Gene Silencing / Gene Editing
And what do our MPs know?
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Note: I was going to add to my previous post information I received from Prof. Jack Heinemann from Canterbury University, but on reading the supplementary submissions on the Gene Technology Bill he directed me to, I felt this information deserved a post of its own.
1. How Informed are our MPs?
How informed will our MPs be when they vote once again on the Gene Technology Bill?
And how informed do they want to be?
Do they realize the ramifications and dangers of a Yes vote or are they dazzled by industry propaganda?
Will this bill progress because of misleading statements, misinformation, industry hype, false promises, and an unwillingness to examine the very real concerns of those opposing the passage of this bill? The second reading is due in late July.
2. Dr Hamish Campbell on GMOs
Dr Hamish Campbell as the chair of the Health Select Subcommittee B has significant influence. For more on this, see Gene Technology Bill: Oral Presentations.
As stated in the previous post, Outdoor Gene Technology Sprays, Dr Hamish Campbell asked,
What technology can possibly be used to be sprayed on crops to make it genetically modified?
He stated if you spray something on, you are not getting the whole organism so you are gene silencing not gene modifying so there is a technical difference there.
You can listen to the video clip here: Dr Hamish Campbell’s question on GT sprays.
Is Hamish right?
For clarification, I reached out to Prof. Jack Heinemann. He has an impressive list of credentials on the subject of gene technology.
Jack Heinemann is a professor of genetics and molecular biology in the School of Biological Sciences and director of the Centre for Integrated Research in Biosafety (INBI) at the University of Canterbury, Christchurch, New Zealand.
Prof Jack Heinemann's experience in gene technology and his long list of credentials make him one of the leading voices in the country; and therefore, one that should be carefully listened to especially by the Health Select Committee on the Gene Technology Bill and all other MPs who will be voting on this bill.
What did Prof. Jack Heinemann say?
Particularly relevant statements:
The means to deliver gene editing and gene silencing tools are in pre-commercial and commercial development, respectively. The tools needed to cause gene silencing through sprays (contact exposure, inhalation exposure, or ingestion exposure are able to also deliver the tools needed for editing (including the use of some editors as gene silencers) and are claimed cargo in the same patents. (Bold mine)
and
"Hamish stated if you spray something on, you are not getting the whole organism so you are gene silencing not gene modifying so there is a technical difference there" If this is what he said then in my view it is misleading. A GMO can be made without every cell in an organism having been directly exposed or derived from gene technology. The international definitions do not require a modified organism to reproduce in order to be a GMO. And for any use outside of a laboratory, exposures will include single celled bacteria, fungi, plants, or animals simultaneously with any multicellular plant, fungus, or animal so the harm pathway is the same regardless of the intention of the user. Finally, for organisms such as plants, every cell under the right conditions can become a new plant.
and
Any use of gene editing will meet all definitions of creating GMOs using gene technology whether it be in or out of doors.
Jack Heinemann also noted that there are different views on whether gene silencing can create GMOs.
3. INBIs Supplementary Submissions
Jack also drew my attention to INBI's supplementary submissions 1 & 2 to the Health Select Committee, which are the submissions I was referring to at the beginning of this post.
INBIs Supplementary Submission 1
Jack summarised the contents of their first supplementary submission:
In this we do a "deep dive" into the ability to gene edit organisms using mechanical (eg drone) delivery in the wider environment. We have been publishing on this since 2019. https://mednexus.org/doi/full/10.1016/j.bsheal.2019.09.003 [bold mine]
Do you want drones flying overhead spraying gene editors just on the assumption they are safe because the industry and our leaders tell us so? Remember, that's what was said about a huge list of substances (like cigarettes, thalidomide, asbestos, lead, glyphosate, x-rays...) later found to be harmful. The problem is with genetic modification and the like, there is no going back to the way it was. There are no second chances!
You can read INBI's supplementary submission1 here.
From its summary (on pg 9):
This supplementary submission is intended to assist the Committee by providing additional perspective on possible uses of gene technology that would be exempt under the proposed legislation. [bold mine]
From the summary analysis (on pg 1):
Examples of gene technology applications in pre-commercial development are provided to expand the understanding of how the proposed Bill could create harm to human health or the environment, unless controlled by ongoing regulation. [bold mine]
From the overview (on pg 5)
Our objective is to ensure that the Committee is aware of the multi-dimensionality of uses this new law would enable and that those uses would escape regulatory oversight and control. Some of these forecast uses include real-time delivery in retail environments. An example of this is to spray on reagents of gene technology through hydration nozzles in grocery stores to interrupt fruit and vegetable ripening while products are on display... [bold mine]
If Hamish had read INBI's supplementary material, he would have been aware of these trait-changing supermarket sprays we will all be exposed to; not only by the aerosols themselves, but also by all the living and non-living things they touch. See GE Sprays in Produce Aisles. https://flagnfix.substack.com/p/ge-sprays-in-produce-aisles.
In this supplementary material, they also explain why these new breeding techniques (NBTs) DO NOT resemble a conventional process. They are being applied in forms that have no biological analogue.
From pg 6:
NBTs rely upon physical, chemical, and biological adjuvants that are specially and recently developed for the purpose of penetrating the cells of living organisms to deliver the gene technology reagents in the combinations and dosages that create new traits and functions at frequencies impossible to achieve by conventional breeding.
Also INBI provide examples of how these new breeding techniques are being scaled up for commercial application.
Also from pg 6:
Use of new genomic techniques at large environmental scales without supervision, and/or by untrained personnel, is within the scope of the proposed deregulated activities.
This is unsettling stuff. Surely, a government in its right mind would throw out such a mad bill? Also, the claim other nations are doing gene technology safely is not a valid argument. Even if we set aside the growing mountain of harms associated with gene technology—which is based on destruction and killing, spraying gene editors in the field is in the pre-commercial state. Therefore, NO claim to their being safe at scale can be made.
And who knows what other gene technologies will be coming down the pipeline that will also be outside the scope of the regulator if this bill progresses.
Do-it-Yourself Kits
On page 6, INBI also draws attention to this important and frightening fact that our leaders need to take into account.
NBTs are unlike other genomic and mutagenesis techniques because they can be used by people who lack training and cannot be held to account....
The price barrier to DIY gene technology is also rapidly disappearing.
INBI gives an example of a newly developed kit named “CRISPRKit,” that is now being disseminated through a pilot program to 500 high schoolers across 25 high schools across the Bay Area in the USA. This kit costs around $2 per student and can be used in a typical high school classroom with only a smartphone.
More actors...are distributing the capability to make intended and unintended mutations in organisms in places such as in homes and garages, or in schools, with limited if any ability to prevent exposures to people and non-target organisms.
...kit components can be used anywhere on practically anything, and repurposed by users who would not be expected to understand the full implications of their actions.
Patents
On pg 7, under the heading Insights into commercial developments, INBI describe two patents that provide insight into the commercial ambitions behind the outdoor use of gene technology processes.
One such patent has a particular focus on use in mammals including people.
And the other patent is about the compositions and scalable production and delivery of biologicals. The necessary components are easily sourced and not presently regulated.
From pg 8:
The important and distinctive elements of this patent illustrate the capacity to use gene technology at unprecedented scales, the feature that makes gene technology a technology not representative of how things happen through conventional breeding. The other notable element of this patent is its focus on using genome editing techniques as pesticides, where the objective may not be to produce a “living” genetically modified organism (although this may be the unintended outcome), but instead to use these agents to cause death, or to reduce viability through mutation.
Imagine the possible significance of unintended consequences associated with agents intended to cause death.
After examining the patent, they close this section with this paragraph:
In other words, [the patent literature shows] the target could be anything. The nanoparticles can be optimised for intended targets, such as plants or even more specifically plant roots. However, this does not prevent them from penetrating the cells of species that are not targeted. As applied to equipment and packaging material, future exposures are uncontrolled. The proposed Bill therefore makes it possible to use genome editing on anything in the environment at any scale.
INBIs Supplementary Submission 2
You can read INBI's supplementary submission 2 here.
The contents of this submission are also disturbing.
From Chapter 1: Size and number of mutations is not a measure of risk.
A real-world example in mammals is a mutation in the PRNP gene in the human genome. A single nucleotide change at codon 200 in this gene is the most common cause of familial Creutzfeldt-Jakob disease (CJD) disease. A second example is a single nucleotide change in HBB, the gene for b-globin resulting in b-thalassaemia. These are two of many...
In particular, Jack drew my attention to Chapter 2. "Gene technology will be used outside, in garages, and in gardens."
Following are some excerpts from that chapter.
The assertion that gene editing and gene silencing is a difficult thing to do and won’t be done in garages or outside is inconsistent with both the primary scientific and patent literature.
and
1. It may be hard to get what you want using gene editing, but that is different from it being hard to create GMOs that you don’t want. Plant biotechnologists and DIYers might be looking for a plant with a particular trait, but if some uses of gene technology are deregulated, plant biotechnologists won’t have to track all the modified plants that don’t have the particular trait they wanted to create.
2. If some uses are allowed outside of registered containment facilities, the bacteria, animals, and fungi simultaneously exposed and genetically modified also will go untracked.
3. Plants are not the only target of biotechnologists or DIYers who will want to use these techniques outside of registered containment facilities on other kinds of organisms...
and
Outdoor use is neither hypothetical nor hard, even if it is challenging to get something of benefit. Presently it only requires that a regulator approve outdoor use. If this legislation passes without change, it won’t even require that. [bold mine]
4. New Breeding Techniques
Definition: (copied from INBI supplementary submissions)
NBT, NGT: New Breeding (e.g. Australia) and New Genomic (e.g. Europe) Techniques. Generally, synonyms that include the use of gene/genome editing, gene silencing, and other techniques.
Those promoting the deregulation of large groups of gene technology have tried to fool us into thinking these techniques are benign by giving them a benign-sounding name i.e. 'new breeding techniques'—but this is deceptive manipulation—in reality these new breeding techniques are powered up old techniques—techniques that can be done more quickly and at scale. And with this exceptional power, comes more risk.
Prof. Jack Heinemann has explained there is nothing new about what they can do, so if anything worthwhile could have been produced, it would likely have been produced already using the old tools. However, what is different, the tools have become more efficient. It is like comparing a hand held screwdriver to an electric one.
What does that mean? Unintended harmful effects can have more widespread devastating consequences.
Listen here to these short clips featuring Prof. Heinemann. These are taken from an RCR interview with Paul Brennan back in Dec 2024. It’s worth listening to. You can listen to the full interview here.
Under the proposed regulations, gene silencers and editors could be sprayed all over the place not only silencing, or modifying, or adversely affecting the genes of the intended organisism but also of all things they come in contact with including microbes, earthworms, worthwhile insects, animals and humans. This is a frightening risk to take when there are much more sustainable, safer, and healthier ways forward, such as those explained in the full RCR interview mentioned above.
The problem is these better methods are not patentable. If it weren't for patents, the better methods would likely prevail and our lives and environment would not be put at risk by a powerful industrial complex chasing dollars and by governments who believe their propaganda and see dollars and not sense.
See here.
5. Conclusion
The statements Dr Hamish Campbell made that were captured in the video clip were misleading at best.
I pray our politicians have the sense and goodness to listen carefully to those opposed to the bill. I pray they will not base their decision on industry hype and unrealistic dreams.
Playing with unregulated, uncontained gene technology is like playing with matches, but worse—at least you can see a fire and put it out. But when gene technology results in adverse effects in the open, there is no going back. And like cancer, it may spread insidiously for years.
Many, many people in their written submissions refer to Prof. Jack Heinemann—and for this reason alone, the Health Select Committee cannot be unaware of his credentials and the need to listen carefully to what he is saying.
6. More Information
For more on the Gene Technology Bill and Prof. Jack Heinemann see the following articles:
Outdoor Gene Technology Sprays
Gene Technology Bill: Oral Presentations