws and set up a national labeling program under the USDA.
Then it was the other speaker's turn. Kuzma quickly challenged the notion that biotech crops are safe. With evidence? Not really. She suggested that taking genes "out their natural context" might have deleterious effects. She darkly noted the concomitant rise of biotech crops with increasing food allergies and cases of irritable bowel syndrome. Suggestive, no? Actually, research has identified no instances of food allergies being provoked by modern biotech crops—and interestingly, the incidence of irritable bowel disease appears to be higher in Europe where growing biotech crops is banned.
Setting those issues aside, Kuzma does not think that regulation of biotech crops is adequate. Instead Kuzma favors "responsible research and innovation." Well, certainly no one wants irresponsible research and innovation. So what is so irresponsible about the current methods of evaluating new technologies? Kuzma complained that the current system of oversight is purportedly based on "sound science." "Sound science is a myth," she declared. "Appeals to sound science have marginalized other values." Why should sound-science evaluations that focus primarily on the health and safety aspects of new technologies and products be privileged over other values, such as maintaining traditional cultures, when it comes to deciding whether they should be permitted to enter the market place? Kuzma dismisses the current paradigm for evaluating new technologies as a "sound-science, values-ignored system" and she wants to put in its place a governance scheme that is "values-respected, science-informed."
Kuzma cited a definition of responsible research and innovation that is apparently taking hold in Europe. It states that responsible innovation "is a transparent, interactive process by which societal actors and innovators become mutually responsive to each other with a view to the (ethical) acceptability, sustainability and societal desirability of the innovation process and its marketable products (in order to allow a proper embedding of scientific and technological advances in our society)."
Clearly, the concept of permissionless innovation is anathema to Kuzma. Mercatus Institute fellow Adam Thierer defines this as "the notion that experimentation with new technologies and business models should generally be permitted by default." He adds, "Unless a compelling case can be made that a new invention will bring serious harm to society, innovation should be allowed to continue unabated and problems, if they develop at all, can be addressed later." Basically, Thierer recognizes that nearly all progress is made through a process of trial and error, with errors being corrected as they arise. Human beings are terrible at foresight, and we tend to be more psychologically disposed to see unintended disaster in innovation than to appreciate its unintended benefits.
Instead of permissionless innovation, Kuzma prefers the precautionary principle—the notion that a proposed activity should be proscribed unless there is a scientific near-certainty that it will cause no harm. As generally practiced, this privileges very conservative risk-averse environmentalist values over what, to other people, may be equally or more compelling values. Kuzma also advocates "anticipatory governance," in which regulators try to foresee and avert the unintended bad consequences of proposed new technologies. Never mind any unintended consequences that "anticipatory governance" would have on technological progress, economic growth, and human well-being.
In any case, governance of innovation, according to Kuzma, should include assessments of ethical affronts, economic impacts, psychological well-being, and cultural disruption. And who should do the considering? Well, of course, it should be done democratically and through wide consultation with stakeholders. (Stakeholder: someone who has an opinion.) What could possibly go wrong with a regulatory—sorry, "governance"—system that eschews reliance on relatively objective criteria such as health and safety effects?
To answer Tupy's opening question: We should be grateful to tech innovators like Fraley, and we should be warned about regulatory innovators like Kuzma.