{"hits":{"total":{"value":10,"relation":"eq"},"hits":[{"_index":"gesis-22-05-2026-02-01-51","_id":"wzb-bib-164914","_version":1,"_seq_no":89118,"_primary_term":1,"found":true,"_source":{"title":"Risikodiskussionen am 'Runden Tisch'. Partizipative Technikfolgenabschatzung zu gentechnisch erzeugten herbizidresistenten Pflanzen ","id":"wzb-bib-164914","date":"1997","date_recency":"1997","portal_url":"http:\/\/sowiport.gesis.org\/search\/id\/wzb-bib-164914","type":"publication","person":["Daele, Wolfgang van den"],"person_sort":"Daele","links":[],"publisher":"WZB","database":"WZB - Wissenschaftszentrum Berlin f\u00fcr Sozialforschung","coreAuthor":["Daele, Wolfgang van den"],"data_source":"GESIS-Literaturpool","link_count":0,"gesis_own":1,"fulltext":0,"index_source":"OUTCITE","literature_collection":"GESIS-Literaturpool"},"system_type":"BASE","doc_rank":1,"rid":29029818},{"_index":"gesis-22-05-2026-02-01-51","_id":"gesis-ssoar-12605","_version":3,"_seq_no":92242,"_primary_term":1,"found":true,"_source":{"title":"Transgenic herbidcide-resistant crops: a participatory technology assessment: summary report","id":"gesis-ssoar-12605","date":"1997","date_recency":"1997","abstract":"\"Dieser Bericht ist die Zusammenfassung eines partizipativen Verfahrens zur Technikfolgenabsch\u00e4tzung von Kulturpflanzen mit gentechnisch erzeugter Herbizidresistenz, das von der Abteilung 'Normbildung und Umwelt' am Wissenschaftszentrum Berlin organisiert worden war. Das Verfahren hat von 1991 bis 1993 etwa f\u00fcnfzig Vertreter der Industrie, der Umweltgruppen, der\nzust\u00e4ndigen Beh\u00f6rden und der Wissenschaft an einem 'Runden Tisch' versammelt, an dem die\nBeteiligten insgesamt fast zehn Tage kontrovers miteinander diskutiert haben. Im ersten Teil dieser Zusammenfassung wird das partizipative Verfahren beschrieben und erl\u00e4utert, wie aus den Diskussionen zwischen den Beteiligten Ergebnisse f\u00fcr die Technikfolgenabsch\u00e4tzung abgeleitet wurden. Der zweite Teil enth\u00e4lt die empirischen Befunde zu den m\u00f6glichen Risiken und zum erwartbaren Nutzen transgener herbizid-resistenter Kulturpflanzen. Der dritte Teil stellt die ethischen, rechtlichen und politischen Diskussionen dar, die zwischen den Beteiligten gef\u00fchrt wurden; er enth\u00e4lt au\u00dferdem die Empfehlungen des Verfahrens zur Regulierung herbizid-resistenter Pflanzen.\" (Autorenreferat)","portal_url":"http:\/\/www.ssoar.info\/ssoar\/handle\/document\/12605","type":"publication","topic":["Diskussion","Politik","Technik","Ethik","Partizipation","Technikfolgenabsch\u00e4tzung","Recht","Umwelt","Verfahren"],"person":["Daele, Wolfgang van den","P\u00fchler, Alfred","Sukopp, Herbert"],"person_sort":"DaeleP\u00fchlerSukopp","links":[{"label":"URN","link":"http:\/\/nbn-resolving.de\/urn:nbn:de:0168-ssoar-126055"}],"document_type":"Arbeitspapier","institutions":["USB K\u00f6ln"],"coreAuthor":["Daele, Wolfgang van den","P\u00fchler, Alfred","Sukopp, Herbert"],"coreCorpEditor":"Wissenschaftszentrum Berlin f\u00fcr Sozialforschung gGmbH","coreSjahr":"1997","coreZsband":"97-302","publishLocation_str_mv":"Berlin","coreLanguage":"en","urn":"urn:nbn:de:0168-ssoar-126055","data_source":"GESIS-SSOAR","index_source":"GESIS-SSOAR","database":"SSOAR - Social Science Open Access Repository","link_count":0,"gesis_own":1,"fulltext":1,"metadata_quality":10,"full_text":"                                 DISCUSSION PAPER WISSENSCHAFTSZENTRUM BERLIN F\u00dcR SOZIALFORSCHUNG SOCIAL SCIENCE RESEARCH CENTER BERLIN FS II 97-302 Transgenic Herbidcide-Resistant Crops: A Participatory Technology Assessment. Summary Report. * Wolfgang van den Daele, Alfred P\u00fchler, and Herbert Sukopp ISSN 1011-9523 Forschung sschwerpunkt : Research Area: Technik - Arbeit - Umwelt Technology - Work - Environment Abteilung: Research Unit: Normbildung und Umwelt Standard-setting and Environment *Originally published in the German language by VCH Verlagsgesellschaft mbH, Pappelallee 3, D-69469 Weinheim, Federal Republic of Germany, under the title van den Daele et al.:  Gr\u00fcne Gentechnik im Widerstreit. Copyright 1996 by VCH Verlagsgesellschaft.  ZITIERWEISE   CITATION Wolfgang van den Daele, Alfred P\u00fchler, and Herbert Sukopp Transgenic Herbidcide-Resistant Crops: A Participatory Technology Assessment. Summary Report. Discussion Paper FS II 97 - 302 Wissenschaftszentrum Berlin f\u00fcr Sozialforschung 1997 Forschungsschwerpunkt : Research Area: Technik - Arbeit - Umwelt Technology - Work - Environment Abteilung: Research Unit: Normbildung und Umwelt Standard-setting and Environment Wissenschaftszentrum Berlin f\u00fcr Sozialforschung Reichpietschufer 50, D-10785 Berlin Tel.:  +49\/30\/25491-0    Fax:  +49\/30\/25491-684 E-mail:  wzb@wz-berlin.de     Internet:  http:\/\/www.wz-berlin.de  Verfahren zur Technikfolgenabsch\u00e4tzung des Anbaus von Kulturpflanzen mit gentechnisch erzeugter Herbizidresistenz Herausgeber: Wolfgang van den Daele  1 , Alfred P\u00fchler  2 , Herbert Sukopp  3 1  Wissenschaftszentrum f\u00fcr Sozialforschung Berlin gGmbH (WZB) Social Science Research Center Berlin Reichpietschufer 50, D-10785 Berlin Telefon: 0049-30-25491-260 Telefax: 0049-30-25491-219 e-mail: daele@medea.wz-berlin.de 2  University of Bielefeld, Institute of Genetics Postfach 100 131, D-33501 Bielefeld 3  Technical University of Berlin, Institute of Ecology, Schmidt-Ott-Str. 1, D-12165 Berlin  SUMMARY This report summarises a participatory technology assessment on transgenic herbicide-resistant crops organised by the Research Unit,  Standard Setting and the Environment , at the Wissenschaftszentrum Berlin, between 1991 and 1993. The technology assessment was a \"roundtable\" involving some fifty representatives from industry, environmental groups, regulatoryagencies and science in more than ten days of controversial debate and analysis. The first part ofthis summary report describes the methodology used applied in analysing the deliberations of thetechnology assessment; the second part presents the empirical findings with respect to theperformance, the risks and the benefits of transgenic herbicide-resistant crops; the third part givesan account of the ethical, legal and political discussions held in the technology assessment, as wellas the recommendations for regulation advanced by the participants. ZUSAMMENFASSUNG Dieser Bericht ist die Zusammenfassung eines partizipativen Verfahrens zur Technikfolgen-absch\u00e4tzung von Kulturpflanzen mit gentechnisch erzeugter Herbizidresistenz, das von der Abteilung\"Normbildung und Umwelt\" am Wissenschaftszentrum Berlin organisiert worden war. Das Ver-fahren hat von  1991 bis 1993 etwa f\u00fcnfzig Vertreter der Industrie, der Umweltgruppen, der zust\u00e4ndigen Beh\u00f6rden und der Wissenschaft an einem \"Runden Tisch\" versammelt, an dem dieBeteiligten insgesamt fast zehn Tage kontrovers miteinander diskutiert haben. Im ersten Teil dieserZusammenfassung wird das partizipative Verfahren beschrieben und erl\u00e4utert, wie aus den Diskus-sionen zwischen den Beteiligten Ergebnisse f\u00fcr die Technikfolgenabsch\u00e4tzung abgeleitet wurden. Derzweite Teil enth\u00e4lt die empirischen Befunde zu den m\u00f6glichen Risiken und zum erwartbaren Nutzentransgener herbizid-resistenter Kulturpflanzen. Der dritte Teil stellt die ethischen, rechtlichen undpolitischen Diskussionen dar, die zwischen den Beteiligten gef\u00fchrt wurden; er enth\u00e4lt au\u00dferdem dieEmpfehlungen des Verfahrens zur Regulierung herbizid-resistenter Pflanzen.  Contents FOREWORD.................................................................................................................... XI PART I: PARTICIPATORY TECHNOLOGY ASSESSMENT AS A POLITICAL EXPERIMENT ........................................................................................................ 1 1   Representative participation and fair allocation of resources..................................................1 2   Steering of the procedure: participants, coordinating committee, WZB working group............3 3   Selection of the subjects for the expert reports.......................................................................4 4   The approach: technology-induced versus problem-induced assessment ..................................5 5   Issues considered: risks, benefits, and alternatives to transgenic herbicide-resistant crops.......5 6   Reference to scientific knowledge and the role of experts .......................................................7 7   Assessment conferences: science-based discussions ...............................................................8 8   The use of argumentation: How conclusions were derived through discourse..........................9 9   Example: Conclusions concerning specific risks of genetically engineered plants..................11 10  The closure of the participatory procedure...........................................................................16 11  Some structural problems of participatory technology assessment ........................................17 PART II: EMPIRICAL FINDINGS - IMPACTS AND CONSEQUENCES............ 20 A  BIOSAFETY ASPECTS OF TRANSGENIC PLANTS.................................................20 1   Physiological side-effects and food safety: Are toxic or allergenic substances to be expected in transgenic plants?.............................................................................................21 2   Horizontal gene transfer: probability and possible consequences ..........................................25 3   Can feral populations of transgenic herbicide-resistant crops become obnoxious weeds or invade natural ecosystems?...................................................................................28 4   Evolutionary aspects: Can transgenic plants change the course of natural evolution? Will they obstruct existing differentiation of species? ...........................................................31 5   The \"special quality\" of genetic engineering........................................................................33 B  BIOSAFETY ASPECTS OF NONSELECTIVE HERBICIDES.....................................36 1   Will greater or lesser amounts of herbicides be applied when transgenic herbicide-resistant plants are grown?...................................................................................36 2   Impacts on health: residues from nonselective herbicides in food crops .................................39 3   Impacts on the environment: Are nonselective herbicides more environmentally friendly?...................................................................................................................... .......41 C  IMPACTS ON AGRICULTURE...................................................................................45 1   Issues of biodiversity: Will transgenic herbicide-resistant crops accelerate genetic  viii erosion in plant breeding and agricultural habitats?..............................................................45 2   Agronomic effects of transgenic herbicide-resistant crops: technical gains, resistant weeds, and integrated crop protection..................................................................................47 3   Economic effects of transgenic herbicide-resistant crop plants: profits, costs, and concentrations................................................................................................................. ....51 4   Food s upply: Is a contribution to be expected from transgenic herbicide-resistant crops? ......53 PART III: NORMATIVE EVALUATIONS-ETHICS, LAW AND POLITICS ..........57 A  IS THE GENETIC MODIFICATION OF PLANTS ETHICALLY PERMISSIBLE?.......... 58 1   Is genetic engineering of plants incompatible with the moral respect we owe nature \"for its own sake\"?............................................................................................................ .59 2   \"Genetic pollution\", evolutionary impact, and moral harm...................................................60 3   The impositions of ethical pluralism....................................................................................61 B  ARE THE RISKS OF GENETIC ENGINEERING ACCEPTABLE? ............................. 62 1   Recognisable risks of transgenic plants: unexpected metabolic changes, feral populations, horizontal gene transfer...................................................................................62 2   Focusing on the lack of knowledge: the risks of ignorance, uncertain prognoses and the limits of testing...................................................................................................... .64 3   Are risk comparisons legitimate? The \"special quality\" of genetic engineering.....................65 4   Reductionist versus synergistic risk philosophy?..................................................................66 5   From hypothetical to speculative risks.................................................................................67 6   Hypothetical and speculative worst-case scenarios...............................................................68 7   Regulating suspected risks..................................................................................................69 8   Reversing the burden of proof- in dubio contra projectum? ...............................................70 9   Reversibility as a criterion? .................................................................................................72 10   Regulatory responses to anxiety..........................................................................................72 C   NONSELECTIVE HERBICIDES: ARE THE BENEFITS APPRECIABLE?................... 73 1   Regulations as a factor in risk-benefit analysis ....................................................................73 2   Shifting criteria of evaluation..............................................................................................75 3   Are small benefits appreciable?...........................................................................................75 4   Reference to intensive agriculture or to organic farming?.....................................................77  ix D   USEFULNESS AND SOCIOECONOMIC NEED AS CRITERIA FOR APPROVAL: A \"FOURTH HURDLE\" FOR INNOVATION?............................................................. 78 1   Risk-benefit analysis under the German Genetic Engineering Act.........................................78 2   Have alternatives to genetically engineered crops to be taken into account?..........................80 3   Socioeconomic need as a criterion for technological innovation ............................................82 E   SPECIFIC PROBLEMS, RECOMMENDATIONS FOR REGULATIONS..................... 84 1   Testing for unexpected metabolic changes and food safety ...................................................84 2   Ecological testing and monitoring of genetically engineered crops........................................86 3   Increasing the transparency of herbicide approvals..............................................................87 4   Precautionary standards for herbicide certification: Zero contamination as goal?..................88 5   Compliance with the conditions of herbicide approval, integrated crop protection, site-specific regulations.................................................................................................................... ......88 6   Specific regulation for nonselective herbicides rotation ........................................................89 7   Labelling of genetically engineered food..............................................................................90 F   OUTLOOK: THE POLITICS OF TECHNOLOGICAL D EVELOPMENT....................... 92 1   Diverging views of the social role of technology ..................................................................92 2   \"High tech\" as a lifestyle....................................................................................................9 3 3   The compromise of technological pluralism .........................................................................94 4   The political function of participatory technology assessment ..............................................94 REFERENCES................................................................................................................ 97 APPENDIX: MATERIALIEN ZUR TE CHNIKFOLGEN ABSCH\u00c4TZUNG.......................... 101  FOREWORD Between February 1991 and June 1993, a technology assessment procedure on the cultivation of crop plants with genetically engineered herbicide resistance was carried out at theResearch Unit,  Standard Setting and the Environment , in the Wissenschaftszentrum Berlin (WZB). The project was financed by the Federal Ministry for Research and Technology(No. 0319481A); it was initiated jointly by  Wolfgang van den Daele  (WZB),  Alfred P\u00fchler (Institute for Genetics at the University of Bielefeld) and  Herbert Sukopp  (Institute for Ecology at the Technical University of Berlin). Crop plants with genetically engineered herbicide resistance open up new possibilities for agriculture. The corresponding products are now coming to the market. They are still theagriculture.application and release of transgenic plants and the future role of chemical weed control insubject of heated public debate, concerning above all the possible risks associated with theherbicide. Herbicide resistance was one of the first projects to apply genetic engineering tonow because they affect not only weeds but also conventional crop plants. This obstacle isranging effect (nonselective herbicides), which were not practicable for most farmers up tochemical weed control. They extend the scope for application of herbicides with a wideremoved if a gene is inserted into the plant which induces resistance to the nonselective These issues were central to the technology assessment. Taking the themes which provoked also discussed and evaluated them in a series of conferences. At the start of the last confer-These groups have not endorsed the final conclusions.upon, the official representatives of the environmental groups withdrew from the procedure.ence, at which the conclusions of the technology assessment were discussed and decidedgroups and from public bodies who not only provided the reports and commentaries butdure. It involved some 60 participants invited from scientific, business and environmentaltechnology. The technology assessment was organised as a participatory, discursive proce-mented reports and 18 commentaries on the various problem areas of herbicide resistancepublic criticism as a starting point, we commissioned a total of 18 expert reports, two comThis report summarises the results of the technology assessment. It comprises three parts. The first part describes the methodology which was applied in analysing the deliberations ofthe technology assessment. It explains how the procedure was able to arrive at conclusionseven though the debate between the participants continued to the last which seemed ratherto indicate that the important issues remained a matter of controversy. We illustrate themethodology taking a strategic question from the risk controversy as an example, namelywhether uncertainties with respect to the properties and behaviour of plants produced bygenetic engineering can be distinguished from uncertainties due to natural processes whichoccur in all plants.  xii The second part of the summary report presents the empirical findings from the technology assessment. These findings relate to the performance and the possible impact and conse-quences of transgenic herbicide-resistant crops. The third part contains the discussions ofthe ethical, legal and political assessment of such plants; it also lists the recommendationsfor regulation advanced by the participants. The expert reports delivered in the technology assessment are only available in German. lished here give a full and fair account of the results of the procedure.the technology assessment. It also makes it possible to check whether the conclusions pub-This material allows the reader to follow the course and the analysis of the discussions indebates reconstructed as sequences of claims, objections, counter-claims, justifications, etc.ology described in Part I below, key areas of controversy were identified and the respectivevarious problem areas of herbicide resistance technology. In accordance with the method-detailed overview of the range of arguments used by the participants with respect to thein a series of WZB discussion papers (see Appendix below). These papers also contain aThey have been published, together with the commentaries and further written statements, Acknowledgements.  The organisation and the analysis of the technology assessment procedure involved the combined efforts of the project initiators and an interdisciplinary groupfrom the Wissenschaftszentrum (WZB) which included  Alfons Bora  (sociology),  Rainer D\u00f6bert  (sociology),  Susanne Neubert  (agricultural science), and  Viola Siewert  (agricultural science). We also received valuable scientific help from  Inge Broer  (genetics) and  Ulrich Sukopp  (ecology). Finally, we would like to thank  Mary Kelley-Bibra ,  Christa Hartwig , Alex Sawyer  and  Axel Tr\u00f6ster-Gr\u00f6nig  for their technical assistance. Wolfgang van den Daele Alfred P\u00fchlerHerbert Sukopp  would promote discursive forms of debate, increasing the likelihood that arguments from theof the respective positions accepted.two sides would be heard, and critical appraisal The substantive results achieved in this technolparticipatory and discursive discussion.how results were achieved in a procedure ofassessment. In particular, we want to explainorganisation and the process of the technologywe give a more detailed presentation of theparts of this summary report. In the followingogy assessment are presented in subsequent PART I: PARTICIPATORY TECHNOLOGY ASSESSMENT AS A POLITICAL EXPERIMENT A technology assessment of crop plants with sessment can be considered a political experi-genetically engineered herbicide resistance wasundertaken in the Federal Republic of Germanybetween 1991 and 1993. It was organised by anment because various angles of embarking onzentrum Berlin (WZB) (Prof. Wolfgang van denDaele) in cooperation with the Institute forGenetics of the University of Bielefeld(Prof. Alfred P\u00fchler) and the Institute for Ecol-ogy of the Technical University of Berlin(Prof. Herbert Sukopp). This technology as-interdisciplinary group at the Wissenschafts-new procedural courses were tried. The keywords here are participation and discursivity. The experiment fostered participation because it which the social conflicts related to the intro-public) were built into the procedure from thepositions of the on-going political conflicts overnew technology in Germany and to include thedeclared advocates and critics of the specifictechnology under consideration. In this way, thedisputes that normally take place outside thedomain of technology assessment (and that oftenbecome really heated when its results are madevery outset.should, in addition, be a political \"arena\" inand discussed in an exemplary manner. Conse-quently, participants in the procedure were putwas based on the notion that technology assess-ment should be more than just a forum of ex-perts at which the state of knowledge on thepossible consequences of a technology is pre-together so as to reflect all the interests and thesented and evaluated. Technology assessmentduction of a new technology can be articulated The experiment emphasised discursivity since out for the technology assessment, to evaluateprocess of on-going face-to-face communicationbe given. The understanding was that such adrawn as well as recommendations that shouldcommissioned, and to discuss conclusions to bethe results of the expert reports that have beenwere to define the scope of studies to be carriedof conferences and workshops the participantssentatives of controversial positions. In a seriesorder to guarantee a dialogue between the repre-going communication amongst those present, inment was organised as a social process of on-the whole procedure of the technology assess1 Representative participation 1 resourcesand fair allocation of Which groups should be recruited into a particibe covered by experts from the relevant disci-churches etc.). Representation of the media wasusual representatives of public life (trade unions,involving politicians from all factions and theparticipants that the idea was dropped of alsoplines. This already led to such a high number ofand the regulatory authorities should be in-the specific technology to be investigated had tovolved. Furthermore, all the problem areas ofmental groups, as the parties of social conflict,Accordingly, at least industry and the environ-competence as the decisive selection criteria.considered interest, political commitment andpatory technology assessment? The organisersoffered through invitations to the press. It cannot be taken for granted that opportunities offered for participation in a field of politicalconflict and controversy will readily be acceptedby the parties involved. It was not difficult toassure the cooperation of scientists for theprocedure, from the relevant research areas, byoffering them lucrative contracts for expertreports. However, all other groups had rathermixed feelings about joining the procedure. Theregulatory authorities maintained a certain                                                    1 More background information in van den Daele (1994). Further analysis of the technology assessment procedureis provided in Bora\/D\u00f6bert (1993), van den Daele (1996,1997), van den Daele\/D\u00f6bert (1994), D\u00f6bert (1994,1996), G ill ( 1993), Holzinger (1996), Neubert (1993), and Saretzki (1996).  tific experts were contractually bound to regular attendance. The coordinating committee suppleforced to arithmetic precision, in such a way thatthe level of participation remained more or lessconstant for the various groups.mented the groups accordingly, without being What is more significant when assessing the According to an internal rating by the WZBfavour of transgenic herbicide-resistant crops.conference, a slight majority was probably ingroup, 29-48% of the participants were inreview. Of the 42 experts and commentatorsattitude of the experts to the technology underrepresentativness of the composition, is thefavour of the technology at the beginning of theprocedure, 33-43% were against it and 15-43%were neutralwho participated in at least one assessment 2 Herbicide-Resistant Crops distance by sending individuals ambivalence. The organisers triedwho did not then appear as officialwas open with respect to its approach andaddition, anyone who refuses runs the risk ofto publicly justify refusal to participate. Inresistance to participation was that it is not easyprobably also played a role in overcomingenvironmental groups in particular. WhatThe question is whether that convinced thecomposition, and that it did not favour any side.only.watching the procedure take place without them,fundamental political reservations.however, both sides decided torepresentatives of their agencies.opposing assessments of theBoth German industry and theenvironmental groups hadto make it clear that the procedureTheir \"coalition against participa-participate despite theirtion\" was certainly founded onsituation. Industry was suspiciousabout being publicly \"chastised\".The environmental groups wereapprehensive that their involvementwould sap protest potential andwould lend legitimacy to thetechnology investigated. In the end,i.e. with the participation of the \"other side\"    At the first conference, opposing parties criti- Technology Assessment of Herbicide Resistant Crops nology assessment, according to institutions andrepresented the various positions in this contro-changes contradicted each other, for instance,both more scientists and fewer scientists wererequested. Hence, there was little room forcould be seen as an indication that those presentreal need for action. The divergent demandsbeing imbalanced. In many cases, the calls forcompromise. After all, there was apparently nocised the composition of the participants asbelow) prepared a proposal to solve the issue,participants in the first conference of our tech-spite considerable efforts. A breakdown ofassessment. This attempt failed, however, de-made to involve farmers in the technologydemand from some participants, an attempt wastaken to mean tacit approval. Taking up afirst conference for comment. No response waswhich was submitted to the participants after thegroups, is shown in the table above.versial area. The coordinating committee (seeGovernmental agencies 1991: 7 (1993: 10) * The number of participants in the procedure Research institutions (not including insti- 1991: 20 (1993: 25) ranged from 50 to 60 persons (not including theWZB group). There were particularly highfluctuations among the representatives of envi-ronmental groups and their associations. Scien-tutions associated with nongovernmental organisations) Nongovernmental organisations (envi- 1991: 11 (1993: 12) ronmental and consumer groups, representatives of organic farming, research institutions associated with nongovernmental organisations) Industry and trade associations 1991:10 (1993: 13) *Figures in brackets show the distribution just prior to the final conference in 1993. 2. The technology assessment procedure constiburden which for many could not simply beand the associated research bodies often facedtuted a major burden for all the participants-atackled during their paid work. There werevarious kinds of problems with resources.Whereas time was probably the critical point forthe participants from industry, participants fromenvironmental groups, consumer organisationsfinancial difficulties when they were obliged towork on an honorary or self-employed basis, orwere financed through donations. In the proce-dure, an attempt was made to compensate for                                                    2 The fluctuations in the rating by the WZB group did not evaluation of self-assessments by the participants in thecorrelate with the raters\" own political preferences; theyhighlight the difficulty of an (external) assessment ofattitudes towards herbicide resistance technology. For anprocedure, cf. Bora\/D\u00f6bert (1993).  ment. Only rarely, however, were there any of the decisions of the coordinating committeeAs a result the participants were more informedparticipants to break out of this consensus later.unanimously, which made it difficult for otherthe coordinating committee were approvedreactions. With few exception, the decisions by to have a final say on them.rather than really called upon Part I: Participatory Technology Assessment As A Political Experiment The participants exerted 3 uting substantive argumentsformally steering the proce-dure.influence mainly by contrib-to the discussions, but not by this to a certain degree by ensuring that the in any case for reasons of equal participation.reports and commentaries. This was necessaryresources allocated to the various groups:experts from these groups were adequatelyThe following table gives a breakdown of theconsidered in the commissioning of expert      Expert Com- Total Reports mentaries Research Institutions (not including insti- 220.000.- 5.000.- 225.000.- 3 More than 40 particitutions associated with nongovernmental through the expert reportspants were already involvedin shaping the contentsand commentaries commis-sioned. Moreover, all theother participants were alsoentitled to submit writtencomments, criticisms andto be discussed at the confer-technology assessmentevaluations. These were thenences and published in the organisations) documentation. The organisers also exercisedby submitting \"provisional conclusions\" on thevarious problems, in order to focus the assess-ment discussion at the final conference (seebelow).this right during the final phase of the procedure Industry and trade associations 30.000.- 3.000.-The WZB working group had not been formally33.000.Nongovernmental organisations (environ- 120.000.- 4.000.-did have real influence. All organisational workwas undertaken by this group, from the recruit-expert reports to the planning of the conferencesand the preparation of the assessment documen-conceal the fact that an \"apparatus\" of this kindexecuted the latter\"s decisions. But this cannotcoordinating committee and who prepared anding of participants to the commissioning ofstaff who continued to be dependent on thediscussions on the procedure. In formal terms,greatly into the structuring of the contents of thewith this organisational work. This extendedaverage of three persons were fully occupiedthe WZB working group acted as the planningtation. For a period of more than two years, angiven the remit of steering the procedure, but it124.000.mental and consumer groups, representatives of organic farming, research institutions associated with nongovernmental What adequate consideration actually meansorganisations) this technology assessment DM may be a matter of argument. The fact is that inGovernmental agencies 124,00020.000.- 3.000.- 23.000.cide-resistant crops. If we include those univer-(roughly 30%) of the expert fees went to scien-tists from the environmental groups or theirassociated research institutes. This sum does notreflect the overall volume of resources whichwere allocated to the critics of transgenic herbi-(45% of the total fees). The question of distri-sity scientists who, according to the rating by theWZB group, were to be assigned to the group ofbution of resources was not problematic in thecritics at the beginning of the procedure, thenthis figures must be increased to DM 185,000procedure up to the final conference. Total 390.000.- 15.000.- 405.000.Steering of the procedure: 2 participants, coordinatingcommittee, WZB workinggroup The central steering body for the procedure of sumer organisations and industry. The decisionslatory authorities, the environmental and con-included three people from the side of the regu-ence. In addition to the three organisers, itcommittee\" which was set up at the first confer-the technology assessment was a \"coordinatingall participants in the procedure for final com-of the coordinating committee were submitted to 3 Only at the first conference did procedural matters play procedure on the basis of self-organisation-at least nota central role but it was not possible to find a bindingsolution at that time. It is just not feasible for some 50 to60 persons with, in some cases, diametrically opposedinterests to jointly conduct a technology assessmentwithin an acceptable period of time.  4 Herbicide-Resistant Crops a specific link to transgenic herbicide-resistant being too narrow. Additional reports weremental organisations: for instance, on soil ero-sion, on the patenting of genetic resources fromthe Third World by companies from the indus-trialised countries, and on the power and inter-ests of the groups involved in the technologyassessment, with special reference to a compari-son of industry and the environmental organisa-tions.hand, the spectrum of subjects was criticised astive herbicides examined in detail. On the otheragainst plans to have the problems of nonselec-crops. This argument was raised in particularsolicited by the representatives of nongoverncan exert considerable influence. A certain together to reflect the various disciplines anddegree of internal control was ensured by thefact that the WZB group itself had been putsial technology.political orientations pertinent to the controverAll strategic decisions in the course of the technology assessment procedure were takenwas the case forunanimously in the coordinating committee. This \u00b7\u00b7   the composition of the participants, selecting the subjects for the expert reports, and the subsequent commissioning of the reportsand the comments requested thereon, \u00b7  the form of publication of the materials and cluding the depiction of the various positions ofthe results of the technology assessment, in-the participants and consideration of thesepositions in the final synthesis report by theorganisers,  Final agreement on the programme structurewas not reached during the first conference. Thea final programme proposal. The proposal waspresented in written form to all participants forcomments and was then taken as accepted as nofurther objections were raised.question was delegated to the coordinatingcommittee which took two meetings to draw up \u00b7  the sequence of colloquia and assessment conferences, \u00b7  the way in which preliminary results of the technology assessment should be presented fordiscussion among the participants in the finalconference. lay citizens. This means that in our technologydecisions concerning the strategy of the tech-nology assessment. First, it adopted a technol-assessment the competence for value judgementsogy-induced approach; second, it rejectedproposals to have expert reports on politicalof plant manipulation. A proposal toflict over new technology, or the interests andobjectives of major actors in that conflict,because such questions have a strong normativeThe final programme structure contained twotouch and can only be dealt with empirically to areport on ethical issues be commissioned, butthat was expressly limited to the moral questionsissues, such as the power structure of the con-assess all the value judgements brought forwardcommission a comprehensive ethical report toin the technology assessment was also rejected.In general, these programme decisions reflectedthe understanding that value judgements cannotand should not be relegated to experts. Morallimited degree. It was decided that an expertand political evaluation is the proper domain of these decisions appeared adequate, in principle,they added to the underestimation of normativeand political issues in our technologyassessment; they ruled out that these issues beput automatically on the agenda through thecritical discussion of the respective expertrested with all the participants as a group. Whilereports. that the decisions at the \"round table\" had to be In the coordinating committee (contrary to thesituation in the plenary assembly of the partici-pants) conflicts were settled through negotiation.All members of the coordinating committee hada factual right of veto. The remit for the steeringof the procedure was subject to the conditiontaken jointly. This did not exclude situations inwhich people occasionally let themselves beoutvoted. Selection of the subjects for  3  the expert reports  The selection of the subjects for the expert problems associated with transgenic herbicide-ducted over a period of several months. Thement and of the individuals from whom thereports should be commissioned were dealt withat the first conference. To this end, the WZBworking group proposed a provisional pro-gramme structure which was the result of nu-merous discussions with potential experts con-reports to be prepared in the technology assess-declared goal was to cover, if possible, all theresistant crops raised in the scientific literatureand the public debate. The experts we consid-ered were invited to present an outline of theirreports for discussion at the first conference. The programme proposal was criticised fromvarious sides. On the one hand, the broad range of topics was criticised, that often did not reveal  induced assessment of transgenic herbicideleast.assessment would then have been doubled atwell. The programme of the technologyhave had to be addressed for organic farming asadditional and corresponding questions wouldresistant crops would have been invalid. Rather, Part I: Participatory Technology Assessment As A Political Experiment 5  The approach: technology4 induced versus problem-induced assessment  Two criteria were applied by the organisers in quences of herbicide-resistant crops, not theassessment should address the possible conse-resistant crops must to be dealt with in thepublic for and against transgenic herbicide-assessment: (1) all the arguments advanced indrafting a preliminary list of the substantiveissues to be investigated in the technologypossible options for weed control in agriculture.technology assessment; (2) the technology 4 posed a return to more conventional types ofpendence of modern societies on technologicalassessments have regularly proceeded from thetions to social needs. Equally regularly, how-from control to design and from technical op-the origins of the technology in question, movinganalysis of the consequences to the analysis ofassessment which focus on the control of theproblems to be considered. Thus technologydynamism, the broader became the horizon ofseen as a vehicle to revise in principle the de-nology assessment is as old as technology as-ever, political and pragmatic constraints im-sessment itself. The more such assessments wereconsequences of new technology. Perhaps the optimum would be to pursue the different ap-proaches in parallel or in cooperation. However,most of the studies which bear the title of tech-nology assessment apply the technology-inducedapproach.The dispute about the proper approach in techthe nongovernmental organisations in the firstconference of the procedure. These participantssystem of agriculture that is socially desirablecide-resistant crops and whether they fit into abeen whether we really need transgenic herbi-farming. The decisive questions would then haveintensive farming and, on the other, by organicoffered, on the one hand, by industrialised,cide resistance, the starting point would thenhave to be the agricultural problem of weed While it would have been difficult not to agreewith the first of these criterion, the secondevoked considerable criticism from the side ofhad fundamental reservations about the narrowfocuses on the analysis of possible consequencesapproach of the technology assessment whichwas \"technology-induced\". This approach takesthe emergent technological option of transgeniccontrol and a comparison made of the optionsherbicide-resistant crops as the starting point; itof such crops and on the political actions thatmight be necessary to cope with those conse-quences. What the nongovernmental groupscalled for instead was \"a problem-induced\"technology assessment. This approach addressesthe underlying problem the technology is sup-posed to solve and compares alternative optionsfor tackling that problem. In the case of herbi-and ecologically sustainable. technology assessment, with a minor modifica-In the end, this approach was adopted in our natives were represented in the procedure, aprior to the final conference.ceased to be a subject of dispute until directlyassessment was approved in consensus andThe working programme of the technologygroups (temporarily) accepted this arrangement.farming was commissioned. The environmentalspecial expert report on weed control in organicof broader technological and agricultural alter-tion: In order to guarantee that the perspectives  Issues considered: risks,  5 benefits, and alternatives totransgenic herbicide-resistantcrops  A \"problem-induced\" technology assessmentnone of the issues raised in the technology-agriculture (intensive versus organic farming)techniques that fit alternative systems ofof a comparative analysis of weed controlparticipants of our procedure come out in favourtechnology-induced assessment. In fact, had thereason to forego the more modest efforts of ainput into the public debate, it cannot be adevelopment. While this may be a necessaryscenarios of desirable futures for socialpolitical planning in the broadest sense and tothe scope of technology assessment to issues ofpolitical issues, but, at the same time, it inflatesallows the discussion of broad and fundamental  In the working programme that was determined for the technology assessment, the possible risksof transgenic herbicide-resistant crops becamethe central theme. Discussion of the possible                                                    4  The evidence, too, that a problem can be solved with conventional, technological resources does not mean thatit is no longer necessary to examine new technologies. Anew technology could bring with it a major improvement.Studies of alternatives place symmetric demands on newand old technologies-unless there are reasons why newtechnologies would, in principle, be less favourable thanold ones.  ate these claims with further argument. 6 Herbicide-Resistant Crops benefits was of far less importance and the only a limited role.alternatives to herbicide-resistant crops played The preoccupation with risks can probably not  It would seem to be a minimum requirement ofbe the main subject of a technology assessment.And, as long as this is the case, risks must alsoengineering in public speak the language of risk.ingly, therefore, the main criticisms of geneticbound to resort to risk arguments. Not surpris-legitimacy of the concerns and arguments whichchored in the constitution by a guarantee ofany technology assessment that it examine thethe structure of science and industry, and an-society in which technical innovation is built intobe avoided in any technology assessment. In aindividual rights, opposition to innovation isthe people raise in public debates. altered through conventional breeding tech-rising all the relevant risk arguments. The othercould possibly be justified.from the risks of new plants that have beenwhether the risks of transgenic plants differedissues that emerged from the discussion wereparallel questions to that report. The paramountcommentary reports or indirectly by way ofexpert reports were related either directly asspecial risks for genetically modified plantsThe expert report of the \u00d6ko-Institut Freiburgconstituted a kind of reference report summa-applied in conjunction with the resistant crops.risks of nonselective herbicides which will beseven dealt with the toxicological and ecologicalwith the risks of genetically modified plants;the procedure, six dealt more or less exclusivelyOf the twenty expert reports commissioned for niques, and how the hypothesis that there are progress vis-\u00e0-vis the status quo. On the other Benefit analyses in our technology assessmentprocedure concentrated on the claims of theadvocates of transgenic herbicide-resistant cropsthat nonselective herbicides implied clear eco-logical and agronomic advantages. Here, differ-ent assessment frameworks were taken as thebasis. On the one hand, even small ecologicaland economic improvements were chalked up ashand, it was criticised that the improvementsproblems of intensive farming; they were simplyvariations of a trend which had to be seen asmistaken development and did not, therefore,constitute real benefit.claimed did nothing to alter the fundamental critics had to make claims of risk and, whenevades political control as the starting point. Theis evolving in a social process that largelyless emphasis than empirical aspects. In mostif it is to be invented or propagated. In line withinnovation: Special justification is required if abution of the burden of proof which favourshidden premise of all risk discussions is a distri-new technology is to be restricted or banned, notseries of consequences: First, it turned theimplicitly accepted the fact that new technologycases the factual preconditions of risk claimsWhen toxic plant ingredients develop, approvalments, by contrast, were often uncontroversial:The normative reference points of risk assess-probability and the scale of potential damage.were controversial, i.e. the causalities, theissues of judgement and valuation were givenfor the latter, tests and procedures for approvalfaced with objections, were forced to substanti-prehend why the problems had to be settled in aogy assessment followed a pattern in which theherbicide-resistant plants and nonselectivethan to the risks of transgenic plants because,the potential risks of nonselective herbicidesthe competent authorities. This applied more totechnology assessment and could not be left toherbicides. Sometimes it was difficult to com- tested in any case for the approval of transgenicappeared to be less well-established. Second,examination of all the issues which had to betechnology assessment into a kind of priorthis rule, many of the discussions in the technol-technology assessment procedure had a wholeThe predominance of the risk aspect in thewill be denied. Third, the technology assessment took the sting out of the debate over whether weogy can be withdrawn. What \"society\" needs is In claims of benefit, the advocates of a technol-ogy have the burden of proof. However, ac-cording to the legal principles that apply in mostindustrialised countries, this does not establishthe critics with respect to the risks of the tech-nology. If critics fail to provide evidence ofrelevant risk, the technology cannot be banned.If the advocates fail to provide evidence ofrelevant benefits, the technology still cannot bebanned. At best, public support of the technol-normally decided on the markets. It is not theactually need transgenic herbicide-resistantany symmetry to the burden of proof required ofassessment, reference to this regulatory structuresubject of political regulation. In our technologyand may not, in itself, constitute sufficienton public awareness and level of consciousness,herbicide-resistant crops is a legitimate question,lated. Whether there is an acceptable demand forgate more issues than can be politically regu-even when the answer can only have an impactthe scope of a technology assessment to investi-by the limits of existing law, since it is withincrops. There was, however, no necessity to abidereason to impose legal restrictions on the tech-  pursue when they enter a technology assessment procedure must be sifted through the filter oftechnology in means of which one can beat the drum for ainvolves the possibility that handy claims, byidea behind technology assessment is that itthemselves to the risk of information. The veryinformation orientation and, so to speak, exposepublic or provoke resistance to it, can be shown to be unprovable, poorly justifiedor simply wrong. This does not mean thatpolitical interests or goals can themselves be\"refuted\", but they can lose their favouritelegitimation. To justify them, new reasons mustthen be provided. This risk can only becircumvented by circumventing technologyassessment altogether; once you participate, youare automatically exposed. Part I: Participatory Technology Assessment As A Political Experiment 7 nology. Furthermore, it is also a legitimate imply a revision of constitutional law.approval of a new technology, even if that wouldneed could be made a precondition for thematter for discussion whether socioeconomic  Within the framework of our technology as-D below). Probably, because of the otherwisemissing regulatory relevance, questions of needsessment fundamental questions of this kindwere mostly referred back to discussions of risk.The thrust of the argument was that uncertain-ties about risks that might be hidden in a newtechnology should not be offloaded onto societyunless there is a real need for that technology.were scarcely touched upon (but see section III, level of technical details. Comparison with the cide-resistant crops were largely confined to theDiscussions of alternatives to transgenic herbi-in the technology assessment.not, however, a subject-matter for investigationon nonchemical methods of weed control; it wasOrganic farming was covered in an expert reportagriculture was taken as the frame of reference.even then the established system of intensivecontrol was repeatedly brought forward, butpotential and problems of mechanical weed the function of the technology assessment proce-participation must be symmetrical. Unequalgroup of activists campaigning against geneticworking basis by all those involved in ouradopted), this commitment was accepted as thecause of it (depending on the political stancepossible that the \"virtualisation\" of politicaltreatment in the technology assessment.that the disadvantages they face in politics inbecause the procedure seemed incompatible withdistribution of power and resources in the soci-of technology assessment, the conditions forgeneral will be compensated for by preferentialWithin the framework of a voluntary proceduremeans, that oppositional groups cannot expectFair and equal treatment must be guaranteed. Onety must not affect the position in the procedure.engineering) declined to participate preciselythe straightforward goal of political mobilisation scientists it was an essential precondition forCommitment to information imposes limits onprocedure. The Gene-Ethical Network (a leadingdure to provide a forum for the political conflictwas not (at that time) considered a fundamental\"just talk politics\". Compromise was necessary.their participation; they would have declined tosocial movements. For industry and manyof the general public. This abstention wasaccepted and viewed as a concession by thethe technology assessment was only reluctantlyaspects through the information orientation ofrejection of the technology assessment. It is verylabour\" among the critics of the technology. Itover technology. Despite this, or perhaps be-declared to be a matter of political \"division ofthe other hand, symmetrical participation also  Reference to scientific  6 knowledge and the role ofexperts  The final stage in every technology assessment scientific investigation. Evaluations are based onvalue judgement. Whether metabolic changes dois a matter of knowledge.knowledge; establishing the limits to knowledgeor cannot know it, we still refer to the domain ofknow. And even if we determine that we do notexpected is something one can investigate andoccur and whether increases in yield can bethrough the use of herbicides are useful, is ais a political evaluation of the technology underunintended metabolic changes justify a ban onprinciple) verifiable or refutable. Whetherthey refer to statements on causal mechanisms,reasons which have empirical references, that is,facts and phenomena which are (at least inconsideration; the main strategy is, however,transgenic plants or whether increases in yield interests are, in general, known in advance. Theimportant point is that the interests participantswould be a waste of both time and money. Thethat really mattered, then technology assessmentsociety. Were political interests the only aspectconsensus which supports that notion in ourseems to be the basis for the broad politicalinherent in the notion of technology assessmentThe commitment to knowledge and information   There was consensus in our procedure thatexpert reports were to be a main element in thetechnology assessment. However, there was alsogeneral agreement that the expert reports shouldnot be its only result. They were to provide the  8 Herbicide-Resistant Crops basis for the political evaluation of transgenic provided in the selection of the questions to be our procedure.during the last 20 years, did not have any role inthe social movements and in the social sciencesexpert knowledge and expert cultures, both inpolitical criticism sometimes waged againsttechnical disciplines. The very fundamentalthe experts from the relevant scientific andforemost the competence and responsibility ofagreed that issues of information were first andherbicide-resistant crops. Furthermore, it was est.They were a matter of knowledge, not of inter-selves, were supposed to be science not politics.addressed in the expert reports and in theevaluation of the findings. The findings, themAssessment conferences:  7  science-based discussions 5 For the evaluation of the expert reports prepared  claims or \"technocratic arrogance\" were effec-expert opinions became a matter of discussion,claims depends on the methods adopted, and thatlutely certain, that the examination of empiricalforecasts on the basis of theory are never abso-pants in the technology assessment agreed thatexisted, would be brought to light. The partici-and that scientific controversies, where theyguaranteed that the unavoidable \"softness\" ofscience can only depict complex realities in aand what was not known. The bringing togetherlimited manner.about a specific problem, what could be known,explicit task of presenting what was knowninherently limited. Every expert report had thetherefore, that the knowledge of experts istively excluded. It was clear from the beginning,of experts with different political convictionstific advice for public policy. The role of theexperts were less contested in our technologyPerhaps the competence and responsibility of the experts was modestly defined, and exaggeratedguaranteed here than in other contexts of scien-assessment because greater transparency was participants was the decisive \"arena\". Discus-ceived the expert reports and a short five-pagein the technology assessment, discussion amongwhich had been prepared in three (one-day)colloquia. All participants had previously re-taries were commissioned for each report fromsummary. In order to guarantee the activeinvolvement of as many participants as possibleand to foster controversial discussion, commen-participants of the \"other side\". The commen-taries were supposed to point out:sions were held at two (two-day) conferences \u00b7  whether the central findings of the report were substantiated,\u00b7   whether important aspects were not covered, \u00b7  whether the report was based on implicit or unusual premises,\u00b7  whether the conclusions were plausible.  The members of the coordinating committee suffered less than is normally the case from timerather than result-oriented.scientific rather than political; it was processwhich were also constraining: the discourse waspressure; but they had other characteristicssion. The WZB working group was to supportDiscussions at these conferences presumablythe coordinating committee in this respect.pool the arguments in order to structure discus-omitted. It was their task, from time to time, toing the findings of the discussions, but rather,ences. They were not responsible for summaris-took turns acting as moderator at the confer-ensuring that no points or contributions were political discussion. Within such a setting, it waswhat the experts knew and what they wanted inhave interests and make value judgements. Theare not truly \"disinterested\"; they do indeedIt was equally clear in the procedure that expertsmost cases in vain) to make clear value judge-ments at the end of their reports, to triggergroup, were able to distance themselves from thebetween facts and evaluations, and to establishnot very cogent to propagate the notion thatvalue judgements of the experts, to differentiate interests. The participants in the procedure, as aexperts were merely the representatives ofmean that the reverse conclusion was drawn thatexperts are politically \"neutral\". This did notpolitical terms or thought was right.experts were even asked explicitly (although in conference to the discussion of these questions.On the other hand, it had never been the inten-political discussions. This was only done to ajustment to the timetable of the technologytion to postpone political questions to the lastconference. It was far more the case that thecoordinating committee had expressly indicatedthat the expert reports and commentaries shouldcontain conclusions based on value judgements,which should be seen as the starting point forassessment, which assigned the complete last could perhaps be attributed to a certain pread-respect to normative and political questionsThe relative \"reticence\" of participants with Legitimate room for political judgement was Thus, the politicisation of the experts in thetechnology assessment was within bounds.                                                    5  See van den Daele (1996).  process rather than result-oriented. In a way, the final conference was designed to solve this task.derive conclusions from such a procedure? Thedence without a final decision. How can one thensions or, in legal language: the taking of evi-discussions were deliberations without concluPart I: Participatory Technology Assessment As A Political Experiment 9 very limited degree, however. With the exception tion could be the commitment to \"neutrality\"to empirical, scientific arguments. One explana-associated with the role of expert. What proba-nipulation, which was explicitly oriented to-wards value judgements, all the other expertreports and commentaries confined themselvesof the expert report on the ethics of plant ma-could possibly occur and how likely it was.ject of controversy than whether the damagebly had more of an influence was the fact thatthe participants, themselves, defined their con-troversies mostly as debates about empiricalfindings and not about values and goals. Whatwas to be classified as damage was less a subThe use of argumentation:   8 through discourseHow conclusions were derived The final conference of the procedure had two  then. And it was designed to do what the as-the participants.problems of transgenic herbicide-resistant cropsfunctions. It was to bring to the fore the politicalsessment conferences on the expert reports hadnot done, namely, to draw conclusions about thewhich had not been discussed extensively up toempirical findings from the deliberations among With this argument the whole debate over thenormative and political discussions were thespect to valuation. Furthermore, the politicalforce of nonconformist normative arguments isprobably rather limited, because they may berelegated to the sphere of pluralism or outvotedby majority decisions. As a strategy of politicalcritique, therefore, it is often more effective toattack factual claims that are based on agreedvaluations than to call for alternative values. Inany case, at the assessment conferences lengthyexception.depends on what you want or find acceptable.they agreed on many normative questions whichmeant that there was little room and little need toParticipants adhered to the relevance of empiri-alleged special risks of transgenic herbicide-cal questions for various reasons. First of all,resistant crops would have been beside the point. the technology assessment were not empiricalNo one argued that the problems dealt with inbut political in nature, and that everythingintroduce completely new arguments with reanswer can be given because the requisitestricter than old technology? Throughout thetechnology assessment all participants proceededfrom the premise that political questions were tobe distinguished from empirical questions, andthat the finding of facts must be prior to themoral and political evaluation-both in time andin logical order. Before we ask whether a risk isacceptable we have to ask whether the riskknowledge is lacking or the matter is controver-Political problems relate to the question, \"Whatsial. But this, too, would then be part of factfinding (or evidence taking), and it must also berecorded before political judgement can refer toit.exists. It may, of course, be the case that noacceptable? Should new technology be regulatedgenic herbicide-resistant crops be approved orshould be done?\" For instance, should trans-banned? Are the risks of genetic engineering mulation rarely led to a declared convergence ofby most participants. In addition, the moderatorsin the expert reports, i.e. they called for sub-stantiation and proof, raised objections, formu-lated and examined counter-arguments. Al-though the arguments went back and forth or incircles (in line with the sequence of requests totake the floor), they often accumulated as far asintimated that it would not be possible to sum-consensus or dissent. This call was not followedcontents were concerned. However, this accu-record the result of discussions as a declaredSometimes there was a call for the assembly toand replaced by arguments on a different level.ual cases, arguments were explicitly withdrawnpositions or to settlement of dispute. In individ-The discussions worked through central claimsmarise   ad hoc , in a reliable manner, the nontransparent state of discussion. The dynamics ofthe assessment conferences were, therefore, that is, no one who acts as judge and who, afterto judge.discourse it is up to the participants themselvesis competent to take a final decision. In such alistening to the evidence from all parties present, as a discursive procedure with no third instance,After all, our technology assessment was set upwhether consensus has been reached or not?merely discuss an issue without determiningparticipatory procedure, when the participantsBut how can empirical results be recorded in a  The WZB working group which was assignedthe task of preparing the final conference pro-posed a methodology for summarising theempirical findings of the technology assessment.The methodology was approved by the coordi-nating committee. It involved three steps: \u00b7 giving an overview of all the arguments  tify such results-if there are any. 10 Herbicide-Resistant Crops presented by the participants with respect to the issues of debate, For that reason the WZB working group decided  \u00b7  reconstructing the state of argumentation to reconstruct the arguments in the procedureto exert such control:explicitly invited by the coordinating committeebe examined by the participants. They werean arbitrary manner was something which had toexample). Whether the working group did this infinal conference (see next paragraph for anthis reconstruction to the documentation for theinto controversial strategic positions and to add controversial,reached in the debates which were particularly \u00b7  formulating \"proposed conclusions\" which were then to be considered and decided upon bythe participants. the divergent nature of the positions. The par-counter-objections, etc. It was criticised that anecessary to truly reflect the course of theshould be reconstructed as a sequence of claims,classified according to content, i.e. whether theyagainst were put together visually in a kind ofsynopsis. What was controversial was whetherthe next step should be taken and the argumentshave intended. Against this criticism it wasparticipants into contexts which they may notgroup, and that it could put the statements of thevalue judgements from the side of the workingreconstruction of this kind could be biased bycounter-claims, substantiation, objections,been discussed, in which statements for andprocedure. The undifferentiated block appositionof arguments pro and con would merely stressdeveloped for the various questions that hadticipants had, however, also produced con-vergence between these positions.discussions). To this end, argument trees were(in the expert reports, in the commentaries andof all the arguments advanced in the procedurethat first of all an overview should be presentedabout this methodology. It was generally agreedThere were arguments in the working group pointed out that such a reconstruction was \"The reconstruction of arguments orders  spect to controversial issues. They repre-the statements of the participants withthey were said in reports, commentariesplicate the state of argumentation whichsent the taking of evidence, in which theparticipants had been engaged. Whetherquence they were said) or in place (whereflect the actual order in time (in what se-reference to the contents; it does not re-was achieved in the discourse with re-participants have produced, is completewhether the state of argumentation thethey really provide evidence, that is,and conclusive, is another question. Anyparticipant may, at any time, point outthat relevant arguments are missing orthat the objections and counter-objectionsreconstructed here are unproved or false.or discussions). The reconstructions exThe reconstructions are nevertheless point exactly it is that one objects andobjection. This procedure ensures thatuseful. With them it is no longer possiblejust to disagree without stating to whichwithout giving further reasons for thethere is progress in the discussion, even ifcontroversies remain unresolved. It be-comes clear where and why disagreementexists. Hence external observers of thetechnology assessment would be in abetter position to evaluate the discussionsand draw their own conclusions.\" (Cir-cular letter no. 13, May 3, 1993) opinions. They continuously argued with onecomplete control over their arguments. Thediscourse\", which seldom moves beyond thepants differed greatly from the usual \"publicHence, the communication between the partici-the actual dialogue, substantiation of claims wasrequested and provided, objections raised andpeople engage in real discursive deliberationscountered, evidence offered and examined.they cannot but open their positions to debate. Inticipants have put on the agenda. It was reason-arguments have a life of their own; they may runable, therefore, that in a participatory technologycontrary to the intentions of those who statethem. What results after discourse as \"the stateof argumentation\" can be far more than thesimple collection of all the statements the par-prompted discursive communication, that is, ina true discourse, the participants do not haveanother (i.e. against each other). The procedureassessment an attempt should be made to iden-In fact, the participants did not merely express repeated announcement of positions. When 6  Even when all the arguments have been summacomputer. It is an act of cognitive evaluationtwo conditions: (1) no new arguments may bebe possible, but these are in any case subject toagainst one another. Different evaluations maywhich must weigh the arguments advancedas to the results. The state of argumentationa logical derivation which could be left to thetransparent and comprehensible. This step is notmake the step to formulation of the resultsdoes not formulate the results. However, it doesrised and ordered, there are still no conclusions                                                    6  Reprinted in van den Daele (1994: 49).  matters of interest. Otherwise attempts to take debate are substantiated by scientific knowledge.claiming that arguments presented in the publicconsequently, one would also have to desist fromwould be beside the point from the outset and,evidence on these issues by consulting experts Part I: Participatory Technology Assessment As A Political Experiment 11 added; (2) no assessment should be made of scientific controversy? The conclusions arerefuted? Is the hypothesis substantiated? Is this acognitive evaluations, not political or moraldefensible but only, in the words of LudwigWittgenstein, whether it actually is the case. Hasthe claim been proven? Has the objection beenwhether something is politically desirable orones. costs there must be a result and that this must beings-they are (at least in principle) a matter ofence, but rather to provide open opportunity fornot to press for consensus in the final confer-cide-resistant crops, it was indeed the intentionto the political evaluation of transgenic herbi-dissent is politics, not science. And, with respectknowledge. The true domain of irresolvablesimply point out that one is of a different opin-are a matter of choice; but not empirical find-ion. Goals may be simply rejected, because theyburden of substantiation. One can no longerresult can only be rejected with a growingaccepted without opposition. It means that thePressure for consensus does not mean that at all diverging judgements. ence. This was in line with a decision by thepresent a draft of the final report on the technol- Conclusions of these kinds were formulated bythe organisers of the technology assessment andpresented to the participants in the final confer-coordinating committee that the organisersprovisional; the participants had the right toogy assessment, that they intended to deliver.The proposed conclusions were presented asdeclare consensus or dissent.  \"It seems necessary to make precise proremaining conflicts can be better under-spared, because that was known before.participatory procedure could have beenpoints of debate. In this case, the wholecontinue to be divided over all majormerely to convey as a result that opinionsstood. It would be highly unsatisfactorycrops. In view of such proposals con-sensus or dissent will also be precise androunding transgenic herbicide-resistantregarding the controversial issues sur-ogy assessment should be formulated,posals for how the results of the technolA crucial question is, of course, which participants to solicit their assent or dis-The organisers claim that the conclusionsthan others. This is why the organisersrather than others.\" (Circular letterno. 13, May 3, 1993)These conclusions are more plausiblearguments which have been advanced.they propose have been suggested by themerely a matter of subjective feelings.plausible ones, given the state of argu-logic, they are also not arbitrary orconclusions cannot be derived with purementation in the procedure. While suchthink that the final conference shoulddiscuss and examine these conclusionssent. The answer can only be: the mostconclusions should be presented to the Example: Conclusions     9 concerning specific risks ofgenetically engineered plants  The question whether there are specific risks involved in transgenic plants, that do not occurin plants modified by conventional breedingassessment.techniques, was a central issue in our technology 7 The report by the \u00d6ko-Institut risks that is in any way specific to transgenicprobability of unexpected side-effects withclaiming that transgenes and transposons cannotbe compared. This point prompted a lengthydiscussion in one of the assessment conferences.The arguments were summarised for the partici-pants in the following reconstruction:plants. The \u00d6ko-Institut defended its position byargued that there was at least an increasedtransgenic plants. One reason for this was thatthe insertion of transgenes would disturb thegenomic context of the host plant and inducepositional effects (insertional mutations). Thecounter-argument was that insertional mutationsalso occur when transposable elements (jumpinggenes) which are naturally contained in plantcells move around; therefore, disturbances of thegenomic context could not be considered as a 8 This methodology put the participants under empirical issues are neither arbitrary nor merelybased on the premise that judgements onjustify dissent. This was criticised. However,pressure for consensus was only exerted withrespect to the empirical aspects of the problemsrelated to transgenic herbicide-resistant crops.The very notion of a technology assessment isgreat pressure either to admit consensus or                                                    7  The final conclusions with respect to this issue are presented in, section II A5 8  For a full documentation of this controversy see the material in (Weber 1994: 215); see also van den Daele(1996).     Controversial issue (claim by the \u00d6ko-Institut):  Transgenes induce disturbances of the genomic context which are different from those induced by the insertion of transposable elements which are endogenous inthe plant. Therefore gene transfer cannot be compared with changes in the plantgenome which occur naturally.    Arguments:       1. That context relations in the host genome are disrupted is nothing which is specific to genetic engineering. The transfer of genes is, in this respect, comparable to the insertion of mobile DNA sequences (transposons). Such insertion, too, separates neighbouring genes.    2. Transgenes and transposons may be    comparable as far as the disruption of the sequence of genes is concerned. They are, however, significantly different in other respects.   Transposition is a rare event; transgenic plants are frequent.     3. Natural changes of the genomic context    through the insertion of transposons w ill seldom give rise to new plants, whereas transgenic crops w ill be grown in large  quantities.       4. Transgenic crops must be compared with other crops, not with wild plants. Transposons play an important role in breeding corn. The resulting cultivars (sweet maize, for example) are grown in equally large quantities. There is no difference here to transgenes.    Transposons do not transfer dominant genes.    5. In contrast to transgenes, transposons    cannot transfer dominant genes which will be expressed; they can only switch off existing, recessive genes.  Part I: Participatory Technology Assessment As A Political Experiment 13       6. Transposons also transfer an active gene (coding for transposase). In addition they contain regulatory sequences which can activate silent genes. This also leads to the formation of a new protein in the plant.   7. New plant properties may be possible     through transposition, but dominant genes cannot be transferred. This remains a difference. 8. The point is whether this makes a difference with respect to possible changes in the genomic context. In this respect, the effects of jumping transposons and the integration of transgenes are comparable.    9. Transposons do not transmit genetic    information that is new to the plant. Transposase is not an \"alien\" gene product; it is already known in the plant.      10. The fact that genetic information is  \"alien\" to the plant may be relevant for the possible consequences of the gene product (coded by the gene). It has no relevance, however, for the question of how the genomic context w ill be c hanged by the integration of the gene.   11. It  is  conceivable  that  new  information     could also make a difference with respect to the genomic context.    Integration of transposons is regulated by the plant; transgenes insert at random.    12. The integration of transgenes cannot be    controlled. It is random. There is no fitting site for transgenes in the host genome. In contrast, transposons jump (at least in part) to specific sequences.       13. The current state of knowledge is that transposons are inserted at random. They move through the genome in a stochastic process without preferring certain sequences or chromosomes.    14. Earlier  studies  (Saedler  et al .) have    found homologies between transposons and sequences at the site of integration. It was suggested that this indicates that integration is sequence-specific.       15. This hypotheses was withdrawn by the authors. It could never be shown that transposons use homologous sequences for integration. The homologies occur by chancewhich is to be expected according to statistical rules.  14 Herbicide-Resistant Crops   16. The thesis withdrawn is still   upheld in    other work (e.g. Fedoro ff,  1991) as representing the state of knowledge in science.      17. Fedoroff (1991) only refers to the regulation of the frequencies of transposition.    18. Transposons are switched on and off    according to regulation by the developmental cycle of the plant. For instance, it has been demonstrated that the frequency of transpositions in maize depends on the stage of growth of the plant.       19. With respect to the possible changes in the genomic context, the relevant question is whether the site of insertion is regulated, not the frequency of insertion. There are no indications, however, that the site at which transposons are inserted is in any way regulated by the plant.    20. The frequency of changes induced in    the genomic context (activation and deactivation of other genes) is also regulated by the development of the plant. This does not apply to transgenes.       21. If this applies, it can only relate to the time of the context changes not, to the type and the consequences. The consequences of changes in the genomic context because of the insertion of a transposon cannot differ from the consequences of the integration of a transgene (at the same gene locus).    22. Apparently transposons only jump to    sites at where sequences have been duplicated before. So, they do not integrate at random.       23. Preinsertional duplications are not known. Duplications occur in the process of insertion. They are a consequence, not a presupposition of insertion.   24. Transposons exhibit homing tendency;     they jump primarily on their own chromosome. 25. There is a certain tendency for transposons to be integrated on the same chromosome. However 50% of the insertions occur on other chromosomes. In principle, any chromosome can be the target of insertion.    Part I: Participatory Technology Assessment As A Political Experiment 15  Integration of transgenes is irreversible; insertion of transposons is reversible    26. Mutations through the insertion of transposons are reversible; the integration of transgenes is irreversible.      27. It is possible to stabilise the insertion of  transposons to the same degree as the integration of transgenes, through changes in the transposon or the outbreeding of gene sequences which are necessary for transposition. 28. Reversibility of transposition m eans that transposons pose a higher risk of unexpected side-effects than transgenes. Transposons can change the genomic context again when they leave the site of insertion. Frequently they leave \"footprints\", i.e. mutations and changes in the pattern of gene regulation, at the site where they insert. This may change gene functions, for example, in mutations of the flower colour.    29. Mutations which can be induced by    insertion of transposons will mostly concern recessive genes; far-reaching mutations are likely to be eliminated immediately.       30. Transposons can induce mutations which lead to dominant alleles; they can, for instance, enhance the rate of reproduction.    31. The differences between transposons   unexpected side-effects were comparable for and transgenes must be assessed in Institut tried to make the case that there was arandom. The representative from the \u00d6ko-wrong: transposons do, in fact, integrate atspecificity, it was concluded that the claim wasthe site where they leave. With respect to site-tions both at the site to which they move and atthan transgenes, because they can induce muta-rather than less side-effects on the host plantmeans that transposons are likely to have moretion of transposons is in fact reversible; but thisreversibility, it was concluded that the integra-transgenes and transposons. With respect tocontroversy in science over this question, by totality. Transposons are reversible and the frequency of transposition depends on the developmental stage of the plant. This warrants the conclusion that transposons, in contrast to transgenes, have a function for the plant and are regulated by the plant.       32. It has never been shown that the activity of transposons, except for the frequency of transposition, is regulated by the plant itself.   This was the reconstruction of the state of  argumentation with respect to the comparison oftransposons and transgenes. This reconstructiontional mutations) and hence the risk ofquestion whether context disturbances (inser-city of integration could have any bearing for thetransposons, only reversibility and site-specifi-were claimed to exist between transgenes andemphasised that, of all the differences whichconference. In these conclusions, they firstthe basis the organisers used to derive tentativetechnology assessment for examination. It waswas presented to the participants of theconclusions which they proposed at the final  16 Herbicide-Resistant Crops referring to Fedoroff (1991) for support in this volved in the procedure had created a fait acnot seem to be convinced by the end of thediscussions. Therefore, to clarify the issuefurther, the organisers offered to contactFedoroff and have her expert statement included.However, the \u00d6ko-Institut did not want to usethat offer. Accordingly, the organisers then feltthat it was legitimate to propose the followingsummary of the conclusions:respect (see statement 16, above), and she did discussion in the procedure,other participants or presenting their plans forherbicide-resistant plants without informing thecompli by applying for the release of transgenic \u00b7  the volume of information and time pressure made it impossible to examine the documentsprepared for the final conference and to formu-late adequate responses to the proposals made, \u00b7  the influence of the WZB working group was too strong and there were doubts as to the fair-ness and impartiality of the summary of re-sults. \"There is neither empirical evidence nor a theoretical model to show that transgenes could in- 10 duce more disturbances of the genomic context, discussed with them. It was pointed out inronmental groups then offered to continue touniversities and (albeit in fewer cases) fromparticular that the final conference was designedexplicitly to hear any criticism they might havewith respect to the substance of the resultspresented so far, and to allow for furthersubstantiation of dissenting opinions. The envi-governmental agencies.At this conference the conditions for the furtherof the final synthesis report be allocated to themDM 50,000 be made available to prepare thisparticipation of the environmental groups wereto present a dissenting opinion, and thatopinion. These conditions could not be metbecause the funds for the procedure had beenexhausted. The demands were subsequentlywithdrawn, and the environmental groups con-firmed their decision to leave the final confer-ence. Their positions were still represented in theconference, however, because these views werealso held by a number of participants from participate under the condition that roughly 20% or a different kind of disturbance, than transposable elements which move around in the plant genome naturally. The gene locus in which transposons are integrated, is not regulated by the plant. There is no controversy in science with respect to this finding.\" This conclusion settled the issue and the contro\"as far as we know today\". This proviso wasto everything we know.transgenes are comparable with respect to theaccepted by all, because it is evident and appliesimpact they might have on the genomic context.They merely pointed out that this finding is validassessment procedure. At the final conference,versy was put at rest within the technologyeven the critics admitted that transposons and 9  The closure of the  10 participatory procedure  When the final conference convened in June 1993, the representatives from the environmentalgroups and their associated research institutionstechnology assessment had failed, in their view,and they withdrew from the procedure. The mainreasons they gave for this action were that:declared that the participatory approach of the basis of participation by going ahead with the period of assessment (which could be years).stop developing or using the technology duringafford to participate if the condition were that itin the course of a (voluntary) technology assess-ment, a moratorium on the technology itgeneral, it would seem unrealistic to require that,and that they remain loyal to the procedure. Onapplications for the release of transgenic herbi-The argument that industry had undermined thecide-resistant crops is a serious one. A parti-cipatory technology assessment requires thatcooperation be stabilised and that participantsdevelop some kind of trust among themselvesthe other hand, given the divergent interests noexcessively high loyalty can be demanded,especially not with respect to the behaviour ofthe participants outside the procedure. Ininvestigates be upheld. No company could                                                    \u00b7  honorary involvement in the procedure took up too many of their resources,\u00b7  the industrial companies and scientists in9 See section II A5 below. Even the representatives from sions had been circulated, did not come back to theirthe \u00d6ko-Institut among whom the drafts of final conclu-original claim. They instead demanded a shift in theburden of proof: The assumption that the consequences(of transgenes an transposons) are different had beenclassified as speculation, \"although no 'proof\" againstthis hypothesis has been found\" (letter from March 16,1994 (see van den Daele 1994: 52). In the political debate context than transgenes-even with reference to the samesee Weber (1996).pressed by the arguments in the technology assessment,literature (Fedoroff); thus, they were completely unim-that transposons have different impacts on the genomicInstitute continued, however, to repeat the original claimoutside the technology assessment procedure the \u00d6ko10 See also Gill (1993).  Part I: Participatory Technology Assessment As A Political Experiment 17 The coordinating committee faced this problem a been decided by the coordinating committee very when it became known that one of theapplication would jeopardise the wholedinating committee was blocked by a veto. Thein our technology assessment felt that themodified sugar beet and a herbicide resistanceyear before the final conference took place,mit an application for field tests with geneticallygene as the marker. The majority of participantsprocedure, but a formal decision in the coor-participating industrial firms was going to sub-problem \"disappeared\" because the firm agreedto postpone their application until after the finalconference. Unfortunately the problem cameback because the final conference was postponedfor half a year. ambivalent feelings about being involved in aApparently, the environmental groups hadthey had not really accepted this rule as justified.opinion. With these procedural rules, \"the lastfinal synthesis report, were not admissible. Thethis issue in the negotiations over their with-fact that the environmental groups came back tosenting opinions, merely to be tacked on to theearly in the procedure that uncommented, dis-findings. On the other hand, it was probably thisprocedure in which they could not control thefurther analysis.very rule which ensured that all the participantsdrawal from the final conference showed thatbeen published. What this means for the conceptargumentation and resisted the temptation todowngrade the technology assessment from theoutset to just another public forum where all thegroups again just display their differences ofof participatory technology assessment requires\"outside\", after the final synthesis report hadFurther criticism could then only come fromcertain extent, reserved for the organisers.committed themselves fully to the dynamics ofword\" in the technology assessment was, to a 11 impartially.check whether the WZB working group and theor less predefined agenda. Those who prepare a The argument that the methodology applied bythe WZB working group in preparing the finalconference placed constraints on the autonomyof the participants is correct. The participantswere required to work their way through a moredraft conclusion have some power to define andselect. On the other hand, draft conclusions areindispensable in a meeting of fifty or morepersons if nonconclusiveness of the deliberationsis to be avoided. So the only way out, it seemed,was to prepare drafts and have the participantsorganisers had used their power justly and Some structural problems  11  of participatory technologyassessment It is certainly not enough to attribute the decithereafter. Written exchange was also the formsion of the material to be published from the The participants had the opportunity to criticisethe drafts submitted, and to revise or replacethem, both at the final conference and in writingtheir own opinions and evaluations together withThis rule entitled all the participants to publishthe results of the procedure. However, it hadcirculated among the participants. Commentar-technology assessment. All such drafts werebe included in the preparation of the final ver-by means of which the participants continued toies, unless incorporated, were also published. sion of the environmental groups to leave theassessment, as such, is a politically ambivalentto the historical, contingent circumstances of thisparticular procedure, that is, to the constellationof actors involved and to mistakes in the steeringof the procedure. Participatory technologystructure, the stability of which always remainstechnology assessment in the final phase solelyfollow.precarious. To this end a few final remarks                                                    dure, nor can they make it dependent on theirwill always have control over the entire proce-procedure does not mean that the opposing sidesParticipation in the technology assessment factual consensus. The participants have controlover the process but not over the results. 11   It should be mentioned that the environmental groups, coordinating committee again refused a formal verdict,in the technology assessment had been finalised. Thetoo, showed limits in their loyalty with the technologyassessment. They presented their version of the findingsof the assessment in a press release before the discussionsremarking only gatory strategies which aim to produce informa-tion. This sets them apart from purely politicalTechnology assessments are essentially investi-not conditioned by the acceptance of the partici-information produced in this kind of procedure isable development of society. The validity ofmarily over the goals and criteria for the desir-dialogues in which discussions take place pri-pants. In terms of social theory, the medium ofsocial integration in this case is not social but  \"that it neither wishes nor is it empowered to control  February 5, 1993).crops by participants in the procedure\" (Minutes ofpublic statements on transgenic herbicide-resistant  The majority of the coordinating committee merely the impression that the procedure had been terminated.criticised the fact that the statement to the press created  18 Herbicide-Resistant Crops cognitive. The participants are not really in a the procedure implies the readiness to submit granted or withheld. Consensus becomes irrefu-situation wherein consensus can be deliberatelysociety and what corresponds to generallyshared valuations cannot be deliberately dis-missed.table because what is viewed as knowledge in oneself on empirical issues to the judgement ofscience  13. Participation offers options to influence theresults proves nothing more than lack of consen-kind, but to examine the matter at hand bythe public not to rely solely on indicators of thisprocedure if it at least offers an opportunity foronly be expected of a technology assessmentincrease in rational conflict management canprocedure or the viability of the results. Anlarge as an indicator against the fairness of thesus. It may, of course, be taken by the public atfact that a group or party did not agree to thecannot be achieved the final judgement must beleft to neutral observers of the procedure. Theparties must have equal rights. Where consensustion are, in principle, symmetrical, i.e. theany case, because the conditions for participa-judgement on themselves. This is ruled out indoes not call on the conflicting parties to sit information of judgement in a procedure, but it themselves. 12 Discursive procedures trigger an argumentationit was organised as an on-going dialogue amongframe of argumentation is also used in publiccommunication, for example, in the media, whenopposing sides take up controversial positions.But the truth is that the parties seldom reallyargue. Recourse to proof and reason serves onlyIn our technology assessment, by contrast, sincethose present, argumentative debate is unavoid-controlled by any individual participant. Aable. The individual positions must be defendedagainst the on-going emergence of counter-predicted nor controlled.arguments. Whether a position proves to beto present one\"s own position more convincingly.dynamic which can neither be contained nor viable under these circumstances can neither be cal aim of a technology assessment. Political controversy would then be the only result. Thisremained controversial; the presentation of thewithout presenting results whenever an issuecontroversies about technology are the startingWZB working group and the organisers. Theto a certain extent was taken, in our case, by theoccupy the role of a neutral third instance, whichdure, the rule should be that no one is allowed toIt is doubtful whether, in a participatory proce-would be in contradiction to the declared politi-public has a right to efforts at least being made,point and subject of technology assessment. Thein procedures of this kind, to determine the stateof knowledge on controversial subjects. Atechnology assessment must give an answer tothe question whether risks that are publiclydecried actually exist, or whether the technologyis likely to provide the benefits claimed. Criti-cism of the methods through which the proce-dure arrives at conclusions must also be sub-mitted to the scrutiny of the general public.consequence would be that we would have to do the impression that empirical information doesopposing sides in the procedure continue to bea complete control of results through participa-tion. Despite this, the strategy of informationseeking remained undisputed to the end. Thereseems to be no alternative, because the publiccontroversy to which the technology assessmentrefers is a debate about empirical arguments,above all, a debate about the potential risks andexpected advantages of the technology. Thebound to the framing they have chosen for thecontested issues in the public debate. If they givethemselves from the discursive procedure, theyalso lose face in public. Anyone who indicatesthat he or she is not interested in arguments, butsimply in interests and power, can neither stakeclaim to participation in the technology assess-ment nor expect, through such participation, togain political profit for his or her own campaign.not really matter for them, they not only exclude Information orientation and discursivity preclude therefore, in arguments about the consequences In controversies about empirical questions, and,a technology might have and about what werecourse to science is compelling. One cannotpresent one\"s position in public as scientificallysubstantiated and then cast fundamental doubton science as a neutral third instance in a tech-nology assessment procedure. Participation inknow or do not know of such consequences,                                                     neutral instance of science. But even then, theorganisations or individuals could represent thedispute will prevail in society, concerning whatOf course, it is conceivable that a never-ending                                                    13   In our technology assessment, the validity of scientific findings was not an issue of debate. Nor was any roleplayed by the epistemological metatheories by means ofwhich sociologists sometimes play down scientific claimsto validity as \"social constructions\" and instead claim apluralism of social forms of knowledge which are mutu-ally incompatible but supposedly all equally valid. 12   Georg Simmel talks about \"intellect\" as the medium of social coordination; cf. details in D\u00f6bert (1994).  Part I: Participatory Technology Assessment As A Political Experiment 19 opposing sides could not demand that they   case, information and technology assessmentately. There would be no point in commissioningthemselves be given this responsibility. In thatwould no longer be credible at all as a means ofabout these interests.would be cheaper for it to inform itself directlyspective parties then, for the public at large, itexpert reports (not even by \"critical\" experts). Ifthe results only reflect the interests of the re-votes could and would have to be taken immedi-political interests, then only power counts, andthe name of science is in fact only presentingIf one really could argue that whoever speaks inideology would be politically dysfunctional, too.that the radical dismantling of science as anconflict resolution. However, it should be noted result. Whether participation is politicallypation the parties lend legitimacy to an attemptserving public (including parliaments, courts,uncertain outcome. From the angle of the ob-technology to cooperation in a procedure with anto withstand the demand for new discursive fora,A participatory technology assessment commits the parties of the political conflict over newor reject participation without ensuing politicalin which they control the process but not thecosts.attractive under these conditions will depend onhow high the normative expectation is thatconflicts will be dealt with in discursive form,i.e. in the form of argument. If these expecta-tions are high, conflicting parties will not be ableetc.) this is an advantage. Through their particiProcedural fairness is the essence of participa-tory technology assessment. If this principle isviolated then withdrawal from the procedure canbe expected and is legitimate. However, onecannot legitimately withdraw from a fair proce-dure simply because the emerging results con-tradict ones own strategic interests. Neverthe-less, in terms of \"Realpolitik\", withdrawal mustbe expected in such a case, too. 14 It must also be tory technology assessment will neverthelessdiscursive procedures is not a suitable form ofexpected that arguments refuted in a participa-political conflict resolution.continue to be used outside and after the tech-however, that, in principle, participation incriticised; it should not be taken as a proof,impress the public. Such inconsistency may benology assessment, as long as these can still                                                    14   And it can be a \"rational\" move in terms of calculation of political costs; see D\u00f6bert (1994), Holzinger (1996) for an explanation of why the environmental groups with-drew from the technology assessment before the finaldiscussion of the conclusions.    PART II: EMPIRICAL FINDINGS IMPACTS AND CONSEQUENCES  Throughout the technology assessment, empiri- alternatives, and cultural meaning of the techwith values, the participants in our technologyassessment treated questions of fact as categori-tions of value.sciences that facts are irresolvably confoundedassessing these consequences. Contrary to theclearly separate from normative questions abouttransgenic herbicide-resistant crops were keptcal questions about the possible consequences ofrelativist rhetoric often exposed in the socialcally distinct from and logically prior to ques- about new developments can easily crystallisenology, and into visions of the future develop-political regulation.into the established frameworks of restrictivethe criticism of new technology because they fitthe same time a powerful operationalisation ofeven beyond the political mandate of the modernprobably due to the fact that diffuse anxietiesaround risk scenarios, and that the latter are atprevailing tendency to concentrate discussionsstate. In public debates, however, there is ament of the society. In many respects, such anon the safety aspects of new technology. This isassessment will go beyond the existing law, or 15 Thus empirical questions such as:  Does a risk or a benefit exist? What can the consequences of classical breeding?quences of genetic engineering comparable toWhat is the causal mechanism? Are the conse-possibly happen? How likely is it to happen?  were such as: always distinguished from normative questionsIs the risk acceptable? Is the benefit crops preferable?appreciable and worth the risk? Who shall bearAre the alternatives to genetically engineeredthe burden of proof in the case of uncertainty? 16  Concerns about risks to human health and theenvironment also dominate the debate overreport of our technology assessment was, there-fore, commissioned from the \u00d6ko-Institut,Freiburg, which has been the most outspokenand articulated source of criticism of geneticengineering in Germany during the last decade.Thus it was guaranteed that the best availablecounter-arguments were placed on the agenda.Geneticists were invited to comment on thesearguments.transgenic herbicide-resistant plants. A main first. The starting point is the examination ofNormative questions involve moral and politicalpossible risks from the genetic modification ofcrop plants.tion. The following sections summarise the then be dealt with in their variety and contradic-differences of values and preferences, and mustcitizens. These questions may reflect legitimatejudgement, and are the domain of lay persons as(given the requisite knowledge) be possible.empirical findings of the technology assessmentexperts. Consensus on these questions mustswered scientifically and are a proper domain ofEmpirical questions can, in principle, be an17 Additional reports were commisassociated with the possibilitysioned to examine in detail the biosafety issues \u00b7  that unexpected and undesirable physiological changes (pleiotropic effects) occur in transgenicherbicide-resistant plants, \u00b7  that the transgene (and the trait of herbicide resistance) is propagated to unrelated organismszontal gene transfer,(such as soil bacteria or other plants) via hori\u00b7 that the transgene \"escapes\" from cultivation, BIOSAFETY ASPECTS OF  either in feral populations of the crop plantsthemselves or through hybridisation with wildrelatives. A  TRANSGENIC PLANTS                                                     The assessment of technology is not the regulation of technology and cannot, therefore, beimplication, namely, benefits and uses, availableconfined solely to issues of safety. It mustextend into broader issues of social and political 16   Cf. van den Daele (1993).                                                    17   Expert report commissioned from Dr. B. Weber (\u00d6kozidresistenten Pflanzen\";Institut, Freiburg): \"Evolutionsbiologische Argumente inder Risikodiskussion am Beispiel der transgenen herbi-  commentary by Dr. A. Heyer*, Prof. H. Saedler**  and  Prof. L. Willmitzer*  (*Max-Planck-Institut f\u00fcr molekulare Pflanze nphysiologie, Golm; **Max-Planck-Institut f\u00fcr Z\u00fcchtungsforschung, 15 K\u00f6ln), in: Materialien zur Technikfolgenabsch\u00e4tzung,    The reference to objective knowledge in the technology Heft 5 (see appendix). assessment by both advocates and critics of transgenicDaele (1996).herbicide-resistant crops is further analysed in van den   Part II: Empirical Findings-Impacts And Consequences 21  We summarise the conclusions from the discus- has perhaps never been part of our food) might was the question of whether there are specificin the WZB discussion paper series (see appen-questions.of conclusions for each topic around theseof the public debate. We organise the summaryraised questions which follow closely the themesThe discussions in the technology assessmentopments and findings are added in footnotes.dix). Some additional references to recent devel-assessment. At the heart of these discussionsmust refer the reader to the materials publishedbreeding. For the details of the expert reports wethrough techniques applied in conventional plantwhich would not occur were the crops modifiedrisks implied in genetically modified crops,sions among the participants in the technology induce allergies in some consumers. 20 In many transfer on the metabolism might in fact becases, therefore, the possible side-effects of genecompletely unpredictable. were discussed:which could lead to unintended physiologicalchanges in transgenic herbicide-resistant plantsIn the technology assessment, four mechanisms  1. Effects of the nonselective herbicide.   A plant. These substances may be toxic. They mayways.secondary metabolic processes in unforeseenalso interact with other substances and influencegates etc. of the herbicide are formed in themechanisms through which derivatives, conju-number of herbicide resistance genes transfer  Physiological side-effects and 2. Effects of the transgenic gene products.   The 1  ted in transgenic plants?genic substances to be expec-food safety: Are toxic or aller- resistance mechanism which is completely newsubstrates which are different from those in thebolic products.case the gene product will hit upon metabolicin the metabolism of the host species. In thisInteractions between this new product andabove all, be true when the transgene encodes asubstances which already exist in the plant canproduct into the metabolism of the host plant.herbicide resistance gene introduces a new geneonly be predicted to a limited extent. This will,substrates and form new and unexpected meta-donor organism. It could interact with such  Lines of consensus and dispute  Transgenic herbicide-resistant plants are supresistant. However, the gene transfer can haveunintended side-effects on the plant metabolism,posed to express the product (enzyme) of thetransferred herbicide resistance gene in thebe altered.metabolism of the plant cells. The intendedeffect is that the plant will become herbicide-through which other properties of the plant may 18 In some cases, it will be possible to  3. Effects of the locus of transgene insertion onthe expression of the transgene.  Gene transfer be tested whether the transgene inadvertentlymation on the transgene and its gene product,host organism. It can, for instance, be testedwhether proteins produced by the inserted trans-anticipate potential side-effects using the infor-gene are toxic or allergenic for humans. It canand on the properties of both the donor and thethe host organism.organism or enhances the allergenic potential oftransmits the allergenic potential of the donor effect). Variations in expression, and in par-expression of the gene product (positionaltechniques do not, as a rule, allow a site-specificlocus of insertion can therefore influence thepressed sites, but also at inactive ones. TheTransgenes may be inserted at frequently ex-integration of transgenes in the host genome.changes in the plant metabolism.ticular over-expression, could lead to unexpected 19 One can, however, only test for known allergies. There is no way to predictwhether a new protein from a donor organismwhich has no history as a known allergen (and 4. Effects of the locus of transgene insertion on                                                     the expression of endogenous plant genes.  The metabolism of the host plant can be affected bythe insertion of the transgene as such, independ-inserted into an active plant gene then this generesult, its gene product may not be produced atall or to a different degree. In addition, theregulation of neighbouring genes may also beent of the gene products. If the transgene iswill be interrupted (insertional mutation). As a 18   Expert report from Prof. B. B\u00f6ger (Lehrstuhl f\u00fcr                                                    versit\u00e4t Konstanz): \"M\u00f6gliche pflanzenphysiologischePflanzenphysiologie und Biochemie der Pflanzen, Uni-herbiziden\"; commentary by Prof. R. Weidhase, Halle, in:Pflanzen und durch den Kontakt mit Komplement\u00e4r-Ver\u00e4nderungen in herbizidresistenten und transgenen Materialien zur Technikfolgenabsch\u00e4tzung,  Heft 2  (see appendix). 19   Thus, tests revealed in a recent case that the transforsoybeans; Nordlee confer the known allergenic potential of the nuts to themation of soybeans with a transgene from paranut canet al. (1996). 20   Cf. Frank-Oberspach and Keller (1996: 55).  22 Herbicide-Resistant Crops influenced. 21 These variations in gene expression dealt with the comparability of side-effects in can also lead to unexpected and unforseeablechanges to the plant\"s metabolic pathways. likely in transgenic plants: nontarget or pleio-tropic effects of the transgenic gene product(change of substrates), instability of transgeneexpression, and effects of the insertion of trans-genes at the DNA level (positional effects andinsertional mutagenesis) (questions 2-4).general (question 1 below) and with threemechanisms why side-effects might be more below.regulation of herbicides, they will be discussedresistant plants are a standard problem in theSide-effects of herbicides on the metabolism of  22 Side-effects of the gene transfer play a transgenic plants. The following sections discusspossible environmental consequences.transfer which might affect the food safety ofThis section deals with impacts of the genecal starting point for a number of risk scenarios.from transgenic plants. They are the hypotheti-key role in many debates over the possible risks genic plants? Question 1: Can unintended physiologicalside-effects in transgenic herbicide-resistantplants lead to the formation of toxic or aller-genic substances? Are such side-effects morelikely to occur in transgenic than in nontranshave been shown to be toxic or allergenic.stances in the plants. In some cases, such effectspractice of breeding and have in many cases led The participants in the technology assessmentagreed that metabolic processes in plants are, ingeneral, quite variable. They vary with changingmodifications caused by breeding techniques.Pleiotropic effects through uncontrolled interac-tions in the plant metabolism are abundant in theenvironmental conditions and as a result ofto \"bad surprises\", e.g. unforeseen and unin-substances or new levels of expression of sub-tented morphological changes, yield losses, new Conclusions from the discussion  metabolism which may give rise to unexpectedsignificant (or which are carcinogenic, muta-stances may be formed which are toxicologicallyThis includes the possibility that plant sub-and unforeseeable phenotypic consequences.formation products, conjugates etc. of the non-enter complex interactions with the host cellselective herbicide. The new substances can1. In the case of transgenic herbicide-resistantplants, new substances are introduced into theplant metabolism: the gene product of the trans-genic or allergenic). ferred herbicide resistance genes and also (de-pending on the resistance mechanism) the trans23 That physiological side-effects are in fact a realproblem has been illustrated throughout thetechnology assessment with examples from thehistory of traditional breeding. Quite plausibly,therefore, the main controversy among theparticipants focused on the question, whetherthere was a special risk of unintended physio-logical changes in the case of transgenic plants.Should we expect more or more dramatic side-effects in the metabolism of transgenic plantsthan in the metabolism of plants modified byconventional breeding techniques? 2. Shifts in plant metabolism and new plant substances also occur as a result of conventionalbreeding or fluctuations in the plants\" naturalenvironment, such as climate variations orattacks by pests. In the latter case it has beenshown that new, humano-toxic plant substancesare induced. 24 Discussions from such transfers represent a specific riskfrom genetic engineering in the sense that with-they could have on the plant metabolism wouldrepresent specific risks, since the side-effectsmutagenesis or intergenera crossing) would alsotechniques of conventional breeding (such asout genetic engineering, the transfer would notbe possible and therefore the side-effects could3. It is plausible to assume that different tech- Side-effects on the plant metabolism resultingintroduced by conventional breeding techniques.distant, nonrelated species, which could not betial to transfer genes (and gene products) fromside-effects. Genetic engineering has the poten-niques to modify plants might have differentnot arise. In this sense, however, the various                                                                                                                               21   Effects of the locus of transgene insertion have been discussed in the technology assessment as \"disturbance ofthe genomic context\"; see also below section II A5. 22   Cf. section II B2. 23   For instance, hybrids between established potato varieties and related wild types have shown excessive121); the allergenic potential of apples became clinicallyvisible only after the breeding of new varieties in the1960s (Aulepp and Vieths, 1992). Frank-Oberspach andKeller (1996: 43\/51) refer to these examples.(toxic) concentrations of glycalcaloids (van Gelder 1991: 24   \"Conventional\" here refers to all methods of breeding between different species has been possible; mutagenesisrelated plants are mixed. In a number of cases crossingthrough which nearly identical genes (alleles) of closelythe crossing of individual plants of the same species,engineering. These methods include far more than merelycurrently used and accepted that do not involve genetic can be used to alter existing genes so that new gene products are formed.  that substances which are naturally formed in induced in transgenic plants.toxicity than substances which might be newlyplants are in general less problematic in terms of Part II: Empirical Findings-Impacts And Consequences  23 not occur if the techniques were not applied.  4. There is up to now no evidence that the technique of gene transfer can cause metabolictransferred. Whether the trait is transferredside-effects in transgenic plants, which are of anot seem to make a difference.through gene transfer or through breeding doeswhenever a problematic trait (or gene product) isWith either technique, risks must be expectedhave been created by conventional breeding.engineered plants applies equally to plants whichunexpected physiological changes in geneticallydevised to anticipate possible damage fromnontransgenic plants. Any scenario that has beendifferent type or quality than those occurring in  7.  Synergism.  There are some indications (aleffects in transgenic crop plants.plants, and not substances occurring as side-be harmless, as long as they remained integratedor metabolic interactions in conventional cropstances formed as a result of natural fluctuationsonly operate to neutralise problematic sub-plants. It is inconceivable that synergism shouldthe case it would also be true for transgenicin the metabolism of the plant. If this were reallyplant as a whole. These substances would thenbe neutralised by synergistic effects within thepotential found for isolated plant substances canthough disputed in science) that a mutagenic through conventional breeding:natural environment or from modificationsside-effects on the plant metabolism than are togenes might have more (or more undesirable)possibility that gene products encoded in trans-ber of reasons were offered to account for thetechnology assessment as a hypothesis. A num-specific physiological risks was defended in the5. The claim that transgenic plants involve be expected either from fluctuations of the domesticated plants we use for cultivation. It isance. Whether or not evolution theory is com-us here. It certainly cannot be assumed to existproducts induced by mutagenesis, transposonsthe reproduction of plant itself) need not concernconsumers of the plant and not of advantages forbe defined in terms of advantages for humanstances in natural plants (which after all wouldor additive lines are not toxic to humans.be particularly prone to jeopardising this bal-incomprehensible that there could be a naturalplant, and that the gene transfer technique maygism may depend on a \"balance\" within thetion of problematical substances through syner-8. The \u00d6ko-Institut argued that the neutralisa- patible with assuming such a \"balance\" of sub-combinations of plant substances with new genebalance in plants guaranteeing that, for example,for the combination of substances possible in the \u00b7  because of evolutionary adaptation (coevolution) plant substances that occur naturallyin food plants are likely to be nonharmful tohuman beings; \u00b7  the toxic\/mutagenic potential of natural subthe plant metabolism;stances is neutralised by synergistic effects in \u00b7  in conventional breeding, unexpected sidethe plant;effects are limited by regulatory cycles within \u00b7  since transgenes introduce gene products which were never in the plant metabolism be-fore, they will lead to more and qualitativelydifferent side-effects;  9.  Regulatory cycles.  It is plausible to assume \u00b7  the insertion of transgenes disturbs the geno- exclude the formation of new substances that dodo not fit the plant\"s own regulatory cycles.tory cycles of the species-although even then athat plants rely on regulatory cycles to limitfluctuations in their metabolic processes andpletely new substances may be produced whichin the case of mutagenesis, for example, com-cycles. The same, however, may also be true forproducts of conventional breeding. In the case ofcross-breeding between closely related plantswhich are almost identical, the metabolism willremain under the effective control of the regula-wide range of surprises are possible. However,not fit the species. Transgenes may escape these mic context of the host plant and will, therefore,induce more and different kinds of side-effects.  The last two points are dealt with in questions 2and 4 below. Consideration of the first threepoints yields the following: 6.   Co-evolution.  The reference to co-evolution evolution theory, there is no reason to assumeadaptation through co-evolution. On the basis ofof human beings and their food plants is unclear.Humans have adapted to their food plants byCo-evolution may help to explain why thehuman genome encodes basic metabolic mecha-nisms for detoxification and immune reactionwhich ensure that plants are edible. However,many plants still remain toxic for humans, andin these cases, by definition, there has been noselecting those plants which they found edible.  24 Herbicide-Resistant Crops Question 2: Is there a special risk of unex-  products in a quite uncontrolled manner, any of ism?the fact that gene products can be introducedmetabolic substrates than in the donor organ-the host plant and which might find otherwhich have never been in the metabolism ofpected side-effects in transgenic plants due to ways with existing metabolic processes. Incontrast, gene transfer only introduces a single,clearly defined gene product. It is nonethelessimpossible to say how these two factors weighagainst each other in the final analysis. We aredealing with side-effects which are conceivable,but undetermined and unforeseeable. For such,no quantitative estimate of the probabilitiesinvolved is possible.which has some chance to interact in unexpected Conclusions from the discussion  are more likely to occur in transgenic than in are transferred which are not naturally estab-10. In theory, unforeseen metabolic side-effectsnontransgenic plants, if new metabolic pathwaysfrom bacteria or plants. In either case, the geneinteract with new substrates.is unimportant whether the transgenes originateproduct can end up in a metabolic context whichis very different from the one in which it hadoperated in the donor organism, and it canlished in the host plant species. In this respect, it than in nontransgenic crop plants. Neither ofthese statements can be proved or disproved.pathways are transferred which have alreadyeffects can be expected in transgenic crops thanthat there will be fewer side-effects in transgenicnor less plausible than the converse hypothesis,with nontransgenic crop plants is neither morecal side-effects will occur with transgenic thanin nontransgenic crops in cases where metabolic14. In sum, the hypothesis that more physiologi-Theoretically, one can derive that fewer side- been established in the host plant species. 25 However, the potential of genetic engineering 11. This additional risk factor is absent whentransgenes confer metabolic pathways whichnot have been introduced by traditional breeding.ways which are new to the host plant and couldtherefore, quite often involve metabolic path-nonrelated organisms. Transgenic products will,lies exactly in the transfer of genes from distant,have already been established in the host plant. logical side-effects for transgenic crop plants? Question 3: Do instabilities in the expressionof transgenes entail specific risks of physioConclusions from the discussion  12. Chemical tests can, to a certain degree,control whether or not the transgenic geneproduct is likely to switch to new substrates.Substrate specificity  in vitro  does not, however,  15. Variations in the expression of genes are anormal phenomenon of plant metabolism. Theyare not a problem specific to transgenes, butoccur equally in nontransgenic plants and inresponse to fluctuations in the natural environ-attacks by pests.ment of the plant, such as climate changes or be found prove that unexpected substrates will in fact notin vivo , i.e. in the plant. Not all plant substances are known, nor would it be possibleto test for all of them in advance. plant gene is of just as little physiological andplants may be programmed to switch genes onutility, is already doubtful. The regulation iscertainly lacking for genes which have beenselected by breeding to optimise agriculturalfor crop plants with genes which have beentageous) to the plant. Whether the same holdsecologically useful (i.e. reproductively advan-factors in a way that is physiologically andand off in response to natural environmental expression by the plant itself can only be pre-mutation is confined to nonregulating sequences.transgenes alone. Full regulation of geneplant. However, this is not a problem ofby the normal regulatory mechanisms of theare certainly not in a meaningful way controlled16. Variations in the expression of transgenessupposed for wild plants, at the most. Suchbe subject to plant regulation, as long as themodified by mutagenesis. Such genes will stillHowever, the altered code area of a mutatedecological \"meaning\" to the plant (adaptive effects are theoretically more probable in non-probable in the case of transgenic plants, be- 13. A comparative assessment of the probabilityof physiological side-effects in transgenic andnontransgenic plants would actually have to takeinto account two countervailing factors: On thedifferent genes (alleles) and modified geneconventional breeding techniques reshuffle manytransgenic plants because (and insofar as)one hand, side-effects are theoretically morelished in the host plant. On the other hand, side-are introduced which have not yet been estab-cause (and insofar as) new metabolic pathways                                                    25   Regal (1994: 11) assumes that  pleiotropic expression may be enhanced when a 'foreign\" gene product from an enzyme and tRNAs are stronger when the moleculesunrelated species is transferred, because studies showed\"that certain types of molecular cross reactions betweencome from more distantly related species\".  and the plant metabolism is changed.  Part II: Empirical Findings-Impacts And Consequences 25 value in evolutionary terms) as a gene from a bacterium introduced by gene transfer. 21. However, positional effects and context   production of humano-toxic substances.17. Conversely, the fact that regulatory plantmechanisms operate does not indicate that therisk is smaller. Variations of gene expressionwhich are \"meaningful\" for the plant in evolu-tionary terms, may nevertheless induce meta-bolic changes which are not safe in terms of thehuman uses of the plant. The normal responsesof plants to external stress often involve the effects and context disturbances (e.g. fromtransposons) have been used by breeders as anotype of the plant. Occasionally positionalof new plant varieties.disturbances (insertional mutations) do not arisesource of genetic variation for the developmentoccur in conventional breeding, for example, inthe case of chromosome breaks and transloca-tions during meiosis. They can lead to unex-pected changes in the metabolism and the phe-solely as a result of gene transfer. They also plant\"s own genes, this would still not mean thatthere was an additional physiological risk.18. Even if it were shown that transgenic herbi- cide resistance genes are more frequentlytive herbicide is applied.switched off under stress conditions than thehappen is that the plant dies when the nonselec-be able to affect the plant metabolism. What willResistance genes which are switched off will not assessment. The \u00d6ko-Institut argued that due tothe \"special quality\" of genetic engineering,unexpected effects at the DNA level (distur-bances of the genomic context) should be differ-ent in transgenic and nontransgenic plants. Sincethis argument played a key role in the debate onboth food safety and environmental safety, itwill be considered in detail in section II A5below.This conclusion was contested in the technology  ylated PAT genes, can at the same time switchthey are more likely to induce unexpected meta-the gene on again. So, metabolic effects becomecysteine to thymine, which is possible for meth-subjected to selection pressure. The mutation ofon the plant metabolism and therefore are notfrequent, exactly because they have no impactnonexpressed (methylated) genes will be morebolic side-effects. Theoretically, mutations ofincreased mutation rate. This does not imply thatsequence of the mutated gene is known.glufosinate) that are switched off may have anstance, PAT genes in the case of resistance to19. Herbicide resistance transgenes (for in- possible; they can, however, be assessed if the  Horizontal gene transfer:  2 consequencesprobability and possible  Horizontal gene transfer means the transfer of the boundaries which have been establishedhowever, it should be a rare event, because ofSuch a transfer is possible in nature. As a rule,ent species which otherwise cannot be crossed.genetic material between organisms from differ-during evolution prohibiting the exchange ofgenetic material between noncrossing species.  which could lead to unexpected and unforsee-able changes in the plant metabolism? Arerepresent a disturbance of the genomic contextQuestion 4: Does the insertion of transgenesdisturbances of the genomic context a riskwhich is specific to transgenic plants? whether herbicide resistance genes from trans-Horizontal gene transfer seems to occur fre- conjugation), but only in a few cases has it beenquently between prokaryotes (mainly throughfrom transgenic plants.shown to operate across kingdoms of organisms,for example, from bacteria to plant or animalgenic crop plants could be spread to soil bacteriaor to other plants through horizontal gene trans-fer, and whether this represented a specific riskcells. Our technology assessment had to examine Conclusions from the discussion   20. Since the available gene transfer methods doformed at all, or not at required or normal levelsnot, as a rule, allow the gene locus to be tar-geted, at which the transgene is inserted, unfore-seen insertional effects at the DNA level are tobe expected. The locus of integration can influ-ence the expression of the transgene itself(positional effect), and the intermittence of thetransgene can alter the expression of plant genesat or near the locus of integration (insertionalmutagenesis, termed \"context disturbances\" bythe \u00d6ko-Institut). In both cases, the result couldbe that respective gene products are either not 26 Discussions concentrated on two questions: How probable is thehorizontal transfer of the herbicide resistance                                                    26   Expert  report  commissioned  from  Dr. I. Broer  and Prof. A. P\u00fchler (Institut f\u00fcr Genetik, Universit\u00e4t Biele-feld): \"Stabilit\u00e4t von HR-Genen in transgenen Pflanzenund ihr spontaner horizontaler Gentransfer auf andereOrganismen\"; commentary by Dr. B. Tappeser (\u00d6ko-Institut), in:  Materialien zur Technikfolgenabsch\u00e4tzung, Heft 3 (see appendix). See also Schl\u00fcter et al.  (1995), Sandermann et al. (1997).  26 nisms can just as well propagate endogenousHerbicide-Resistant Crops plants as an intermediary.directly between soil bacteria without transgeniccally modified; or they can propagate genesgenes from plants which have not been genetigenes? What effects could such a transfer have in a worst case scenario? from the donor organisms to other soil bacteriapropagated through horizontal transfer than Discussions of the first question were mainlyabout whether and under what conditions geneti-via transgenic plant cells.should be more likely than the indirect transfercally modified plant genes are more likely to bethose cases the direct transfer of such genesbacterial genes. The latter are considered as theThese included not only the transfer rates fortransfer rates served as a frame of reference.unmodified (endogenous) plant genes. Naturalresistance genes originate from soil bacteria. Inendogenous plant genes, but also those forappropriate reference in cases where herbicide tion. Transfer of these genes between soil bacte-attacked microorganisms in the course of evolu-tance genes have not, however, spread to theotics to attack other microorganisms. The resis-ria has only been observed under laboratorytance to antibiotics in the soil. A number of soilto account for the limited distribution of resis-conditions. (Transfer rates of the resistanceentiation of species, as we observe it, would notrare event in nature. Otherwise, the clear differ-2. Horizontal gene transfer will, in general, be a genes are also high under the special selectiveconditions of clinical applications of antibiotics.)bacteria have resistance genes producing antibi-exist. Low transfer rates must also be assumed produced at the same or greater levels (or with aeffects, since comparable effects can or will behigher probability) by common agriculturalpractice, such as the use of herbicides, plough-ing, or crop rotation.fact be counted as a significant cause of suchabout whether horizontal gene transfer should ineffects are possible. They disagreed, however,tions of the soil. Participants agreed that suchthe soil, and on the chemistry and hence func-on the biodiversity of microfloral populations inthe effects horizontal gene transfer might haveDiscussions of the second question focused on  3. The natural rate of gene transfer is unknown.It will, however, by no means be high enough to probably already been tested and selected for inresult from transgenes would be negligible,every possible environment. Whether naturalcannot be decided.warrant the assumption that every gene hasfurther increase of the transfer rate which mightgene transfer is frequent enough to say that any  resistance might be propagated through4. The probability that transgenes for herbicide   horiin the chemical and dynamic processes in thebacterial metabolism (and thus also to changes transfer of transgenes could lead to changes inThe counter-argument to this comparison wasother practices which also modify soil processes.soil) which were different to those caused bythat reason it was assumed that horizontalgenetic modification might also involve a specialquality of consequences of these techniques. Forthat the \"special quality\" of the techniques of zontal gene transfer depends on the informationof the transgene and the character of the geneconstruct. It must be assessed case by case foreach herbicide-resistant plant. to glyphosate induced by an glufosinate (phosphinothricine) and to resistancegenes. This applies, for example, to resistance toexpected than for natural (endogenous) plantzontal gene transfer to soil bacteria must beoperate in bacteria, then a higher rate of hori-and are coupled with promoters which alsowhich are homologous to bacterial sequences 5. When  transgenes  contain  major  sequencesathrobacter  gene. together with resistance genes isolated fromplants facilitate integration in the host genome.or bacterial sequences (e.g. T-DNA) transferredHerbicide resistance genes isolated from bacteriaPromoters which operate in bacteria lead to theexpression of the herbicide resistance genes andallow the selection of the transformed bacteriaunder the pressure of herbicide application. through horizontal gene transfer? Does suchtransfer represent a specific risk from trans-genic plants? Question 1: Is it to be expected that herbicideresistance genes will spread from transgeniccrop plants to bacteria and to other plants Conclusions from the discussion  (a) The probability of gene transfer to soil  microorganisms  1. Horizontal gene transfer is not a specific same mechanisms which operate for horizontalgene transfer in nature anyway. These mecha-transferred from transgenic crop plants by thegenes coding for herbicide resistance can only befeature of genetically modified plants. Trans-  6. On the other hand, even when herbicideresistance genes are isolated from bacteria, thetransfer rate for them is not likely to be higherthan for endogenous plant genes if they arecoupled to a promoter which is only effective in   Part II: Empirical Findings-Impacts And Consequences 27 plants. Such constructs are feasible. Nor are  cide resistance genes from transgenic plants?effects of a horizontal gene transfer of herbi-Question 2: What are the possible harmful to glyphosate resistance induced by genes fromdo not include bacterial sequences (this appliesmaize or petunia).increased transfer rates to be expected whenherbicide resistance genes isolated from plants  Conclusions from the discussion  (a) Possible harmful effects of a transfer to soil with such genes. This is, however, only the casebetween soil bacteria is much more probableisolated from soil bacteria then direct transfer7. When herbicide resistance genes have been if the herbicide resistance genes are from en-plants which have been genetically modifiedof our region.has not yet been demonstrated to exist in the soilthe gene for resistance to glufosinate (PAT gene)vated. For example, the bacteria which providedin the soil where the transgenic plants are culti-dogenous bacteria and, in fact, already aboundthan indirect transfer through the biomass from bacteria 11. Horizontal gene transfer to soil bacteria will  already arise with conventional agriculturalpast as representing any damage.lead to the selection of a new herbicide-resistantbacterial population, when the herbicide isapplied. If the emergence of this new populationis not, in itself, regarded as a harmful effect,then only further consequences of it could con-stitute a harm. So far, however, all the conse-quences which have been identified or proposedpractice, quite independent of the introduction oftransgenic crop plants. These consequences arenor have they necessarily been regarded in theneither specific to genetically modified plants, 8. No increase in the rate of horizontal genetransfer is to be expected with transgenes con-ferring resistance against herbicides whichspecifically attack metabolic pathways in plants (this applies, for example, to bromoxynil). Suchgenes, even if they are occasionally picked up bybacteria, could not offer any selective advantage. major changes in bacterial populations occur asas ploughing, fertilising, or crop rotation.a result of conventional farming practices suchformed, herbicide-resistant bacteria may bespontaneously resistant bacteria. In general,12. One consequence of the selection of trans-due to the bactericidal side-effects of the herbi-grow whenever herbicides are applied-eitheranyway. Herbicide-resistant populations willSuch fluctuations or shifts are quite commonpopulation dynamics of soil microorganisms.fluctuations or shifts in the composition and cides, or due to the unavoidable selection of may by itself increase the probability that theselective herbicides, the use of these herbicides than the rate of transfer from transgenic plants.9. Since there are numerous strains of soilHowever, the mechanisms involved in the natu-ral resistance are still largely unknown. Thus, itis unclear how frequently the resistance is basedon genes which can be passed on by transfer, orhow frequently it is due to mutations. It istherefore not possible to estimate whether or notthe rate of direct horizontal gene transfer fromnaturally resistant soil bacteria will be higherresistance is propagated to other soil bacteria.bacteria which carry natural resistance to nonsoil. The same situation can also arise if new mon plant variety is replaced by a new one.previously been grown in the area, or if a com-if a crop species is cultivated which had notchemicals are introduced for crop protection, ormetabolic substances not previously found in thein soil chemical processes due to the release ofherbicide-resistant bacteria can lead to changes13. The selection and growth of transformed, (b) The probability of gene transfer to other  plants  10. The horizontal transfer of herbicide resis- 14. It is conceivable that \"new\" metabolicproducts which are introduced to the soil bytransformed herbicide-resistant bacteria couldwould no doubt constitute a harmful effect.However, such an effect is also conceivable withany other technique which influences chemicalstances or changing the quantitative relations ofprocesses in the soil by introducing new sub-existing substances. It is much more probablethat soil functions would be disturbed by theimpact of herbicides directly, than by the impactof metabolic changes in bacteria expressingdisturb soil functions (e.g. soil respiration). Thisherbicide resistance genes which they picked up  which is relatively improbable, has an extremelytance genes from transgenic plants to otherplants is not impossible, but extremely unlikely.Theoretically, transgenes which are more likelyto be transferred to soil organisms than naturalplant genes are also more likely to be transferredback to other plants. However, the completechain of the implied transfer events, each oflow overall probability.  28 Herbicide-Resistant Crops from transgenic plants through horizontal trans-  Can feral populations of fer. 3  weeds or invade naturalcrops become obnoxioustransgenic herbicide-resistantecosystems? able way.possible to exclude with certainty that theywhich have up to now been brought in by knownagricultural techniques. In theory, it is conceiv-able that they therefore have different effectsthan the known techniques. Although it may notbe possible to describe these effects, nor toindicate a mechanism which explains how theycould lead to appreciable damage, it is also notoccur and could lead to damage in an unpredict-resistant plants will also involve some new formof harm. The transformed bacteria may bringmetabolic products into the soil which are 15. It is not possible to either confirm or refutethe idea that the \"new quality\" implied in bacte-ria which have been transformed through hori-zontal gene transfer from transgenic herbicide-\"new\" in a different way than the new qualities Feral populations are formed when crop plants  establish themselves outside their agriculturalor their genes \"escape\" from cultivation andcultivated areas or invade natural ecosystems.target sites. They may either become a weed in 28 therefore concentrated primarily on whether it isascribed a higher risk to escape because they arewhether the cultivation of transgenic plants canlegitimately be compared with the introductionof nonindigenous species. Such species are oftenreleased from the natural ecological controls ofplants produced by conventional breedingthe areas in which they have originally evolved.Critics of genetic engineering use the \"exoticspecies model\" to justify their assumption thattransgenic plants pose a higher risk as well.will more easily lead to feral populations thanreasonable to assume that transgenic crop plantsway). Discussions in the technology assessmentnontransgenic crops alike (in exactly the samespecies-do, however, apply to transgenic andmainly hybridisation with related weeds or wildmechanisms through which this may happen-cultivation and form feral populations. Theto be expected that crop plants can escape fromthe technology assessment that it is, in principle,There was agreement among the participants of methods. In this connection it was also examined 27  (b) Possible harmful effects of a transfer to other plants 16. In agricultural habitats horizontal transfer of  resistant mutants. Horizontal gene transferapplied, due to the selection of spontaneouslyherbicide resistance genes to weed plants couldemerge when the same herbicide is continuouslybetween plants, on the other hand, is extremelylead to the formation of new herbicide-resistantpossible source of resistant weeds.unlikely; it will, therefore, not be significant as aare a common risk anyway; they are likely toweeds when selective pressure through thethe effectiveness of the nonselective herbiciderespective herbicide is exerted. Consequently,would be diminished. However, resistant weeds as (herbicide-resistant) weeds. This would Another line of discussion considered the possi-ble consequences of feral populations fromagreed that they could invade agricultural sitesagement and possibly result in financial loss toaggravate the technical problems of weed man-the farmers. Doubts were raised, however, aboutwhether herbicide-resistant plants would actu-impair natural ecosystems. For the annual andbiennial crop plants discussed in this technologyassessment (in particular, sugar beet, potato,maize, and oilseed rape) such damage scenariosally be able to invade natural communities andtransgenic herbicide-resistant crops. It was                                                     herbicide resistance genes to a wild plant ge-nome would (under optimal conditions) give riseto nothing more than a single transformed herbi-cide-resistant plant within the wild population. Itcannot be assumed that this plant could possiblyoutcompete its untransformed rivals in a naturalhabitat (i.e. without the selective pressure fromherbicide applications) and become the origin ofa new population.17. In natural habitats horizontal transfer of                                                    28   Expert report commissioned from Prof. H. Sukopp and von Kulturpflanzen\"U. Sukopp (Institut f\u00fcr \u00d6kologie, Technische Universit\u00e4tBerlin): \"\u00d6kologische Langzeiteffekte der Verwilderung; commentary by Prof. H. Scholz (Botanischer Garten, Berlin), in:  Materialien zur Tech27 nikfolgenabsch\u00e4tzung,  Heft 4 (see appendix). Cf. also  Whether assumptions of hypothetical risk warrant Molecular Ecology) (1994), Ammann Sukopp and Sukopp (1993); Symposium (special issue ofet al. (1996), Keller retically refuted, was a major point in the normativediscussions of the technology assessment, see section IIIregulation, if they can neither be substantiated or theo-C7 below. et al. (1996).   Part II: Empirical Findings-Impacts And Consequences 29 were not regarded as realistic by most partici- vant whether herbicide resistance has been pants. The situation might be different, if com-petitive crops with a wide ecological range wereconsidered (particularly woody perennials), or ifproperties were transferred which increasefitness (such as virus resistance) and give theplant a competitive advantage. acquired through conventional breeding, geneticengineering, or natural processes (mutations). transgenic plant into an organism which ismay have been transferred, does not turn theorganisms other than plants (e.g. from bacteria)the transgenic variant. The fact that genes fromwhere it is grown, then the same also applies forgenes. If the initial plant is native to the areaconsider transgenic crops as \"exotic species\".from the initial nontransgenic variety by a few4. A genetically engineered crop only differs Plants do not evade the ecological controlsnonnative in ecological terms. It is a mistake toare genetically engineered.which have evolved with them just because they than with conventional plants.engineered plant. Therefore, at least the uncer-also influence the ecological behaviour of themodification will have side-effects which mightassumption by pointing out that the geneticconventionally bred plants. They justify thisecological impact than feral populations fromprinciple be expected to have a more seriouspopulations from transgenic crop plants must inOther participants, however, insisted that feral tainty about its consequences must be greater lack suitable partners for cross-fertilisation in5. Data collected on the introduction and estab-than nontransgenics. Nonnative crops may nottheir new environment.lishment of nonnative species can be used toinfer quantitative statements about how likely itis in general that cultivated plants form feralpopulations and that these will have undesirableecological effects. Such use of the so-called\"exotic species model\" will, however, yieldstatements which apply equally for transgenicand nontransgenic crops. If a reference case isgenic crop plant, then the only correct compari-son is with the nontransgenic variety from whichthat plant has been derived. Moreover, even ifthe comparison of transgenics with exotic spe-cies is conceded, it does not necessarily supportthe conclusion that transgenics pose higher risksneeded to assess the risks of a specific trans- be riskier than native ones since they frequently  Question 1: Are transgenic crops more likelyto escape from cultivation and form feralpopulations than conventionally bred crops?  Conclusions from the discussion cultivated plants (i.e. plants which have acquiredor propagate their genes through hybridisation toplants may themselves escape from cultivationof breeding) can form feral populations; the genetically fixed domestication traits as a result1. Generally speaking, it is to be expected thatclosely-related wild species. 29 2. The probability that a feral population will beusually spread spontaneously without restric-highly domesticated crop plants for whichcrossing partners exist in the wild flora ofCentral Europe. In addition, breeders also useless highly domesticated and even wild plants.escape from cultivation and form a feral popu-used as crops in agriculture just as they are) canlation varies considerably and must be assessedtions. Therefore, the risk that a new crop couldon a case-to-case basis.Facultative cultigens (i.e. wild plants which arein the area where it is grown. These conditionsare not, however, met in the case of every cropformed is low if the cultivated plant is highlydomesticated and has no wild or weed relatives plant in Central Europe. There are a number of ing, can lead to unexpected and unwantedity that the plant (or its genes) become estab-crop in question, and thus increase the probabil-possibly also increase the ecological range of thecounter the breeder\"s plan. Such changes could 6. Any form of developing a new crop variety,be it conventional breeding or genetic engineer-changes in the phenotype of the plant, which runlished in feral populations. Such changes arenot, however, a specific risk of transgenicplants.  3. The ecological behaviour of a plant has to bejudged on the basis of its phenotype. When itcomes to the question whether a crop which ispopulations than a nonresistant crop, it is irrele-herbicide-resistant is more likely to form feral plants which have been genetically engineeredwhich have been conventionally bred; or that 7. The claim made in the report of the \u00d6ko-are susceptible to more and wider-rangingno supporting evidence. Thus it is assumed thatbased on hypotheses for which there are as yetferal populations than nontransgenic crops, ismore likely to escape from cultivation and formInstitut, that transgenic crops are in generalunexpected phenotypic changes than plants                                                    29   The plant may also escape (without gene flow) by next crop.surviving over winter and appearing as a volunteer in the  30 Herbicide-Resistant Crops transgenic crops are more likely to undergo Question 2: Must we expect changes of natuevolution towards increased fitness. To justifythese assumptions reference is made to the\"special quality\" of genetic engineering (in par-ticular to disturbances of the genomic contextand positional effects). This justification isquality\" of genetic engineering cannot in fact besubstantiated.invalid, however, if the postulated \"special from cultivation?cide-resistant plants (or their genes) escaperal ecosystems in case that transgenic herbiConclusions from the discussion  is the development of crop-weed complexes.on farmers (e.g. in terms of lower yields).in land management and inflict financial lossestrial sites). As weeds they can lead to problemsactivity (such as roadsides, wasteland, or indus-ecosystems which are highly disturbed by humantats (fields, pasture) as weeds or spread toFeral crop plants can invade agricultural habi-tion and become established in feral populationscrop plants (or their genes) escape from cultiva-9. The most common effect to be observed when  30 8. For the case-to-case examination of the riskstechnology assessment, the following conclu-which may be associated with the herbicide-resistant transgenic crops discussed in this sions can be drawn: \u00b7  For the cases of herbicide-resistant maize and potatoes, the risk that the plants (or their genes)Central European flora.escape from cultivation in Central Europe canbe practically excluded. Both crops are highlydomesticated, and there are no related specieswith which they could cross-fertilise among the  10. As far as the annual and biennial crop plantstive herbicide is applied. So even if the transgeneis dispersed to related wild species it would notenhance the ability of these species to invadenatural ecosystems.case of transgenic herbicide-resistant crophybrid forms of beets in coastal areas. In theAn exception to this is constituted by somenontransgenics) have been observed up to now.considered in this technology assessment areconcerned, no effects on natural ecosystemsplants, the transgene would not have any selec-resulting from invasions by feral populations (oftive advantage outside areas where the respec\u00b7 In the case of herbicide-resistant sugar beet, improbable.coast, the development of feral populations isthe risks depend on where the beets are grown.In coastal areas hybridisation with wild beet ispossible and has to be expected. Away from the \u00b7  In the case of herbicide-resistant oilseed rape, there is a clear risk that the herbicide resistanceis propagated. Spontaneous crossing occursbetween a number of related cultivated species( Brassica napus ,  Brassica rapa , and  Brassica juncea ). Geneflow to closely related wild species is likely (in particular to  Brassica nigra  and 32 Sinapis   arvensis ).  way to predict what the possible consequencesthey necessarily involve fitness costs. Thereforesome genes for herbicide resistance may becomeestablished in wild populations. This would,however, also be the case if herbicide resistancethat has been acquired naturally (throughmutation) or through conventional breeding washave been transmitted to a wild population11. On the other hand, it can also not beof such genes in a long-term evolutionaryperspective could be; any statement in thisrespect would be purely speculative.again from the gene pool of this population. Thecrossed out to related wild plants. There is nothrough hybridisation will definitely disappearassumed that herbicide resistance genes whichtransgenes do not increase fitness, but neither do  To date, research in ecological risk assessment seems to support the view that transgenic cropsdo not pose specific risks; they are not morelikely to develop into feral populations solelybecause they have been genetically engineered.However, the results of this research may still beconsidered inconclusive, since the experimentshave only been in progress for a few years.                                                    31                                                    30   See section II A5 below. 31   Mikkelsen  et al.  (1996) found hybrids of transgenic oilseed rape and weedy  Brassica campestris; see also Jorgensen et al . (1996).   The question is, how often do 32 of particular transgenes can be assessed (1994: 35).establish baseline data against which the possible impacthybrids with wild relatives occur with nontransgenic rapevarieties? Dale emphasises the need to investigate this to    There may be some open questions as to whether the transfer of herbicide resistance could at the same timeincrease the resistance of the host plant to draught(Sandermann 1997: 215) or to cold (IHE 1994: 46).   Part II: Empirical Findings-Impacts And Consequences 31 Evolutionary aspects: Can  to claims made in the report by the \u00d6ko-Institut,  4 Will they obstruct existingcourse of natural evolution?transgenic plants change thedifferentiation of species? that genetic engineering could destroy naturaldistinctions between species.but rather to speculation in the public discourse natural communities in the distant future? Iswill influence the evolution of species andit possible to distinguish effects transgenicplants might have from effects nontransgenicplants might have?of transgenic herbicide-resistant crop plantsQuestion 1: Should we expect that the release   The \u00d6ko-Institut claims \" evolutionary risks\" assuming that a massive release of transgenic tive effects on the biodiversity of natural speciesgenes to wild species, this amounts to afor such effects is held to be the spread of trans-centuries or even millennia. The key mechanismand communities in the very long term, i.e. overherbicide-resistant crop plants could have negaConclusions from the discussion  \"change of the parameters for future spe-  of ecosystems are all conceivable and cannot, inany case, be excluded with certainty. Sucheffects are also conceivable, however, when newplants are introduced which have been modifiedusing traditional breeding techniques.genic herbicide-resistant plants could possibly 1. The effects which the introduction of trans-plants and other organisms, and in the structureunpredictable and indeterminate. The formationof new species, changes in the composition ofhave on evolutionary processes in the future areplant communities, in the interaction between cies formation.\" 33  On the other hand evolutionary risks are linked achieved through natural evolution up to now.transgenic plant and a de-differentiation of thespecies: The transfer of bacterial genes to plants,for example, is seen as involving both a de-differentiation of the genome organisation of thethe structure or diversity which has beenexisting species. The term \"de-differentiation\" ismeant to indicate a retrograde step or a loss inis involved in gene transfer between distantentiation\" which, according to the \u00d6ko-Institut,in various ways with a process of \"de-differ2. It is questionable whether the chance that theintroduction of new crop plants in agriculturemight lead to the formation of new species in nature in the long run can be considered a\"risk\". In any event, such a \"risk\" would not bespecific to transgenic plants. As yet, there is noreason to assume that, in general, geneticallyquickly induce evolutionary processes of speciesformation than conventional crops. There is alsono reason to suppose that the evolution of a newspecies derived from transgenic crop plants ismore likely to reduce biodiversity or disrupt theorganisation of ecosystems than the evolution ofa new species derived from nontransgenic crops.engineered plants could more easily or more 34 some of the participants as completely futile. In described or predicted in any way. Therefore,statements about such effects were regarded byspecies formation should actually be counted asdamage.The concept of \"evolutionary risk\" is notpossible influences on future processes ofaddition, it remained unclear as to what extentevolution in the distant future cannot betransgenic crop plants might have on naturalassessment. It was agreed that the effectsclearly remained a moot point in the technologycommon. Whether or not it can be defined 35 3. Certain indicators for assessing possibleevolutionary consequences of new crop plantscan be inferred from the traits added to such  plants, which would eventually escape to wildble consequences from herbicide-resistant plantsexample) then the effects could conceivably bepopulations. In accordance with this, the possi-should be negligible, since herbicide resistance isgreater, since such traits do represent a selectiveadvantage.or freezing, or improved photosynthesis, foradaptive traits are added (resistance to draughtadvantage in natural habitats. If, however, novelnot an adaptive trait and provides no selective Another point of discussion was whether gene Discussions in the technology assessment con-centrated on whether it is at all possible to find adifference between transgenic and nontransgenicplants with respect to the effects such plantscould conceivably have on natural evolution.natural evolution. This discussion did not refertransfer between distant gene pools could triggerthe evolution of new species which would breakthrough the reproductive barriers established by                                                    33   Weber (1994: 29\/51\/103). Materialien zur Technikfolgenabsch\u00e4tzung, Heft 5 (see appendix). 34   Weber (1994: 33\/36).  4. This assessment holds irrespective of whethersuch novel traits are conferred through genetic 35   Cf. section III A2 below.  32 mainly by changing the environmental condi-Herbicide-Resistant Crops tions, in particular by extending anthropogenicral ecosystems.locations, and by exploiting and polluting natuengineering or conventional breeding. The only constitute a problem which is specific to trans-cases, only be possible through genetic engi-transgenes but also endogenous plant genes andspecies, and this mechanism propagates not onlyneering. Evolutionary consequences which mightto wild species. ) It is, on the other hand, truethat phenotypes with novel traits transferredfrom nonrelated, distant species will, in manynot relevant for the gene flow from crop plantscultivation is cross-breeding with related wildbe associated with such phenotypes would thenmechanism for the escape of such traits fromgenic plants. But even here, the fact that aphenotype is based on genetic engineering doesnot, as such, imply that the phenotype is danger-ous in ecological or evolutionary terms. A case-by-case assessment is necessary.the respective traits. (Horizontal gene transfer is species?between species and produce mixtures ofreleases of genetically engineered organismsQuestion 2: Is it conceivable that large-scale cancel naturally evolved differentiation  Conclusions form the discussion this may be called, appropriately, \"de-used in a purely descriptive way, characterising engineered into the genome of transgenic plants,differentiation\". In this case, the term would be8. When genes from widely different species arethe gene transfer as such, but not indicating anydescription would then also apply to certaincrops that resulted from conventional breeding,for example, inter genera hybrids like triticale (acombination of rye and wheat).problem or loss associated with the transfer. The cies. It does not make sense to assume that everylong-term ecological impacts of invasions ofthe survival of humanity is mere speculation.probably limited. Taking as a comparison thecrop plants into natural habitats, what couldhappen is that undesirable, \"weed-like\" feralpopulations could be formed, which couldjeopardise certain human uses of ecosystemfunctions, or could conflict with the goals ofspectrum of species. The idea that the spread oftransgenics could lead in the long run to a disor-nature conservation by changing the regionalcase, the suspicion that transgenic species are, infounded. On the basis of our current knowledge,general, more likely to give rise to ecologicalthe potential damage new species can cause isdisruptions than nontransgenic species is un-5. The evolution of new species will have someinfluence on existing natural communities; theeffect will depend on the phenotype of the spe- change which might be induced in a communitynecessarily represents a \"disruption\". In anyganisation of ecosystems which would threaten  9. However, the term \"de-differentiation\" is notappropriate if it is used to convey that a problemis implied in genetic engineering, namely the lossSuch loss cannot be demonstrated, either at thelevel of the plant genome or at the level of thecommunity of species.of structure or diversity due to gene transfer. genetic pool of the host plant population isexpanded; genetic diversity (variation) within theevolutionary biology, but rather, a gain. Thesent a structural loss from the point of view ofof transgenes from other species does not repre-10. At the level of the plant genome the inclusion species increases. uted to their genome: it is added to them. On theeffect is an increases in biodiversity.tutes a gain in structure; its direct and primarylevel of the community the new species consti- 11. At the level of the species community thereof the spectrum of species. A new species doestute de-differentiation, but rather, differentiationthe species. Nevertheless, this would not consti-excluded due to the reproductive separation ofpossibly display combinations of traits hithertoIf such species were to originate, they wouldnew (transgenic or nontransgenic) plant species.transgenic plants might initiate the evolution ofis a purely theoretical chance that the release ofnot replace the original species which contribmatter.evolution in natural habitats is quite another6. The statement that genetic engineering\"accelerates\" evolution is confused. What isactually accelerated is the breeding process, i.e.the construction of crop plants adapted to andgrown on agricultural land. Here genetic engi-neering makes combinations feasible whichcould not be achieved (or not as quickly) byconventional methods. Whether the possibleimpacts of these plants (or of their genes) onwild populations would actually \"accelerate\"  36 7. Theoretically, every increase in genetic vari- ability and every change in selective conditionscan trigger evolutionary changes. In this sense,human activities \"accelerate\" natural evolution                                                    36   It is quite another question whether the introduction of herbicide-resistant crops could lead to a loss of biodiver-sity in agricultural habitats, see section II C1 below.  which warrants the hypothesis that they might involve specific risks which do not occur whenbreeding techniques.organisms are modified through traditional Part II: Empirical Findings-Impacts And Consequences  33 12. The transfer of genes between different  species. A transgenic potato with a herbicidethough such fears have played a role in therium or petunia.species does not lead to the disappearance ofwill evidently continue to be a potato, and not aresistance gene from a bacterium or a petunianatural differences between these species. Al-\"intermediate\" species between the originaland the transgenic does not become ancommunity between donor and host organism,does not, however, create an interbreedingties (producing joint offspring). Gene transferSpecies are defined as interbreeding communi-might involve, they are without basis in science.public framing of the risks genetic engineeringspecies half-way between a potato and a bacterisks by comparison.among the participants tended to \"normalise\"the risks of nontransgenic plants. Deliberationsdistinguish the risks of transgenic plants fromsion seemed inevitable that it is not possible torepeatedly ended up at a point where the conclu-Risk debates in our technology assessment  37 Against this tendency the constitute a difference on the molecular level\"special quality\" of genetic engineering wasbrought forward: Disturbances of the genomiccontext and the possibility of positional effectsbetween genetically engineered and convention-justify the assumption that the possible conse-quences of gene transfer are (in the words of arepresentative from the \u00d6ko-Institut)ally bred plants. Such differences therefore this scenario for transgenic plants, then it must13. Transgenic plants which could be crossedconventional breeding in which new varieties areproduced by crossing related species.outcompete them on a large scale. If one acceptsassumption: namely, that this new form is fitterthan the two original species and is able to only conceivable in the case of gene transferTheoretically, in this case, an evolution might bebetween relatively closely related plant species.with both the donor and the host organism arepossible during which the two originallyseparated species converge into a new \"inter-mediate\" form. This would, however, only bepossible, if one makes a further (improbable)also be accepted as valid for the products of  \"fundamentally different to what can happen with a nontransgenic plant.\" 38  In particular, the \u00d6ko-Institut referred to the following cases:\"special quality\" of genetic engineering tojustify the assumption of increased risks in the \u00b7 because of context disturbances and positional effects the genetic engineering of plants mightinvolve more and different side-effects on theplant metabolism than are known from thehistory of conventional plant breeding; \u00b7 because of context disturbances and positional  processes which end up in species mixtures andengineering can transfer genes between species14. In contrast to conventional breeding, geneticthat they will somehow converge. Therefore, thefurther genetic engineering moves beyond thewhich are widely different in evolutionary terms.there to fear that it could trigger evolutionarya loss of differentiation in the species spectrum.However, the greater the evolutionary distancelimits of traditional breeding, the less reason isbetween the species, the lower the probability effects horizontal transfer of transgenes fromwhich also severely affect soil may not be le-comparison, therefore, to agricultural practicesserious and unexpected effects on the soil; theplants to soil bacteria might have particularlygitimate; \u00b7 because of context disturbances and positional effects transgenic crop plants might inadver-natural ecosystems as weeds.tently achieve increased ecological fitness, thusenhancing their ability to invade agricultural or \" of  There was agreement in the technology assess-ment that context disturbances (insertional  The \"special quality                                                     5 genetic engineering The strategic uses of \"context distur-  37   See sections III B1-2 below. bances \" and \"positional effects \" 38   Alternatively, the hypothesis that genetic engineering engineering in the report by the \u00d6ko-Institut anda prominent role in the criticism of genetichost organism and cause positional effects playswill disrupt or disturb genomic contexts in theThe argument that the insertion of transgenes in the German discussion in general. It is seen asproof that the techniques of genetic engineeringdo indeed represent a novel or special quality the fact that genes from distant, nonrelated species can bemore severe side-effects must be expected with trans-genic plants than with conventional plants.transferred which may inadvertently change the plantmetabolism (see section II A1 above). According to thisargument the constitutive difference is on the level ofgene products, rather than on the level of molecularstructure of the genome. However, both lines of argumentconverge in the conclusion that, because of the difference,involves unique risks has been justified by reference to  34 Herbicide-Resistant Crops mutations) and positional effects do occur. the context of the plant genome. The possibility the gene in the donor organism. To some extentcontext that matters!\" is also true.host plant. In this sense, the statement \"It is thethese effects also depend on where and how thetransgene becomes inserted in the genome of thecoded in the transgene, nor from the function ofcompletely from the information which is en-transfer on the host organism cannot be derivedindeed be qualified. The possible effects of geneunderlying common safety regulations, mustters!\" which is part of the basic philosophyThus, the statement, \"It is the gene that mat- of side-effects from such rearrangements is notspecific to transgenic plants and thus is notsufficient to establish the \"special quality\" ofgenetic engineering. 2. In the case of fusion proteins gene transferthe transcriptional frame of a neighbouring plantof genetic variation.inserted) really matters. But again, fusion pro-mic context (where and how a transgene isteins seem to be a good example that the geno-fer; they can also result from conventionalgene; then the transgene and the plant gene canintegrated and its loose end happens to fall intobreaks, translocations or mutagenesis as sourcesformed when the transgene is incompletelycoded in the transgene. Fusion proteins areleads to a new gene product which is not en-together form a new gene product. Fusion pro- breeding processes which use chromosometeins are nothing which is specific to gene trans39 There was, proteins being an exception).however, agreement in the technology assess-ment that the effects of changes in the genomiccontext are quite limited. They can influencelevels of gene expression, but they cannotchange the type of gene product which is addedto the host organism (the possibility of fusion way specific to genetic engineering and trans-ment concerned the question whether contextthe test of whether genetic engineering is reallynew.discussion of the functional consequences ofdebate of these questions in a way repeated the Extensive discussions in the technology assess-disturbances and positional effects are in anywhich take place in all plants anyhow? Thegene transfer. In both cases comparison withgenic plants. Do they also occur in conventionalplant breeding? What is the difference withnatural recombination events, for example theinsertion of mobile DNA elements (transposons),conventional breeding and natural processes wassame arguments which had already ensued in 3. The hypothesis that changes in the genomictransgenes than by modification through breed-to be expected in the construction of transgenictioning of plants. It remains an open questiondifferent and hence have different consequencesthan changes which may be caused by conven-tional breeding techniques requires substantia-tion if it is to be more than mere speculation.The \u00d6ko-Institut has argued that there might bea \"gene balance\" in the plant genome which ismore likely to be disturbed by the insertion ofcontext by the insertion of transgenes could be ing techniques. It gives, however, no reason whypatible with transgenes than with the variouschanges breeding can imply. The very fact thatgenetic engineering of plants is possible andsuccessful seems rather to suggest that theintegration of transgenes is compatible with thebalance of plant genomes and the proper func-whether more failures and nonviable variants aresuch a balance, if it exists, should be less com-plants than in conventional breeding.  Question 1: Are disturbances in the genomiccontext caused by the insertion of transgenes(insertional mutations) comparable to distur-bances which may occur, when plant genomesare modified through conventional breedingmethods?  Conclusions from the discussion pected differences definitely do not exist or toclaim negatively that there are no differencesbetween context effects in transgenic and non-transgenic plants. All what we can say is that nosuch differences can be recognised. Whateverwe claim is valid only relative to the state of ourcurrent knowledge, and no level of knowledgewill be sufficient either to prove that the sus-exclude their possibility with certainty. Thisdoes not, of course, mean that we could just as4. Strictly speaking, it is also unwarranted toences-for example by comparing the effects ofwell stop the systematic search for such differ-transgenes and transposons on the genomic context at identical gene locations (if the respecpractices, such as intergenera crosses or chemi-cal mutagenesis, also imply rearrangements induring meiosis, and conventional breedingral processes, e.g. chromosomal translocationsthrough genetic engineering. A number of natu-only occur when new genes are transferred1. Disturbances in the genomic context do not                                                     39   The term \"context\" refers to the molecular level of the appropriate \"safety philosophy\" cf. section III B4 below.strated by pleiotropic effects. For the controversy over thegenome in this section. It may also refer to the level of thegene product. The latter context, too matters as is demon-   Part II: Empirical Findings-Impacts And Consequences 35 frequently and spontaneously move out of the place to which they jump. If the frequency ofinsertions indicates the amount of side-effectsbeen, but they also induce further changes in thebehind changes in the place where they haveble. Transposons which move out not only leaveeffects on the genome organisation are negligi-position is reversible. This does not mean that itsgene locus into which they have jumped. Trans-involved, then more side-effects have to beexpected from a transposon than from a trans-gene. tive experiments become feasible). Question 2: Can changes in the genomic  context which are caused by the insertion oftransgenes be distinguished from changescaused by the insertion of transposons fromthe plant?  Conclusions from the discussion cases.of genes on the chromosome is altered in both 5. Both transposons and transgenes interferewith the existing genomic context; the sequence rable lies in what determines the locus of inser-tion. Genetic engineering cannot yet control thethere is no controversy in science over this fact.This is the current state of our knowledge, andtion. Transposons are also inserted at random.There is, however, no evidence for such regula-then transpositions would indeed be different.are inserted were regulated by the plant itself,transgenes and through transposons are compa-gene is transferred. Transgenes are inserted atexact locus on the host genome to which a newrandom. If the gene locus at which transposons9. The real test whether context changes through  plant itself.and the regulation of the insertion site by thecontext: the reversibility of transposon insertionInstitut; only two of them relate to the genomicand transposons have been claimed by the \u00d6ko-context. Various differences between transgenesmust relate to the rearrangement of the genomictransgenes and transposons. The differencessufficient merely to cite any differences betweeneffects from transgenes and transposons, it is not6. To challenge the comparability of context  7. The following differences have no relation topossible changes in the genomic context:  transgenes.such deviances from random distribution couldfor the insertion of transposons than others, thenregulatory programme of the plant itself. And,Nevertheless, it would not be controlled by awould not, in fact, be completely at random.the distribution of transposons over the genomethat the insertion of transposons is regulated bycertain sites on the genome lend themselves morea misinterpretation to conclude from such dataat the locus at which they integrate. It would bebetween the transposons and the gene sequences10. Data suggest that there are similarities the plant. If for chemical and physical reasonsthen also be expected for the integration of \u00b7  The number of plants.  Given the large-scale which are based on transpositions could also becultivation of transgenic crops, plants withcontext effects from the insertion of transgenesmay be much more frequent than plants withcontext effects from the insertion of transposons.This does not mean that the effects are differentin both cases or have different consequences forthe plant. Furthermore, new plant varietiesgrown in large fields. \u00b7  The content of genetic information.  Transpoconsequences. It does not, however, determinetion is relevant for the gene product and itsorganisms. The content of the genetic informa-been in the plant gene pool from nonrelatedthe effect of the transfer on the genomic context.traits to the plant; but only transgenes cansons can, like transgenes, add new phenotypictransmit genetic information which has never  thesis that disturbances in the genomic contextgenome; one will have to look for it at the levelcan be added that transposons are but oneexample of random processes in plants whichinfluence the genomic context. One could alsopoint to mutations which insert or delete geneticinformation. These mutations also refute theare a unique and specific risk factor of genetic11. As a general comment to the whole debate itengineering. In the final analysis it seemsdifficult to uphold this thesis in view of the factthat natural evolution presupposes randomchange in genomic contexts. It is unlikely that a\"special quality\" of gene transfer can beestablished at the level of organisation of theof the gene product. \u00b7  The frequency of transposition.  The frequency is regulated by the plant. This suggestsdevelopmental programme of the plant.that transposons have a definite function in the   Freof transposons will change the genomic context.quency has no implications for how the insertionThis change depends on the site in the genome towhich the transposon moves, not on the fre-quency with which it moves. a transgene into the plant genome. For transpo- 8. Gene transfer aims at the stable integration ofsons it is, in contrast, quite normal that they  36 Herbicide-Resistant Crops BIOSAFETY ASPECTS OF   This debate proceeds from the assumption that  B NONSELECTIVE HERBICIDES decrease. This assumption was also made in theparameters of toxicity and, in addition, takingthe amount of herbicide used is a good indicatorof whether the burden on human health andenvironmental integrity is likely to increase or tograting the amount of herbicides applied and theinto account local conditions at the place ofcomparing quantities is only a very crude indi-cator for comparing the possible negative im-pacts of herbicides. What would really beneeded would be a comprehensive index inte-such an index.erosion etc.). It has not been possible to developapplication (e.g. type of soil, susceptibility totechnology assessment, but it was agreed that  With the construction of transgenic herbicidebiosafety for such plants: What risks areresistant plants, broad spectrum, nonselectiveherbicides (which normally affect all or nearlyall plants) can be used widely in agriculture forthe first time. This raises further issues ofinvolved in the use of nonselective herbicides,both with respect to the consumers\" health andto the integrity of the environment? nevertheless critical points of public debate. market for agricultural application. They areThese risks are examined extensively within thenonselective herbicides can be placed on theestablished procedures for approval before 42 Thus, comparing amounts of toxicity and ecotoxicity. This can be taken asherbicides is a substitute which will only providerelevant information if the nonselective herbi-cides used in conjunction with transgenic plantsand the selective herbicides used with conven-tional plants are widely similar in terms of theirbeing the case for glyphosate (Round-up) andglufosinate (Basta), the main herbicides consid-ered in this technology assessment. herbicides change the present situation to thebetter or to the worse? A number of participantscontinued to argue, however, that these herbi-cides would still be unacceptable even if they didimprove the status quo. This group consideredcussed mostly in a comparative way: Do theseaspects of nonselective herbicides were dis-In our technology assessment, the biosafety any use of herbicides unacceptable. 40 conventional weed control methods are availablethe total cultivated land might well be the maxi-herbicides.mum range of application for nonselectiveeffective and cheap. As a result, one quarter ofoften competitive enough and may not need(including selective herbicides) which are bothbe applied in all crops. The most likely candi- dates are row crops. Cereals, in contrast, arefact, nonselective herbicides would probably notareas of agricultural cultivation. As a matter ofresistant crops could become standard for mostuse often imply that transgenic herbicide-Arguments about the development of herbicideherbicide treatment at all; and, if necessary, and changes in agricultural practice. Our sum-amounts of herbicides applied in agriculturemary, therefore, starts with the discussion of thisissue.tive herbicides, not only with respect to possiblekey issue for assessing the impacts of nonselec-would increase or decrease once transgenicrisks, but also with respect to possible benefitsherbicide-resistant crops were introduced, is aIt was agreed that the question whether the   Will greater or lesser amounts  1 of herbicides be applied whenplants are grown?transgenic herbicide-resistant 43 and answer two questions: Will the amount ofherbicides used per hectare increase or decrease?Discussions of whether greater or lesserWill the total agricultural area treated withdifferentiate between the various crop culturesamounts of herbicides would be used must  Opinions are divided over this question.                                                                             Whereas critics of herbicide-resistant cropswarn that farmers will use more herbicides thanthey have up to now, supporters of the technol-significantly smaller amounts of herbicides.ogy claim, to the contrary, that farmers will use 41 Technikfolgenabsch\u00e4tzung, Heft 6: 126-152 (see appendix). 42   According to a Danish expert the problem is: \"how to  40 Cf. section III C3 below. compare LD50 values with e.g. the persistence. You haveto put some value judgement into each of those parame-ters. That\"s why it is very difficult to reach any agreementon it\" (IHE 1994: 49). 41   In our technology assessment, discussions of the issue technology assessment see: \"Entwicklung der Aufwand-mengen beim Herbizideinsatz\", in:more comprehensive account of the discussion in thecide-resistant crop plants; see section II C below. For adealing with agronomic and economic impacts of herbi-were based on several expert reports and commentaries Materialien zur 43   While this may be the case in Central Europe Gressel (1996: 240) sees a definite need to engineer new herbi-cide resistances into wheat in order to control grassweeds in India, for instance.   Part II: Empirical Findings-Impacts And Consequences 37 herbicides increase or decrease? In our technol- However, such application is not likely to bemust no longer fear that they might damage theirsome crops, also mechanical methods. A greatogy assessment, comparisons were generallytechnology assessment:made with the weed control strategies farmersnormally apply at present. For most crops thismeans application of selective herbicides, but forwhether herbicide-resistant crops would \"invite\"deal of discussion was devoted to the question offarmers to use herbicides excessively, since theyrealised in practice. Three main topics turnedcrops. If this were the case, then reductionswhich might be possible in theory would not beout to be relevant in the discussions of the crops. In either case, yield losses must be ex-bly only be possible to delay herbicide applica-For agronomic reasons it will, therefore, proba-pected if weed control is postponed for too long.Since weeds would also be larger at this stage,they are also a source of viruses which damagethey would compete more vigorously with crops;come a standard method of weed treatment.tions by up to about 14 days beyond the usualdate. wave of weeds has appeared in the field. A 3. With glyphosate (Round-up) and glufosinate(Basta) current experience suggests that the bestscheme of application might be to split thetreatment: A crop would then be treated the firsttime at about the four-leaf stage, when the firstthe crop sufficiently competitive.leaf stage, when weeds have emerged again.Second (and further) treatments may eventuallysecond treatment is envisaged at about the ten-be spared if the pressure from weeds is low and \u00b7  the technical options herbicide-resistant plants may involve for reducing the amounts of herbi-cide applied in various crops, \u00b7  the level of herbicide management that would actual practicebe required if these options were to be realised in \u00b7  the displacement of mechanical methods of able.herbicide-resistant crop varieties become avail-weed control by nonselective herbicides when herbicides (in particular glyphosate and glufo-crops, which suggest that with nonselectiveto 30%. No reductions can be expected forsinate) some reductions in herbicide quantitiesmight be achieved for various crops. Expectedreductions are considerable for sugar beet-upsignificant reductions can be expected for allcereals, if herbicide-resistant varieties are notdeveloped because they are not economicallyattractive. In cases where the fields are infestedwith weeds which are particularly hard to con-trol using conventional (selective) herbicides,crops. 4. Calculations have been made for the various completely clear.The following conclusions from the discussions effectiveness of nonselective herbicides nor themust be viewed as preliminary. Herbicide-practical conditions. Therefore, neither thedetails of their regime of application are yetresistant crops have not been widely tested under 44  Question 1: Will the use of herbicide-resistantcrop plants lead to reductions in the amountsof herbicide applied? Conclusions from the discussion  Whether the switch to postemergence treatment1. Herbicide-resistant plants favour the switch tocation.depends on the exact scheme of herbicide appli-will in fact reduce the amount of herbicides usedimply less damage to the crop plants and have amore complete spectrum of weed control.this respect than the (selective) postemergence(Round-up) or glufosinate (Basta) are better insary. Nonselective herbicides such as glyphosatethen decide whether or not treatment is neces-the farmer can wait until the weed grows andpostemergence treatment in weed control, where herbicides which are available at present. They which must be treated with high doses andexample, be spared if the re-emerging weeds areyear can be reduced in some crops; furthertoo weak to compete with the crop plants.applications in a splitting scheme could, forcides; (b) that the number of applications pertrue particularly in the case of strong weeds 5. These calculations are contingent upon twoassumptions: (a) that the doses necessary foreffective weed treatment are less with nonselec-tive than with selective herbicides; this would becombinations (tank mixtures) of selective herbitrials.practice will have to be tested in further fieldpossible in theory can actually be achieved in6. Whether herbicide reductions which are   applied at a very late stage in plant growth.2. In theory, nonselective herbicides could be 45                                                                                                       44  45   Recent trials with glufosinate resistant sugar beets  Data have only recently become available; see Reschke suggest that 4-6 litres of the product per hectare (in twoapplications) provide sufficient weed control; this com-pares with 8-9 litres of selective herbicides used at from these data in subsequent footnotes.(1996), and Rasche, Donn and Waitz (1996); we quote  38 Herbicide-Resistant Crops 7. Should the use of broad spectrum herbicides  circumstances, guarantee effective weed control. amount of herbicide used could even be in-herbicide is no longer effective.creased for a while, until it is clear that thelead to the selection of resistant weeds, farmerswould in this case be negated. Theoretically, thehave been achieved with nonselective herbicides,reductions vis-\u00e0-vis the status quo that mightincreasing the doses of herbicides applied. Anymight try to maintain effective treatment by normal herbicide management in Germanyindeed advisable. If integrated crop protectionIn practice, lower doses are often possible andand good field practice are the criteria, thenselection of resistant weeds can be ascribed todisplays many shortcomings, including unneces-sary routine applications of herbicides, excessivedosage locally, and lack of herbicide rotation.Many cases of groundwater pollution and theinadequate herbicide management. 46 themselves on the market.transgenic crops had lower yields or required 8. It is sometimes argued that herbicide-resistantcrops will result in increased overall amounts ofchemicals used in agriculture, assuming thattransgenic varieties will be less competitive orparticularly susceptible to fungal attack (there-fore requiring more fertilisers or fungicides).These assumptions seem to be unwarranted: Ifmore fungicides, they would fail to establish amounts of herbicides they invest. This is, ofvant cost factor. In this respect, atrazine is anexceptional (low cost) case. In general, thehas fallen dramatically in recent years.manage herbicides properly and reduce thefarmers have a clear economic incentive to10. Because of pressure from rising costs, out by the fact that the turnover for herbicidescourse, only true if herbicides represent a rele-try to profit by using less of them. This is borneprices of herbicides are such that farmers will 47 agriculture because they are more likely to be Question 2: Will herbicide-resistant plantsincrease the amount of herbicides applied inmisused? general problem; nonselective herbicides will be 11. Deficits in herbicide management are athe case.no exception in this respect. However, there iscides would be handled particularly recklesslybecause crops are resistant, or that the farmerswould engage in more unnecessary treatments oruse excessively high doses. This could only beexpected if economic controls played no rolewith nonselective herbicides, which is clearly notlittle reason to suspect that nonselective herbiConclusions from the discussion 9. Proper herbicide management requires more high levels which, even under unfavourablethan just adhering to the maximum doses per-mitted for the product applied. For reasons ofproduct liability, the permitted doses are set at                                                                            present (Reschke, 1996). For the agronomic details, see uses of herbicides. The incomplete spectrum of 12. Nonselective  herbicides  like  glyphosate(Round-up) and glufosinate (Basta) could, onthe contrary, resolve a number of managementproblems which up to now have led to increasedtraditional herbicides causes problems in majordifficult to control and require additionalcrops: Weeds are selected which are particularlyherbicide use. The selection of such weeds couldherbicides. Some of the herbicides to be usedcome close to meeting the standard of completedweed control.with transgenic herbicide-resistant crops maybe avoided with broad spectrum, nonselective below, section II C2 below. With oilseed rape, oneapplication of up to 600 g active ingredient is enough(Rasche et al., 1996). This does not necessarily constitute weeds, producers should be able to use total postemer-current management systems\" (Wilcut fields could be reduced by at least 50% as compared togence management systems. The herbicide load in thesestwo applications of two to three litres per hectare provideexample, cotton. \"In fields with light infestations ofcrops not dealt with in our technology assessment, forsufficient control. Reductions might be considerable inalso IHE (1995: 4). With glyphosate-resistant sugar beetappreciable reductions compared to current practices; seeet al. 1996: 221). 46   The risk that resistant weeds are selected depends on section II C2 below.the mode of action of the herbicide resistance. The riskglufosinate (Basta), and it is assumed that it can be keptherbicide management (e.g. herbicide rotation), seewithin limits for all nonselective herbicides by properappears low in the cases of glyphosate (Round-up) and 48 displace mechanical methods of weed control?Question 3: Will nonselective herbicides  47   Ahmad et al. (1995) did find that glufosinate impairs Conclusions from the discussion  the antagonistic control of the phytopathogen  Fusarium been displaced by herbicide application over the13. Mechanical weed control has already largely  oxysporum by  Trichoderma species. However, this does fungal attack\".production of induced phytoalaxins that defend againstnot, according to information from AgrEvo, result inincreased need of fungicides. See, however Gressel(1996: 243) \"Even low rates of glyphosate suppress the                                                    48   Although glyphosate and glufosinate, too, have gaps in their weed control spectra. Cf. section II C2 below.   Part II: Empirical Findings-Impacts And Consequences 39 applications could be reduced by shifting to recent decades. It is now restricted mainly to at any rate, not likely to be appreciable.cides used for cultivating potatoes. The effect is,would be a rise or fall in the amount of herbi-net effect of these contradictory developmentsproblem. It is not possible to predict whether thethey use anyway are sufficient to cope with theapplication, or whether the mechanical measuresweed pressure warrants any further herbicideinstead decide on the spot whether the actualcould then be abolished and the farmer couldtreatment, which is a routine in many areas,herbicide-resistant potatoes. Preemergencepostemergence treatment in conjunction with are labour-saving and more cost-effective.displacement of mechanical weed controlalternative, they are likely to encourage furtherenvironmental properties become an availablesufficient control spectra or favourableexpect that when nonselective herbicides withintegrated crop protection schemes. One mustweed control are also given some weight withinincomplete control spectra or adverseherbicides are inapplicable because oforganic farming and to areas in which availableenvironmental impacts. Mechanical methods ofmethods in conventional farming because they 14. The potential of mechanical weed controlrow crops which are the main targets of trans-methods has not yet been fully exploited. Me-ods may even be indirectly supported by theintroduction of herbicide-resistant plants. Ifbroad spectrum, nonselective herbicides areapplied in a postemergence treatment of rowcrops, they will also reduce weed pressure oncereals which are grown the following year;chanical methods can, for example, be quitemechanical treatment might then become techni-cally and economically viable. This effect couldbe very wide-ranging, since cereals account forsome 75% of the cultivated land in Germany,and since about half of them are cultivated aftergenic herbicide resistance.cost-effective in cereal crops with a low inci- dence of weeds. In such crops mechanical meth- 18. Even if nonselective herbicides replace increase in the amounts of herbicides used.will probably lead to a reduction rather thancase, the applicability of nonselective herbicideswhere herbicides are applied. And, in the latterused are minimal in comparison to those areaswhere mechanical methods of weed control areat large. The areas in conventional farmingincreased overall use of herbicides in agriculturecrops, this does not imply that they result inmechanical methods of weed control for some 49 Impacts on health: residues  2  from nonselective herbicides infood crops  Only transgenic herbicide-resistant plants can be killed. Obviously, therefore, products from suchplants may have residues that are different fromthose which could occur in products from non-exposed to nonselective herbicides without beingThe decisive point here is not that the herbicideresistance has been genetically engineered, butthat a new herbicide is applied. A new situationwith respect to residues would also arise ifresistance to nonselective herbicides was createdwith other methods (e.g. through conventionalbreeding) or if crops were exposed to newlydeveloped selective herbicides which make useof a natural tolerance mechanism, the operationof which implies that the herbicide will havesome impact on the plant metabolism.transgenic plants exposed to selective herbicides. crops have to be considered case by case.nalised in conventional farming. The various15. To the extent that nonselective herbicidesdisplace mechanical weed control, the introduc-tion of transgenic herbicide-resistant plants willincrease the use of herbicides in agriculture. Theeffect will be rather limited, however, becausemechanical methods are already very margibe integrated with other agronomic measures,like hoeing or hilling up, both of which are control will continue to be practised where it canof Germany\"s farmland, mechanical weed16. For potatoes, which are grown on about 4%where (preemergence) treatment with traditionalmethods might be displaced, however, in areasnecessary for cultivation of the crop. Mechanicalherbicides was inappropriate because thesestandards or because they did not have asufficient spectrum of control. In those cases,the availability of applicable nonselectiveherbicides could result in increased amounts ofherbicides used in potatoes.herbicides did not meet water protection 49   The displacement of mechanical methods of weed control may nevertheless be an undesirable po litical signal. Even participants in the technology assessment,who did not oppose herbicides in principle argued thattechnical monostructures in weed control and over-reliance on chemical methods should be avoided (seesection III F3 below). Mechanical methods of weedcontrol should therefore continue to be applied andinnovated. However, this goal cannot be pursued success-fully by restricting herbicide-resistant crops; financialsupport for the mechanical methods is what is required. be compensated, if the number of herbicide17. On the other hand, this negative effect might   40 Herbicide-Resistant Crops  Existing law requires that a toxicological dossier Question 1: Will the application of nonselecin the testing. On the other hand, it can goof residues which could occur in transgenicproducts. A technology assessment can neithertoxicologically incompatible residues in foodreleased onto the market were they to lead totherefore, that these herbicides would not benonselective herbicides can be approved forherbicide-resistant crops be produced beforethat precedes the approval of new herbicides. Itapplication to such crops. It can be assumed,can only raise points which should be consideredand appropriate for nonselective herbicides.beyond the criteria which are already legallybinding. Some participants in our technologyassessment argued that the criteria for herbicideapproval should become stricter; they alsodebated whether the existing rules are applicablesubstitute nor anticipate the extensive testing tive herbicides lead to increased residues inthe harvested crop plants?  Conclusions from the discussion those currently in use; with certain crops, for 1. For herbicide-resistant plants the amount ofherbicides applied per hectare and year willprobably be somewhat reduced in comparison tosituation concerning herbicide residues shouldexample, sugar beet, these reductions may beconsiderable. This suggests further that theimprove rather than worsen with the introductionof herbicide-resistant plants. In general, whenless herbicides are applied, less residues must beexpected in crops. percentage of farmland, however, since me-areas where conventional herbicides were inap-plicable. Displacement can only affect a smallthose crops where nonselective herbicides dis- 2. Herbicide residues are likely to increase innalised in the present system of crop husbandry.place mechanical weed control. Ironically, thiscould also be the case exactly because theseherbicides are better in environmental terms. Forchanical weed control is already highly margi-example, should they be classified as not harm-ful to water, they could be used in protected More residues in food crops were regarded inhectare.There was agreement that it would be undesir-tolerated under the usual toxicological criteria.able and a clear disadvantage of transgeniccides involved higher residues in crops. Thisopinion was held irrespective of whether or notthe residues remained within the limits of what isdecrease in the amount of herbicides applied perherbicide-resistant plants if nonselective herbi-ment and harvest delay), and on an increase orapplication (early or late postemergence treat-herbicide resistance, on the timing of herbicidethis would depend on the mode of action ofactually increase or decrease. It was clear thatwas reached about whether the residues wouldprinciple as undesirable. However, no agreement  cides.may become unnecessary. This could, for in-are still widely treated with preemergence herbi-compete well with weeds; at present these crops 3. On the other hand, residues are likely todecrease where nonselective herbicides allow areduction in the total number of herbicide treat-ments in a yearly crop sequence. If herbicideslower weed pressure by reducing the seed bank,then successive treatments in the following cropstance, be the case with cereal crops which can  Apart from this question, it was also discussedwhether our current state of knowledge was asufficient basis for testing the residues of non-selective herbicides and controlling possiblerisks for the consumers. A number of partici-these herbicides could not be approved at all.pants denied this and concluded, therefore, that  4. The shift of herbicide application to post-increased residues. Presumably, nonselectivedelay of harvest and, therefore, time for herbi-herbicides would not be applied at a very latecide residues to be diluted in the crop.emergence treatment does not necessarily implyfirst appear in the field. This ensures sufficientsplit applications relatively soon after the weedsstage of plant growth, but rather in a scheme of 50                                                    50   Expert report commissioned from Prof. H. Sandermann Aspektelogie, Universit\u00e4t D\u00fcsseldorf): \"Nutzpflanzen mit k\u00fcn-herberg) and Prof. K.-F. Ohnesorge (Institut f\u00fcr Toxiko-(Forschungszentrum f\u00fcr Umwelt und Gesundheit, Neu-stlicher Herbizidresistenz: Verbessert sich die R\u00fcck-standssituation? Biochemische und toxikologische\" ; commentaries from environmental groups by resort to herbicide application at later stages of5. Increased residues could result if farmersTherefore, very late additional treatment couldplant maturity shortly before harvest, in the casesure. Such applications are more likely to occurlikely to affect the crop and cause yield losses.mergence herbicides, since the former are lesswith nonselective than with conventional poste-of unexpected and unusually high weed prescommentary from industry by J. Honegger (Monsanto), in:W. B\u00f6decker,  (Pestizid  Aktions  Netzwerk,  Hamburg),V. Haas  and  L. Peters  (Umwelt-Institut  M\u00fcnchen); Materialien zur Technikfolgenabsch\u00e4tzung, Heft 6 (see appendix).   Part II: Empirical Findings-Impacts And Consequences 41 prove profitable. It may be necessary to restrict toxicologically relevant interactioncally, but only when there is specific evidence ofsynergistic effects are not carried out systemati-testing within acceptable bounds. Tests for the number of model systems (animal species)suggests that it might involve risks. Moreover,application in the field, is tested only if evidencetion, i.e. additional substances required foractive ingredients in herbicides. The formula-dossier related to health risks is confined to thepragmatic reasons. In general, a toxicologicaltested is limited in order to keep the costs of9. The testing of herbicides is also limited for plant growth and plant metabolism, so thatsuch applications of nonselective herbicides byregulation, in order to ensure that residue con-centrations would be reduced sufficiently bytolerances of residues are not exceeded in theharvested crop. harvest. Such abuse is, however, a general risklate applications which have neither been tested 6. Herbicides can nevertheless be abused andthus give rise to additional residues. Forinstance, a farmer, if confronted with unforeseenweed problems, may disregard the rules ofherbicide approval and good field practice, anduse nonselective herbicides anew, shortly beforewith postemergence herbicides; with all of them,nor authorised remain technically possible. .  10. Despite these limitations there is no empirifails to protect consumers against health damagedeliberately ingested to commit suicide).tion or medical drugs). Cases of poisoning havebeen recorded for individuals handling herbi-cides-paraquat, for example-have, beennot for consumers ingesting food products fromcrops treated with herbicides (although herbi-vested crops constitute health risks (in contrast,cides during application, or manufacturing, butbelow this. Nor are there any epidemiologicaldata suggesting that herbicide residues in har-from herbicide residues. Levels of residues areoccur; usually the quantities of residues are wellViolations of maximum permissible levels rarelyroutinely controlled in samples of food products.cal evidence that existing herbicide regulationfor example, to chemicals used in wood protecQuestion 2: Do we have sufficient knowledgeto assess possible residues from nonselectiveherbicides and to control toxicological risksfor the consumers?  Conclusions for the discussion taken for granted, therefore, that the accumula-knowledge is not available refer to points which 7. Many of the arguments that the necessarytransgenic herbicide-resistant crops. It can behave to be considered in the tests legally re-and evaluation. This also includes metabolites ofpossible to extract them.be subjected to standard toxicological testingplants will be investigated, and that residues willdation pathways of nonselective herbicides intion of active ingredients in a crop or the degra-quired before approval is granted for use ofthe herbicides, formed only in plants, if it isnonselective herbicides in conjunction with about whether chemical crop protection isstrike a balance between maximising the pre-is likely to remain controversial in the publictechnology assessment. This is perhaps notrealm, and it also remained controversial in ouracceptable at all in agriculture. When any use ofweed control techniques. Any such compromisevention of risk and allowing for innovation ofsurprising in view of fundamental disagreementherbicides is rejected as a severe mistake, oneinvolve political compromise, since they try to cannot, of course, be satisfied to learn thatnonselective herbicides pose no special problemsin comparison with conventional (selective)ones.11. Regulations for the approval of herbicides  herbicides which are only formed in plantsand technical reasons. What cannot be knowncannot be tested. There is, for example, no wayto test whether herbicide residues at concentra-tions below the level of detection exist and, if so,whether they might be toxicologically relevant.There is also no definite answer as to howreliable extrapolations from animal testing tohumans really are. Furthermore, metabolites ofbase-line effects for toxicological assessmentcannot, as a rule, be tested if they remain unde-tected, or if they cannot be isolated from theplant itself. Feeding the crop to animals wouldbe one theoretically possible test strategy; but inpractice this is often impossible because theamount of plant material needed to produce8. The tests developed for the approval of herbi-cannot be incorporated in the test animals with-out killing them.cides have systematic limits for methodological 51 Impacts on the environment:  3  Are nonselective herbicidesmore environmentally friendly?  Our technology assessment examined the possible effects of nonselective herbicides on soil(including problems of soil erosion), on aquaticecosystems and on the phytocoenosis in agri51 For this debate see section III C3 below.  42 Herbicide-Resistant Crops cultural habitats. The findings tended to empha- transgenic herbicide-resistant crops differ little nonselective herbicides, and from the assump-sise that the proper use of nonselective herbi-application rates and numbers of treatmentstion that theoretically possible reductions inwould be actually achieved in practice.soil and ecotoxicological properties of someexpected would probably also be only slight.in agriculture, but that the improvements to becides would at least not aggravate the environ-mental impacts of current herbicide applicationsImprovements were projected from favourable soil mobility (bonding and leaching), they arein terms of their effects on the soil from theherbicides already used. In certain respects, forinstance, rapid degradation (persistence) and lowslightly better. 54  2. If it turns out that lesser amounts of herbi-cides will be used with transgenic herbicide-actually significant remains to be established infield trials.resistant crops then, in principle, the burden onthe soil will decline. Whether this effect is regulation. The question of whether limits ofnonselective herbicides pose no particular envi-mained one of the controversial issues of legalertheless did not warrant the conclusion thatand political debate in the technology assess-ment. ronmental problems. They argued that theto deem a new technology unacceptable re-findings, while not contested in principle, nev-For the critics of herbicide-resistant crops thesepredict all the possible effects and that testsapply to any scheme of risk testing and riskconducted for herbicide approval cannot defi-nitely exclude the possibility that additional risksmight nevertheless exist. The other participantsacknowledged these points but countered thatthey merely describe general problems whichknowledge and preventive control are sufficientcurrent state of knowledge does not allow us to methodological problems. Tests are not carriedextrapolations are only valid to a limited extent. dardised model soils which do not adequatelyout in the field, but in the laboratory on stan-3. Predictive testing of soil behaviour facesreflect the complexities of the processes in realsoils. The results must be extrapolated from themodel systems to the agricultural fields. Such soil substances and metabolic products formed interaction between nonselective herbicides andby soil microorganisms under pressure fromherbicides are not explicitly tested. They are,however, dealt with implicitly through tests forpossible negative impacts on soil functions likerespiration.4. Synergistic effects which might arise from 52 the state of the art in soil science. Currentcompensated by monitoring the technology afterit has been introduced.ban a technology outright, then they must bethe assessment of nonselective herbicides: it will 5. The methodology and theory of soil testingperformed with nonselective herbicides reflectapply likewise to possible soil impacts from newtechnology. If such limits are not sufficient tofraught with significant uncertainty. Such un-certainty will then, however, not be confined toknowledge may be unsatisfactory and, therefore,selective herbicides and other agronomicchanges like new tillage schemes, variations infertilisation, or variations in crop rotation. Ingeneral, the limits of predictive testing are aproblem for all precautionary regulation of newpredictions of effects on real soil processes  As in the discussion of health impacts, the criticsdid not accept the comparison of selective andnonselective herbicides when assessing environ-mental impacts. They insisted that organicfarming was the only appropriate system ofreference and alternative to be considered. Thisargument also reflected the basic differences invalue judgements among participants in ourtechnology assessment. been used up to now? Question 1: Have nonselective herbicides lesseffects on the soil than herbicides which have  Conclusions from the discussion 53 1. The nonselective herbicides to be applied with  55                                                    52   See section III B7 below. The issues are the same for conceivable risks from transgenic plants and nonselectiveherbicides.  53 Expert report commissioned from Prof. B.-M. Wilke                                                    54   See also Moorman and Keller (1996). den\"; commentary by Dr. Ch. Siewert (Institut f\u00fcr \u00d6kolo-gie [Bodenkunde], Technische Universit\u00e4t, Berlin), in:Berlin): \"Verhalten der Komplement\u00e4rherbizide im Bo-(Institut f\u00fcr Landschaftsbau, Technische Universit\u00e4t, 55 Materialien zur Technikfolgenabsch\u00e4tzung, Heft 7 (see    This solution was favoured by the majority of particiappendix). pants in our technology assessment, see section III E2below.   Part II: Empirical Findings-Impacts And Consequences 43  Question 2: Will the application of nonselec- agronomic management. tive herbicides have an effect on soil erosion? 56  10. In  theory,  transgenic  herbicide-resistant  Conclusions from the discussions cropping, which imply significant improvementhowever, a major shift is not likely to occurthan on technical opportunity.because it depends on economic profit rathercrops offer new opportunities to shift to tech-niques of conservation tillage and mulchwithin our present system of agriculture,in soil protection against erosion. In practice, 6. The use of herbicides is not a major factor ofsoil erosion in agriculture. Soil erosion is mainly and site-specific choice of crops to be grown.due to mismanagement with respect to tillage monocultures of corn the factor may be as highsumption is that the soil will be better and, for adepending on location, choice of crop and mo- 7. Theoretical calculations predict a certainreduction of the disposition to soil erosion whennonselective herbicides are applied in postemer-gence treatment of weeds. The underlying as-longer period, covered by weeds (or their re-as 17%.mains after treatment). Reductions will varydalities of herbicide application. The calcula-to erosion may be reduced by 11% for sugarbeet and 7% for potatoes and oilseed rape ifnonselective herbicides are applied to one cropin the rotation sequence. If they are applied totions suggest, for example, that the disposition 57  Question 3: Will water pollution l evels be reduced when nonselective herbicides areapplied in conjunction with transgenic herbi-cide-resistant crops? 58 Conclusions from the discussion:  cides with favourable properties (low mobility 11. The pollution of groundwater with residuesfrom herbicides is due partly to the properties ofthe herbicides themselves and partly to poormanagement or reckless handling in herbicideapplication and disposal. Nonselective herbi-and rapid degradation in the soil) may reduce therisk of groundwater pollution. Whether theywould actually improve the situation measur-ably, as long as the practice of herbicidehandling is not effectively controlled, remains anopen question. plausible. This effect does not occur, ifeffect results, which would actually increase the(splitting). Whether in this case a clean weedingapplied in repeated treatments of low dosagenot be achieved if nonselective herbicides arethe case of late postemergence applications will8. Positive effects on soil erosion calculated fordisposition for soil erosion, remains to be seen. Theoretically, a certain negative effect islead to broad spectrum weed control; in any casecombinations of selective herbicides (tankmixtures) have been used up to now, which alsothe impact would be quantitatively small. glyphosate, than with the selective herbicides 12. One must expect that herbicides used inagriculture will leach into surface waters, sincesome soil loss and run-off from farmland isinevitable. Leaching may be slightly lower withnonselective herbicides, such as glufosinate orconventionally used. This projection is based onthe assumption that the amounts of herbicidesfactor might be that herbicide washout fromgence, contact herbicides are applied. It is not tobe expected, however, that this factor wouldcompletely outweigh the advantages from areduction in the amounts of herbicides used.will be reduced as calculated. A countervailingcrop leaf surfaces could increase if postemervariations in crop rotation or tillage techniques. 9. The predicted changes in the disposition tosoil erosion are derived from model calculationswhich disregard the high fluctuations of naturalevents. It is, therefore, questionable whether theycould be demonstrated in real practice. They arein any case significantly smaller than changesdue to normal practices in agriculture, likewould be achieved through proper, site-specificAny positive effect the application of nonselec-tive herbicides might have for soil protection isnegligible compared to the improvements that                                                    leaching into surface waters could induce the13. A possible ecological risk is that herbicides                                                     57   In Germany mulchseed is practised on no more than 12% of the total area of row crops. However, in sitesamount to 30-50% (personal communication Dr. Reschke,Pflanzenschutzamt Hannover).which are particularly prone to erosion mulchseed may 56   Expert  report  commissioned  from  Prof. K. Auerswald (Institut f\u00fcr Bodenkunde, Technische Universit\u00e4t M\u00fcn-58  chen):  \"Auswirkungen des Anbaus von Kulturpflanzen  Expert report commissioned form Prof. G. Klein mung\"; commentary by Dr. L. Ebner (Ciba-Geigy, Basel).Ausma\u00df der Bodenerosion und der Pestizidabschwem-mit gentechnisch erzeugter Herbizidresistenz auf das (Institut f\u00fcr Wasser-, Boden- und Lufthygiene, BundesgeMaterialien zur Technikfolgenabsch\u00e4tzung, Heft 8 (see sundheitsamt): \"Auswirkungen der HR-Technik aufaquatische \u00d6kosysteme\"; commentary by Dr. E. Dorn(Hoechst AG, Frankfurt), in: Materialien zur Technikfolappendix). genabsch\u00e4tzung, Heft 9 (see appendix).  44 Herbicide-Resistant Crops selection of herbicide-resistant mutants of weed control can affect the phytocoenotic nate all uncertainty with respect to the effects ofthat is, if they reduce the fitness of these variantsaquatic organisms. If these organisms spreadthey could disturb the biocoenosis of an aquaticprinciple, be excluded by the required testing forecosystem, for example, by disrupting existingresistant water organisms.the herbicides exert selection pressure on thenonresistant variants of the aquatic organism,food chains. This could only happen, however, ifor are toxic for them. Such effects should, inherbicide approval. These tests may not elimi-theless, herbicide leaching into surface waters is,herbicides on aquatic ecosystems, since testingrelies on model systems and indicators. Never-in general, brief and concentrations are very low(in micrograms per litre). It is therefore notlikely to give rise to a spread of herbicide- individuals) and diversity (number of species),of seed banks in the soil and spread of weedmechanisms for such changes could be reductionwhich extend beyond the vegetation period. Thespecies that remain unaffected by nonselectivecan induce changes in dominance (numbers ofstructure in agricultural ecosystems, that is, itherbicides (incomplete spectrum). to be sustained (perhaps at a lower populationnonselective herbicides are used in monocultureshand, if a nonselective herbicide is only usedlevel) or it should be able to restore itself.and, hence, the agricultural habitat. On the othervidual species from the normal weed communitylikely to cause irreversible reductions in theor in all crops of a rotational sequence, they arethat reproduce later in the vegetation period. Ifspecies spectrum of the weed community oughtthe crop plants, and they favour weed speciestolerated because they are poor competitors forsuppress weeds which may previously have beenspectrum of weed species in the field. They17. Nonselective herbicides will change the weed seed bank and eventually eliminate indi-once in the crop rotation sequence, then the  14. Drift response of water organisms to herbi-cides is possible and can lead to (presumablytemporary) changes in aquatic ecosystems. Sucha response has also been observed with nonse-lective herbicides like glyphosate. Drift responseleaching events could be reduced.treatments per year and, hence, the number ofhave a positive effect insofar as the number ofof nonselective herbicides could, however, alsocontrolled by ecotoxicological testing. The useare several orders of magnitude below the levelcan occur even when herbicide concentrations 18. From the point of view of agricultural the field and, when fewer weeds appear, thenproduction a reduced weed seed bank in the soilwould seem to be a positive rather than a nega-tive factor. It would lower the weed pressure inless herbicide treatment is needed-also anadvantage in ecological terms. On the otherhand, increased selection and spread of weedspecies which are not controlled by those herbi-cides may confront the farmer with additionalagronomic problems. pollution will at least not be aggravated, and 15. It can be concluded that problems of waterleached to surface waters of 10-30% representspossibly even slightly improved, if there is aWhether a reduction in the amount herbicidesshift from selective to nonselective herbicides ina real improvement in ecological terms is amatter of debate.well or better than herbicides used up to now.nonselective herbicides generally come off asweed control. With respect to ecotoxicology the fields virtually free of weeds. In these cases, noagricultural ecosystem should be expected from 19. The spectrum of weed control is not extra-ordinary with nonselective herbicides comparedto tank mixtures or successive treatments ofselective herbicides. Such treatments, routinelyapplied in sugar beet, for instance, also keepadditional impacts on the phytocoenosis of annonselective herbicides. The same may even bevery thorough manual weeding (which wasextremely low).true if one compares use of these herbicides withapplied previously when labour costs were still 59  Question 4: Will the application of nonselec-tive herbicides change phytocoenotic struc-tures in agricultural ecosystems? Conclusions from the discussion  60 16. The application of nonselective herbicides in                                                     59   See section III C3 below. or variations in the crops grown. Such effectstural practices, such as different tillage schemestrum biodiversity are implied in many agricul-including shifts of dominance and weed spec-20. Changes in the agricultural phytocoenosis, are, therefore, in no way specific to the intro-duction of nonselective herbicides. 60   Expert report commissioned from Prof. E. Mahn (Instischutzamt, Hannover), in: Einf\u00fchrung herbizidresistenter Kulturpflanzen aufLuther-Universit\u00e4t Halle): \"Zu den Auswirkungen dertut f\u00fcr Geobotanik und Botanischer Garten, Martin-\u00d6kosysteme\"; commentary by Dr. M. Reschke (Pflanzen-Materialien zur Technikfolgenabsch\u00e4tzung, Heft 10 (see appendix).   Part II: Empirical Findings-Impacts And Consequences 45  IMPACTS ON AGRICULTURE \u00b7\u00b7  the protection of species, C  \u00b7the development of plant breeding,  good field practice in agriculture.  This part deals with the indirect consequences of While these problem areas do overlap to some  ance of modern agriculture. In Germany suchbeyond the issues of biosafety and considersimpacts are, as a rule, not accounted for inregulatory frameworks for state approval of anew technology. They are nevertheless crucialfor the political judgement and public accep-tance of a technology and, therefore, an essentialtopic in a technology assessment. We consideredthe impact of transgenic herbicide-resistantcrops on biodiversity in breeding and cultivation,on the practice and the economy of weed control,possible impacts on the structure and perform-transgenic herbicide-resistant crops. It reaches extent, within each of them, loss of diversity hassummarise these differences.cepts of damage. The following table tries toa different meaning and implies different conplants might cause a loss of biodiversity; how- In our technology assessment, all of these issueswere invoked in the discussions of whether theintroduction of transgenic herbicide-resistantever, the arguments were varied. All the partici-pants did agree that we are experiencing adramatic, world-wide loss of biodiversity andgenetic resources. The on-going destruction of DEFINITIONS OF GENETIC EROSION  CONCEPTS OF DAMAGE   Reference: Diversity of Species  extinction of wild plant species  nature conservation; loss of genetic resources for plant breeding  elimination of weed species from agricultural habitats  nature conservation; loss of useful organisms depending on such weeds  reduction in the number of crops grown in agriculture food supply becomes increasingly dependent on fewer  crop species reduction in the number of crops in the crop rotation  increased susceptibility to pests   and phytopathogens, and on food ssequence upply. increased use of pesticides, environmental damage Reference: Diversity of Plant Varieties   extinction of local cultivars (land races) at centres of loss of genetic resources for plant breeding  genetic diversity  fewer crop varieties cultivated in fields increased susceptibility to pests   tropical rain forests, for instance, probablyand phytopathogens; monopolising the seed marketeradicates thousands of species per week. Whileadded considerable negative impacts as well, itis not likely that herbicide-resistant plants willplay a significant role in this respect.the expansion of modern agriculture has indeed reduction in the number of registered (marketed) crop   same as above plus loss of options for farmers varieties  elimination of cultivars from breeding programmes loss of genetic resources for plant breeding   Issues of biodiversity: Will  1 crops accelerate genetictransgenic herbicide-resistantagricultural habitats?erosion in plant breeding and the number of cultivars for each crop smaller. It grown in the fields would become narrower andplants, the spectrum of crop species actuallywith the introduction of herbicide-resistanthusbandry at large. Key questions were whether,possible losses of diversity in the system of cropfor plant breeding. Other arguments addressedcultivars, thereby destroying genetic resourcesmight reduce the level of variability withinArguments were raised that genetic engineering  The term \"genetic erosion\" is used to designate problem areas should be distinguished:rotation and monocultures. Broadly, threecrops actually grown in the fields, lack of cropvars in plant breeding, the genetic uniformity ofloss of wild species in nature, the loss of culti-reference is made to heterogeneous issues: thediversity. Its definition remains vague sincevarious forms of loss of biological or genetic  46 Herbicide-Resistant Crops was further assumed that herbicide-resistant extinct. crop varieties monopolise the seed market, eitherbecause of economic advantages or privilegesresulting from patent law. The main objection tosuch scenarios was that lack of diversity withinthe spectrum of crops and varieties cultivatedwas the result of the political, legal and, aboveand not the result of any particular breedingtechnique. A good test would be to ask whetherthe problems would, in fact, be avoided if thetechnique were changed, i.e. if conventionalbreeding techniques were used instead of geneticengineering.all, economic conditions of modern agriculture, 3. Genetic resources for plant breeding are lost  modern, high-yield varieties. Although thesignificant factor in this respect.on a massive scale because, in the Third World,local, traditional cultivars (land races) of im-portant crops grown in the centres of geneticdiversity are now increasingly displaced by\"globalisation\" of agriculture, prevalent in theindustrialised countries, is a driving force behindthis process, herbicide-resistant plants are not a guaranteed through their inclusion in the genepools of new varieties from which old traits canreplace old varieties with new ones in the field.nevertheless, this is an unavoidable price to pay,cultivation at breeding stations. Moreover, thesince breeding is by definition designed tobe retrieved through suitable crossing. It is truecontinuity of genes from older cultivars is can be adequately ensured by gene banking andconservation, the protection of genetic resourcesCentral Europe at present. In contrast to naturebreeding does not seem to be a problem in4. Maintaining the level of biodiversity in plantthat, in this case, older cultivars will no longerbe grown and developed in the fields; 61  crops cause further losses of biodiversity andgenetic resources?Question 1: Will transgenic herbicide-resistant  Conclusions from the discussion cide-resistant crops will not have a significant 1. The main reason for global loss of plantbiodiversity is continued extinction of wildspecies in natural ecosystems. This implies adramatic loss of genetic resources for plantbreeding. The introduction of transgenic herbi-political and economic pressures to harness everimpact on this process. Some key factors are themore land for agricultural and industrial use,high population growth, rapid climate change,ill-conceived nature conservation policies, and(land races) still used in the Third World bynewly developed, high-yield varieties.the displacement of local, traditional cultivars  cated (cloned) in cell cultures does not imply afrom a few transformed cells identically repli-5. The fact that transgenic varieties are derivedloss of biodiversity. The development of trans-genetic variability within the cultivar. Theity which is, in turn, expressed when these cellsare crossed with others in the process of devel-oping a new variety. The genetic variabilitybetween varieties is, in contrast, quite limited(see below). However, this indicates, a lack ofdiversity in agriculture and not a loss of geneticresources.genic varieties has no influence on the amount ofcloned cells still contain all the genetic variabilfrom the local agricultural habitats. Althoughposes, it is sufficient if a species continues tospecies, i.e. regionally adapted variants, becomeresources are lost, however, when ecotypes of aexist in any other site or nature reserve. Geneticweed species from an entire region would notever, even the elimination, for instance, of a rarepreserved. In terms of genetic resources, how-nature conservation which requires that theconstitute a loss of biodiversity in terms of existing spectrum of species in all habitats beconjunction with transgenic herbicide-resistantcrops could lead to the elimination of rare weedspecies from the local seed banks and, hence,2. Extensive use of nonselective herbicides inthe effect would be local, it would neverthelessimply any permanent loss. For breeding purcrops reduce the diversity of crops and varie-Question 2: Will transgenic herbicide-resistant ties grown in agriculture?  Conclusions from the discussion  6. Diversity in crop varieties has increasedrather than decreased over the last decade, bothin terms of number of varieties registered byplant breeders and number of varieties actuallygrown in the fields. There is, nevertheless,reason to infer genetic erosion since, for eachcrop species, few varieties dominate in cultiva-tion and all varieties are closely related. Culti-homogeneous) imply higher risk of yield lossvars that are closely related genetically (i.e.through pressure from pests and phytopatho61 Expert report from Dr. H. Umbach, Dr. J. Zeddies and Aktions-Netzwerk, F\u00fcrth), in: Ressourcen\"; commentary by C. Freudling (Saatgut-Technik auf die Z\u00fcchtungspraxis und die genetischen(KWS) Einbeck): \"Auswirkungen der Herbizidresistenz-Dr. R. von  Broock  (Kleinwanzlebener  Saatzucht  AGMaterialien zur Technikfolgenabsch\u00e4tzung, Heft 11 (see appendix).   Part II: Empirical Findings-Impacts And Consequences 47 gens. This certainly applies if the plants are  Agronomic effects of protected only by the mechanisms of verticalpest resistance which can be easily overcome bymutation in the pest organisms.  2 transgenic herbicide-resistantcrops: technical gains,resistant weeds, and integratedcrop protection And, farmers prefer homogeneous stocks ofharvested crops easier to process.usually also the most successful on the market.ing in general. The best available varieties areto herbicide-resistant plants or genetic engineer-agronomic considerations which bear no relationvated in the fields results from economic and7. The low number of varieties actually culti- plants because these are easier to cultivate and The application of nonselective herbicides with  placed on the market.fast, few herbicide-resistant crops have beencarried out under practical conditions is growingtransgenic crops is still at the beginning stage inGermany. Although the number of field trials 62 Therefore, judgements practice.sional and subject to further demonstration inabout the agronomic advantages nonselectiveherbicides may have for the farmer are provi(8. The current law of plant variety protection  Saatgutverkehrsgesetz  in Germany) reinforces dures require that new plant varieties meet thethe varieties they find most suitable for theirtest is to ensure the quality of the seed a farmerend up with very similar products.products: Since all breeders use the best avail-cally encourages technical uniformity of seedpromote diversity on the seed market, paradoxi-designed to preclude commercial monopolies andavailable plant varieties for breeding, initiallyarea. Finally, the legal privilege of free use ofable varieties for further development, they alllegal test of \"value for cultivation\". This makescan be registered and marketed. The aim of thisthe market for seed products highly transparent,the trend towards homogeneity, because itpurchases, and to guarantee that all plants of avariety are suitable for a designed purpose, forinstance, wheat for baking bread or potatoes formaking chips. In addition, registration proce-requires a test of \"uniformity\" before a varietyso that farmers can easily and shift en masse to  tages were claimedIn our technology assessment various advan63: \u00b7 Weed control would become easier and more with nonselective, broad spectrum herbicides.the application of tank mixtures herbicides couldflexible. The underlying assumption was that,be spared, that problem weeds would be effec-tively controlled and that the opportunities forpostemergence treatment would increase. \u00b7 The farmer can use a wider range of herbicides and avoid one-sided (nonrotational) appli-cations. This is the minimum advantage claimedvalid even if these herbicides were otherwise notfor nonselective herbicides, since it would besuperior to the selective ones used up to now. \u00b7 With postemergence, nonselective herbicides, economic threshold criteria can be applied, i.e.anticipated costs of yield loss from weeds areless than the costs of the herbicide needed tocontrol those weeds.herbicide treatment can be spared if the impact on the level of diversity in crop hus-bandry.chosen and irrespective of whether special traitsusually long before a specific variety of crop iswithin the constraints of agronomic needs-16. Economic calculation and political regula-farmers choose to cultivate on their land. Thetion (quotas) determine which crop speciessuch as herbicide resistance are available in theparticular crop rotation sequence is decidedcultivars. Herbicide-resistant varieties couldcultivation would be prevented by quota restric-technical and economic advantages. This isprobably the case for sugar beet, at present. Butany further expansion of the area of sugar beettions in Europe. In general, the availability ofherbicide-resistant varieties is not likely todetermine farmers\" decisions about crop speciesto be grown; it will therefore have no significantattract farmers, however, if they offer clear  \u00b7 The farmer has more options to shift to new systems of crop husbandry, such as directdrilling, conservation tillage mulch cropping andmixed cropping, because these systems will beeasier to manage when postemergence, nonse-lective herbicides can be applied. \u00b7 Farmers gain flexibility with respect to which quence, since the nonselective herbicides havecrop species he can grow in the rotational se62 According to reports from AgrEvo, over 1700 field to be granted in the U.S. in 1997, soybean and sugar beetin 1998; see Rasche 1995. Approval of glufosinate resistant maize is expected1996). Resistant oilseed rape was approved in Canada insoybean and sugar beet resistant to glufosinate (autumntrials have been carried out with oilseed rape, maize,et al . (1996). Monsanto achieved U.S. approval of its glyphosate resistant soybeans in1994.   These soybeans have been cultivated on 1-2% of the soybean area in the U.S. in 1996 (Monsanto, pressrelease Information Sojabohne). 63   See also Wilcut et al. (1995); Burnside (1996: 400).  48 Herbicide-Resistant Crops low persistence and no carry-over effects to the herbicides does not meet the standards of intenext vegetation period. 64 are should not change this situation profoundly.must be placed on preventive measures, imply-and cultivation systems, breaks down in the faceof economic constraints. Nonselective herbicidesissues were discussed in this respect: Are eco-The question is, rather, whether they wouldimprove it slightly or make it even worse. Twonomic thresholds more likely to be observed ifnonselective herbicides are applied? Can theagronomic functions of residual weeds in culti-vated fields be maintained?grated crop protection. The idea that prioritying a revision of current crop rotation sequences  Most of these claims were controversial. It wasargued that the advantages, although possible intheory, could not be achieved in actual practice,and that they were outweighed by disadvantages. fewer rather than more choices of herbicides fornonselective herbicides increase the technical In particular, doubts were raised whether thenonselective herbicides currently under discus-sion would not also have incomplete spectra and,therefore, not be clearly superior to the selectiveherbicides already in use. On the other hand itwas argued that selective herbicides could bedriven off the market, leaving the farmers withweed control. In general, it was conceded thatfor implementing these systems.economic conditions there would be little scopesuch options was denied, since under existingbandry. However, the practical relevance ofoptions to shift to new systems of crop hus65 Question 1: Do nonselective herbicides pro- control and crop management?vide more flexibility and new options in weed Conclusions from the discussion   1. Nonselective herbicides applied in conjunctionwith transgenic herbicide-resistant crops provideadditional options for postemergent weed con-trol. They extend the range of choice for herbi-cide rotation. mechanism would be spontaneous mutations incan evolve through gene flux from the crop plant Arguments over possible agronomic disadvan-tages focused mainly on the emergence of herbi-cide-resistant weeds. Are nonselective herbicidesparticularly likely to produce resistant weedpopulations when they are extensively applied?Were this the case, then these herbicides wouldbecome useless for agriculture. Resistant weeds(hybridisation); however, the most relevantthrough herbicide application.individual weeds and selection of the mutants resistance to one and the same nonselectivecultivars of all row crops.herbicide were engineered into the commonin the crop rotation sequence, for instance, whennonselective herbicides were applied only oncethese in many areas. This could occur even ifculture. If they have significant advantages overthe total number of herbicides applied in agri-2. Actually, nonselective herbicides could reduce the herbicides currently used, they could replace including treatment with herbicides, should beof nonselective herbicides would be compatibleincreasing the number of crops in the rotationalinstance, growing competitive crop varieties,measures and good agronomic management, forweeds indirectly through preventive cultivationmise pesticide use and try instead to suppressThese standards require that the farmers mini-with the standards of integrated crop protection.A long debate in the technology assessmentaddressed the question of whether or not the useto suppress weed growth. Direct measures, adopted only when weed problems are so severethat the cost they might incur (in terms of yieldloss) would surmount the economic threshold ofthe cost for additional weed control; residualweed populations below this level are viewed notmerely as tolerable, but also as desirable.sequence, or using ground cover or mulch crops to suppose that this wdrive older ones off a market, there is no reason3. While new and better products can always  ill be the case for nonsethey would completely disappear as options forlective herbicides. Selective herbicides areherbicide treatment.will keep a share of the market; it is unlikely thatwidely used with many crops at present and they 4. Postemergence, nonselective herbicides can                                                     65   Export report on organic impacts commissioned from tary by Dr. P. Niemann (Biologische Bundesanstalt f\u00fcrLand- und Forstwirtschaft, Braunschweig), in: Prof. K. Hurle (Institut f\u00fcr Phytomedizin, Universit\u00e4tHohenheim): \"M\u00f6gliche Ver\u00e4nderungen in der land-wirtschaftlichen Praxis durch die HR-Praxis\"; commen-Materialien zur Technikfolgenabsch\u00e4tzung, Heft 12 (see appenmissioned from Prof. R. Heitefu\u00df, Dr. B. Gerowitt andPflanzenschutz, Universit\u00e4t G\u00f6ttingen): \"HR-Technik undintegrierter Pflanzenschutz\"; commentary by A. Gnekow-Metz, in: Dr. H. Steinmann (Institut f\u00fcr Pflanzenpathologie unddix). Expert report on integrated crop production com-Materialien zur Technikfolgenabsch\u00e4tzung, Heft 13 (see appendix).  There was agreement that the current use of                                                    64   On the discussion of possible cost benefits for farmers see section II C3 below.   Part II: Empirical Findings-Impacts And Consequences 49 improve weed control. They allow more thor- This assumes that nonselective herbicides indeed the risks of yield loss through herbicide applica-nificant advantages might be expected particu-larly for those row crops with wide row distancesuch as sugar beet or potatoes, but also foroilseed rape and maize. All of these crops aresubject to high weed pressure.ough elimination of problem weeds and reducetion, since the crop plants are insensitive. Sig- available.need not be applied in herbicide combinationsselective, postemergence herbicides currentlyand that they do less damage to crops than the  framework of conventional agriculture.herbicide-resistant crops were available; but, forresistant crops, but large-scale intercroppingsomewhat by the introduction of herbicide-more often cost-effective and could be boostedniques of minimal tillage (direct drilling) areeconomic reasons, it has been little used. Tech-systems. Ground cover to prevent weed growthdrilling, mulchseed or intercropping, whichcrops will do little to enhance a shift to suchcally, however, transgenic herbicide-resistantimply more effective soil conservation. Practi-in row crops, for instance, was possible beforesystems of crop husbandry, such as directcrops extend the range of technical options for7. Theoretically,  transgenic  herbicide-resistantwill hardly be economically viable within the 66 cides or in a series of repeated treatments. their spectrum is by no means complete.broader spectrum than most other herbicides,Although glyphosate and glufosinate have acombination (tank mixtures) with other herbi-plete spectra and must therefore be applied inever, if nonselective herbicides also have incom-5. These advantages may not materialise, how67 be recovered later without harming the crops.arise, a treatment that was spared previously cannecessary, i.e. when unexpected weed problemsspan available for postemergence treatment. Iffarmer gains flexibility with respect to the time6. With transgenic herbicide-resistant crops, the                                                    8. With transgenic herbicide-resistant maize, a monoculture could possibly be better managed.tice.according to the principles of good field prac-But monocultures are never advisable anyway, 66   Reschke (1996) summarises findings from field trials with transgenic herbicide-resistant sugar beets: \"Two applications of three litres of BASTA per heclitres per hectare (plus an additive of oil) provide suf-and plant growth enhanced, two applications of 1.5nearly all weeds. If weather conditions are favourableleaf stage of the sugar beet) provide good control oftare (one at the four-leaf stage, the other at the eight-ficient coverage, even for fool\"s parsley (Aethusa selective herbicides will hardly be a decisivecrops to be grown is above all contingent uponand are unlikely to have carry-over effects to thefactor for this choice. certain cases, because they have low persistenceeconomic factors, and the applicability of non-9. The use of glyphosate and glufosinate canallow greater flexibility in crop rotation innext vegetation period. However, the choice of cynapium) which is otherwise difficult to control. Annual nettles (Urtica urens) which occur in rare instances are somewhat less sensitive if weather condi-tions are not favourable; the same applies (although toa lesser degree) to cleavers (Galium aparine) and field pansy (Viola arvensis). These require higher dosage, as a rule, or a supplement of one litre of GOLTIX perhectare. This supplement also prolongs the herbicidalBASTA is optimal in terms of effectivness and cost ofweed control.\"effect and, in combination with 1.5 to 2 litres of weed populations?ticularly prone to produce herbicide-resistantQuestion 2: Are nonselective herbicides parCrop tolerance to glufosinate has been ranked very high Conclusions from the discussion  herbicide-resistant oilseed rape in Canada, according to a(9.45 of 10 points) by farmers who cultivated transgenicsurvey by AgrEvo (Rasche  et al ., 1996: 10). Reschke herbicide (Reschke, personal communication).(1996) reports comparable results with the application ofglufosinate in transgenic herbicide-resistant sugar beet.With glyphosate-resistant sugar beet sufficient control canbe achieved with two applications of three litres of the depend on the characteristics and managementcrops. Resistant weeds presuppose that resistantmutants evolve which are fit enough to surviveand reproduce. The rate of spread will thendepend on the selection pressure exerted on theweed population. Selection pressure, in turn, willherbicide mixtures.of the herbicide, e.g. its spectrum, phytotoxicity,the rate and frequency of its application, orconjunction with transgenic herbicide-resistantspecific to herbicides which are applied inspread of resistant weeds. The problem is not 10. There is a certain risk with any herbicide ofbecoming ineffective with time because of the 67   In herbicide-resistant sugar beet appreciable reductions release Information Sojabohne, December 1996).from 1.13 to 0.74 kilogram per hectare (Monsanto, pressherbicides and reduce the amount of herbicides by 30%-glyphosate can replace a combination of five differentglyphosate in sugar beet will be comparable. In soybeanapplications); see Reschke 1996. Reductions withversus eight to nine litres per hectare (in three to fourtotal of five to six litres per hectare (in two applications)if glufosinate is used in a tank mixture with Goltex: ain the rate of herbicide application can be achieved even  11. Since nonselective herbicides with a broad  50 Herbicide-Resistant Crops spectrum and high phytotoxicity exert a greater Question 3: Is the application of nonselective  herbicides, they will, in principle, increase therisk that resistant weeds would be selected,provided that suitable mutants exist.pressure on weed populations than conventional grated crop protection?crops compatible with the standards of inte-herbicides in transgenic herbicide-resistant weed mutants have been observed. Neverthelesssuch mutants may still be possible.(not involving transgenic plants), yet no resistantherbicides have a long history of extended usecases of glyphosate and glufosinate. Thesehand, this risk seems to be relatively small in theto render the herbicide ineffective. On the othermutations in the target enzymes of weeds sufficeurea, resistance can evolve easily because singleenzyme of the herbicide. In the case of sulfonyl-with sufficient fitness depends on the target12. The probability of resistant mutants evolving  Conclusions from the discussion  as a strategy of weed control. The current use ofprovide a more attractive alternative. Preventiveas increased dependency on the weather, unpre-constraints would also apply for nonselectivewith ground cover etc. To the extent that thesedictable effectiveness, or management problemsgrated crop protection will be modest at best.labour input and investment costs for newweed management not only implies increasedmeasures) are neglected because herbicides (in particular, through appropriate cultivationindirect control through preventive managementintegrated crop protection. Existing options forherbicides does not comply with the standards ofmachinery, but also technical difficulties, suchthey will probably stabilise herbicide treatmentthe options for herbicide treatment. As a result,15. Nonselective herbicides improve and extendherbicides, their possible contribution to inte68 The risk of spontaneous mutations conferring resistance toweeds may be further reduced if the mechanismof herbicide resistance in crop plants is derivedfrom bacterial genes. options for weed control.cause of economic considerations and not thecide application and avoid excessive treatment.Crop sequences may not always correspond tothe rules of good field practice, but this is be-13. No reasons were given in the technologyand that they are therefore more likely to lead toselective herbicides would be routinely misusedassessment to support the hypothesis that non-the selection of resistant weeds. Rising costs provide an incentive to reduce the rate of herbi70 economic thresholds to be observed in herbicideand mulch cropping, as well as the feasibility ofthe prospects for cultivation with direct drillinggrated crop management because they improvebicides are more in line with the ideas of inte-16. In theory, postemergence, nonselective her- use. In practice, however, nonselective herbi-cides will probably have little effect in thisrecognised by farmers in weed control, and theavailability of nonselective herbicides willprobably not make a great difference.respect. Economic thresholds are not widely  These disadvantages could probably be avoided14. The use of nonselective herbicides withtion sequence are resistant to the same herbicide.through all stages of a crop sequence is notadvisable, since it clearly increases the risk ofherbicide-resistant weeds. Furthermore, volun-teer plants from the previous vegetation periodif nonselective herbicides were used only once inwill be difficult to control if all crops in a rota-monocultures or without herbicide rotationa rotational sequence. 71                                                                             \"The risk of selecting herbicide-resistant weeds in a selective herbicide in a naturally tolerant crop. In ei-ther case repeated use of the same herbicide or herbi-cides with the same mode of action will eventually se-lect for herbicide-resistant weed biotypes. This can be[herbicide-resistant crop] is no greater than using aprevented or greatly delayed by using effective inte-grated weed management strategies in all parts of thecrop producvtion system. Most importantly, avoidusing the same herbicide or herbicides with the samesite of action routinely in any cropping system.\" 69                                                    68   Rasche et al. (1996: 9) emphasise that any mutation in would be lethal for the plant, and hence the spontaneousthe target enzyme of glufosinate (the glutamin synthetase)despite wide ranging application of glufosinate over adevelopment of herbicide resistance in weeds is unlikely.Consequently resistant weeds have never been observed,period of more than 10 years. On the other hand, glypho-sate resistance has apparently been detected recently in 70   As one participant in the technology remarked, the Lolium rigidum . This weed has accumulated several plough, new seed-drilling techniques are required to copebeen thwarted by the fact that, without the use of theintroduction of conservation tillage (minimal tillage) haswith the mulch and surface weeds. \"This means thefarmer has to buy a second drilling machine.\" multiple resistance to at least nine dissimilar herbicideresistance mechanisms; an Australian biotype showschemistries, according to Preston et al. (1996). 71   This tentative conclusion was criticised by one participant, who claimed that herbicide-resistant crops are a realstep towards integrated crop protection,  \"because for the first time a herbicide will be available 69   See also the summary of Thill (1996: 336): which is effective against all weeds, including thelarge ones. The biggest barrier to observing economic   Part II: Empirical Findings-Impacts And Consequences 51 17. Even if economic thresholds are not  they occur in practice, has yet to be demonlead to appreciable reduction in the amount ofherbicides applied.actual weed infestation in the field. This couldthe rate of herbicide application, depending onpostemergence, nonselective herbicides to reduceobserved, farmers have better opportunities with ease.increase the risk of transmission of plant dis-also serve as habitats for plant pests and theystrated. Residual weeds, on the other hand, can 72 Economic effects of transgenic  nonselective herbicides would have such anweeding\"), contradict the standards of integratedwith combinations of herbicides, nonselectiveherbicides will not mean increased smore effective than previously available selec-sate) or contact (glufosinate) herbicides, they actalthough they have a broad spectrum and areemerged. Weeds can grow up again immediatelycrop protection. It is doubtful, however, whethercompletely void of any residual weeds (\"cleanafter herbicide application, from the seeds in the18. Herbicide treatments which leave fields effect. Glyphosate and glufosinate, for example,tive herbicides, are far from leaving fieldscontrol those weeds which have alreadyon plants which appear in the field, i.e. they onlypermanently free of weeds. As systemic (glypho-soil. In crops which had previously been treateduppression  3 herbicide-resistant crop plants:profits, costs, andconcentrations of weeds.  Discussions   about the economy of transgenic those plants on the economic situations of indi-vidual farmers and the structure of seed produc-tion and markets.reference, and considered possible impacts oftem of intensive agriculture as the frame ofherbicide-resistant plants used the current sys74 approach in economics. But it disregardsSince the evidence presented in our technology\"external\" costs, in the case of herbicides,possible damage to the environment, or the costsof developing and testing herbicides. This maybe methodologically justifiable, if conventionalagriculture is chosen as the frame of reference.Measuring costs and benefits in terms of pricesassessment suggests that the ecological andwill not differ significantly from the conse-quences associated with current herbicide use,external costs should be comparable and may,therefore, be disregarded.social consequences of nonselective herbicidesof agricultural inputs and products is a standard 73 from crops or harbouring beneficial organisms.principles of integrated crop protection would beWhat would certainly not be compatible with thetion of nonselective herbicides may not begrated crop protection, namely, diverting pestsascribed to residual weeds as a factor in inte-sufficient to fulfil the agronomic functionsticides had to be applied to fields already treated19. Weed stocks which re-emerge after applica- if, due to the loss of residual weeds, more insec-ual weeds are largely a matter of theory; whetherwith nonselective herbicides. As yet, there are nosigns that this is in fact the case. Moreover, theso-called positive agronomic functions of residcomprehensive economic assessment of herbi-tions in conventional agriculture as part of ainclude the external costs of herbicide applica-it would indeed be reasonable and legitimate topoint notwithstanding, there was agreement thatvalid approach, however. The dispute over thisuse was not accepted by all participants as aagriculture and current practices of herbicideComparison to the status quo in conventional cide-resistant crops. To that extent it was atfarmers and consumers are not the sole criteriafor economic costs and benefits.least implicitly conceded that market prices for thresholds in weed control has been the fear of not being able to deal with large weeds with certainty.\" 72   The standards of integrated crop protection are not concept of economic thresholds. As a participant writes,practices solely because they do not comply with theclearly defined. It would be inappropriate to reject current no way to monetarise ecological, social andpolitical consequences without making arbitraryunresolved methodological problems. There isNevertheless, calculations of external costs raise  \"Instead of adopting the economic thresholds proposed by the scientists, farmers have frequently re-duced the amounts of herbicide they apply by up to athat a residual weed population remains which doesno economic damage.\"half if weed cover is low, with the same result, namely 73  74   Expert report commissioned from Prof. V. Beusmann  As one participant notes: \"In view of the lower persis- (FSP Biotechnik, Gesellschaft und Umwelt, Universit\u00e4tHamburg): \"Betriebs- und volkswirtschaftliche Auswirlikely to be in the fields than previously.\"tence of nonselective herbicides, residual weeds are more kungen des Einsatzes herbizidresistenter Nutzpflanzenf\u00fcr Agrar\u00f6konomie, Universit\u00e4t Kiel), in: (HR-Technik)\"; commentary by Prof. R. M\u00fcller (InstitutMaterialien zur Technikfolgenabsch\u00e4tzung, Heft 14 (see appendix). in order to prolong herbicidal effects.This argument fails, however, if glufosinate is applied in a tank mixture with a herbicide which is explicitly added  52 Herbicide-Resistant Crops too, have incomplete spectra and, therefore, have assumptions. The technology assessment did not totally rule out all the calculated benefits.glufosinate, however, gaps in the spectrum willwith other herbicides or in repeated treatments into be applied in combination (tank mixtures)order to be fully effective. For glyphosate and would show, in the final analysis, that the use ofcomprehensive balance of all costs and benefitsnomical.herbicides in modern agriculture was not eco-not, therefore, try to provide such calculations,and the results remain a matter of speculation. Itwas clear, however, that there was no agreementamong the participants about whether or not a 75 prices sooner or later.the consumers in the form of lower productfor the farmers would have to be passed on tokets, it is to be expected that financial benefits3. Given the competition on agricultural marare, in part, controversial. addition, it made assumptions about reductionsbased its calculations on 1992 market prices. Inreport delivered in the technology assessmentprices for nonselective herbicides constant. Theprices have not yet been established. Nor are thecrops have hardly arrived on the market, seedat present. Since transgenic herbicide-resistantherbicides involves a high degree of uncertainty,farmers might harvest from using nonselectiveCalculating the economic gains individualin the rate of herbicide application and furtheradvantages from nonselective herbicides that 4. In many cases nonselective herbicides willcompared with those herbicides used at present.Nonselective herbicides will only add to thenumber of postemergence herbicides from whichfarmers can choose, and they must face compe-tition from products already established on themarket. Under such conditions, nonselectiveherbicides may have a competitive edge, if itturns out that they do indeed mean easier man-agement and greater flexibility of weed controlfor the same price. probably not offer tangible price advantages herbicide in a \"package\".ers and herbicide manufacturers become morebecome economically more dependent because vanced in public debates that farmers wouldalso considered the argument frequently ad-the seed market. In this context, the discussionsvarieties could be pushed to gain a monopoly onlikely, and whether herbicide-resistant cropamong breeding companies, and between breed-seeds together with the matching nonselectivethe main point made was whether concentrationsherbicide-resistant crops on the seed business,With respect to possible impacts from transgenicthey would be forced to buy herbicide-resistant  Question 2: Will transgenic herbicide-resistantand make farmers more dependent on herbi-cide manufacturers?cultivars gain a monopoly on the seed market Conclusions from the discussion  5. No single crop variety will come to dominate the seed market just because it has been com-plemented with transgenic herbicide resistance.If herbicide resistance constitutes a real eco-nomic advantage, then it is rather to be expected                                                    crops and nonselective herbicides more cost-Question 1: Are transgenic herbicide-resistanteffective for the farmer?  75   According to calculations by Reschke (1996), maxiDM 250 per hectare (two applications each of three mum costs for weed control in sugar beet would belitres of Basta (glufosinate) plus one kilogram of Goltix); thisimplies a savings of DM 100 (30%) compared to the costfor current applications of selective herbicides (DM 350).Savings increase up to 45% if fields are infested withfool\"s parsley or if mulchseed has been applied(DM 450). Conclusions from the discussion  through postemergence treatment, minimisesyield loss from crop damage. Calculationscrops. suggest that there is a clear cost advantage forsugar beet, perhaps a saving of up to 50%.Smaller advantages can be expected for maizeand soybean, followed by winter rape and po-weeds, some benefits may be derived for alltato. If fields are heavily infested with problemtotal amount of herbicides used at present and,farmers economically insofar as it reduces thejunction with resistant crop cultures benefits1. The use of nonselective herbicides in conU.S. (1996). Although the seeds are 25% more expensive The figures may be even more favourable with glypho-sate-resistant sugar beet: about DM 100 for two applica-tions with two to three litres each (Reschke, personalcommunication). According to IHE (1994: 42\/44) datafrom the notifier suggest that savings could amount to 50-70% (75 ECU per hectare instead of 150-250 ECU); ifmight still be 30%. On the other hand, Meisser andfamers still gain from the reduction in the amounts ofGuenat (1996: 27) estimate a gain of no more than 2-7%on gross margin for sugar beet in Swiss agriculture. Withrespect to glyphosate-resistant soybeans herbicide costsare reduced from $54.42 per hectare (1993\/94) to $23.30herbicides used (Monsanto, press release Informationproblems with nettles are taken into account the savingsSojabohne, December 1996).  2. The calculated savings will become less ordisappear altogether if nonselective herbicides,  fact, what is being done.  Part II: Empirical Findings-Impacts And Consequences 53 that it would be engineered into all the major 76 cultivars which have a significant market shareat present. This will also apply to the cultivarsof sugar beet currently grown. Food supply: Is a contribution    4 to be expected from transgenicherbicide-resistant crops? economic crisis in agriculture is the main driving6. Economic concentration is likely to continue factor behind this trend. To a certain extent,US and many European countries. The chronicdoes not warrant a prediction of that kind.increased is an open question. Economic theoryties marketed would decline as concentrationcapital intensive. Whether the number of varie-process, if it renders competitive breeding moremodern biotechnology could accelerate thisin the seed business, as indicated by trends in the  It is not particularly sensible to ask whether which can contribute significantly to solving thetransgenic herbicide resistance is an innovationproblems of world food s upply. This is obviment, the question was therefore broadened toously not the case. In our technology assess-sions focused on agriculture in Third Worldinclude the possible contribution of herbicides ingeneral as a strategy for weed control. Discus-countries. 77 available without an additional product insepa-ties, and this is obviously an absurd assumptionfor all herbicides.rably linked to it. The same applies in reversefor the herbicide, if it could only be sold togetherwith some specific crop variety. For the herbi-cide manufacturer, the \"package\" would, in anytogether with a herbicide is by definition at aapplication other than that associated with thecompany\"s own herbicide-resistant crop varie-case, only be conceivable if the herbicide had nodisadvantage compared to a variety which iswould try to force farmers to buy \"packages\" ofA crop variety which can only be purchased7. The assumption that chemical companieswhich become involved in the seed business herbicide-resistant cultivars and matchingnonselective herbicides is not realistic. In eco-nomic terms, it would be definitely more profit-able to sell the seed and the herbicide separately. need for technological innovation and vice versa.play the need for political reform off against thepolemics in the public debate, which tended toquestion of increased production in agriculture.question of distributive justice, and a technicalsupply is clearly both a social and politicalParticipants had no doubts that world food They thus by-passed much of the ill-conceived herbicides. Others, in contrast, argued that aeconomic conditions of agriculture in Thirdsubsistence economy of smallholder farmerswould not feed urban masses and that thereforeindustrialised, high-input agriculture is indis-perspective, herbicides and also herbicide-resistant crops were a possible technical option.There was further disagreement about whetherherbicides could be considered a useful option atall for weed control under the natural, social andWorld countries (tropical climates, large sectorsWhereas all the participants agreed that foodof subsistence economy, and cheap labour).pensable in the Third World as well. From theirnents of this scheme excluded any use of farming and the improvement of indigenous,their hopes on the development of smallholderremained a matter of controversy. Some placedmust be increased, the strategy to be chosenproduction in the countries of the Third World\"appropriate\" agricultural technology. Propothe market.or whether the herbicide is freely available on\"package\" including the nonselective herbicidespective of whether a company offers aown crop varieties. This is true, however, irre-monopolise herbicide resistance genes for theirindeed expect extra profit if they were able to8. Seed companies, on the other hand, could sales of nonselective herbicides to exclusivepackages with a limited number of transgenic9. For herbicide manufacturers, in contrast, itwould be sheer economic nonsense to restricters. There are some indications that this is, ingenes freely, i.e. without license fees for breed-economical to provide the herbicide resistancenot. From their perspective, it might even beas possible, whether they own these varieties orin having them transferred to as many varietiesown resistance genes, they must have an interestherbicides. Therefore, if herbicide manufacturersthe limited period of patent protection for theirvarieties. They are bound to exploit to the full  76   It seems difficult to anticipate commercial strategies of a return on investment from licencing the herbicideresistance gene, if the herbicide is off patent, which isalready the case for glyphosate and will be the case forglufosinate in a few years.herbicide manufacturers. These must, of course, try to get 77   Expert report commissioned from S. Neubert and J. Knirsch (Pestizid-Aktions-Netzwerk, Hamburg): \"DerBeitrag des Anbaus herbizidresistenter Kulturpflanzen f\u00fcrdie Ern\u00e4hrungssicherung in der Dritten Welt\"; commen-tary by  Prof.  K. Leisinger  (Ciba  Geigy  AG,  Basel),  in: Materialien zur Technikfolgenabsch\u00e4tzung, Heft 16 (see appendix).  54 farming would produce sufficient food surplusesHerbicide-Resistant Crops to feed the masses of people in the expandingurban agglomerates of the Third World.  It was not possible to deal with these issues instance, it has yet to be demonstrated howfollowing conclusions are preliminary remarkswhether industrialised farming with chemicalinputs or organic farming with appropriatetechnology should constitute the model for thefuture of agriculture. It became clear in theThird World reflects the general battle overother hand, it is not clear how the productivity oftechnology assessment, however, that both sidesto an ongoing discussion. The controversy overadequately in our technology assessment . Theincreased to such a degree that food spolicies for agricultural development in theface a battery of unresolved problems. Forfarming systems which rely on \"appropriate\"extended industrialised, high-input agriculturecan be ecologically stabilised in tropical climatesand whether it would constitute a sustainablebasis for increasing food production. On thetechnology and reject any chemical inputs can beupply would be guaranteed in the future. 4. A dramatic increase in Third World agricul-supply in the l solution might be a \"dual system\" of agriculturetural productivity is indispensable. One possiblewhich relies, on the one hand, on a sector ofsmallholder farming producing mainly for self-subsistence in rural areas and, on the other hand,to avoid breakdowns in food production andproducing for urban populations. However, aon a high-input, industrialised farming sector\"dual system\" of this nature would only be ableong run, if industrialised agriculture can be made ecologically sustainable,particularly in tropical climates. seem to tolerate Third World agriculture\"sthis option smallholder, labour-intensive farming 5. Furthermore, a \"dual system\" policy woulddisintegration into separate sectors, a traditionalone and a modern one. The effect might well bethat the rural areas become even more margi-nalised. In fact, it might be preferable to mod-ernise agriculture and develop the infrastructurethroughout all rural sectors and areas. Underwould be guaranteed a significant place inagricultural production and it would have to bepromoted. In general, the development of ruralareas will be the key factor for comprehensiveeconomic progress in many countries of theThird World. ised agriculture be played off against oneShould smallholder farming and industrial-food supply for a growing number of people?quired in Third World countries to guaranteeQuestion 1: What type of agriculture is re-another?   Conclusions from the discussion  recent years because of the \"green revolution\"1. Hunger is endemic in many countries of theThird World, not because there is a lack of food,but because there is a lack of income. Domesticproduction of food has increased considerably inamong other factors. Food s upply is nevertheless afford to buy food.those in underdeveloped rural areas, cannotnot guaranteed since poor people, especially  6. It must be emphasised that increased agricul-tural production is a necessary but not sufficientcondition to guarantee food s upply. Problems of means. This includes no discrimination and a\"fair share\" for Third World countries withinthe international trade system.just distribution must be solved by political inadequate distribution than of inadequateand not just new technology; and transgenicpopulation, food shand, given continued growth of the worldreform and economic development are needed, 2. At present, hunger is more a problem ofherbicide resistance engineered into crop plantsproduction. To solve this problem, politicalis certainly not part of the solution. On the otherupply w ill again become a Question 2: Can herbicides and hence nonse-usefully in Third World agriculture?genic herbicide-resistant crops be appliedlective herbicides in combination with transwhich increase agricultural productivity willproducts. Therefore, technological innovationscontinue to be crucial for future food sproblem of absolute, available quantities of foodupply.  Conclusions from the discussion mercial inputs, such as chemicals or transgenicseeds. And, since unemployment is high in ruralareas of the Third World, manual weed controlwould appear to be a suitable alternative. There-fore, if subsidies for chemical inputs are avail-size, cultivation systems and crops. Herbicidesers because they lack cash income to buy com-will not, as a rule, be used by smallholder farm-able, they should be invested in pest controldepend on regional and sectoral factors, farmfor weed control in Third World countries will7. Whether or not herbicides are a useful option  3. Problems of hunger are most severe for  hand, it cannot be expected that smallholderand should be further developed. On the otherpeople living in rural areas. To feed these peo-ple, smallholder farming is an important basis   Part II: Empirical Findings-Impacts And Consequences 55 (insecticides or fungicides) rather than in weed by making mixed cropping in large, monoculcontrol (herbicides). Manual weed control isrational in economic terms, despite the fact thatit may be otherwise undesirable to use much ofthe labour force in rural areas, especially womenand children, to do the hard work of hoeing. soil protecting methods of conservation tillagehowever, improve the prospects for shifting toadopted in practice. Nonselective herbicides do,are no indications that such a strategy would bewere divided over this point. In any case, theretural fields a feasible technical option. Opinions(minimal tillage). farmer in the final analysis.yields and income, must assessed case by case.would be profitable, and would in fact increaseand machinery. Whether or not herbicide usewhose production is based on chemical inputsoption for middle to large-sized, intensive farms8. On the other hand, herbicide use can be anThis assessment will rest with the individual  herbicides are applicable, in principle, are alsozones. Some of the most urgent weed problemsare typically grown by smallholder farmers whoof question for another reason: since these cropslike sorghum or millet, herbicide use is also outwhich are highly infested by parasitic weeds,the weeds appear in the fields. For many cropsto crop roots will have already occurred beforehardly be controlled by herbicides, since damagein tropical zones, such as parasitic weeds, cantropical climates than for more moderate climatewarranted.cation (dosage, effectiveness) are different for9. Technical specifications for herbicide appli-cannot afford chemical inputs. On the otherhand, a number of important crops to whichless susceptible to parasitic weeds. Therefore, ageneral argument that herbicides, includingnonselective herbicides, cannot be used effec-tively for weed control in tropical climates is not  78 the question whether or not transgenic herbicide-be used to improve this situation, for instance,resistant crops and nonselective herbicides couldwhich cause the most severe problems of soilerosion. Our technology assessment consideredviable. But exactly these cultures are the ones chemical and modern machinery inputs can onlybe sustained in the long run, however, if thesevere ecological problems in tropical agricul-ture can be resolved-problems of soil fertilityand soil erosion above all. It is mainly in termsof large-scale monocultures that herbicide10. Yield increases which result from highapplication will be technically and economically                                                    78   Gressel (1996) provides a much more optimistic control of parasitic weeds, such as broomrape (crops in Third World countries. He reports efficientassessment of the possible role of herbicide-resistantorobanche) and witchweed ( Striga), as well as  Cyperus through glyphosate, because the herbicide is translocated. \"At present the only cost-effective control for  Cyperus and Striga is the too-commonly practiced abandonment of farms.\" (243)    important points in the conflict over herbicide resistant crops. Apparently no side was preparedto make such a declaration.  PART III:  NORMATIVE EVALUATIONS ETHICS, LAW AND POLITICS  Our technology assessment was a pluralistic procedure. The participants represented a broadassessment; rather, it is a consequence of thespectrum of political interests and frequentlythe public arena.proponents in the assessment procedure and inway in which the conflict over herbicide resis-tant crops had been framed by opponents andbe blamed on the procedure of the technologyevidence was criticised. However, it can hardlynormative evaluation. The focus on scientificrelevant empirical facts than the criteria ofdifferences. Participants argued more about thecontroversies rather than political or ethicalnumerous discussions concentrated on scientificheld contradictory views. Nevertheless, our known? Is it legitimate to compare the riskseconomic need be a prerequisite for the approvalof transgenic plants? These are the questions towhich discussions will shift once empiricalcontroversies are either resolved or reach animpasse.from transgenic and nontransgenic plants? What of proof for risks which may be hidden or un-plants count as damage? Who bears the burdenShould the spread of herbicide resistance to wildmanipulation of plants morally acceptable?normative evaluation unresolved. Is the geneticScientific discussions leave the problems ofis a relevant benefit? How can risks and benefitsbe weighed against each other? Should socioand envisaged clear benefits from the technologyhealth, ecological stability, food sappeal to political and ethical values (especiallymore profitable. Both sides in this conflictenvironmentally more friendly, more flexible andbecause weed control in agriculture will becomeyield no appreciable benefits. The proponents, inrisks for human health or the environment, andherbicide resistant crops imply considerableWithin this framing opponents claimed that contrast, denied that there are any specific risksupply) which bred plants? If herbicide resistance genes escapeherbicides used decrease when nonselectivethe natural ecosystem? Will the total amount ofare enshrined in social consensus and thereforecannot really be disputed. Dispute arises overthe empirical statements on which both sidesbase their claims: Can unexpected toxic sub-stances be metabolised in transgenic plants?Could the same also occur with conventionallyherbicides are available? And so on . . .to wild populations, will this have impacts on the issues mentioned have already been coveredsary for coping with the problems posed by ation in a technology assessment. The very factnot the ultimate criterion of normative evalua-ing means that it can and should be used as aforum where one can raise issues of legal andconstitutional change, or propagate the reforma-tion of moral standards if that is deemed neces-new technology. Our technology assessment wasNormative discussions do not start at zero. Alloccasionally transformed into such a forum,although consensus was rarely achieved.distance from the true process of decision mak-that a technology assessment operates at someBut, existing law is only the starting point; it is by existing regulations in one form or another. does not mean that it has been resolved in anyable. However, the fact that a problem is oldThe basic normative problem underlying all thenologies generate today. Solutions which maygies. What is the appropriate response to theuncertainties, and objections which new tech-way. There is no reason to belittle the worries,discussions is how to deal with new technolo-on their way of living has truly become unbear-challenges of technical innovation? This is by notechnological change and the pressure it imposespeople have always complained that the speed ofgies. In every epoch, resistance was endemic;burdened with having to adapt to new technolo-modern societies, people have been continuallymeans a new problem. Since the advent of  what they say in public, risks and benefits are noclared right at the beginning, that, contrary toinevitable in the technology assessment. It couldfore, preoccupation with scientific issues wasdiscussions centred on these arguments; there-argument. In accordance, expert reports andpolitical or moral evaluation but on scientificanswer is at all possible) would not depend onquestions (including the question whether antechnology assessment that answers to suchIt was agreed among all participants in the only have been otherwise had the parties de-  58 Herbicide-Resistant Crops have been appropriate in the past can fail today  IS THE GENETIC MODIFICAdeveloped appropriate methods and regulationshave unleashed can never be put at rest. Thecurrent controversies surrounding genetic engi-neering may be taken as evidence of this.for dealing with the technological dynamics theyif innovation is piled upon innovation. Thequestion whether modern societies have already  A PERMISSIBLE?TION OF PLANTS ETHICALLY There is consensus in our society that we have a  protection of species diversity and commitmentjust arbitrary political preferences. They aremoral obligation towards nature. Technologicalintervention should not call into question the\"sustainable\" use of nature, or threaten theto the long-term stability of ecosystems are notsurvival of human beings. Nature conservation,necessary conditions for the survival of human-kind and, therefore, have the status of moralimperatives. Moral obligation is based on humaninterests and rights for the present and for futuregenerations. This is an anthropocentric view: Wemust respect nature \"for our own sake\". that decisions on major innovations be trans-tion, regulation of tangible risks, questioning the If the discussions in our technology assessmentare taken to reflect the level of awareness ofpeople in general, they reveal that the range ofviews on how society should react to the chal-lenges of a new technology is really not verybroad. This range includes outright moral rejec-social need for a new technology and the demandwhat will be considered in detail below.bodies. These positions correspond broadly toferred to democratically controlled political 79 society. It rules that we are responsible for thetion of plants is not morally permissible if it Anthropocentric ethics represents theconsequences of our actions; \"Do not harm!\" isthe prime duty. On this view, genetic manipula-uncontested minimum of moral standards in ourentails unacceptable risk for humans and thebe no other hand, in the absence of such risk, geneticnatural resources on which we depend. On themanipulation becomes morally neutral. On thebasis of anthropocentric ethics, then, there cana priori  moral objection to transgenic crop ment.agreement within society, but rather how tocal issues, disputes over value judgementscannot be said to have one correct solutionwhich must, in principle, be reached by everyonewhen arguments are exchanged in a true dis-real issue in dealing with questions of evalua-course. There remains scope for dissent. Theresistant crop plants should be left to observersconsiderable \"judicial restraint\". But therecontrast to the scientific claims raised by theparticipants, no attempt has been made to inte-grate the various normative claims and deriveoverall \"conclusions\". Participants agreed thatproduce legitimate decisions despite disagree-the final judgement of transgenic herbicidewould seem to be no alternative. Unlike empiri-society. The technology assessment displayedaccepted values? What are the implications forimplications and problems associated withdecision makers. And one can foresee that A correct account of the normative discussionsin our technology assessment must document thedifferences in judgement among participants.This will not exclude a critical analysis of thevarious stances: What are the criteria for therored in the on-going public controversy in ourjudgements? Are they consistent with otherof the technology assessment and to politicalcomparable cases? What else would need to betion, therefore, is not how to produce normativeregulated if the proposals were adopted? Innormative disagreements which were irreconcil-able in our technology assessment will be mir- plants.                                                    modification of plantsever, thrown up more radical moral issues. Is it Public debate on genetic engineering has, how-permissible to engineer living beings like ma-chines? Should humans have the right to breakthe barriers natural evolution has erected for thereproduction of organisms? Do we owe respectmoral objections to genetic engineering can berisks becomes superfluous. Such objectionsexpert report on ethical aspects of the geneticconcern the very act of intervention into nature,rather than its further consequences. Proponentsof this view sometimes postulate new moralgoods which demand our unconditional respect,such as the \"integrity of evolution\". Ethicalraised at this level, then the need to examinereservations of this kind also had a role in ourtechnology assessment. In the discussion of theto nature \"for its own sake\"? If substantive 80, participants considered                                                    80   Expert report commissioned from Prof. G. Altner (Institut f\u00fcr Evangelische Theologie, Universit\u00e4t Ko-blenz): \"Ethische Aspekte der gentechnischenVer\u00e4nderung von Pflanzen\"; commentary by A. Stanger(Zentrum f\u00fcr Ethik in den Wissenschaften, Universit\u00e4tT\u00fcbingen), in:  Materialien zur Technikfolgenabsch\u00e4tzung, Heft 17 (see appendix). 79   Specific recommendations for regulations are dealt with in section III E below.   Part III: Normative Evaluations-Ethics, Law And Politics 59 whether the production and release of transgenic cannot possibly imply the right that no other newvarieties just as much as genetic engineering.agriculture, in this case, resulting from geneticthe introduction of additional crop varieties inevolution\", such a right would not be violated byfar as to assign crop plants a \"right to their ownthey are \"unnatural\". Even if one would go soadapted to suit human needs and, to this extent,ture. But crop varieties have always beenplements the crop varieties available in agricul-these plants for cultivation. Gene transfer sup-individual crop plants and the propagation ofThe existing spectrum of natural species ismoral objection to genetic engineering in plants.clearly not affected by the transfer of genes tolevel; but even this still fails to reveal a credible\"respect the integrity of plants\" to the speciesOne can perhaps apply the moral obligation to species (crop varieties) be introduced alongside.New crop varieties may displace old ones inagricultural fields and, in the longer term, per-haps at breeding stations. But if this contravenesour moral obligations to nature, then, logicallywe must proscribe conventional breeding of newmodification. A \"right to one\"s own evolution\" crops would be morally impermissible from thepoint of view of a \"biocentric\" ethical view, i.e.one which demands respect for nature for itsown sake.  Is genetic engineering of 1  \"for its own sake\"?plants incompatible with themoral respect we owe nature  Even if one accepts the moral perspective of crop plants should be absolutely unacceptable.keep anG\u00fcnter Altner argues that humans are obliged tobiocentric ethics, it is still by no means obviouswhy the transfer of herbicide resistance genes to  \"acceptable balance between respecting the self-purposiveness of nature and sub-jecting nature to human interests\".  He sees four reasons why transgenic herbicide resistant crops could be ethically unacceptablethe sake of plants\" if gene transferand calls for a moral halt to the technology \"for \u00b7  has adverse effects on the physiological From a biocentric point of view, a valid moral stability of the plants, combine what natural evolution has separated.prohibit us from using human technology re-species barriers would not be permissible be-cause it interferes with the natural balance ofgenes in the host species. This view rests on thepremise that this balance is itself a moral goodand that therefore respect for nature would second criterion: the transfer of genes acrossgrounded on ethical principles remained an openquestion in the technology assessment. It seemedthat those who adopted this view could only tryto convince others by appealing to some com-crop plants can be derived if one adopts Altner\"sWhether such a premise can in any way beargument against transgenic herbicide resistantmon moral intuition. \u00b7  disturbs the normal interaction of genes in the host species, \u00b7  causes irreversible changes in communities of organisms and ecosystems, or\u00b7  seriously shifts evolutionary parameters. Points 3 and 4 concern the consequences of the  crop plants. Of course, it could be argued thata value should be acknowledged, since it isresistant crop plants. Apparently, the transfer ofresistance genes has no adverse effects on thephysiological stability of a plant. Field trialsshow that the transgenic plants clearly \"thrive\"because they cannot survive under naturalthe plants do indeed lack physiological stabilityconditions, i.e. without being tended by cultiva-tion. But were this ethically relevant, one wouldquestionable whether it could at all be violatedunder the conditions necessary for cultivatingunder the heading of risk prevention. In anyunacceptable.since it appeals to the integrity of the plant as aecosystems. The first criterion is truly biocentricnoticeable effects on the evolution of species andnatural habitats and hence are not likely to haveresistance genes offer no selective advantage incase, one must bear in mind that herbicidehave to reject crop plants in general as morallycentric (anthropocentric) moral view as well,points must be taken into account on a nonbio-introduction of transgenic crop plants; thesemoral value. We need not discuss whether suchin the case of genetically engineered herbicide evolution of the plant. But the same applies for amits more genetic variability in plant breeding Many of the participants in the technologyThey simply failed to see why a bacterial gene ina crop plant should call the intrinsic value of theplant into question and, in a way, offend itsdignity. Undoubtedly, genetic engineering per-than would otherwise be available for the naturalbreeding of plants? Whether crop varieties areassessment could not respond to this appeal.number of other breeding techniques (e.g. muta-genesis) which have been used without raisingmoral objections. Why should we adopt a rulestating that the natural barriers for the evolutionof plants also constitute moral barriers for thenatural, in the sense that they could also have  concepts of risk or positive legal standards for 60 from interventions in evolution altogether or thatwe denounce these as inherently immoral.nature conservation. In ecological terms, humanpopulations live and reproduce in nature as thedominant consumer species, and they will influ-ence the future evolution of other species andecosystems, whenever they interfere with theliving conditions of other organisms, be itthrough agriculture, industry or the public healthservice. Such influence is not only unavoidable.Strictly speaking, it is also irreversible. Even ifsome particular interferences can be reversed,evolution does not return to its former state. Noethics can demand therefore that we abstainHerbicide-Resistant Crops evolved without human intervention, or whether \"unnatural\" is not normally a sufficient reasonto reject it on moral grounds.moral issue. The fact that a technique isconditions of natural evolution was never athey could compete successfully under the \"Genetic pollution\",  2  moral harmevolutionary impact, and  Strictly speaking, the question whether interfershould transgenic crop plants in any way changemaintenance of species diversity. Sometimes,plants to other organisms in which they wouldoccurred if transgenes had escaped from cropbelieved that relevant damage had alreadyence with natural evolution is morally admissibledoes not refer to the evaluation of transgeniccrop plants as such, but rather to the conse-quences the cultivation of such crops could haveon other organisms. It is obvious that the conse-quences must be assessed in terms of impliedrisks, for example, to ecological stability or thehowever, the fact that such consequences exist atas \"genetic pollution\". Furthermore, they con-all is held to be a sufficient ground for moralrejection of transgenic crop plants-whether ornot any risks are implied. This view is based onthe premise that any impact on natural evolutionis in itself morally harmful. This position wasoccasionally adopted in the technology assess-ment: for example, a number of participantsnot be transferred naturally. This was denouncedformation (e.g. by outcrossing transgenes).sidered it an unacceptable \"evolutionary risk\"the conditions of future processes of speciesnot normally be found and to which they could  One could anticipate that genetic traits whichwill, in general, have more profound effects onevolution than the spread of endogenous plantgenes or mutant genes from conventionally bredcrop plants. In any case, it is impossible topredict, even remotely, what phenotype of somenew natural species might result in the distantfuture from the propagation of crop plant genes;and it is impossible to predict how this pheno-result from conventional crop plants. There is notype could interact in a future ecosystem withoffer a clear selective advantage would haveIn addition, moral evaluations become embroiledgreater consequences than others. This argumentrefers solely to the phenotype, however, and it isvalid irrespective of whether a phenotype hasbeen produced by genetic engineering or con-ventional breeding techniques.tion of species are only deemed unacceptablesome future existing species unknown at present.but are held to pose no moral problem when theyreason to suppose that the spread of transgeneswhen they result from transgenic crop plants,in contradiction, if impacts on the natural evolumental change-constitutes an influence on theempirical meaning, and they refused to acceptinto the living world-in particular, shifts inway into organisms in which they would notnaturally occur. These participants criticised the\"genetic pollution\" rhetoric because it lackedThese views were contradicted by other partici-the idea that impacts on natural evolution con-stitute damage. Since any human interventionselective pressure, which result from environ-pants, for whom it remained unclear why it course of evolution, the concept of \"evolutionaryrisk\" makes no sense.would be morally harmful if genes found their quo nor the direction of future development aresent an optimum which would be jeopardisedThere was probably agreement in our technologyassessment that it does not make sense simply toequate interventions in evolution with damage tonature or violation of the natural order. Existingspecies and communities of species in natureremain subjected to evolutionary change. Theythat evolution itself must be considered a risk, ifdifficult to predicate damage from the mere factenvironmental change), and neither the statusthat the status quo might be changed or thedirection of future evolution shifted. One par-ticipant in the technology assessment commentedare not in static equilibrium, nor do they repre-underlying \"purpose\" or goal. It is thereforein any way determined or \"ennobled\" by anshould evolution continue. Evolution is a ran-dom process (caused by genetic variation and  tive and disregard established (anthropocentric)and impermissible acts. There seem to be nolem of how to distinguish between permissiblehuman intervention in evolution faces the prob-It is indeed true that the moral evaluation of clear criteria, if we adopt a biocentric perspec-  ethical problem when genes are transferred the transfer are not at issue)across species boundaries to crop plants (notabene: as long as the possible risks involved in.  There appears to be no way to mediate between these conflictingherbicide resistant crop plants?does this imply for the evaluation of transgenicment of moral issues are irreconcilable. Whatwhere differences in the perception and judge-evaluations. We may well have reached the point Part III: Normative Evaluations-Ethics, Law And Politics  61 we adopt the notion that transgenic plants\" \"evolutionary risk\".of years) to the formation of new species andleading in the long term (hundreds or thousandsnew patterns of coevolution constitutes human choice. The limits to human interventionrights. This question remained open in ourin this debate, over which opinions and feelingsmorally impermissible human intervention into distinguish between morally permissible andThe difficulties in specifying operational criteria which we refer to the interests and needs oflong as it does not harm human interests andabout our attitude towards nature come into playdoes not mean that the underlying questions areto define. It may be that fundamental issuesmerely because the moral limits were so difficultintervention in evolution should be toleratednot disputed. No one argued that any and everysurvive (or which we want). Such evaluationavoids the more radical moral issue of whetherany intervention in evolution is permissible asevolution are obvious and unresolved. But thisreduce the level of biodiversity which we need toinherent goal of evolution in \"nature\" to whichdiversity of fundamental moral attitudes towardswe could refer for guidance. In the final analysisit will always remain necessary to resort tocultural and political criteria, i.e. to criteria ofand standards will then reflect the underlyingin nature cannot be derived from nature itself,but only from human interests in nature andnature properly. Conflicts over these interestsnature in our society.pointless. We usually avoid the problem byhowever, is that \"respect for nature\" is not yetan operational criterion, because there is nofrom the standards we set for dealing withare deeply divided. What does seem clear,adopting an anthropocentric perspective inhuman beings. Thus intervention in evolution isclearly not permitted, if it would endanger thestability of the global climate, for instance, ortechnology assessment, but its legitimacy was the conflicting judgements had to be discussedtake or leave according to interest and taste.on the postulate, \"Do no harm\", which arelaw, individuals should be entitled to live theirown lives according to their own values. Whatthey cannot expect, however, is that their ownmoral views be adopted by everybody else. Theimpositions of pluralism are that people mustaccept or at least tolerate the fact that, in amodern society, values which they considerethically well-founded and absolutely bindingare regarded by others as mere preferences toirreconcilable ethical convictions to be acceptedviews. Indeed, a synthesis of respect and toler-well-founded, minimal ethical standards basedand to coexist peacefully in society. Beyond thegenerally enforced in our society by the rules oforganised could itself be a kind of model in thisand mutually acknowledged as valid moralsociety. Perhaps the technology assessment weviews be taken serious and dealt with properly inThe first requirement is that differences in moral respect. It proceeded from the assumption thatance must surely be necessary for a plurality of nature, the only things which are clearly morallythe degree of unnaturalness of the technology. The verdict on transgenic plants, which can beperspective, is not entirely without public sup-account by appealing to moral grounds. Ratherethic. The moral consensus in our society is lessto higher organisms in the special case of animalprotection). General moral judgement of atechnology is thus based on the direct or indirectconsequences for humans, and not on the type orthe intensity of the interference with nature, i.e.harmful effects for humans (with some extensionrestrictive. When dealing with (nonhuman)As long as this remains the dominant view, it isviews the transfer of genes from other species asport; but it is still a particularistic or groupcould become the basis for collectively bindinglegal regulation. At the level of regulation,restrictive ethical codes which go beyond themoral, \"common sense\", cannot be taken intodifficult to imagine that a moral position whichproscribed are interventions with unacceptableethically \"harmful\" and hence strictly illicitformulated from a restrictive biocentric ethical  The impositions of ethical 3  pluralism As soon as ethical criteria above and beyond the  society at large, as there was among the partici-prevention of harm to human interests and rightsare applied, there will be as little consensus inpants in our technology assessment. We mustexpect that moral judgements on the admissibil-ity of genetic engineering in general-and trans-genic herbicide resistant crops in particular-will remain divided. Some people will find thatevolution has put asunder. Others will see noscience should not put together what natural  62 Herbicide-Resistant Crops they become downgraded, so to speak, to the \u00b7  from the isolated assessment of risk involved not find a majority in the political process.status of legitimate group interests which mustcompete with other interests, and may or may in genetically modified plants to a comparison ofrisk between transgenic and nontransgenicplants: Are there specific risks associated withgenetically modified plants, which do not arisewith conventionally bred plants? 81 considerations or economic considerations andtant mechanism for peace-making in differenti-topic of fundamentalist conflicts of belief. In ourneering of plants is not exactly predestined as aspecies barriers may be morally valid, the engi-stance against any transfer of genes acrosstion is not particularly great. While a stricttant crop plants, the danger of moral polarisa-sanct. In the case of transgenic herbicide resis-which are considered fundamental and sacro-sponsible. Even in a biocentric ethical view it isnism will only work if no values are at stakeated, pluralistic societies. However, this mecha-competitive arena of group interest is an impor-case, it will be necessary to weigh agriculturalfrontational arena of ethical conviction to theRedefining and shifting conflicts from the con- accuse those who did not share their particularmoral views of being ethically blind and irre-there are good reasons for doing so. In eachstill possible to suspend \"respect for nature\", ifalways tend to work against the rise of funda-\"respect for nature\". And, such deliberationsthere is indeed sufficient justification to ignorealso advances in science, to determine whethermentalism in moral belief.technology assessment, no one went so far as to \u00b7  from the need to substantiate suspected risk to before a new technology can be introduced?the reversal of the burden of proof: Shouldfreedom from any and all risk be demonstrated \u00b7  from arguments over risks to arguments over social benefits and needs: Are uncertainties withrespect to risks only acceptable if there is a realand significant social need for the technology? Going through these stages of debate is bothissues will be brought into play, which raise theout the course of the discussions, both propo-nents and critics of genetic engineering wereconfronted with empirical findings they couldnot avoid. Empirical findings do not, by them-but they may force people to reconsider andeventually modify or replace the reasons fortheir assessments. As a result, new normativeorder which the criticism of risk will followselves, force a revision of political assessment;sheer novelty of genetic engineering.typical and necessary. It reflects the logicalsections summarise the transformation of risk conflict onto a different plain. The followingdiscussion in our technology assessment, start-ing from imminent, recognisable risks andculminating in restrictions based on diffuse,unsubstantiated fears that may be induced by thewhen put to the test of argumentation. ThroughARE THE RISKS OF GENETIC B  ENGINEERING ACCEPTABLE?  The novelty of genetic engineering raises fears,  Recognisable risks of transand criticism of risk is the most common politi-cal manifestation of these fears. Discussions inour technology assessment over the possible riskof genetically engineered crop plants wentthrough various stages with which we are al-ready familiar in the  public debate over genetic  1 metabolic changes, feralgenic plants: unexpectedpopulations, horizontal genetransfer engineering in general. The discussions pro-ceeded as follows:  New toxic or allergenic substances in plants . able that some known allergenic potential wouldresistant plants three possible risk mechanismsnonselective herbicide in the resistant crop plantNo participant of our technology assessmentcontested the notion that unexpected toxic orallergenic metabolic products represent a rele-vant risk which must be regulated at least forfood and fodder crops. For transgenic herbicide-are clearly identifiable. (1) Detoxification of theuct) can activate or increase the level of toxi-can result in toxic metabolites of the herbicidebeing formed. (2) The gene product introducedvia gene transfer can itself be toxic. (3) Genetransfer (and the introduction of the gene prod-cants typical for a given crop species (for in-stance, alkaloids in potatoes). It is also conceiv-increase, i.e. that the host plant could become a \u00b7  from recognisable risk with predictable consequences to the hypothetical and to unknown riskwith unforeseeable consequences: Should weregulate imaginable risk or risk that we cannot,in any case, exclude with certainty?                                                    81   If the law ignores the moral beliefs of some segments of society, it will only be acceptable if it is based entirelyon the principle of legitimation by majority decision andif it refrains from any judgement about the validity ofoverruled moral beliefs. Political battles neverthelesstend to provoke appeals to moral f undamentalism; campaigns against transgenic organisms in Austria andconsider, for instance, the rhetoric used in the referendumSwitzerland.   Part III: Normative Evaluations-Ethics, Law And Politics 63 more potent allergen as a result of plant meta- where the matching herbicide is applied. bolic interaction with the transgenic gene prod-uct. And it is conceivable that a known aller-genic potential in the donor organism be trans-mitted to the host plant through the transgene.82 Horizontal gene transfer  . Herbicide resistance with endogenous plant genes from nontransgenicquence would be selective growth of thesedid not previously exist in the soil in thischemistry by releasing metabolic products whichthe transformed bacteria could influence soil(usually close to the soil surface). In addition,parts of the soil where the herbicide is effectiveapplied; the growth would be confined to thosebacteria, so long as a matching herbicide isit does, and if the resistance genes find expres-sion in the soil bacteria, a foreseeable conse-gene transfer will probably occur only rarely. Ifon the gene construct. In any case, horizontaltheoretically for certain transgenes-dependingplant cells, the transfer rates would be highertransfer. Although such transfer can also occurcells to soil bacteria through horizontal genegenes can be proliferated from transgenic plantform.83 are not specific to transgenic plants: they canmodified using conventional breeding techniques While there was consensus that these risks mustbe regulated, it was also pointed out that theyalso occur in crop plants which have beenwhether there are nevertheless good reasons to(see above, section II, A1). The real issue was,therefore, how far such the tests should go andregulate transgenic plants more strictly thanconventionally bred crops varieties (see below,section III E1).  Feral populations . Much the same arguments plants through hybridisation-if suitable repro-for the farmer and, more significantly, for thea market for the nonselective herbicide. Feralincrease in herbicide load on the field-forinstance, if farmers attempt to kill resistantweeds by increasing herbicide dosage or numberof herbicide applications. It seems unlikely,offers no selective advantage outside the areamore competitive, since herbicide resistancehybridisation with resistant crops will not bewhich develop herbicide resistance throughpopulations could also result in a temporaryecological threat to natural habitats. Wild plantsplants could become weeds in agriculturalresistant plants does seem to be limited. Suchherbicide manufacturer who, in turn, would losewere applied with respect to the risk that feralsystems, which would then imply financial lossbe formed. There is a recognisable risk that adomesticated transgenic crop could run wild, i.e.that it \"escape\" from cultivated areas or that itcould propagate the transgene to related wildpopulations of herbicide-resistant plants mightductive partners were available. But thesemechanisms apply equally to transgenic andnontransgenic cultivars. Furthermore, the possi-ble harm that could result from feral herbicide-however, that feral populations would pose any                                                    Since it was agreed that horizontal transfer ofgenes from herbicide-resistant crops cannot beexcluded, the question whether the effects wecould expect should be considered environmentaldamage became a crucial point of discussion.Many participants denied that any damagewould result. In particular, it was pointed outthat many farming activities, such as cropin soil chemistry, and that mechanical weedrotation or fallowing, induce significant changes                                                     83   This summary of the discussion in the technology assessment was criticised by one of the participants: \"The text unfortunately fails to point out that in pargene transfer under this selective pressure would beeffective against bacteria and fungi, so that horizontaland glyphosate (Round-up) and their derivatives areticular the nonselective herbicides glufosinate (Basta)considerably enhanced.\" Whether glufosinate and glyphosate actually do exercise  expert report by Wilke on the effects nonselectivecertified herbicides requires closer examination. Thegreater selective pressure on bacteria and fungi than otherherbicides have on the soil concludes tentatively that thisis not the case, in:  Materialien zur Technikfolgenabsch\u00e4tzung, Heft 7 (see appendix); see also the statement eration Regarding Glyphosate Tolerant Crops\", in:by Dr. J. L. Honneger (Monsanto): \"Factors  for  ConsidMaterialien zur Technikfolgenabsch\u00e4tzung, Heft 6, pp. 90-93; and section II A2 above. On the basis of this presupposeffectiveness of nonselective herbicides was one of theselective pressure resulting from the anti-microbialcrops is more likely than from nontransgenic plantszontal gene transfer from transgenic herbicide-resistantsions of the technology assessment) that whether hori-finding, it seems reasonable to assume (as in the discus-depends primarily on the gene construct. Incidentally,itions in our technology assessment; otherwise resistant bacteria and changes to soil chemistry aswe could not have considered the accumulation ofpossible impacts of gene transfer. 82   This apparently happens when the gene coding for 2S albumin in the Brazil nut is transferred to the soybean(Nordlee  et al ., 1996). It should be noted that this saying that such risk must be tested for and excluded (seecompany, Pioneer Hi-Bred, in the early phase of devel-FDA, 1992). In the present case, the tests were carriedout by university researchers in cooperation with a seedfinding, although new, has by no means come as aoping the transgenic soybean, i.e. well ahead of thetesting required for the approval of transgenic products.food. That 2S albumin could transfer allergenicity tocomplete surprise. The Brazil nut is a known allergenicsoybeans is a clearly identifiable risk. It goes without  with respect to environmental consequences. It is have unexpected side-effects on the plant me-resistance genes transmitted to wild speciesthe transfer of herbicide resistance genes couldsingle, transmitted trait (herbicide resistance);not enough to assess the ecological impacts of apossibly expand its ecological range, i.e. in-crease its fitness. Such impacts will not neces-sarily be revealed through the testing requiredfor the approval of new cultivars, so long asthey do not impair breeding goals. It is alsotabolism, which affect the plant phenotype andimpossible to predict what impacts herbicidethrough hybridisation could have on the evolu-tion of natural species and habitats in the longrun and under changing ecological conditions.Finally, it is difficult to refute the theoreticalpossibility that bacteria transformed throughhorizontal gene transfer from herbicide-resistantplant cells would release substances into the soil,significantly different from and more harmfulthan new substances which might result fromchanges in crop husbandry or from the use ofnew herbicides. 64 Herbicide-Resistant Crops control, in particular ploughing, also leads to naturally occurring resistant mutants areapplied to nontransgenic crops, becausewhich permanently eliminate nonresistant soilapproval of a herbicide is granted. HerbicidesThe impact of herbicides on soil is tested beforebe impaired is not a very realistic expectation.selectively favoured. That soil functions couldbe expected when selective herbicides areapplies in the case of nonselective herbicides.resistant populations of bacteria in soil can alsogrowth and temporary increase of herbicide-counted as environmental damage. Selectivemicroorganisms. None of these effects have evermassive fluctuation among populations of soilbacteria will not pass these tests; this also The risks from transgenic herbicide-resistantfrom nontransgenic plants. Recognised risks dramatic, were they compared to the risks fromcrop plants described so far would not seemconventionally bred crops using well-establishedseem to \"normalise\" through comparison. Attransgenic plants was identified in the technol-this point the debate in the technology assess-ment moved one stage further, from recognisedrisk to hypothetical (i.e. suspected or unknown)risk.ogy assessment that was not already knowntechniques and practices. Basically no risk from requires that risk be minimised. For them,While it was generally admitted in the technol-tionally bred plants, without ever being consid-uncertainty of prognosis also applies to conven-sion. They argued that unforeseeable conse-quences must always be expected, and thatcrops, on the other hand, rejected this conclu-uncertainty of prognosis was not only an un- ogy assessment that uncertainties exist whichproponents of transgenic herbicide-resistantcannot be resolved, participants disagreed abouthow the uncertainties should be dealt with. Dothey constitute a sufficient reason to ban trans-genic herbicide-resistant crop plants? Critics ofling, invoking the principle of precaution whichthe technology deemed this conclusion compel-avoidable risk, but an unacceptable one. Theered sufficient reason to ban such plants.  Focusing on the lack of  2 the risks of ignorance,uncertain prognoses and thelimits of testingknowledge:  The main argument against normalising risks must not be confined to recognisable risk whichthrough comparison was that an assessmentyet know exactly what all the risks are. We cancan be described and tested. The real risk fromtransgenic plants lies in the fact that we do notneither foresee all the possible consequences oftransgenic herbicide-resistant plants, nor controlthem through preventive testing. And we cannot,therefore, rule out physiological and ecologicalfrom those we know from nontransgenic crops.impacts of transgenic crops, which are different unexpected or undesirable side-effects (pleio-background of the host plant. \"Surprises\", i.e.might be or to control them, given the geneticwhat the physiological impact of new genesBreeders have, in fact, never been able to predict tropy) are abundant in conventional plantbreeding; they must always be dealt with  ex post facto  through testing to select those examples which are suitable for being further developedinto new crop varieties. The testing process isplant substances to detect changes which mightbe toxicologically relevant. Phenotypic changesin new plants will be identified through selectionprocedures only if these changes are undesirablenecessarily limited. One can never screen allin terms of breeding goals. On the other hand, do not know all the substances in plants, nor canpletely by extending the certification tests. Wespecies. Nor can we eliminate these risks com-that we have not or cannot observe in the hostthe presence of toxic or allergenic substancestransgenes on plant metabolism nor to rule outno way to predict all the possible effects ofuncontested: Our knowledge is limited. There isThe basic premise of this argument was we test for them all. Similar uncertainties exist   Part III: Normative Evaluations-Ethics, Law And Politics 65 other changes which may still be ecologically such pitfalls exist when the risks from transgenic relevant (like increased stress resistance) couldgo unnoticed. With respect to long-term impactson the evolution of species and ecosystems, onecan only say that they are as indeterminate andunpredictable for conventionally bred plants asfor transgenic plants. legitimacy of this comparison is confirmedMoreover, in our technology assessment, theand nontransgenic crop plants are compared. prima facie  by the fact that it was the critics of rability of transgenic and nontransgenic plants,The report commissioned from the \u00d6ko-Institutquality\" of genetic engineering:plants. This approach invites the claim to thewhat could happen with genetically engineeredconventional breeding, in order to demonstraterisks, side-effects and uncertainties known fromrefers explicitly and repeatedly to the problems,shows, at the same time, that the risks andthis conclusion, critics must dispute the compa-uncertainties from transgenic plants are the samegenetic engineering who put it on the agenda.difference. Two arguments were used in thetechnology assessment to prove the \"specialand show that genetic engineering makes aas those from nontransgenic plants. To escapecontrary that, if the criticism is valid, then it sight of the possible consequences of suchwhether the comparison between conventionally As a result, comparison to conventionally bredplants not only tends to \"normalise\" the recog-nisable risks from transgenic plants, it also tendsto normalise the uncertainties involved in suchplants and the hypothetical risks that may bederived from the fact that we have limited fore-a central focus in our discussions.plants. This defeats the main public argumentbred and transgenic plants is legitimate becameagainst transgenic plants, namely, that suchplants will present us with new, specific risks.Not surprisingly therefore, the question of Are risk comparisons  pathways can be introduced into a host plant,genes across species barriers. Hence metabolic (1) Genetic engineering allows the transfer ofevolution or conventional breeding. Such newcould not have been acquired through naturalthat have never belonged to that species andpathways constitute a specific factor of uncer-tainty; therefore the risk of uncontrollablephysiological or ecological side-effects (pleio-tropic effects) is higher with transgenic plantsthan with new conventional plants. 3  quality\" of genetic engineeringlegitimate? The \"special Risk comparisons were commonly used in the  debate over transgenic crops. 84 They suggest parably, but this need not be the case. It is alsoand to consider if there are any reasons to devi-themselves as a general method of evaluation fornormative issues. Since levels of acceptable riskcannot be objectively determined, an obviousapproach would be to refer to what has actuallybeen accepted in comparable cases in the past,ate from this model. The underlying assumptionis that comparable risks should be treated com-possible to decide that the risks from a newtechnology should be regulated more strictlythan comparable risks from a well-establishedtechnology with which we are already familiar.In this case, \"novelty\" would be the main crite-rion for such regulation. (2) The transfer of genes through genetic engi- neering disturbs the genomic context of the hostgenome. Therefore, positional effects (inser-induce changes in the traits of the transformedplant, which are unrelated to the informationcoded in the transgene and hence cannot beforeseen.tional mutagenesis) must be expected, that canplant. Transgenes are inserted at random in the  Comparing risks will in general be regarded ascontroversial. Arguments, for instance, whichlegitimate as long as the risks are indeed compa-damage slowly accumulates slowly, resultingsudden catastrophe, and diffuse risks, wherecomparison of dread risks, which could inflictconsidered conclusive. The same holds for thecompare voluntary and involuntary risks are notrable. However, the criteria of comparability arefrom a series of scattered events. more side-effects do in fact occur; nor canhence, an additional factor of risk. This argu-plants. There is no empirical evidence as yet thatuncertainty\" is implied by transgenic plants and,In our technology assessment and in the Germanpublic debate these were the key arguments usedto support the claim that transgenic plants posehigher risks than new plants produced by con-refer to the suspected or hypothetical risk thatthere might be more severe unexpected side-effects from transgenic than from nontransgenicventional breeding techniques. These argumentstheoretical models be invoked to elaborate thishypothesis in any detail. However, as one criticput it, one can infer from the \"special quality\"of genetic engineering that a \"special type of  85 Obviously, no                                                    84   See OECD (1993). 85   Even if the absolute amount of damage (in terms of lives lost) is the same in both cases; see Slovic  et al. (1985); Slovic (1987).  66 pected from transgenic than nontransgenicHerbicide-Resistant Crops pathways which are already established in thehost plant species.plants, if the gene transfer introduces metabolic ment is designed to refute the comparative implicitly confirms the validity of the compara-tive approach in principle: if the \"special qual-ity\" of genetic engineering cannot be demon-strated, then the comparison to conventionalcomparable. At the same time, however, itthat transgenic plants constitute a specific riskbecomes unfounded.genic and nontransgenic plants are, in fact, not\"normalisation\" of risk by claiming that trans-crop plants remains legitimate; the assumption Reductionist versus  4  synergistic risk philosophy?  In Germany, the public debate over genetic organism in order to assess the risks of the genetransfer: \"It is the gene that matters\". Criticsengineering has frequently been framed as abattle of competing risk philosophies. Thedominant regulatory approach concentrates onconsiders the function of this gene in the donorthe gene (gene product) to be transferred andhave rejected this approach as an unacceptablyorganism. Therefore the effects cannot be de-reductionist view of the problem. They empha-of the gene function in the donor organism: \"It isrived from knowledge of the gene sequence andthe context that matters\".86genetic background which they find in the hostsise that the effects of transgenes depend on the sons) move around in the plant genome. Trans-rally occurring transposable elements (transpo-argument that these disturbances demonstratethe \"special quality\" and special risks of geneticengineering was invalidated.the discussions, context disturbances, too, were\"normalised\" through comparison, and theposons, too, are inserted at random. No reasonsconventional breeding techniques or when natu-were given why context disturbances in trans-plants. Such disturbances also result fromtute a \"special quality\" of genetically engineeredgenomic context (and positional effects) consti-to defend the notion that disturbances in theIn our technology assessment it was not possible genic plants should be different. At the end of was reached on the following points:in our technology assessment, since consensusThis controversy did not have a prominent role  interact with the existing plant metabolism (inthe claim that there will be more physiologicalonly one, exactly identifiable gene product ismined genes is exchanged, all of which cancrossbred, an uncontrolled number of undeter-genic plants because, when these plants arecontrast to genetically engineered plants, wheretransferred). No method exists to balance theseside-effects is theoretically higher for nontrans-is about hypothetical but undetermined andsis can be confirmed or refuted.will be fewer such side-effects. Neither hypothe-or worse than the claim to the contrary that thereside-effects with transgenic plants is not bettertwo countervailing factors. Since the argumenttransferred, it is also true that the probability ofunpredictable side-effects, quantitative prob-side-effects is theoretically higher for transgenicparisons. While it is true that the probability ofhowever, the argument was relativised by com-was declared as valid in principle. Once again,the host plant constitute a special risk factor,duction of new metabolic pathways unknown inOn the other hand, the argument that the intro- abilities are unknown. In the final analysis, then,plants, whenever new metabolic pathways are \u00b7  The coding information of a transgene depends on the gene sequence and not on thecontext of the gene, which means, that the site inthe host genome to which the gene is transferredhas no influence on the type of gene product thatcan be formed. \u00b7  Transgenes coding the information for a gene product which induces toxic substances in thegreater risks than transgenes for which no sucheffects have been identified.donor organism or enhances its fitness pose \u00b7  Transgenic gene products can have effects in in the transgene or from the gene function in thethe host organism, which result from interactionwith the existing plant metabolism and thereforecannot be derived from the information encodeddonor organism. \u00b7  The locus of integration of the transgene can the donor organism.information of the transgene or its function incannot be derived from knowledge of the geneticalso have impacts on the host organism, whichneighbouring endogenous plant genes. This mayinfluence the expression of the transgene or of the gene that matters\". While they still sThese points shed doubt upon the formula, \"It is  upport the notion that one must consider whether thespecific gene construct to be transferred poses  It would seem, therefore, that opting for one ortheoretically fewer side-effects are to be ex-preference. It should be noted, however, thatrisk assessment is merely a matter of politicalthe other of these hypotheses as a basis of our                                                    86   Cf. Kollek (1988). the \u00d6ko-Institut Freiburg adopted these arguments as the basis of its expert report.   Part III: Normative Evaluations-Ethics, Law And Politics 67 proposed for such a risk. The standard argument quality\" ascribed to genetic engineering becausethis argument effectively, it remains a mysteryadvanced in the German debate was the \"specialof context disturbances and positional effectsresulting from the insertion of transgenes. If oneaccepts that the comparison with transposons,breaks occurring in nontransgenic plants refuteschromosome translocations or chromosomewhy gene transfer should be able to cause moreor different unexpected side-effects in cropplants than changes induced by conventionalbreeding techniques. The claim that transgenicplants might involve specific risks is reduced tosuspicion without foundation. any known risks in the donor organism, they phies. And in dealing with this question theagreed, however, about whether these reasonsby conventional techniques. It was the questionnontransgenic plants which have been modifiedwell.This conclusion was not controversial in thetransgenic plants is clearly legitimate but not atcrop plants, then reference to synergistic risks inthe genomic context (insertional mutations) inchanges (pleiotropic effects) and disturbances oftechniques can induce unforeseeable metabolicengineered plants. If it is true that all breedingwarrant specific regulation for geneticallyport a synergistic risk philosophy. They dis-to anticipate the effects the gene might have inagreed that there are some reasons which sup-technology assessment. Participants implicitlylished, that dominated discussions in the tech-gene that matters, the context matters asthe host organism. Therefore, it is not only theall sufficient to mark a real difference fromnology assessment, not competing risk philoso-also show that such consideration is not enoughcritics had to resort to ever more remote hy-potheses about the specific risks of geneticallyengineered plants.of whether and how a difference can be estabharmful effects are possible in principle andbasis of this distinction, the claim that transgenicassumes that mechanisms might exist or eventsmight occur which are not yet known. On thebecause they have been genetically engineeredcrop plants could involve specific risks solelymust be classified as speculation, not as hy-pothesis.87\"speculative risk\" should be used when noshow how these could arise. The termapply only if a scenario bases suspected risk onknown mechanisms which demonstrate thatguished: The term \"hypothetical risk\" shouldproposed that different risk scenarios be distin-In our technology assessment discussions, it was mechanism is specified or when a scenario  From hypothetical to 5  speculative risks All participants agreed that the assumption of  not considered sufficient to substantiate sus-hypotheses which differed in their degrees ofreference to the novelty of genetic engineering is\u00d6ko-Institut attempts to do just that. In general,ously into account. The expert report from themust be substantiated if it is to be taken seri-genic but not in conventionally bred crop plantspected risk. The critics suggested various riskelaboration.specific risks which may be involved in trans- regulation of genetic engineering, i.e. wheretion that genetic engineering against this regulatory approach, if the assump-methods through which the genes have beengenes and gene products are assessed, not thewards product-based rather than process-basedThis result tends to justify current trends to- transmitted. A good case could have been madeper se  involves the case is much weaker, of course, if it isunderstandable that the critics of transgenicmerely unfounded speculation. It is thereforespecific risks were a well-founded hypothesis;                                                    product that was never in the plant metabolismrisk: It is possible that the transgenic genebefore.product metabolises other substrates and henceplants if genes are transferred which code for ahas a different impact in the host plant than inthe donor organism. The probability of this willbe higher in transgenic than in nontransgenicble mechanism is described for this postulatedeffects seems relatively well-founded. A plausi-specific risk in terms of physiological side-The hypothesis that transgenic plants pose  87   In contrast, the assumption that the introduction of gene assumption is also just speculation.hypothesis. One participant argued, however, that thisproducts alien to the metabolism of the host plant speciesmight imply additional risk was accepted as a valid \"That new toxic or allergenic substances will be  formed is mere speculation, as long as it is not clearwhy one should reasonably expect that substratesmodified by the gene product could be toxicologicallyrelevant.\" On the other hand, the hypothesis that genetic engineering might involve specific risks  per se ,  In the case of transgenic plants with resistance to glufosiis, seems rather weak. No mechanism waswhich exist irrespective of what the gene product suspicion would be warranted only, \"if there were someindication that acetylated substances are likely to be toxicnate (introduction of a specific acetyltransferase), theor allergenic\". But there are no such indications.  serve any differences, we can assume that they exist and base our risk assessment on this as-sumption. Obviously, no one thought this argu-ment to be sufficient. In sum, therefore, the factthat transgenes, as far as their impact on thegenomic structure is concerned, cannot bedistinguished from transposons and the recombi-nations that occur in conventional plant breedingprecludes the hypothesis that specific risks mightbe involved just because genetic engineering hasbeen applied. 68 Herbicide-Resistant Crops plants in our technology assessment did not between transgenic and nontransgenic plants,They argued further, however, that differencessimply give in at this point. They insisted thatthe discussions could, at best, have shown that,on the basis of existing scientific knowledge, the\"special quality\" of genetic engineering (andexist.which cannot be demonstrated, can neverthelesshence specific risks) cannot be demonstrated. This argument replaces reference to an empiricalfact, \"  genetic engineering has a special quality \", with reference to a logical possibility , \"it is  Hypothetical and speculative conceivable that genetic engineering has aspecial quality\".  It seems that this move is no 6  worst-case scenarios longer an attempt to provide reasons for thehypothesis of specific risks, but rather an at-tempt to avoid the need for further reasons.  When we consider suspected risks which might catastrophic consequences?\"unforeseeable\", in the sense that anything couldcannot be foreseen. But is the damage alsodefinition, the possible damage from such risksexist but have not been experienced, then, byhappen? Should we assume that the hypotheticalrisks from transgenic plants could have fatal or comparable had to deliver the arguments. Whatof transgenic and nontransgenic plants areConsequently, those who claimed that the riskswhoever makes a claim must substantiate it.assessment proceeded from the premise that, In general, the discourse in our technologythey did was to show that whatever risk oruncertainty was identified and described fortransgenic plants, equivalent risk or uncertaintycan be identified for conventionally bred plants.But they were not supposed to demonstrate theimpossible, namely, that unknown risks fromtransgenic plants, which might exist but have notbeen identified and cannot be described, are alsoequivalent. necessarily be harmless for human health,difficult to attribute to the transgenic food cropdamage would likely go unnoticed or it would bewere low-level, however, while they may not taken off the market immediately. If the effectsidentify and the respective cultivar could bestance were severe, the risk would be easy tounsuitable as food. If reactions to these sub-stances could be formed, making the plantsdamage was that toxic or allergenic plant sub-ated with alien gene products, the envisagedmetabolic risks from transgenic plants, associ-the technology assessment. In terms of specificDifferent worst-case scenarios were discussed inas the probable cause. observable differences, things must be countedwere proven. The fact that our knowledge is limited mitigatesagainst those who claim that differences whichwe do not recognise may nevertheless exist.Logically, lack of evidence does not prove thatdifference we treat things as being equal (for thethe differences do not exist (we may find onement for those who claim that things are compa-would lose all meaning if, in the absence ofrable. On the other hand, the concept of equalitytomorrow); practically, however, if we find nocannot distinguish. This makes an easy argu-no alternative. Where we do not know, weas different and not as equal, until the contrarytime being), not as different. There seems to be 88 ples and theoretical models from plant physiol-ogy, plant breeding and food toxicology toThis worst-case scenario uses empirical exam-a herbicide resistance gene is added.suddenly begin to produce deadly poisons whenfor example, that harmless crop plants wouldknown causal mechanisms and does not assume,circumscribe possible consequences. It relies on   lems or yield loss for the farmer. Eventually thecould result from transgenic plants: Shouldunexpected metabolic changes lead to increasedecological fitness then, it was assumed, trans-genic crop plants could invade agriculturalhabitats as weeds and cause agronomic prob-the worst case of environmental damage thatplants (or their hybrids with wild relatives) couldA cautious approach was also taken to describe                                                    have argue instead that even if we do not ob-transgenic and nontransgenic plants. They couldquality\" which makes a difference betweenshow why genetic engineering has a \"specialcould have foregone sophisticated arguments toassessment. Otherwise, critics of the technologyimplicitly, by all participants in the technologyThis rule was apparently accepted, at least  88   See section III E1 below for the testing required.   Part III: Normative Evaluations-Ethics, Law And Politics while hypotheses of risk might be a proper 69 plants.off possible harm from genetically engineeredwarrant drastic precautionary measures to wardregulation. Others felt that even speculative risksshould on no account be the basis for additionalreason for demanding more research, they become established in natural ecosystems and dron in the British countryside.such as the American black cherry in Germandigenous or poorly domesticated crop plantsassumption was the undesired spread of nonin-change these. The empirical model for the latterforests, topinambur along rivers, or rhododenOccasionally, however, much more dramaticplants became used on a massive scale, affectduction of earth\"s atmosphere. As a result, ourimages of worst cases were proposed in ourtechnology assessment. In a kind of \"thoughtfollowing scenario of how horizontal genetransfer from genetically engineered crop plantscould result in ecological catastrophe: Trans-formed bacteria could release new metabolicproducts into the soil which induce permanentatmosphere and climate could be changed sig-changes in the composition and function of soilthe changes normally induced by agriculturalpractice. These changes could, if transgenicthe evolutionary balance between bacteria andplants-the basis of the composition and pro-microflora that differ from and go farther thannificantly. experiment\", one participant developed the reasons to suspect risk. It is not necessary to accepted principle in many fields that precau-ical stability presimportant goods such as life, health, or ecolog-danger imminent. Effective protection ofThe first position outlined above is morerestrictive than current policy and law. It is anwait until some risk is clearly recognisable andtionary measures can be taken if there are goodupposes some response to uncertain risk. This applies in particular whensuch risks could have catastrophic consequencesshould they become real. Therefore, it should beno question that some kind of regulation isappropriate in dealing with hypothetical risk. 89 hidden risk from a new technology will justifyThe question is, how restrictive can theregulation be? In general, the assumption ofadditional safety measures and controls, but nota complete ban on the technology. In theGerman law this rule follows from the principleof proportionality. This principle also says thatthe greater the potential damage from assumedrisk, the more restrictive the precautionarymeasures may be. have to postulate them as a hypothesis, that is,we are unaware, but which operate specificallytion-it is not a reasoned hypothesis. Thisstands in sharp contrast, for instance, to theworst-case scenarios discussed in relation tonuclear power. Here, the causal mechanisms thatwould inevitably lead to catastrophe, providedcertain initial conditions are met, are known: forsystems. No comparable mechanisms are knownquences into large, long-term catastrophe.assume that hidden mechanisms exist, of whichtransfer must be dismissed as mere specula-and only for transgenic organisms and have thecircumstances. The above scenario for ecologi-example, a permanent breakdown of all coolingcal catastrophe triggered by horizontal genefor the case of transgenic plants. One wouldimagined could become real under suitablemechanism to explain how events which areone after the other without identifying anyhypothesised if logical possibilities are compiled shows that a catastrophic threat can easily beThis thought experiment is revealing because itcapacity to translate small, immediate conserisk can only be described as \"theoretically notsocially adequate, since the only alternativeThe second position outlined above, that drasticprecautionary measures always be taken, goesbeyond current policy and law in most countries.It implies that any kind of suspected risk is avalid reason to ban a technology, even if thatwould be that the state had to ban the new\"residual risk\" which must be tolerated asto be excluded\" (a formula used throughout thenuclear power plants and ruled that it constitutesThe German Supreme Court had to deal withnot know and hence cannot describe in any way.the technology implies hidden risks which we dosufficient that there is a logical possibility thatthis kind of uncertainty about risks in the case of\u00d6ko-Institut\"s report). In this case it would be                                                     89   The German Federal Administrative Court has ruled 7 Regulating suspected risks  power,that, in designing precautionary measures for nuclear    \"also possibilities of harm must be taken into account aspect remained controversial. Some argued thatand legal responses to suspected risk, and thisnology assessment about appropriate politicalThere were widely differing views in the tech-  which cannot be excluded because, given the presentstate of knowledge, certain causal relations can neitherbe confirmed nor denied and, hence, there is no clearand present danger, but only suspicion of danger or apotential of worry\" (Bundesverwaltungsgericht, Vol-ume 72, 1985: 315).  70 Herbicide-Resistant Crops technology completely. 90 However, the court did based on speculative risk is limited. But this decide what the state  must  regulate in order to possible harm that can ensue, then speculativecontext of technology assessment. In principle, itbe invoked against anything at any time. Theworst-case scenarios are useless as criteria.provided for suspected risk, then such risks canand what forbidden. If no justification must benot distinguish between what should be allowedcriteria of normative assessment because they dospeculative risk arguments are inadequate asrisks. A more serious objection would be thattechnology and those who want to minimise itsbasic rights between those who want to use newples, including a redefinition of the balance oftion requires a revision of current legal princi-would be legitimate to argue that proper regula-same applies to speculative worst-case scenar-of new technologies with a view to the maximumcould happen constitutes legitimate reason tomay not be a conclusive objection within thetoo, may have hidden risks. Therefore, if we arebe possible, then we would have to expectcatastrophes everywhere all the time, and noinnovation could be approved. There is no way,really, to know what can happen with a newtechnology until it has been tested under realconditions. And even then, we cannot be surethat we have complete knowledge of all thepossible consequences. Established technologies,assume that any imaginable consequence mightto calibrate precautionary policy and approvalios. If the fact that we do not know exactly what meet its obligation to protect the basic rights ofits citizens. What the state  can  regulate under tion. There is considerable scope for a morethe precautionary principle is a different ques-restrictive policy. cation for them was the fact that genetic engi-The German constitution, for example, certainlyno further indications that the suspected risks incrop plants. They recommended some additionalsafety measures to be reviewed after a specifiedperiod.be lifted after a period of testing, if there are stillguidelines envisages that these restrictions couldexclude them completely; the scope of theposed to regulate transgenic herbicide-resistantparticipants in the technology assessment pro-leave some freedom. While they restrict the usewould have been permissible as binding law does not rule out precautionary measures againstregulation of speculative risk. The guidelinesunder the German constitution, because theydiffuse public anxiety that some unknown eviloccur if transgenic plants are released. The earlysafety guidelines for genetically engineeredorganisms issued in most countries during thespeculative risk, or regulations that respond to1975) may be taken as an example for thelate 1970s (after the Asilomar Conference inconsequences. Nevertheless, these guidelinesence was lacking with respect to its possibleneering was a novel technology and that experi-fact exist. It was along these lines that mostwere quite restrictive although the main justifi-of genetically engineered organisms, they do not  Reversing the burden of 8  proof - in dubio contra 91  Under German constitutional law, projectum? with an interest in the technology (manufacturersand complete prohibition of transgenic plants onthe ground that this would be the only way toeliminate all the conceivable, unknown risksthese plants might imply. Such a ban would beincompatible with the basic rights of the partiesor users).however, it would be difficult to sustain absolute  Discussions in our technology assessment suggest that unsubstantiated, hypothetical risks andthe existence of unknown risks could not beworst-case scenarios that fail to explicate suit-be placed on claims of safety, not on claims ofment seems to be that the burden of proof shouldexcluded. The underlying rationale of this argu-risk.resistant crop plants should be banned, becausewas, at any rate, rejected by all those partici-technology. But is this conclusion compelling? Itwill have no relevance for the regulation of newpants who had argued that transgenic herbicide-able mechanisms for how damage might occur  Therefore, the legal relevance of arguments                                                    90   Bundesverfassungsgericht, Volume 49 (1978) 143. The Federal Administrative Court requires under the Federal Clean Air Act  (Bundesimmissionschutzgesetz) that \"there propose a theoretical assumption which is falsifiable, inpossibly lead to harmful effects on the environment\"(principle, but untestable with the available means\"enough, however, if \"small minority opinions in scienceand calculations\" may be sufficient reason; it is notSuspected risk \"on the basis of theoretical considerations(Bundesverwaltungsgericht, Volume 69, 1984: 43).are sufficient reasons to assume that immissions couldibid.). filter of preventive testing before it can betechnology, although it may have survived thethose who claim risks. Those who argue that aprinciple is that the burden of proof lies withunleashed on society. But the general legaltesting for approval, is nevertheless still not safe,must be demonstrated by passing it through aAs a rule, the relative safety of a new technology  91   See section III E below.  living with the risks and uncertainties of old technology than with the risks and uncertaintiesof new technology.  Part III: Normative Evaluations-Ethics, Law And Politics 71 have to prove that there are additional risks. If in nature, the possible harm from hidden risksauthorised. This principle favours innovation. Itoccur in the future. Apparently, neither broadsuch risks and their consequences, should theyconfidence in society to be able to cope withthe freedom to innovate. Furthermore, it impliesworthwhile price to pay for new technology andescape our best efforts of anticipation are astantiate suspected risks in plausible hypotheses,is based upon the value judgement that hiddenthey are unable to do so, or if they cannot sub-they loose their case and the technology isability to repair things if they go wrong can beThey demanded a complete reversal of therisks and unforeseeable consequences thattaken for granted in society. And these premisesadditional risk.transgenic plants in our technology assessment.were definitely not shared by the critics ofargued, the release of such plants should not bereleased into the environment. Therefore, it wascould be irreversible once transgenic plants areallowed until it is proven that they involve noresistance genes cannot be contained or retrievedburden of proof. Given the fact that herbicideacceptance of innovation nor confidence in our as any of those unknown risks from a newtechnology-for instance, climatic changestake if we forego innovation and stick to oldconsider the risks (including hidden risks) wetionary principle would also require that wenot only responsible for what we do, but also forfuels. In addition, where we could act, we arebrought about by the continued burning of fossilwhat we do not. Strictly speaking, the precau- These, too, could have consequences as severehidden risks which we may only recognise later.practices can also be fraught with unknowntechnology against innovation. Establishedside when we opt for the continued use of oldtroversial. We are not necessarily on the safeOf course, this value judgement was also con-technology.  and to adapt to them. We have extensive practi-whether this advantage is a sufficient reason toprefer an old technology over a new one. Opin-ions over this question were indeed divided inour technology assessment. In any case, if theburden of proof is to be reversed some additionalwould fall victim to the suspicion of hiddenof doubt to the older technology. Without such arule of preference, any technology, old or new,risks.breeding techniques may also be new and hereto-A remaining argument in this debate was thatrule would be needed to justify giving the benefitplants (although some so-called conventionalhad some time to detect their hidden problemsthis sense, nontransgenic plants indeed faretechniques, but not with genetic engineering. Inbetter in terms of safety levels than transgeniccal experience with conventional breedingseem less threatening because we have alreadythose technologies with which we are familiarfore untested). The final question would then be  Under such a rule any kind of risk assumptionbecomes a conclusive argument. Remote orspeculative scenarios do not have to be justifiedby the critics of a technology; rather, they mustbe refuted by its proponents.  In dubio contra projectum!  Consequently, reversal of the burden burden of proof to both old and new technology?of proof suggests itself as an ideal strategy tomaximise the impact of risk arguments. Thequestion remains, however, whether this strategyis practicable. In particular, two problems wereraised: (1) Must we not apply the reversal of theunder this rule?(2) Will any new technology ever be approved has little to lose if innovation is slowed down orto this question might be that we also treat oldsuch asymmetry discriminates against innova-ing to current standards. In principle, however,products which would not be approved accord-substances or medical drugs still allows oldcases. For example, the German law on toxicand new technologies asymmetrically in otherjust as much an experiment involving uncertain-blocked, and that we are generally better offties and unforeseen consequences as the intro-After all, continued use of an old technology isapply to new technologies and not to old ones?Why should the reversal of the burden of proof This is based on the value judgement that societyduction of new technology. A pragmatic answertion and favours the technological status quo. that hidden risks do not exist, is a logical impos-always be made and can hardly be refuted.The main weakness of regulatory schemes whichreverse the burden of proof to minimise techno-logical risk, is that they are unable to distinguishbetween acceptable and unacceptable innova-tions. The unsubstantiated assumption that atechnology could involve unknown risks canEmpirical proof of a negative fact, in this case,vation. From the perspective of risk prevention, sibility. One cannot, in a finite period of time,examine an infinite set of possible facts in orderto demonstrate that it does not contain somespecific element. Consequently, a strict reversalof the burden of proof would exclude all inno-then, no new technology would ever be accept-  not. The main objection in the technology aschanges in the ecosystem and natural evolution.certain circumstances, induce irreversiblecally engineered crops and they can, underjust as difficult (or easy) to retrieve as geneti-techniques are also able to reproduce; they arethe crops developed using conventional breedinggenic and nontransgenic crop plants. As a rule,far as reversibility is concerned between trans-sessment was that no difference can be made as 72 Herbicide-Resistant Crops able.  It seems plausible, therefore, to assume that should be regulated within a framework of riskother hand, if it is accepted that new technologycontrol, the burden of proof can only be reversedburden of proof have a moratorium on thefreedom to innovate in mind. They want toreplace control of risk as the test for approval ofnew technology with other criteria such associoeconomic need or democratic vote. On thethose who insist on the strict reversal of thereason will count as an argument stantiated. Then, only doubts justified by goodscenarios which can neither be tested nor sub-indicators for relative safety and leave aside riskto a limited extent. One must be satisfied withcontra projectum , and reversal of the burden of proof comes close to what we have in existing regula-tions under the precautionary principle.  If reversibility were really taken seriously as acrops would also not be allowed. This wouldcondition for approval, then conventionally bredthat such crops be accepted. Lack of reversibil-ity cannot be a sufficient reason to ban any newcrop. In the final analysis regulation returns tothe issues of risk. The relevant question iswhether a crop will have harmful consequences,not whether the consequences will be reversible.Accordingly, possible damage from transgenicherbicide-resistant plants was the central topic inour technology assessment, not whether therelease of such plants can be reversed or not.clearly be absurd. There is general consensus 9 Reversibility as a criterion?    in contrast, for example, to chemicals-werereleased in large quantities. These participants Various efforts have been made to find criteriawhich take unknown risks into account withoutthe need to ban new technologies outright. In thepublic debate, it was proposed that new technol-ogy only be permitted if its possible conse-quences are reversible. In the event of unex-pected risks, it must be possible to revoke theapproval of a technology without leaving lastingdamage. This criterion was adopted by someparticipants in the technology assessment, whoargued that genetically engineered organisms-able to reproduce themselves and multiply, andhence could not be recalled once they have beennature could occur.ensure that no irreversible harmful effects onshould be banned, as a precautionary measure tofelt that transgenic herbicide-resistant crops Regulatory responses to   10 anxiety The assumption that transgenic plants pose new,  ously worried; it may be sufficient that geneti-German constitution it is not possible to ban aplausible and probably widespread. People needAnxieties are a legitimate political signal, even ifthey cannot be justified on scientific grounds. Ina democracy, citizens\" feelings count; everyonehas, so to speak, the right to choose what he orshe fears and what not. On the other hand, thisdoes not imply a right to have one\"s fears put atthe basis of collective regulation. Under thetechnology merely because some people arepeople by imposing additional safety measuresafraid of it. However, there is no reason why thecally engineered plants are novel and unfamiliar.law should not respond to the anxieties of thenot have particularly good reasons to be seri-short of a complete ban on the technology.unknown risks which, in extreme cases, couldprove fatal or catastrophic may be arbitrary andscientifically unfounded and therefore unsuitableas the basis for regulation. However, fear ofunforeseen consequences is psychologically to have been a mistake. However, the questionWe may disregard the philosophical objectioncriteria. Responsible decision making ought toconsider whether and at what cost it would bepossible to reverse a decision, should it turn outwhereas released organisms and their genes aresense pharmaceutical products can be recalled,which are more or less irreversible, and in thissame as before. From a practical point of view itagain is whether this is a viable criterion fortion continue, and the world can never be thesince historical development and natural evolu-that, strictly speaking, no decision is reversible precautionary regulation of transgenic plants.is sufficient to distinguish between consequencesReversibility or retrievability seem plausible transgenic herbicide-resistant crops.tional tests and monitoring be required formade in the normative discussions in our tech-nology assessment. It was proposed that addi-Some recommendations along these lines were  92 These                                                    92   See section III E below.   Part III: Normative Evaluations-Ethics, Law And Politics 73 requirements should apply even if there were no \u00b7 Nonselective herbicides such as glyphosate or using conventional breeding. This asymmetrictreatment of transgenic plants could be regardedreasons to suppose that these plants are in anyas a sort of safety penalty for the novelty of thetechnology.way more dangerous than plants developed ductions in the amount of herbicides used willerosion are not to be expected. The use of onlyronmental impact than the herbicides they wouldreplace. Rapid degradation in the soil and re-one nonselective herbicide with monocultures ortheoretically reduce the risk of groundwatercontamination. Measurable effects on levels ofseed bank.in the all crops of a rotational sequence couldresult in the loss of rare weed species from theglufosinate are slightly better in terms of enviRegulations which are not based on identifiable risks but on the novelty of genetic engineeringare increasingly denounced as anti-modernism inthe international discussion. Such regulationswere, however, not really in dispute in ourtechnology assessment. They represent a kind oftribute to the lack of acceptance of geneticengineering among the general  public (albeit an widely accepted without reservation. This diver-in the short term by reiterating that the identifi-insufficient tribute according to the critics).Transgenic plants are frequently viewed withsuspicion, whereas new conventional plants aregence of opinion will probably not be overcomeAdditional safety measures seem to be an ap-restriction as long as they do not in fact amounttransgenic plants altogether.able risks for both types of plants are equivalent.to an attempt to obstruct the introduction ofpropriate response. They can be imposed for alimited period of time. They are open to revisionand they do not represent an unreasonable \u00b7 Nonselective herbicides improve agronomic purely theoretical, since they may not be eco-direct drilling, ground cover crops) may remainherbicides could, however, increase the selectionof herbicide-resistant weeds. New opportunitiesconditions by providing new options for flexiblepostemergence application and better control ofproblem weeds. Nonrotational use of suchnomic under present conditions.for systems of integrated crop management (e.g. \u00b7 For some crops, nonselective herbicides will offer financial benefits for farmers because weedcontrol becomes cheaper. The dispute was over the normative evaluation.Many participants rejected the conclusion whileThese findings were considered provisionary,since they were based on assumptions about theuse and effects of nonselective herbicides, whichmay have to be modified when more data areence. But they were not really in dispute amongthe participants in our technology assessment. that nonselective herbicides promise only slightof technological innovation in our society.advantage, they at any rate have no significantdisadvantage and their use, therefore, constitutesan acceptable method of agricultural manage-ment. Participants disagreed over the assessmentof existing regulations, over the proper criteriaof benefit, and over fundamental issues of futuredevelopment in modern agriculture and the roleavailable from field trials and practical experiNONSELECTIVE HERBICIDES:  C ARE THE BENEFITSAPPRECIABLE?  Public debate is preoccupied with the control of benefits can be expected:risks involved in genetic engineering. However,this is only one of the issues generated by trans-genic herbicide-resistant crop plants. Anotheragriculture, which becomes a feasible option forweed control if herbicide resistance genes areengineered to crop plants. The risks and benefitsof such a strategy have been dealt with in nu-merous reports and discussions in the technologyassessment. The results are, to put it cautiously,nonspectacular. As was shown in sections II Band II C above, neither grave risks nor dramaticissue is the use of nonselective herbicides in Regulations as a factor in risk1 benefit analysis It was a common practice throughout the techpossible risks, disadvantages and misuses ofnonselective herbicides by sayingnology assessment to counter arguments about: \"the argu\u00b7 Nonselective herbicides will not pose any with the problem\".practice, because existing regulation is copingment is true, in principle, but irrelevant, in This form of counterparticular problem of residues in food products.The situation is basically the same as it is withthe introduction of new selective herbicides. nate all negative factors. At the other extreme,ideal regulations and controls which will elimi-any risk-benefit analysis positive, by assumingpants. Indeed, one can easily make the results ofargument considered \"unfair\" by some partici\u00b7 The overall amount of herbicides used in could be some increase, however, in marginalagriculture is likely to decrease; in some cropsdisplaced.considerable savings could be achieved. Thereareas if mechanical methods of weed control are  74 Herbicide-Resistant Crops however, it would also be misleading if regula- herbicides in general, the debate on the scope results with or without the proposed regulation.in our society is approved without any restric-continuously applied without rotation, theymake the technology acceptable. To the con-to argue that these would solve the problem andbe \"unfair\" to recommend new regulations andimpacts of such plants would be. Nor would itcation, liability etc.), to determine what theeven positive.account legitimately the established regulatorytrary, such recommendation is clear evidencetion. Therefore, a risk-benefit analysis of trans-genic herbicide-resistant plants can take intoframework (testing requirements, rules of appli-\"integrated crop protection\". However, if properthat risk-benefit analysis will yield differentonly once with rotational crops, their impactsregulations ensure that these herbicides are usedwill probably be neutral or, in some respects,counted as negative according to standards ofspecies from the seed bank, and this must betions were not considered at all. No technologyFor example, if nonselective herbicides werewould cause the total eradication of some weed predictive risk assessment.the argument that available tests should bein toxicology and ecology is desirable. However,development of better test methods and modelsthe discussions. There was agreement that theapproval of herbicides remained a side issue inand predictive power of preventive testing foreliminate all objective, reproducible criteria fromdismissed as useless because they have inherentlimitations was clearly rejected: that would There can always be risks which will not beOne thing the debate did achieve was to call tomind that regulations should not make unrealis-tic guarantees of safety. No preventive testingcan exclude every risk; it can only control afinite set of clearly defined risk assumptions.controlled, because they are unknown oruntestable. Thus, if tests find no risk, this isstrictly speaking, only an indication of relativesafety, and not a proof of full safety. The factthat we accept such indicators and consider atechnology safe (enough) once it has passed thetests for approval, is a political compromisebetween minimising risks and enabling techno-logical innovation.  93 adequate to solve the problem, or that the rulesexisting or proposed regulation is in fact notwould not be observed in practice. Argumentstion. But it is still a legitimate argument thatproblems which are dealt with by proper regula-A risk-benefit analysis may have to disregard technology assessment. In particular they re-on this line were raised against all regulationferred to the limits of preventive testing, both incides.ticularly low in the case of nonselective herbi-compliance with existing rules would be par-and model systems). Critics also claimed thatterms of size and validity of tests (use of animalsconcerning herbicides by the critics in our  terms, however, the question of what constituteswhich must be tolerated without being tested.This applies as well to the approval of nonselec-tive herbicides and of transgenic herbicide-resistant cultivars. Uncertainties which may stillbe implied by such cultivars but have not beencontrolled by preventive tests will, in legalterms, count as residual risk which may beimposed legitimately on the society. In politicalthe technology is approved, and possible effectsapproved is a highly controversial matter-bothSince it is impossible to test for all conceivablein the public debate, in general, and in ourtechnology assessment. While it is true that testswhich prove, to the negative, that no risks exist,ogy must draw a distinction between possiblethan has been done up to now. Therefore, therewill always be room for new demands to tightenthe conditions for herbicide approval.an acceptable residual risk when herbicides areeffects which can be tested and controlled beforeare impossible, it is always possible to test morenegative effects, any regulation of new technology assessment was not soccurred, the regulations could be tightened oradmitted that the tests for herbicide approvaltion or lasting soil impacts). Since our technol-Germany (because of groundwater contamina-case of the ban on atrazine and paraquat inapprovals for the herbicides withdrawn, as in theAll participants in the technology assessment sufficient in the past to prevent damage. Ifstead that the regulations had apparently beenhealth and environment. They pointed out in-regulations could not guarantee the safety ofthat, because of these limitations, existinghave limitations, but many contested the claimunexpected harmful effects from herbicidesupposed to judge                                                    makes the introduction of new herbicides virtu-ally impossible or uneconomical. Those whoconsider the use of herbicides acceptable andplace. Those who reject all use of herbicides willdemand ever more exacting tests, even if thisnecessary in agriculture will advocate limitedherbicides should be approved at all, in the firstof the underlying disagreement over whetherThis dispute is not likely to be resolved because  93   See above section II C2.  entails some loss of biodiversity. In addition, local or regional biodiversity within agriculturalagricultural areas.would have to be created for rare weeds outsideexisting biodiversity. If necessary, reservescultural habitats with a view to preservingecosystems, it makes no sense to regulate agri-reforested. Therefore, in contrast to naturalsame applies if large areas are set aside orthese crops will disappear from the fields. Theable), then the weed complexes associated within Central Europe if alternatives become avail-are no longer cultivated (for instance, sugar beetchoice of crops to be cultivated. If certain cropshabitats is in any case contingent upon the Part III: Normative Evaluations-Ethics, Law And Politics  75 testing programmes and warn against \"overtotal rejection of the technology, regardless ofshould admit instead that they really seek theregulation\". It would be honest, in this dispute,to do away with the misleading scientific rheto-ric that preventive testing will prove the safetytesting.that some compromise between what is tested,and what is not, is always implied. Political andmoral arguments must then explain why thiscompromise should be accepted as fair andfitting. On the other hand, it is dishonest to drivedemands for stricter regulation to the extreme:those who press for ever more preventive testingas a means to exclude all conceivable risk,of a new technology; instead one should admit role in the assessment of nonselective herbicides. Some participants concluded from this thatspecies conservation should have no significantThe general feeling was, however, that whileproduction must have priority on farmland, thisdoes not imply a  carte blanche  for unrestricted  Shifting criteria of evaluation eradication of weed species. This is in line withthe German  Plant Protection Act  which rules 2  that herbicides cannot be approved if theycompatible with agricultural production. Thosebiodiversity from herbicide use was avoidableintensive agriculture felt that any loss of weedand desirable alternative to conventional,who considered organic farming as a feasibleby the argument that nonselective herbicidesextent species conservation on farmland isthere was no agreement concerning to whatimpair the \"household of nature\". However,Consequently, these persons were not impressedand should therefore count as damage.the tank mixtures of selective herbicides used atpresent; they demanded instead that weedcontrol be carried out in general at much lowerlevels. A common ground for evaluationaccepted by all participants was the notion of\"integrated crop protection\", with the objectiveto reduce the chemical load on agriculturalfields, if possible. The majority accordinglyrejected permanent, nonrotational applications ofnonselective herbicides because this is likely tolead to extreme depletion of weed seed banks.would not reduce weed stocks more than would flict. When it comes to these issues, pluralisticprevail. This was especially the case in ourcriteria. What counts as damage, what as bene-fit? In many cases the answers are clear. Ingeneral, there is a social consensus on basicgoals and values (human rights, protection of theenvironment, productivity in agriculture). Plu-ralism does not mean that people live in separatenormative worlds. Disagreement arises overquestions of how accepted goals and valuesmoral attitudes and political preferences willhow priorities should be set if they are in con-technology assessment whenever the develop-ment of acceptable or desirable forms of agri-culture was at issue. The debate over whetherprotecting the diversity of weed species is aproper goal when we consider agriculturalfarmland, can serve as an example.should be realised in concrete situations, and Any risk-benefit analysis requires evaluation factor in the risk-benefit analysis? If we applyincluding organic farming, attempt to eliminateexisting spectrum of species be preserved overthe widest possible range of sites. But is this aproper criterion for evaluating a method of weedcontrol? Evidently, where farmland is concerned,some aspects of biodiversity will give way toaspects of productivity. Agriculture gives, byother plant species. All forms of agriculture,most weeds from the fields and reduce the pressure from weed seed banks. Weed controlof a rare species in a region constitutes signifi-definition, preferential treatment to crops overthe criterion of nature conservation, then the lossspecies from the areas treated. Is this a negativebanks and occasionally eliminate rare weednonselective herbicides will reduce weed seedWe can assume that the widespread use ofcant damage; this criterion demands that the Are small benefits  3  appreciable?  Most of the participants in the technology assessment felt that transgenic herbicide-resistantcrops did not represent a major technologicalbreakthrough in chemical weed control. Thesecrops contribute to innovations that were alreadyin place before, like shifting to postemergencetreatment using split doses of herbicides. Tech-nically speaking, nonselective herbicides are  76 Herbicide-Resistant Crops equivalent to new postemergence, selective ment. 95 In the discussions on soil erosion it was herbicides. They will offer some advantagescontrol, and with respect to more effectiveelimination of problem weeds (especially in rowcrops). However, most participants saw littlereason to vest great hopes of agronomic benefitsin them.with respect to flexibility and cost of weed site-specific crop management were observed.other hand, they would be superfluous if propersate for existing losses from erosion and, on thehand, they were in no way adequate to compen-herbicides should be ignored because, on the onefrom a shift to postemergence, nonselectiveargued that any improvements that might result 94 assessed in comparison?evaluation to be dealt with in any risk-benefitlems? Should alternatives to the technology be This assessment raised some basic questions ofstatus quo suffice to \"really\" solve the prob-analysis: Are small benefits appreciable? Is atechnology acceptable if it improves the statusquo moderately, or must the status quo beevaluated as well? Will any improvement to the smaller quantities. With respect to the economicwas taken as the criterion of benefit, becausereduced cost of agricultural inputs and productsevaluation, some participants criticised thatthe practices of intensive farming, as the startingbeneficial just because they would be used innot find them more acceptable or ecologicallyment, who rejected herbicides in principle, didHowever, participants in the technology assess-was generally booked as an ecological benefit.case, relative improvements in terms of reducedpoint. They argued that if external costs werenegative environmental effects and also socialproblems-then conventional, intensive farmingas a whole might prove \"uneconomical\". In thiscosts for the farmer could no longer be consid-ered an economic benefit of herbicide-resistantcrops.included in the economic assessment-especiallythis implicitly accepts the status quo, namely, A reduction in the amount of herbicides used technology in general, if we are to assess trans-other problems against which the possibleappear to be negligible. Therefore, opportunityThere was broad agreement that risk-benefitharmful effects from herbicide-resistant cropsmakes little sense to extend the evaluation toalways be some innovations which are moreworthwhile to pursue. And there will always be ute to that problem.genic herbicide-resistant crops. There willimpacts herbicide-resistant crops might contrib-be used as an argument to ignore the negativeprimary cause of loss of genetic diversity cannotfact that destruction of tropical rain forests is theuse) should not be considered. Conversely, theherbicide-resistant crops could be put to betterdevelopment, introduction and regulation ofcosts (i.e. how the resources necessary for theanalysis implies a limited frame of reference. It  This pattern of argument repeated itselfthroughout the discussions in our technologyassessment. While some individuals emphasisedprovements were to be expected, others arguedthat such \"improvements\" should not countbecause, in absolute terms, they merely amend astate of affairs which was not acceptable fromthe outset. They make things \"less bad\", at themost, but not \"good\", and they do not, therefore,represent any real benefit.that relative ecological or technological imlatter would only accept reductions in herbiciderequired by the precautionary principle. The tuted any real improvement. Some took currentuse of at least one order of magnitude (i.e. toEven so, the choice of reference level remained areference, others the optimum of zero pollutionlevels of groundwater pollution as the point ofexpected with nonselective herbicides, consti-differed over whether a reduction of 10 to 20%,used in agriculture are desirable. But views asand that savings in the amounts of herbicidesleaching into groundwater must be preventedexample, participants agreed that herbicideproblem in the technology assessment. Forone-tenth or one-hundredth) as a real improveence to suit their interests in the argument. Forexample, in our technology assessment, changesrated as a change for the worse. In the latterin the amounts of herbicides used were valuedasymmetrically by many participants: a 10%reduction was not considered an improvement atall, but a 10% increase would clearly have beenthat such choices need not be consistent. Peoplefound it convenient to shift the frame of refer-How the frame of reference for evaluation isbut merely laid open. It then becomes apparentselected, is itself a matter of evaluation. The choice cannot, in the final analysis, be refuted                                                    94   This rather tentative assessment may have to be 95   Expert report of G. Klein: \"Auswirkungen der HRmodified in view of the results from recent field trials;see above section II B2. Technik auf aquatische \u00d6kosysteme\", in: Materialien zur Technikfolgenabsch\u00e4tzung, Heft 9 (see appendix).  the frame of reference. The question was Part III: Normative Evaluations-Ethics, Law And Politics  whether or not we can expect relative improve-ments compared with current weed controlpractices. The context of these practices-cultivation of high-yield crops, small croprotations, and high chemical inputs of fertilisersand pesticides-were taken as given. 77 case, the status quo of herbicide inputs is the an equally small increase which might result ifconsidered to represent real harm.starting point of reference for evaluation; in theformer case, it is not. Similarly, a slight reduc-tion in water pollution, which might result ifamounts, was not considered a real benefit; butnonselective herbicides are applied in lessermore herbicides were washed off leaves was Our technology assessment was not s  upposed to ticipating environmental groups operated on theengage in a systematic, comparative evaluationof alternative farming systems. However, par-premise that were such a comparison to bemade, organic farming would come out ahead,and that it could (and should) replace conven-contradicted by others whose main argumentwas that organic farming could not ensure foodsupply for the world population. Nor was itaccepted unconditionally that organic farmingrepresents the superior model in terms of envi-tional farming on a broad scale. This view wasronmental impacts and sustainability. acceptable to those who oppose the use ofthat this is treating the symptoms but not curing Nevertheless, there is still scope for a balancedpolitical assessment of herbicide-resistant crops,irrespective of the frame of reference adopted forevaluation. Even if one concedes that any im-provements achieved through such crops wereonly variations of a status quo which itself mustbe regarded as problematic, one could still arguethat we ought to do what we can to improve thisstatus quo step by step. The counter-argument isthe disease. Although this may be true, it is stillherbicides as a matter of principle.not a sufficient reason to reject herbicide-resistant crops altogether. Why should a positivedevelopment be rejected just because it does notgo far enough and cannot solve all the problemsat once? It is possible to justify herbicide-resistant crops as an option that offers moderateagronomic and environmental benefit and, at thesame time, emphasise that these crops representno significant contribution to the more ambitiousgoal of making modern systems of agriculturesustainable. This argument will, however, not be denied that organic farming has a better envi-that, for this reason alone, the transition to sive shift in emphasis between two co-existingdiscussed. This issue is mainly of \"academic\"environmental terms if it were developed ac-cording to the principles of \"integrated cropmanagement\". Opinions were divided over thisquestion. However, even the advocates of or-ganic farming did not rule out that, with appro-priate management, conventional agriculturecould be continued indefinitely and also fulfil thecriterion of sustainability. They did not claimthat present agriculture would inevitably lead tothe ecological collapse of food production andcould prove an equally viable alternative inmany insisted that conventional agricultureorganic farming was indispensable. The questionreplace conventional agriculture as the basis ofworld food production was not extensivelyWhereas no participant would probably haveinterest since even the advocates of organicfarming did not assume that the phasing out ofconventional agriculture was a realistic politicalgoal for the near future. It is obvious that anytransformation to organic farming would notimply an abrupt switch from one system to theother; but at best it would mean a slow, progres-whether organic farming could completelyronmental record than conventional agriculture,strategies.  Reference to intensive  4 agriculture or to organicfarming?  Normative discussions in the technology asof intensive agriculture is considered to besessment frequently ended up with more funda-mental questions of how agriculture should bedeveloped in the future. If the prevalent systemthen virtually no improvements to this systemneither worthy nor capable of being reformed,would count as real benefits. Accordingly, it wasargued by some that the technology assessmentdealt with the wrong issues. Instead of assessingonly transgenic herbicide-resistant crops, acomparative assessment of alternative systemsof agriculture (intensive versus organic farming)would be needed. conventional, intensive agriculture was taken asrespect to possible ecological, agronomic andlimited answers. In deriving conclusions withlimited questions and can therefore only giveOur technology assessment indeed only posed economic benefits of herbicide-resistant crops, The dispute over which form of agriculture wewithin the broader framework of alternativecide-resistant crops. Nevertheless it would notof political disagreement over transgenic herbi-should develop was in many ways the real corebe appropriate to evaluate these crops solelysystems. Even advocates of organic farming   78 Herbicide-Resistant Crops would have to admit that improvements in sis required by the German law (article 16 of  the vant, since this form of agriculture is what isof distribution than of production. A realistic,to increased yields in conventional agricultureThird World, feeding billions of people. Thanksthe industrialised countries and much of the(including the so-called Green Revolution), foodproduction has been able to keep up with popu-lation growth in recent decades. At least for thetime being, therefore, hunger is more a problemshort-term alternative to replace the presentsystem is not in sight. Despite all their differ-methods could not take over the role of ensuringences, participants in our technology assessmentwould not have disputed that organic farmingconventional agriculture could be highly rele-food spractised on almost the total area of farmland inupply on a global scale in the foreseeable Genetic Engineering Act , article 15 of the  Crop political and technological revolutions notwith-continue to depend on conventional agriculture,and steady agronomic, ecological and economicimprovements in this type of agriculture areabsolutely indispensable.One must therefore concede that-dramaticon the basis of its present level of productivity.future; nor perhaps would it ever be able do so,standing-a growing world population will Protection Act ). In part, they were concerned cal control of innovation in our society.with more radical demands to extend the politiRisk-benefit analysis under  1  Engineering Actthe German Genetic According to article 16 of the   Genetic Engineering Act , transgenic herbicide-resistant crops may only be released or placed on the market if  \"according to the available scientific evidence no effects are to be expected whichpurpose of the release\".are unjustifiably harmful in view of the 97  The elements to be considered for such a deciassessment. Most participants assumed thatthis test and could be approved.transgenic herbicide-resistant crops would passsion were brought together in our technology 98 However, assessing damage?several aspects need to be clarified: When is aWhat effects have to be taken into account inrisk-benefit analysis necessary (admissible)? unfortunate circumstances occur? Or can bene-denied without any consideration of benefits.that, in the latter case, approval must always beorganisms? The European law seems to ruleis, for damage inherent in the application of suchfits also compensate for imminent danger, thatwould result from transgenic organisms if some compensate for risks, that is, for harm thatbut definitely to be expected. Can benefits onlypose, if harmful effects are not only a possibilityOne question is whether a release can at all bejustified by weighing the risks against the purUSEFULNESS AND                                                     D INNOVATION?SOCIOECONOMIC NEED ASCRITERIA FOR APPROVAL:A \"FOURTH HURDLE\" FOR What benefits might be obtained from transgenic  for the community.herbicide-resistant crops is, without a doubt, acentral topic in a technology assessment. Butnology? Seed producers and chemical companieswill try to estimate the economic advantagesbefore they invest in transgenic herbicide-resistant crops, and public funding should bewithheld if these crops do not promise a benefithow relevant is it for decisions about the tech97 Harm is defined in terms of impacts on life and health of humans, on animals and plants, as well as otherand on material goods. See article 1.aspects of the environment and its fabric of interaction, 96 But to what extent should a approval of new technology? Could\/shouldlegal test for benefits become a criterion for thetransgenic herbicide-resistant crops be bannedbecause they offer no real benefits or becausewe actually do not need them as equally good orbetter alternatives are available? 175\/25). Monsanto\"s glyphosate-resistant soybean wasmarket as seeds for breeding purposes (but not for food orrape and chicory were authorised for being placed on the1994. On the European level, herbicide-resistant oilseedrape and maize were approved (for field trials only) in98 In Germany, releases of glufosinate-resistant oilseed feed) in 1996 (Official Journal, 1996 L, Nos. 37\/30 andauthorised for food purposes in April 1996 ( Official Journal L 107\/10). Transgenic pest-resistant maize with a herbicide resistance gene as a marker was finally ap-marketing in December 1996. France refused, however,to register the variety, which is a precondition for grow-ing it (see proved on the European level without restrictions forNature Biotechnology, 15, 1997: 308). Thus, the maize is not yet grown in Europe; import has beenapproved in all EC countries except Austria and Luxem-bourg (May 1997).  centred in part on the limited risk-benefit analy-in our technology assessment. DiscussionsThese questions were the subject of controversy                                                    96   Probably because of public criticism surro unding the development of transgenic herbicide-resistant crops.ogy decided not to become involved in the funding of theproject, the German Ministry for Research and Technol-   Part III: Normative Evaluations-Ethics, Law And Politics 79 Directive 90\/220 on the deliberate release re- chemical industry, but the protection of these quires measures \"to avoid adverse effects\" onThis question is controversial,human health and the environment (article 4). interests is not covered by the  Genetic Engineering Act . The same applies for negative 99 but it appears to isms.than the law for genetically modified organ-are a matter for the plant protection law ratherSuch problems concern the use of herbicides andtive herbicides were used particularly recklessly.ronmental damage that might result if nonselec-with these crops. An example would be envi-use of the nonselective herbicides introducedherbicide-resistant crops themselves, but to theconsequences attributable not to the transgenic have no particular significance for transgenicmore or less remote and the probability of whichherbicide-resistant crops since these pose nospecific risks for human health or the environ-assessment all referred to possible harm that wasment. The risks discussed in our technologycould be further reduced by appropriate safetymeasures. Harm may nevertheless be possible,but that possibility can be compensated legiti-mately by the purpose (the benefits) of thetechnology. 100 dicted or described because they are not knowndiscussed in our technology assessment substan-risks which were the subject of controversy inour technology assessment fall under this cate-gory, for example, the assumption that herbi-cide-resistance genes which had been outcrossedto wild plants or transferred to soil bacteriacould have unforeseen environmental or otherthey could initiate evolutionary developmentswhich could prove harmful after many years. Itis questionable whether any of the scenariostiated sufficient risk to warrant an assessment of purpose as a condition for the approval oftransgenic herbicide-resistant crops under arti-novel effects not previously observed, or thatare not taken into account, even if they remain aquently, harmful effects which cannot be pre-assessment under the German law. Conse-not have to be compensated in a risk-purposerisks, that is, uncertainties about hidden risks, doIt is generally agreed that so-called residualtheoretical possibility. Many of the assumed harm to the economic interests of farmers or thereasons the possibility that transgenes for herbi-selective advantage in natural habitats, oneagricultural fields be brought forward as damagequences which are possible or probable but notharmful need not be justified by the purpose ofthe technology. This would probably apply, forexample, to horizontal gene transfer from croptance genes be transferred, the effect to beexpected would be a temporary increase innumbers of transformed herbicide-resistantbacteria near the soil surface while the herbicidein a risk-benefit-analysis. They constitute realis active. Whether this in itself represents acide resistance are outcrossed from crops tosome degree of probability. Therefore, conse-related wild species will be irrelevant. Sinceherbicide resistance does not represent anycannot envisage ecological damage from occa-sional wild plants which might have taken up thetransgene. Nor can the disadvantages resultingfrom the selection of herbicide-resistant weeds inharmful effect is questionable. For similarplants to soil bacteria. Should herbicide resis-law if adverse effects are to be expected withpurpose of a release is only necessary (andOn the other hand, weighing the risks and the hence only admissible) according to the German                                                                                                       100   This is also the standard rule in the European law. The scope of Directive 90\/220; see, for example the decisionby the Commission on herbicide-resistant chicory (practice of herbicide use in agriculture is outside theimpact of transgenic herbicide-resistant crops on theOfficial Journal, 1996 L, No. 175\/25). Such arguments may committees (see IHE, 1996: 5). The legal separation ofnevertheless be used to block decisions in the respectivewhich represent a broad range of interests. The excludedsafety issues from socioethical problems runs counter toLevidow aspects must either be dealt with in other legal arenas orbe taken up in informal deliberations and dialogues\"surrounding\" decision making on genetic engineering;see, for the Netherlands, Schomberg (1996). However, athe mood of public debates and policy advisory bodiesnumber of countries (Denmark, Austria) explicitly referto social criteria in their gene technology laws; seeet al. (1996: 148) and below. On the other hand, any risk-benefit-analysis under the  Genetic Engineering Act would have to include agricultural disadvantages and problems related to the use of nonselective herbicides asafter it has been decided that harmful effects must betaken into account. But benefits would only be assessedresistant crops; these factors reduce the benefits to benegative factors in assessing the benefits of herbicide-expected. 99   Expert report commissioned from Prof. E. Rehbinder (Fakult\u00e4t f\u00fcr Rechtswissenschaft, Universit\u00e4t Frankfurtam Main): \"Rechtsprobleme gentechnisch ver\u00e4nderterherbizidresistenter Pflanzen\"; commentary by Dr. J.Steinberger (Bundessortenamt Hannover), in: Materialien zur Technikfolgenabsch\u00e4tzung, Heft 18 (see appendix). ate if it were not even possible to consider whether, forof the food chain. See the official commentary on arti-cle 16 in Hirsch and Schmidt-Didczuhn (1991, No. 17).example, the use of genetically modified microorganismslevels of water pollution or a shift in the species spectrumunavoidable harmful effects. It would hardly be appropri-necessary to consider a really useful application withneed for revision would arise as soon as it would beWere the EC Directive to be applied strictly, then theagainst the malaria mosquito might not warrant certain  80 Herbicide-Resistant Crops cle 16 of the German  Genetic Engineering Act . trols than conventionally bred plants. The Gerthat horizontal transfer or outcrossing of herbi-release. Moreover, the definition of what con-Perhaps one could argue that the risk of unex-pected metabolic side-effects in food crops is anexample. This risk must be tested in every case,but it still cannot be completely ruled out. If it isnot classified as a residual risk, it would have tobe balanced by the purpose (the benefits) of theAnd with no established jurisdiction in this field,it is difficult to predict whether the judgementstitutes harm is not a mathematical exercise.cide resistance genes does not constitute harm,will finally be accepted by the courts. It seemsadvisable, therefore, to consider what benefitscould be pointed out to compensate for suchrisks. man law requires safety measures correspondingto the state of scientific knowledge ( Stand der Wissenschaft ), which generally means a parpurpose assessment. It can be assumed thatshould suffice to outweigh them in the risk-ticularly high standard of precaution. However,if, despite the safety measures transgenic cropsstill involve risks, and if these risks are compa-rable to those normally accepted with conven-tionally bred plants, then a moderate benefitthis requirement.transgenic herbicide-resistant crops would meet 102  Have alternatives to  2 genetically engineered cropsto be taken into account? edge about the performance and the effects ofconditions. When transgenic crops are placed onamount to at least one order of magnitude (oneassessment that a reduction in herbicide useraised by some participants in our technologyThere seems to be no legal basis for the demandbenefit. Any reduction in the use of chemicalsprovements relative to the status quo must beflexibility and higher crop yields. Small im-used, better control of problem weeds, greaterinclude reductions in the amounts of herbicidesthe market, the benefits to be considered willfor crop protection is a legal objective accordingto the German tenth) less before it could really count as ataken into account (with appropriate weighting).transgenic herbicide-resistant crops under fieldbenefits to be considered are increases in knowl-Insofar as only field trials are concerned, the  Plant Protection Act  (article 6). Whenever risks and benefits have to be balanced  crops justify the risks when other options arethe question of alternatives comes to the fore.available for weed control, with the same orCan the benefits of transgenic herbicide-resistantlower risks? Can approval be denied if thesecrops, although useful when viewed in isolation,are not better than what we already have? Thereis no provision in article 16 of the German Genetic Engineering Act  that alternatives have oped by the German Federal Administrativebe required under the general principles devel-Court in the paraquat case.to be taken into account. This may nevertheless 103 However, the law poses tight restrictions here.  It is uncontested that the risk-benefit assessmentunder article 16 may not be used to test forsocioeconomic need nor to enforce political                                                    101  In balancing the risks and purpose of transgenic 102   This conclusion is based on two assumptions: bred plants. It is true that comparability of risksherbicide-resistant crops it seems legitimate toconsider as well that the risks to be compensatedspecial legislation has been enacted for geneti-cally modified organisms suggests that trans-genic crops could be subjected to stricter con-does not imply acceptability. The very fact that(like uncontrolled metabolic changes or in-creases in fitness) also exist for conventionally law really required that \"harmful effects on the environ-such effects will be outweighed legally by the benefits ofbenefit. According to the results of our technologyit should lie here.application for the risk-purpose assessment of article 16,made very small by appropriate precautions. If there is anthese crops. This interpretation would not be valid if theassessment, harmful effects cannot be excluded. Thisment must be excluded\" (see Rehbinder, p. 25). Strictlyspeaking, this formula would bar any approval of trans-genic herbicide-resistant crops, irrespective of purpose ortransgenic herbicide-resistant crops. (2) The possibility ofdoes not just mean that it is logically impossible toexclude unknown risks: it is also not possible to reducerealistic, identifiable risks to zero. It is only possible toshow that the risks are very small or that they can be(1) Certain harmful effects are possible if we release                                                    101   On the other hand, it is questionable whether it can be vantage and as abuse of herbicide-resistant crops, even ifbenefits which can be taken into account.the risks of transgenic crops; rather, they reduce theLike other agronomic disadvantages, they do not add tofarmers could benefit economically in the short term.technology assessment, they were considered as a disad-with the rules of \"integrated crop protection\". In ourin his report, p. 27). Such options are hardly compatiblemanagement of monocultures (as concluded by Rehbinderresistant crops, farmers have better options for theconsidered a benefit that, with transgenic herbicide103 Judgement by the German Federal Administrative Court, 10 November 1988, Volume 81, p. 12: Approval ofa herbicide which has considerable effects on the house-hold of nature may be denied, because substitutes areavailable that have fewer effects and that are suitable forthe farmer in agronomic and economic terms. See alsoRehbinder, p. 40.   Part III: Normative Evaluations-Ethics, Law And Politics 81 choices of the technology on which agriculture authorisation when new and better products are natives that might have to be taken into accountally needed. And it is not an admissible legalresistant crops can be spared altogether if agri-should be based. Competent authorities have totages and are not an equivalent option.crops are useful, but not whether they are actu-examine whether transgenic herbicide-resistantargument that herbicides and thus herbicide-culture were shifted to organic farming. Alter-they have agronomic and economic disadvan-are technical options for weed control withouttransgenic herbicide-resistant plants. Mechanicalmethods will not usually be considered because resistant crops to zero just because nonselectiveing selective herbicides.herbicides may not be better than already exist-better. Consequently, it would not be legitimateto reduce the benefits of transgenic herbicide-be launched even if existing ones are as good orbrought onto the market, and new herbicides can paraquat ruling, environmental impacts of protected legal goods and (2) if selective herbi-tion\u00b0herbicide-resistant crops do not meet condi-suggests that the possible risks from transgenicare less probable. Our technology assessmentcides are available from which harmful effectsare unjustifiable (and cannot be compensated byinvolved in transgenic herbicide-resistant cropsreasoning, one could perhaps argue that risksexpected from herbicide use. In line with thisthat the impacts exceed the levels normally to benatives are available. This ruling presupposesherbicides may be unjustifiable if suitable alter-benefits) (1) if they pose an imminent danger togreater significance since, according to theIn evaluating risks, alternatives may have1 . They refer to possibilities of damage, proved. Such a rule does not even apply fornuclear energy. If it were adopted then, in theharmful effects are to be expected from conven-ogy assessment, it is questionable whether lessherbicides). However, on the basis our technol-conventionally bred plants (and not selectivealternatives to be taken into account would becase of transgenic herbicide-resistant crops, thenology that implies the least risk can be ap-which are either remote or \"normal\" in dealingwhen alternatives are available, only the tech-into account in order to minimise risks, and thattionary principle that alternatives must be takenThere is no established rule under the precau-mate to compensate them with possible benefits.with crop plants. Therefore, it should be legiti-tionally bred plants than from transgenic ones. 104 But be made in this respect. The first is that, becausealternatives are available, no benefit accruesfrom herbicide-resistant crops. The second isthat, because alternatives are available, the risksposed by herbicide-resistant crops are unaccept-able. Both arguments are to the same point butherbicide-resistant crops? Two arguments couldwith a slightly different focus.tions for the risk-benefit balance of transgenicleast for some crops. Has this any legal implica-Such alternatives might in fact be available, atherbicides would provide a suitable alternative.ance and equal or less risks than nonselectiveselective herbicides with comparable performtechnology.represent a benefit. In general, the approval of aWhen we compare benefits of different tech-versions of a technology, in our case, that wesenting real progress compared to an oldernologies, we may find that one is more usefulhave more options for herbicide use, can itselfnew technology is not contingent upon its repre-at all. The very fact that we do have differentreally useful and that the others offer no benefitconclude from this that only the best one isthan the other. However, we would not normally 105 Older herbicides do not lose their                                                    106  104 Following the \"paraquat\" ruling they would neverthe-  In conclusion, any suggestion that transgenicherbicide-resistant crops should only be ap-proved if they offer clear advantages over previ-be treading new legal ground. It advocates theously applied strategies of weed control would produced in our technology assessment that severeless have to be considered if severe impacts on thehousehold of nature were to be expected from nonselec-tive herbicides, which exceed those levels usually causedby herbicides. Having to tolerate such impacts would beunjustifiable, if mechanical methods were an availableand suitable alternative. However, no evidence wasimpacts must indeed be expected. Therefore, as long asthe availability of mechanical methods of weed control isherbicides in general, it will also not be possible to use itas a legal argument against the approval of transgenicherbicide-resistant plants.not a sufficient reason for denying the approval of                                                                            expected (article 34,  Saatgutverkehrsgesetz); see also Rehbinder, p. 8. 106   It would seem that there is also little scope for taking lective herbicides tend to have less and not more impacton the household of nature than commonly used herbi-cides. The risk that rare weed species could be eliminatedby excessive reductions in weed seed banks may requireadditional regulation; it hardly justifies denial of approvalfor nonselective herbicides because alternatives areavailable.alternatives into account in herbicide approval. Nonse105 The certification of new plant varieties is an exception improvement\" compared to existing varieties is to bepass the test of \"value for cultivation and use\" which,to a certain degree; new varieties only get listed if theyaccording to the German law, requires that a \"noticeable  82 Herbicide-Resistant Crops rule that old technology should be given prece- rejected by mainstream policy and, as was to be dence over new, and that \"novelty\" is sufficientreason for rejecting a technology if no additionalbenefit can be demonstrated. It was surely notthe intention of the German law to subjectgenetically modified organisms to such a rule.That would have been expressed clearly in the assessment as well.expected, met with opposition in our technology Genetic Engineering Act . This rule cannot, 109 The objections were in of the risk-purpose assessment required undertherefore, be introduced through the back doorarticle 16 of the act. part pragmatic and in part a matter of principle.  delimitation: Pragmatic arguments considered problems ofWhat counts as need?  Are transcontrol spectra which can only be plugged withconsideration. One could solve this problem byunder current law, in determining benefits whichmight balance risks. In this case, the assessmentwould have to be confined to the intended appli-environmentally friendly and economicallyand consider the need for technically reliable,taking only direct effects of the new technologyviable weed control. This proposal does notcation of transgenic herbicide-resistant cropswhat about lower food prices, or jobs created interm effects of new technology are taken intoof social need depends on which short and long-the breeding sector? Obviously, the assessmentinterest in cutting costs an acceptable need? Andbetter than the existing ones? Is the farmer\"sfor additional herbicides even if they are notnonselective herbicides? Or, is there also a needexisting herbicides have gaps in their weedgenic herbicide-resistant crops only needed whenor product into account. This is the practice                                                                            107 However, participants in the technology assessment discussed whethersuch a rule was desirable, in principle, andwhether it should be included in the law in thefuture. Socioeconomic need as a  3  innovationcriterion for technological  In a way, the postulate that new technology risk of harmful effects which we do not knowherbicide-resistant crops within the commonframework of risk regulation. The central argu-socially useful and to fulfil a real need, was thelogical endpoint of the risk debate in our tech-nology assessment. It refers to residual (hidden)risks and implicitly admits that no conclusiveargument could be formulated against transgenicment is simple: If no innovation can escape thetives are available, does not even justify residualshould only be approved if it is shown to beand therefore cannot test in advance, then weshould take this risk only if the innovation isreally worth it. A technology which, strictlyspeaking, is superfluous because it serves noacceptable need or because appropriate alterna-risks being imposed on the society. for example, to make sure that a particular product will not exacerbate existing agricultural surpluses orresult in further decline in small farming operations\"(1992: 8). 109   The Commission of the European Communities different way. It is not the intention to have anotheralso tend to discourage useful innovations\" (OSTP 1992).emphasised that regulation should be confined to risks.(CEC 1991: conclusion); see also Cantley (1995: 639).systematic assessment in addition to the three criteria\"proposed to amend the The German government followed that reasoning when itthe scope of oversight on grounds other than risk wouldintends to assess products only under the conventionaland avoids hindering  safe  innovations. . . .  Determiningprotects public health and the environment against risk,\"The risk-based approach is scientifically sound, properlyThe US Office of Science and Technology Policy hassocio-economic aspects need to be considered in acriteria of safety, efficacy and quality. \"By their nature,Genetic Engineering Act in 1993. humans and the environment\" (warranted to the extent that they are justified to protect\"Restrictions of the use of genetic engineering are onlyBundestagsdrucksache 12\/5145: 10). The Austrian Gene Technology Act of 1994 unacceptable for economic, social or ethical reasons\"a mandate (and an obligation) to issue special regulationincludes, however, broader criteria. The government hasin order to prohibit products if they \"could lead to aburden on society or social groups, which cannot becompensated and if the burden on the society appears(section 63). The Norwegian  Gene Technology Act  of 1993 requires \"that in deciding whether or not to grantcommunity and a contribution to sustainable develop-whether the deliberate release represents a benefit to thethe application significant emphasis shall be placed onment\" (section 10); see Backer (1995).  This is a standard argument of the critics ofmodern technology in many areas. It wasbrought before the European Parliament by amember of the Green Party, who advocated a\"fourth hurdle\" in the regulation of innovation.New technologies or products should not onlypass tests of safety, efficacy and quality, butalso the test of socioeconomic need. 108 It was                                                    107   Nor can it be read from the European law. 108   Breyer (1992), as rapporteur of a draft report for the criticises the intention of the Commission of the Euro-pean Communities (CEC Hiltrud Breyer, member of the German Green Party,Committee on Energy, Research and Development.1991) to exclude socioeconomic genetic engineering.and need criteria from the regulation of products of \"This position runs counter to that repeatedly taken  (BST) and to the views of numerous public interestby the European Parliament in its recommendationsorganisations. Such a stance will make it difficult . . .on genetically engineered Bovine Growth Hormone   Part III: Normative Evaluations-Ethics, Law And Politics 83 answer the question, however, how alternatives is very broad. These questions were not dishave to be taken into account in the assessmentof social need. Is need to be denied if suitableselective herbicides or nonchemical methods ofweed control are available? Is it a valid needargument that herbicide-resistant crops aresuperfluous because crop sequences could bechanged or organic farming methods used? socioeconomic need would replace marketThe main objection was that a legal test forcussed a length in our technology assessment.ultimately lead to a planned economy.mechanisms with political decision making and 110 demand is normally taken as the irrefutablewell or better without them) is not a legitimatetransgenic herbicide-resistant crops.are superfluous (because we could live just asdustrial robots or holidays on the MediterraneanWhether video recorders, mountain bikes, in-constitutes a proper need and which does not.actors by deciding which economic demandrisk, but it may not try to \"educate\" marketmarket to protect the moral order and minimiseindicator of real need. The state may control thefor military or infrastructure technology. In linestate has a virtual monopoly on demand, such asin our society in determining whether a newMarkets have become the decisive mechanisms technology or product is needed, and economicweed control, but only through subsidies or taxincentives, not through a ban on the use ofstill implement a preference for nonchemicalwith this reasoning the political majority couldfor a technology is confined to decisions onsubsidising the technology or to cases where thestate concern. Full political control over the need  These questions indicate that more fundamentalproblems are involved in the proposal to intro-duce \"need\" as a legal prerequisite for innova-tion:  Who decides  whether there is a proper need alternatives have to be weighed against onewhich establish a separation of powers in allwhether the society really needs some newmandate for regulatory agencies to determineagencies. A \"fourth hurdle\" which implies adecision making be relegated to regulatorydemocratic societies, seem to exclude thatmine such demand (particularly if availableTherefore, normal standards of the rule of law,and this is the prerogative of the legislator.another) implies wide-ranging political choiceconstitutional law.case, it could not be upheld under Germanis not an operational legal criterion. To deter-for a new technology? Acceptable social demandtechnology would be out of the question. In any 111  determination violates basic individual rightsDetermination of socioeconomic need by parlia-that guarantee economic freedom and freedom oftion. Even then one would have to consider,research. However, the mandate of the legislatorunder the German constitution, whether suchment or referendum would be a different quesMost of the participants in our technologyassessment defended the established institutionalbalance between markets and political decisionmaking. 112 They pointed out that the decline of examples are the Euro-fighter, the Transrapidthe continued use of subsidised coal burning formonorail project, the use of nuclear energy anddomain of politics. Moreover, whether thedecided by the state may be a moot point: somewhere the need for technology had actually beenresults were always convincing in those casesdecisions on innovation and investment are themodel for an efficient economy exists in whichthe socialist countries had demonstrated that nopower generation. 110   The Norwegian Ministry of the Environment was Environment). The Austrian \"social compatibility\" clausetion or spraying if they were removed from warm roomshas not yet been applied, see Martinsen (1997).confronted with these problems when it had to decide onchemical sprays (from the files of the Ministry of theedge to be expected from the project and in the saving ofneered with antisense ACC-synthase to make the flowerssaw a \"benefit to the community\" in the gain of knowl-overnight. The competent authority finally granted thethe flowers could be preserved without genetic modifica-gian Biotechnology Advisory Board denied any benefit;the release of Christmas begonia which had been engi-export opportunities. A dissenting opinion in the Norwe-The Department of Agriculture supported the argument ofmentioned export opportunities for Norwegian gardeners.durable as the \"benefit to the community\"; they alsochemical sprays normally used to make the flowersapproval; it did not consider the export opportunities, butmore durable. The applicants referred to savings in  The critics conceded the problems but insistednevertheless that some revision of the institu-tional balance between market and politics wasnecessary, and that the question of whether wereally need a new technology must be put on thement, as it has in the rest of the society. Opin-political agenda. The controversy over this pointremained unresolved in our technology assess111 Similar arguments apply to the broad mandate given 112   They opted instead for a regulation that genetically the government in section 63 of the Austrian  Gene modified products be labelled so that consumers canchoose (see section III E below). Labelling and consumerchoice are, so to speak, the conformist response to theradical demand for a \"fourth hurdle\". Technology Act  to restrict products if they imply an which must be left to the legislator (Waldh\u00e4usl, 1995).unjustified social burden. These are value decisions  84 Herbicide-Resistant Crops ions will depend among other things on how the Testing for unexpected  gains and losses of modern technology arebalanced. Those who see mainly losses willplead for the political control of needs in orderto limit the dynamics of technology develop-ment; those who see mainly gains will rejectsuch controls and defend the principle of free-dom of innovation. 1  safetymetabolic changes and food  The approval of nonselective herbicides implies routine testing to determine whether metabolitesconsumer. Similar testing of other metabolicof the herbicide formed in transgenic herbicide-resistant crops could pose health risks for thechanges that occur in such crops, apart fromherbicide metabolism, is or should be required inthe law governing the introduction of geneticallyengineered plant varieties or food products.Tests should be designed particularly to controlunintended or unexpected side-effects of thegene transfer and the transgenic gene product. 113  SPECIFIC PROBLEMS, E  RECOMMENDATIONS FORREGULATIONS In the course of our technology assessment  option. The supporters felt that some kind ofthey felt that the regulations implied acceptancethe wider public.recommendations were made on the regulationthat a complete ban on transgenic herbicide-additional regulation was the price to be paid inof various points. Most of these were controver-sial. Critics of transgenic herbicide-resistantcrops had fundamental reservations, becauseof the technology, even with limitations. Advo-top of existing rules making the introduction andcates of the technology were worried that addi-resistant crops was not a realistic politicaltional bureaucratic hurdles might be added onuse of new technology practically impossible.Nevertheless, the disputing parties did establishsome kind of lowest common denominator forvarious points. The critics were probably awareorder to gain acceptance of such crops among 115 toes); this includes control of whether silent oror increased (e.g. alkaloids in tomatoes or pota- Most participants in our technology assessmentwanted to confine the testing to problems whichare known to be characteristic for the speciesinvolved in the gene transfer. For instance, itshould be controlled whether toxicants known toexist in the host plant species would be activatedcryptic metabolic pathways characteristic to theplant species are activated, that have the poten-tial to synthesise toxicants. The tests should alsoensure that toxicants or allergenic determinantscharacteristic of the donor species have notinadvertently been transferred to the hostplant. 116                                                    limited period of time. Such regulations could be Stricter regulations for genetically engineeredplants were justified as precautionary safetymeasures that take the novelty of the technologyinto account and should be implemented for awithdrawn subsequently if no problems arose;whether these regulations should be extended tocover conventionally bred plants as well.otherwise it would be necessary to consider 115   As a rule, food products from transgenic crops are test for the safety of their products, to avoid injunction orand approved prior to marketing, in most cases; how theyprosecution and damage claims under product liabsubjected to stricter controls than products from conven-tionally bred crops. The latter do not have to be reviewedility Novel Food Regulation in Europe (EC 258\/97). The USgene product that differs significantly in structure,law, is left to the producers. A shift to premarket controlsin the case of transgenic food is common policy in allcountries and in 1997 this policy was enacted in theFood and Drug Administration considers a transgenicfunction, or composition from substances found currently in food as a food additive that is not generally recognisedas safe (GRAS) and, therefore, requires premarket review(1992). The FDA considers substances that occur unex-pectedly in the food as a result of pleiotropic effects as\"added substances\" which require formal premarketreview if they occur at a level which may be injurious tohealth. 114                                                    113   The question is by no means settled. While the not uncontested in the general public. The argument thatdecisions on whether \"we really need\" biotechnologicalSchweizer Bundesrat (1995).innovations should not be relegated to scientists, privateinvestors and markets may well win the case throughreferenda-for instance, in Austria and Switzerlandexclusion of need criteria from administrative regulationswhere the requisite initiatives have been taken; seemay become common practice in almost all countries, it is 116   The FDA (1992) includes toxicants, antinutrients and 1995 that the mere presence of a \"foreign\" nucleic acidthis argument the Administrative Court of Berlin ruled incells they are \"generally recognised as safe\". In line withas potentially harmful; since nucleic acids occur in allhand, transgenic nucleic acids are not as such consideredhost or donor organism or related species. On the otherthat must be tested if they are known to be present in theallergens in the list of potentially harmful constituentsdoes not yet constitute a \"harmful effect\" on the legal 114   Some of the additional safety measures discussed here Article 16 of the German would not be merely possible but necessary conditions forthe release of transgenic herbicide-resistant crops.Genetic Engineering Act rules technology\".necessary according to the current state of science andthat \"all safety measures must be adopted which are   Part III: Normative Evaluations-Ethics, Law And Politics 85  Even limited tests such as these go beyond what tests were to show that a transgene-coded prodthat the risks of metabolic side-effects werewidely met with scepticism. This should behas recently been reintroduced in Holland). Thatlevels in potatoes was stopped in Germany sometesting should be stricter for transgenic plantdecades ago (although it applies in the US andble wild relatives. Routine testing for alkaloidconventionally bred crop varieties. Metabolicincreased risk was indicated-for example, if thechanges were only tested in special cases wherewas hitherto required for the registration of newvarieties met with opposition from some partici-crops had been crossed with poisonous, nonedi-pants in the technology assessment. They arguedsufficient justification for special regulation.exactly the same for conventionally bred plantsand had been tolerated without testing. This hadnever led to identifiable problems. However, thepoint in designing additional tests for transgenicvarieties is not so much that these varieties posespecific risks, but rather that they raise specificpublic concern. Whereas new conventionalplants are easily accepted, transgenic plants are testing of the transgenic plant would probably beappropriate in this case.uct could change substrates; further metabolic 119 postulate that metabolic testing should provideeffects, would indeed block any development ofany unintentional or undesirable change inducedMetabolic tests which control for known toxi-cants and allergens are available. However, testswhich screen the complete plant metabolism foring in general.tional crops it would put an end to plant breed-transgenic crops. If it were extended to conven-complete control of possible harmful side-constituents could be identified, which were rial necessary to produce toxicological data. Theadministered the (excessive) dose of plant mate-the test animals would die before they could benot a feasible solution in many cases, becausetransfer. Feeding studies with whole plants arenever associated with the species involved in theThe chances are low that unknown harmfulby the gene transfer are technically not possible. 117 character, it can be assumed that a wide range ofvarieties.laboratories and companies that develop thesetesting is being carried out in any case by thegenic varieties are still largely experimental inprotocols are available. Moreover, since trans-For most of the proposed tests standardised  Uncertainty about possible harmful side-effectsthat are unknown and untestable, are a normalconventionally bred or transgenic plants.problem of food safety. It is not possible tocompletely eliminate such uncertainty, either for 120 Therefore, it is questionable whether the fact 118 Therefore, to formally require addiburden.tional testing is not likely to represent an undue 119   The FDA also gives no clear answer. With respect to formula that the metabolic effects on the host plant\"should be considered at the conceptual stage of devel-occur can be viewed as analogous to intentional changes.opment and monitored, when appropriate and feasible\"(FDA, 1992). Substrate changes that testing has shown tointentional changes in biochemical pathways, it uses the Along these lines, it was recommended in ourtechnology assessment that the substrate speci-ficity of the transgenic gene product be tested if a metabolic function is transferred which is newTests could be carried out unexpected metabolic side-effects will occur.specificity indicates a higher probability thatin the recipient plant. Little or no substratein vitro  on substrates theory. In addition, some that have been selected according to biochemicalin vivo  testing could be carried out on selected model plants. Discus-sions in our technology assessment did notsubstantiate what the consequences would be if                                                                            120    This applies also to the question whether new proteins cannot be addressed at this time\" (FDA, 1992). Theconferring glyphosate resistance to soybeans. \"Theor new plants could themselves be (or contain) allergens.foods derived from new plant varieties for the presence of1995: 212).donor has no history of food use, the issue of allergenicitydigestibility assays are a valid method to exclude un-known allergens (see Astwood et al., 1996) remains to beseen. Monsanto used (among other indicators) an aminoacid similarity analysis to known allergens for its assess-ment of the allergenic potential of the transgene productprotein expressed was shown to be derived from aintroduced protein is closely related, both structurally andno history of food use is introduced. Whether in vitrononallergenic source, to have no significant amino aciddigestion model and to be present in low levels relative tocommon allergenic proteins. Most importantly, theunknown allergens are not currently available. If thefunctionally, to the corresponding soybean protein. Basedon this information, it was concluded, that this introducedprotein posed no significant allergenic concern\" (Fuchshomology to known allergens, to be rapidly degraded in aproblem is the same, if a nontransgenic plant variety with\"The FDA recognises that routine procedures for testing goods protected by the German law,  Zeitschrift f\u00fcr Umweltrecht, 3 (1996: 150). 117   To that degree, the regulation should indeed be process-based, which means that formal review isengineered. This is the regulatory approach underlyingtriggered by the fact that the plant has been geneticallythe European directives. It does not imply that risk isassigned just because the plant has been geneticallyengineered. 118   Extensive testing will be needed, in addition, to comply with the legal obligation to ensure that foodproducts brought to the market are safe and wholesome.  86 Herbicide-Resistant Crops that no tests exist to ensure complete control of advantage outside agricultural areas, it may be cide-resistant crops is sufficient reason to rejectsuch side-effects in the case of transgenic herbi-such crops. that such testing is appropriate for transgenicthe ability to survive outside cultivation as aexperience shows that it is not necessary. But, itresult of side-effects from gene transfer. Testingfor increased fitness in transgenic crops is aprecautionary measure which could, in principle,be dropped after a certain period of time, ifis also conceivable that experience would showplants in certain cases and that it should beas woody perennials). Highly domesticatedplants with a low degree of domestication (suchhaps it could be confined to highly competitiveselective advantage is to be expected, and per-reduced sooner or later in those cases where noextended to conventionally bred plants as well.annual or biennial crops are not likely to regain  Ecological testing and  2 monitoring of geneticallyengineered crops Environmental risk assessment has to consider  plants. The following criteria were used in ourcase by case whether transgenic crop plants, orthe respective transgenes, could possibly escapefrom cultivation and spread to natural habitatsor wild species. Since the risk depends on thephenotype, the criteria for transgenic plantsmust be the same as those for nontransgenictechnology assessment: \u00b7  the degree of domestication of the crop plant, very limited extent. It does not seem to beknowledge at present. Predictions about thecannot be met on the basis of our scientifictransgenic and conventionally bred plants.prudent, however, to set test requirements thatwider ecological effects of new crop plantsremain uncertain-this applies to bothplants. Testing will be performed on modeldoubts about the ecological safety of transgenicthe proposed testing could not, in fact, removeIn our technology assessment, it was argued that plants at selected sites, and the results can onlybe extrapolated to other plants and locations to a \u00b7  the presence of related wild species with which the crop plant can crossbreed,  \u00b7the selective advantage that might be conferred by the transgenic trait, and \u00b7  the frequency of the release. 121  On the basis of these criteria it was concluded gene is not likely to proliferate in wild speciesselective advantage beyond the agriculturallective herbicide. It was nevertheless proposedfields that are treated with the matching nonse-included in the regulation of transgenic cropplants, even if the transgenic trait confers noresistance-coding gene on the plant phenotype.synergistic impacts or side-effects from thecrease in fitness could occur as a result ofnatural habitats and that the herbicide-resistancethat herbicide resistance does not confer any(even if it would be captured occasionally as inthe case of oilseed rape). The main reason wasthat the herbicide-resistant crop plants consid-ered in this technology are not likely to invadeselective advantage, since an unexpected in-that routine testing for increased fitness be be identified and regulated \"after the fact\". Theneering.field experiments under the law of genetic engi-long-term, i.e. beyond the period required formonitoring of transgenic plants would have to bewould be blocked, then it seems good policy toensure that harmful effects of the technology can be accepted because otherwise all innovationcrops. If uncertainties about risks are inherent insystematic postmarket monitoring of transgenicpreventive testing be compensated by a morethat the limits of ecological prediction andIt was proposed in our technology assessmentnew technology, and if these uncertainties must organisms. While such testing seems indispen-Tests usually performed in plant breeding arethe experiments carried out for developing new not designed to identify whether fitness in natu-ral habitats has inadvertently changed. Testrequirements for transgenic plants are morecomprehensive at present. This seems to befitness change will already have been included injustified. In many cases an investigation oftransgenic crop varieties. They should be em-bodied in the step-by-step procedures currentregulations require for the release of transgenicsable if the transgenic traits confer a selective                                                    on a permanent basis through governmentcultural stations in Germany. In the case offor more than 80 years by experimental agri-herbicide-resistant plants, this monitoring shouldschemes, that has been carried out continuouslyThey referred here to the testing of fertilisingdelegated as research projects to universities.institutions or agencies, and that it could not becover not only the escape and uncontrolledproper ecological monitoring must be organisedpants in our technology assessment felt thatwhere these exist or are planned. Most partici-be coordinated with other monitoring activities,Monitoring of transgenic plants would have to  121   These are standard criteria; see, for example, EPA (1994: 60512), \"Environmental Fate Analysis\".   Part III: Normative Evaluations-Ethics, Law And Politics 87 spread of the crop and the transgene, but also crops will remain a matter of controversy for the cide-resistant weeds. It was further recom-that all possible consequences will be discoveredherbicides on agrophytocoenosis and weedgathered with reasonable effort. It was suggesteddiversity should be monitored. However, thereare pragmatic limits to any ecological monitor-ing. No programme can guarantee with certaintyin time. This will not, as a rule, be an argumentto forego as well the knowledge that could bethat the ecological monitoring of transgenicplants should correspond in scope and method tothe respective programmes carried out in thefield of nature conservation.mended that the long-term effects of nonselectivethe early recognition of the selection of herbi- decisions on the level of residual risk that can beanalysis, a scientific question; it implies politicalforeseeable future. Whether approval testing canprovide sufficient safety is not, in the finalall the more important that the procedure forthe public.the reasoning behind decisions be explained toapproval be as transparent as possible and thattolerated by those who disagree. It is thereforeimposed legitimately onto society. Underdemocratic rule such decisions have to be public money and, with respect animal testing,reproduced by independent scientists (for in-repeated.if, in principle, the investigations could bealso violate existing law. However, it wouldthe investigations should actually be repeated-this would, in many cases, amount to a waste ofstance from universities). The point was not thatthat they could, if necessary, be controlled and competent authorities, but also to the public, sodossiers should be made available not only to thethat the relevant toxicological and ecologicallack of transparency. In particular, it was feltin Germany for herbicide approval because of itsCriticism was directed against current practiceincrease transparency and trust in the procedure history of safe use of such organisms. Monitoring is not the answer for all ecologicalissues at state with transgenic herbicide-resistantcrops. Specific programmes of safety researchwill be necessary, for instance, to clarifywas further stressed that field trials with trans-genic organisms should be designed and evalu-was emphasised in the technology assessment. Itcrops. The importance of funding such researchhorizontal gene transfer from the transgenicwhether soil functions would be impaired byensure that these trials can really demonstrate aated more often as ecological experiments, to 122 far enough in this respect. It allows access only  It is unclear whether EC Directive 91\/414 goesinstance, article 13 of the German cants is already provided for in the law (foranimal testing, cost sharing with second appli-extending patent protection. With respect tocants contribute to the cost of approval, or bymation, for example, by having second appli-without denying public access to relevant infor-interests of the first applicant could be protectedcants to repeat all investigations. The legitimatecan ask if it makes sense to force second appli-required investigations. On the other hand, oneof information concerning the complete dossiersapplicant, since competitors (second applicants)specified in the annex to the directive). Freedomauthority of the dossier provided by the appli-cants (test protocols that have to be applied areis at odds with the commercial interests of theto the summaries produced by the competentcould then \"save\" the costs of repeating thePlant ProtecIncreasing the transparency of tion Act ). 3  herbicide approvals  The approval of transgenic herbicide-resistant                                                    122   The question of postmarket monitoring should not be issues (see Wrubel et al., 1992; Mellon and Rissler,confused with the question of whether the monitoring that(according to existing regulations) should be inherent inthe step-by-step approach when releasing transgenic pro-ducts is properly done. There is evidence that the fieldtesting of transgenic plants has been inadequatelydesigned and evaluated from the perspective of safety1995; R\u00fcdelsheim, 1995). Limited trials in small fieldsunder conditions of reproductive containment cannot be United Kingdom explicitly requires the applicant \"to1997) proceeding to commercial releases willkeep himself informed of any damage to the environmentby postmarket monitoring. The competent authority in theWhether this assessment is correct should be controlledassessment that one feels \"safe enough\" to go ahead.knowledge. Such steps must be based on the politicalnevertheless, in any case, remain a step beyond existingthough 500 true releases have now informed scientistslevel of risk\" (Deliberate Release Regulation).(1994: 11). But even if field trials are better designed andthat there are no legitimate scientific concerns\"any information which would indicate a change in thenondata on nonreleases has been cited in policy circles asare harmless. Regal is more critical: \"Yet this sort ofconclusive evidence that large-scale commercial releaseslinked to safety research (see also Neemann and Braun,caused by the release or marketing [and] notify if there is  In order to increase transparency, it was also demanded in our technology assessment thatreasons for refusing or withdrawing the approvalfor herbicides be disclosed. The public has alegitimate interest in and a right to be informedabout the harmful effects or abuse of herbicides,which may constitute grounds for rejecting themor withdrawing the approval for their use.  plied. Against this background, it was obviously not easy to argue for a relaxation of the zerocontamination standard for groundwater. 88 Herbicide-Resistant Crops Precautionary standards for   4 contamination as goal?herbicide certification: Zero  There is probably general agreement that herbi- a very special foodstu The tolerance limits set for herbicide residues indrinking water by EC Directive 80\/778 of 0.1micrograms\/litre for individual substances and0.5 micrograms\/litre in total are coming underpressure because, on the basis of normal toxi-may not be an objection. The extremely lowpublic health. This is probably correct, but itnitude below the limits necessary to protecttolerances (at the sensitivity limits of existingdetection methods) have been set to ensure thatwater is measurably free of pesticides. Suchregulation can be justified for reasons other thanthe protection of human health, namely, as ameasure of food hygiene (since drinking water iscological criteria, they are some orders of mag-ff), and as an incentive for tives. On the one hand, it was argued that con-nature. Only in the cases of drinking water andtoxicological terms. The discussions relativisedered as \"overregulation\" and unjustified inhand, tolerance levels close to zero were consid-cide residues in food products. On the otherfrail or sick) might still suffer harm from herbi-nerable groups (small children, the physicallysumer protection was inadequate because vul-both views.herbicide certification were criticised in thetechnology assessment from opposing perspec-groundwater are tolerance limits set to a level ofharmful for the consumer or the household ofwhere it can be guaranteed that they will not beregulations permit certain levels of residuesronment are undesirable. However, existingcide residues in food or elsewhere in the envi-zero contamination. Existing regulations for better protection of groundwater, the mostdards enacted in existing regulation be weak-ened; the need was rather to ensure their properimplementation.assessment; at least, there was no open dissent.contamination was accepted in the technologyNo one advocated that the precautionary stan-important source of drinking water in Germany.The objective to achieve zero groundwater larly high standards of \"naturalness\", likecide residues only amount to a fraction of whatby consumer\"s expectations that food productsnecessarily warrant additional regulation. Con-tions, while undoubtedly legitimate, do not(absence of foreign substances). Such expecta-should satisfy certain standards of naturalnessorganic farming products.markets of food products which meet particu-Zero contamination could perhaps be justifiedfor zero contamination is hardly justifiable ondetection levels. Under these conditions, the callwould be permissible; often they are belowThese limits are rarely exceeded; usually herbi-a hundredth of the so-called no-effect level).those levels which produce toxic effects (usuallycide residues in food products are well belowof toxicology. The tolerance limits set for herbi-gens) were they tested according to the standardsclassified as toxicants (or mutagens or carcino-natural substances which would have to bebut also on dosage. Most food plants containsent a health risk depends not only on toxicity,Whether herbicide residues in foodstuffs repre- the grounds of preventing human health risks.sumers might instead be advised to turn to  Compliance with the  5 conditions of herbicideprotection, site-specificregulationsapproval, integrated crop  Opinions remained divided among the participants in our technology assessment whetherstricter requirements should be set for the ap-proval of herbicides in general, or nonselectiveacceptable at all.herbicides in particular. This was no doubt dueto the deep split of opinion over the questionwhether the agricultural use of pesticides is contamination, selection of resistant weeds)\u00b4, thehad caused obvious problems (e.g. groundwatersome agreement that where the use of herbicidesApart from this controversy there was, however, disposal of herbicides would probably be totion. Therefore, instead of adding further condi-tions for herbicide certification, the proper wayto avoid problems resulting from lack of herbi-cide rotation, excessive applications or improperrather inadequate implementation of the regula-improve monitoring of compliance with theregulations and to raise the standards for howfarmers handle herbicides.main reason was not inadequate regulation, but herbicides to the fields on which they are ap-policy therefore to try to confine the impacts oftural technology, and it would be reasonablehighly problematic. Herbicides are an agricul-discharge of herbicides into groundwater ispants in our technology assessment that anywas, first of all, consensus among the partici-With respect to water protection standards, there   While the argument that nonselective herbicides   Part III: Normative Evaluations-Ethics, Law And Politics 89 are particularly likely to be abused because they that are not ecologically sustainable. Whether do no damage to crops was rejected in thetechnology assessment, it was generally admittedthat the application of herbicides often fails tomeet the standards of \"good field practice\" andthe rules of integrated crop protection. rules.very difficult to formulate plausible generaldifferentiation of farming practices, it would beadmitted that, in view of the inevitable regionalquestion in our discussions. It was generallylegal regulation of integrated crop protectionwas a viable alternative remained an open 123 Thereextent, one would have to rely on methods ofcomprehensively and effectively. To a largeance with the rule.counselling and education to improve compli-fore, the demand that compliance with existingrules be better monitored seemed plausible. Onthe other hand, it raises considerable problems ata pragmatic level. One can hardly imagine thatthe actual practice of farmers can be \"policed\" 125 Therefore, one would have to rely local conditions.implications of integrated crop protection forlargely on proper counselling to specify the regulated more often by negotiating the appro-more cooperative, persuasive policy instruments.something to be done in the area concerned.sufficiently strict tolerance limits to forceof the law\", that is, if general regulations imposesuccessful, if they are negotiated \"in the shadowtive, site-specific arrangements will only belevel of precaution. On the other hand, coopera-activities may not be the best way to improve theand more bureaucratic control of all farmingpriate, site-specific precautionary measures withregulatory approaches and puts emphasis onsuggestion marks a break from conventionalthey were confined to restricted areas. Thismonitor adherence to additional regulations ifthe farmer. It would also be much easier tobe expected because of soil conditions-befor example, where groundwater pollution is toherbicide use in particularly vulnerable areas-Along these lines it was also suggested that Ever stricter conditions for herbicide approval guidance as to how herbicides should actually beambivalent. The Germanthe legal status of these standards remainsapplied practically on the farm. Consequently, further specified, do not entail particularly cleartection are fairly vague and, unless they areof good field practice and integrated crop pro-Moreover, it was pointed out that the standards Plant Protection Act imposes them as a goal, but implies no sanctions if they are violated. 124 However, the idea that the comed by all the participants. The regulation oftion for engaging in systems of crop husbandryenforced as legal regulation was also not wel-crop rotation sequences met with particularopposition, since this might force farmers toadopt cultivation systems that are not economi-cal for them. Instead of encouraging the furtherbureaucratisation of agriculture, it would bebetter, on this view, to rely on proper counsel-ling and education of farmers, and on the effectsnomic interest of farmers is clearly no justifica-of good examples to demonstrate that integratedpants as completely unsatisfactory. The eco-market controls was rejected by other partici-ple of relying on economic constraints andrules of good field practise be specified andas a herbicide tax, would be needed. The princi-further regulation or additional incentives, suchtives to reduce herbicide use and, therefore, nothe European Union provided sufficient incen-terms. Falling prices for agricultural products incrop protection does in fact pay off in economic                                                     Specific regulation for  6 nonselective herbicidesrotation All participants in the technology assessment,  continuous use of nonselective herbicides would:once in a crop rotation sequence and not withit is advisable to use nonselective herbicides onlyresistant crops, operated on the assumption thateven the advocates of transgenic herbicide-monocultures. The reasons given were that \u00b7 select problem weeds, because all herbicides have gaps in their weed control spectra, \u00b7 increase the risk that herbicide-resistant weed populations spread,\u00b7  make the herbicide inapplicable for the control 123   A number of participants have objected to the impres- of volunteer crops from the previous vegetationperiod, field practice were widely neglected in the use of herbi-different for nonselective than for selective herbicides.point here is, however, that the situation is at any rate notto show how representative such examples might be. Theexamples of such neglect and that no data were availablecides. It is indeed true that the discussions focused onsion created in the discussions that the standards of good \u00b7 have more serious environmental impacts,                                                    125   The  amended  German  Nature Conservation Act (1997) exempts agriculture from the liabilities of nature 124  agriculture\" are observed (article 2a). Accordingly, thereconservation if the \"rules of environmentally friendlyis a need now to develop these rules into an explicit andstandardized code (Bundestagsdrucksache 13\/19930).  Article 6 \"Pesticides may only be used in accordance with good field practice. Good field practice implies thatthe principles of integrated crop protection are observed.\"  90 Herbicide-Resistant Crops because a small number of herbicides would be protection and therefore a matter of public applied over larger areas,\u00b7  per hectare in postemergence treatment.concern. A regulation which specifies where andhow often nonselective herbicides may be ap-plied in the crop rotation sequence should befeasible in principle. There are examples ofdetailed regulations of this kind. For instance, inGermany atrazine (before being banned) couldonly be used in conjunction with one crop,namely, maize, only once in the vegetationperiod, with a maximum dose of one kilogram lead to excessive elimination of weeds from agricultural habitats and to irreversible reduc-tions in weed seed banks-a practice incompati-ble with the objectives of integrated crop protec-tion, \u00b7  violate the rules of good field practice (especially in the case of monocultures). Not all participants found all these arguments compelling reason for herbicide rotation.vented was probably considered as the mostThat resistant weed populations had to be pre-the same nonselective herbicide without rotation.was sufficient reason to reject the use of one andequally compelling, but it was agreed that there use of atrazine.regional differences, but that local conditionsfurther issue is how compliance with the regu-case of maize monoculture and the nonrotationalWhether such regulation could be established ona Europe-wide basis is an open question. Aresistant cultivars and matching nonselectiveherbicides become readily available for all thecrops farmers grow. Finally, it was argued that have a crucial influence on whether and howproblems. Proper site-specific choice of croprapidly nonselective herbicides can lead togeneral regulations make no allowances forrotation sequence and herbicide management canperhaps be better ensured by counselling than byadditional regulation. On the other hand,counselling may not be enough to excludepractices which, although disadvantageous in thelong run, appear economically attractive for thefarmer in the shorter run, as illustrated in thelation could be monitored once herbicide126 the development of herbicide-resistant cultivarsgenetic erosion of weed species is taken seri-sequence, the use of herbicides is declining andcereal crops, an element in every crop rotationfor agriculture in Central Europe, since forThe question was considered to be \"academic\"throughout the whole crop rotation sequence.argue that, even with rotation, nonselectiveherbicides should not be applied exclusivelyously and the principles of integrated cropwith nonselective herbicides. If the threat ofprotection strictly observed, one could probablythat weed elimination would still be more radicalcombinations of tank mixtures), others insistedwith different selective herbicides (often used inwhich all crops in a rotation sequence are treatedwould be equivalent to the current situation inpants pointed out that, in agronomic terms, thisof action was advisable. While some partici-of nonselective herbicides with different modesDifferent views were held as to whether rotationis apparently not being pursued. Labelling of genetically   7 engineered food After lengthy discussions in the technology  127 industry, agreed that genetically engineered foodassessment all participants, including those fromought to be labelled as such. The rationale forof human health.labelling is consumer sovereignty, not protection with the legal objectives of integrated cropapplications are, by definition, incompatible Should the restrictions to be observed for propermanagement of nonselective herbicides belegally regulated? This would not be necessary ifbad management were purely a private matterand if farmers alone would have to bear thecosts of the mistakes they made. But, this is notthe case. Unnecessary or pointless herbicide                                                    128 Health issues should be dealt with by testing for food safety before productsfrom transgenic crop plants are placed on thetives, interests and preferences. Freedom ofmately on individual (even idiosyncratic) mo-to buy such products or not can be based legiti-accepted criteria and sound reasoning, decisionscan be placed on the market must be based onsions about whether transgenic food productsother aspects into play. While regulatory deci-market. Consumer sovereignty brings completelychoice means that consumers can follow subjec-tive fears, fundamental ethical reservations or                                                    126   It must be noted, however, that rotation while, a means application (see Gliddon, IHE, 1994: 14).necessarily imply a fitness penalty in absence of herbicideof resistance in weeds again, since resistance will notresistant weed populations, may not be a means to get ridto contain the problems that might result from herbicide127 The situation may of course be different in other countries; weed grasses may have to be controlled in(1996: 240).selective herbicides is quickly developing. See Gresselwheat by herbicides, and cross-resistance to wheat- 128   See also Rehbinder 1994: 99; health protection would be implied in the labelling, if transgenic food crops wereever approved that have been transformed with genesfrom a donor plant which is a known allergen.  Why should they not be allowed to express their rejection of genetic engineering in their choice offoods! Thus, there is no reason to dispense withlabelling requirement  because  it makes political boycotts possible.  Part III: Normative Evaluations-Ethics, Law And Politics 91 political goals without asking whether their fears belled.are well-founded, whether their ethical judge-ments are based on common sense or whethertheir political goals are supported by the major-ity. In order to guarantee freedom or choice,transgenic food products must be clearly laOn the other hand, it is doubtful whether label-ling is required   in order to  make political boywhere do the limits lie?whether the product comes from an automatedpreference as on economic incentive when theyHowever, the sovereignty of the consumer is aneconomic right, not a political one. It is a factthat individuals may rely as much on politicalpurpose of product labelling to provide whatever\"calculate\" the usefulness of a product. Theymay, therefore, be really interested to learnsome participants in our technology assessment.what the company\"s policy is with respect towhen they consider what to buy or not. Butlabour organisation or nondiscrimination ofwomen, whether the firm is involved in the armsbusiness or invests in low-wage countries, etc.Up to now, however, such information has notbeen required for product labelling. If consumersfactory or from labour-intensive production,want this kind of information they must seek itcotts possible. This view was propagated byinformation \"politicised\" consumers may wantfrom other sources. Obviously, it cannot be the  This principle was only reluctantly accepted inour technology assessment. It was argued thatlabelling would \u00b7  deceive customers by creating a false impression that the labelled products were dangerous, \u00b7  discriminate against genetic engineering, since other products of modern food technologieswould not be labelled accordingly, \u00b7  be abused, or instance, to organise boycotts of transgenic food products for purely politicalreasons, \u00b7  be impractical if food products were procproducts.essed further or mixed with other nontransgenic The first three objections were found untenable;mation are surely factors of legitimate concern,they wouldn\"t have put a label on it!\"). Thisrhetoric as a signal of danger (\". . . otherwisepublic or deliberately misinterpreted in politicalwithholding information.Consumers have a right to be informed irrespec-level of information, but never a reason forbut they can only be a reason for improving therable in most respects. Prejudice and misinfor-tive of whether they have a true understanding oftransgenic and nontransgenic foods are compa-labelled might be misunderstood by a scepticalgenetic engineering or whether they realise thatfood products from transgenic plants must bewith respect to the fourth objection a pragmaticcompromise was proposed. The very fact that does not remove the rationale for labelling. neered organisms should be labelled, but alsoing is used to remove or suppress a gene thatof genetic engineering\". Drugs must be similarlylabelled, and there seems to be no grounds whythis should not apply to foodstuffs as well. Theneed to be informed could, of course, disappearOne example is the use of rennin (chymosin)is made with chymosin from genetically engi-from genetically engineered bacteria for cheeseguishable from the one that has been extractedonce it becomes generally known that all cheesemaking. Although such rennin may be indistin-neered bacteria.products). This would, for instance, apply toshould be labelled even if they only containpotatoes from herbicide-resistant potato culti-vars. The same would apply if genetic engineer-consisting of or containing genetically engi-normally occurs in the food. In this case theproduct is also \"modified by genetic engineer-ing\", even though the modification may beindistinguishable from a natural deletion muta-food containing transgenes (and transgenic genetion. There was also consensus that productssubstances (enzymes) from recombinant genes.The participants agreed that not only food from calves, it nevertheless remains a \"product also applied in the case of labelling food addi-justify extra regulation. The same reasoning wasdebate and source of anxiety should suffice toengineering has become an issue of publicdiscriminatory and unfair. The fact that geneticproducts be labelled can hardly be consideredA specific requirement that transgenic food tives. freedom of choice to express opposition tomental behaviour of multinational companies.World cooperatives, or to criticise the environ-apartheid in South Africa, to support Thirdtional. In the past, consumers have used theirillegal, unless the declared goals are unconstitu-boycotts are not in any way illegitimate orpolitically motivated consumer boycotts. Suchthey can indeed more easily become the target ofIf transgenic food products have to be labelled,   There was no agreement about whether productsshould be labelled that contain neither trans-  forced to buy on alternative markets. 92 Herbicide-Resistant Crops genes nor their products, but that have been derived from transgenic crops. Sugar fromties in a narrow sense (the declaration of thecide-resistant soybeans are examples. In thesecases genetic modification leaves no trace in thefinal product; sugar and oil from transgeniccrops are identical to sugar and oil from non-transgenic crops. Current labelling proceduresprovide only information about product proper-but not information on the mode of production ifherbicide-resistant sugar beet or oil from herbi-country of origin is an exception in this respect),this does not affect the final product. Someparticipants argued, however, that in the case ofgenetic engineering the mode of productionshould also be labelled since the consumers maywant to opt against the use of this technology ingeneral.  It may be true that widespread labelling requirements would be difficult to enforce ininternational trade. This does not mean, how-ever, that we can dispense with an examinationof whether such labelling is not in fact advisablein view of the manifest lack of public confidencein genetically engineered food in most countries. OUTLOOK: THE POLITICS OF   F TECHNOLOGICALDEVELOPMENT  The discussions in our technology assessment not be dealt with on the level of risk regulation,ences can be summarised as follows.them in never-ending controversy. The differ-regulation tends to polarise people and involvebut they may help us to understand why riskshowed that the participants had widely differingtechnology can play. These differences cannotshould develop and the role which modernviews about the direction in which society  exercise their sovereignty by choosing productsIt was pointed out that consumers could alsowhich are explicitly declared to be  not derived from transgenic crops.  While it was not sugfor those cases in which the use of geneticrequirements altogether, it might be consideredengineering in production has no effect on theproduct. Consumers who nevertheless wish toavoid such products would then have to turn toorganic farming products or other alternatives.No consensus was reached on this point in thetechnology assessment. It seems, however, thatboth solutions are compatible with the recog-nised principle of consumer sovereignty; there isscope for political compromise here, which canbe determined legitimately by majority decision.gested that this option could replace labelling  Diverging views of the social 1  role of technology In our technology assessment, one side saw  technology in modern society as an essentialresource for solving problems. New technologiesoffer new opportunities, and the increase inopportunities must itself be considered a clearFrom this point of view, the fact that transgenicherbicide-resistant crops play a pathfinder role,contributes to their usefulness. While they maynot offer spectacular benefits by themselves,they help to break the ground for genetic engi-neering in agriculture and clear the way for othermore important applications.gain (provided the risks are under due control). entail insurmountable practical problems,pointing to the German system of waste recy-mixtures of products from transgenic and non-crops also have to be labelled? What aboutradical proposals, even sugar) from transgenicto the entire processing chain of transgenicproducts. Would any food products containinginvolve pragmatic problems if they are extendedneering pleaded for maximum declaration of allflour or potatoes (or, according to the moreConsumers who oppose such food would beengineering is somehow involved in food pro-secondary products. They denied that this wouldnormal expectation of the consumer that geneticproducts labelled, the sooner it will become ais carried to the extreme. The larger the range ofThe idea of labelling will indeed be refuted if itlabelling and compromises should be accepted.products. Others felt that the pragmatic limits ofcling labelled (the green dot) a vast number ofIt was admitted that labelling requirementsduction; then one could do without labelling. transgenic crops? The critics of genetic engities will only continue the trends that have got usproblems worse.they herald developments which will make ourrelatively harmless when viewed in isolation,down a slippery slope. While they may beherbicide-resistant crops were the initial stepinto the present mess. On this view transgenicways attributable to the technological dynamicshalt these dynamics. New high-tech opportuni-unleashed in our society, and that it was time toenvironmental and social problems were in manythe problem. They emphasised that currenttechnology as part of the solution but as part ofThe other side, in contrast, did not see modern   It is difficult to see how these divergent perspec-tives could be mediated. In our technologyassessment it was at least possible to get rid ofsome of the clich\u00e9s which abound in the public   Part III: Normative Evaluations-Ethics, Law And Politics 93 the very fabric of industrialised societies was debate over these issues. Consensus was reached not accepted was the negative view of thislifestyle and the assumption that industrialsocieties are inherently unable to achieve re-forms which would make the use of high tech-nology ecologically and socially acceptable.generally accepted by all participants. What was among the participants about the followingpoints: What is wrong with a lifestyle based on \"high \u00b7  Modern societies face ecological and social genes from one organism to another.in order to obtain high yields and optimal controlthan a method which simply transfers singletech\"? The pursuit of the domination of nature,for which genetic engineering represents aparadigm, cannot be the problem. As wasof environmental impacts, comes much closer tomeans unique to recent developments in technol-ogy. It is already a feature of traditional agri-cultural techniques and is just as much inherentin the alternative approaches of organic farmingas in the most advanced strategies of geneticengineering. This argument was not discussed atlength in the technology assessment, but it seemsthat integrated ecological management coordi-nating the biological feedback mechanisms thatoperate in natural systems, using breedingthe Baconian ideal of the domination of naturemethods and mechanical agronomic techniquespointed in the discussions, this pursuit is by no of modern technology did not claim that thestructural reform. Even unambivalent supportersproblems which cannot be overcome without\"business as usual\".world is in order or could be put in order by It is to be expected that alternatives to current lifestyle. For example, an economy based onlifestyles will also be variations of a high-techthe neutrality of technology. Does this mean thatsolar energy would hardly be possible withoutwould then also be acceptable for its critics?goals for its application, genetic engineeringunder different social conditions and with otherbe based on the degree of control we exert overthis control is put-which implicitly recognisesobjections to a modern high-tech lifestyle cannotnology and further innovations. Therefore themobilising the entire repertoire of modern tech-natural processes, but only on the ends to which The general assumption that new technologies under any alternative social conditions. On theand widen the gap between the world\"s havesload the environment, deplete natural resourcesinnovation in industrial societies tend to over-claiming that the dynamics of technologicalother hand, critics may still have a point ining the world population. These are undisputedsocieties which one would not want to foregotechnological achievements of the industrialtechniques that have played a major role in feed-medical technology and plant breedingbe defended, as evidenced by advances inwill always have negative effects as long as theyare embedded in industrial societies can hardlyand have-nots. It was not the purpose of our \u00b7  General goals such as sustainable developpresent.ment, fair distribution between North and South,and responsibility for future generations werenot in dispute. The dispute referred to the strate-gies needed to reach these goals and the specificpolicies that could and should be adopted at \u00b7  No advocate of transgenic herbicide-resistant respect to world food scrop proceeded from the assumption that tech-nological development would automatically leadto social progress, or that a technological fixcould be found for every social problem. Withupply, for example, there not simply lie in new technology to increaseproduction.was general agreement in the discussion thatdistribution, and that therefore the solution couldfamine was at present primarily a problem of \u00b7  On the other hand, opponents of transgenic herbicide-resistant crops did not blindly opposeall new technology. They accepted that newtechnologies might be needed to cope withexisting problems. Thus it was clear that faminewould again become a problem of production asthe world population continued to grow, and thatnew technology would be needed to increaseproductivity-either in conventional or organicfarming. A key objection by the critics was that new conditions under which the technologies wouldour problems. In contrast, critics routinely denybut must be viewed in the context of the socialstructures and ways of life in which they areembedded. It is indeed true that supporters tendto conceive of new technologies as a relativelyneutral instruments which could be used forbetter or worse; they could be abused but, undersuitable conditions, they could also help to solvetechnologies can never be judged in isolation,that new technologies can ever be neutral in anyway. New technologies are bound to have nega-tive ecological and social effects under theexisting social and economic regime because thereally be useful simply cannot be established. 2 \"High tech\" as a lifestyle The point that \"high tech\" is not so much aninstrument but more a lifestyle which is part of  strategy. Since no single technology can be expected to represent the \"best\" solution to aproblem for all times, it is advisable to ensurepluralism and avoid the emergence of techno-logical monostructures in society. This wouldimply that alternatives to or variations of thedominant technology must at least be preserved,so that they can be resumed and further devel-oped if the need arises in the future. In the case of weed control, technological plumechanical methods, even if herbicides representEurope a considerable increase of the area oftional farming, producing comparable yields atdeveloped into a realistic alternative to conven-determine whether organic farming could becould be improved and evidence collected tointo a viable alternative, on the assumption thatwere reallocated. This would create aorganic farming could be achieved if subsidiesof large-scale food production. In Centraldation was that organic farming as a wholechemically based agriculture as the only systemit is undesirable to be entirely dependent on\"laboratory\" in which organic farming methodsshould receive extensive support to develop itcriteria. Going one step further, one recommen-a superior technology according to receivedbe maintained for the use and innovation ofralism means that sufficiently large niches mustreasonable costs. Such ideas were a concession to the advocates of portunity to establish whether a consensusogy, not as a way of life. The discussion of thesetechnology assessment, and there was no op-points was not brought to a conclusion in theadmission that it is also legitimate to adopt newfarming is thus regarded as an option in technol-(provided risks are properly controlled). Organictechnologies, including genetic engineeringorganic farming, but required in return thewould have been reached. 94 Herbicide-Resistant Crops technology assessment to discuss basic issues assessment as they are in the public debatessuch as what kind of production and economicpursued over these issues.regime we would need to protect the world\"sresources and ensure that available goods weredivided more equitably, whether economicgrowth could be maintained much longer, orhow industrial societies can function withoutgrowth. It is certain that opinions were asdivided among the participants of the technology In the end basic political divisions among the genetic engineering, on the other hand, wereby suppressing the society is facing could in any way be alleviatedconvinced that none of the obvious problems thisogy assessment. The critics of genetic engineer-agroindustrial techniques. The supporters ofsented a viable alternative to conventionalThey also claimed that organic farming repre-ble to halt the further growth of the technology.ing felt that society would gain if it were possi-participants remained unaltered in our technol-dynamics of technological innovation. Nor did they accept, as a rule, thatorganic farming was a better alternative for theenvironment in all respects or that it couldprovide the yields needed to ensure food sup-plies. Many participants were of the opinion thatfuture, that would ensure food san ecologically sustainable agriculture of theupply for a growing world population, would have to be animproved version of the present system of high-tech agriculture, and that new technology,including genetic engineering, would be neces-sary to achieve this goal. The compromise of 3 technological pluralism There seems to be no middle ground for mediating a dispute in which one side argues for moremodern technology because it provides optionsmethod to reach a decision in this case.referendum would suggest itself as a legitimatebetween which we must choose. Voting orincompatible political visions and strategiesargues for less modern technology because itto solve pressing problems, while the other sidewould only make the problems worse. We have To a certain extent, it should be possible to have it was argued in the technology assessment thattechnology policy should be based on a doubleimprove organic farming methods. Occasionallyat the same time, provide additional support tostance, opt to introduce genetic engineering and,in modern agriculture. Society could, for in-conflicting view of the proper role of technologyit both ways by combining some aspects of each The political function of 4 participatory technologyassessment What was the political significance of our participatory procedure on transgenic herbicide-resistant crop plants? Can such procedures serveas a model for future technology assessment?Can it resolve conflicts over the acceptance ofnew technology? These questions were notdiscussed during the procedure itself; they arestill under investigation at the Wissen-schaftszentrum Berlin (WZB). A few remarksare given here. 1. A procedure of participatory technology assessment may be suitable to restore the credi-   Part III: Normative Evaluations-Ethics, Law And Politics 95 bility of the experts. As an instrument of expert tion which operate under \"ideal\" conditions of such reports is the concurrent public demonstra-have been possible to document this knowledgeand fair participatory procedure.commissioning reports from the respectiveoffer. In our case the procedure just repeatedadvice for policy making, it has probably less toand confirmed the knowledge that was availablein the international discourse. It would probablywithout a participatory procedure simply byexperts. What would not have been achieved byfor policy making. It can be stabilised whention of the credibility of experts. Credibility is animportant and scarce resource in expert adviceexperts are exposed to the critical questions andobjections of \"counter-experts\" in a symmetrical and transformed fully to the level of argumenta-symmetry, fairness and mutual respect. It is notto be expected that political conflicts that arefought in the public domain could be translatedobserve the process of argumentation and nottion in such a procedure. Nor can one expectargumentation. Acceptability conflicts arewith the participants who actually pursue thatprocess.patory technology assessment; they will at besttherefore not likely to be resolved in a partici-be redefined. Many of the rationalising effects ofrelinquish their strategic interests in a process ofthat the parties involved would really offer tothe procedure will only occur with those who 129 130 political mobilisation of the a rule \"framed\" as battles of arguments, the2. Argumentation is a medium for rationalisingconflicts. While conflicts in public arenas are asconflicting parties are mostly involved in thepublic rather than in open question. It is a plausible assumption,will make it ever more difficult to arrive atlegitimacy of decision making and increase thehowever, that the refusal to grant participationmandate. Whether participation will enhance thewillingness to accept majority votes remains anmandate, but they also do not have a democraticing. The participants do not need a democraticcratic transformation of political decision mak-from the political decision. It is advice notinclusion of a plurality of views in a process ofdecision making. Participation ensures thetechnology assessment operates at a distancedespite the conflicting views. Participation in atherefore, how legitimate decisions can be takenresolved by consensus. The real question is,disputes about new technologies will seldom be5. Participation is not democratisation. Politicalpolitical communication, but it is not a demo-legitimate decisions. the examination of arguments. A participatorytechnology assessment provides a social modelof how the frame of argumentation can be takenseriously and how conflicting parties can beeffectively committed to engage in true dis-course. The procedure ensures that all relevantsubstantiated and justified, and that objectionsbe heard and answered. If there is any room to\"rationalise\" political conflicts and explore thechances for consensus, it should become appar-ent under these conditions.points will be brought together, that claims be 3. Participation is a political goal in itself. Experiments are being conducted in manyforms of participation like the right to be in-never be sure that they will \"win\" their case.which they cannot control and where they canconflicting parties in a process of argumentationhas a price, however, because it involves theserve\/testify in hearings. Inclusion in a discourseformed or to give comments, or to ob-normative and functional terms) to \"one-sided\"experiments the question is not only whethersociety. Discursive models like the participatorypolitical culture one wants to promote in thebut also whether they represent the kind ofthey are necessary in order to resolve conflicts,cooperative forms of politics. To assess thesemodern societies with new participatory andtechnology assessment are superior (both in 4. Conflicts over the acceptability of a new assessments are social constellations of interac-ticipatory procedures. Discursive technologytechnology are not likely to be resolved in par131 ogy really is and what direction social develop-must somehow \"return\" such demands to theforum of constitutional debate. Conflicts overthe acceptability of new technology often implypolitical demands which simply cannot beprocessed by the established procedures ofdecision making, such as the demand for politi-logical and social change. The political systemcal planning and democratic control of techno-society. For that matter social forums of com-munication are needed which can deal convinc-ingly with the interests, needs, hopes and fearsreflected in such demands, even if they cannottranslate them into effective regulation. Discur-sive technology assessment may be one exampleof such a forum, if it is extended into an organ-ised discussion about how useful a new technol-6. Technology assessment may function as                                                    130 See Holzinger (1996). 129 See van den Daele (1996). 131 See van den Daele and Neidhardt (1996).  96 Herbicide-Resistant Crops ment should take. 7. Participatory procedures cannot replace standard procedures of technology assessment.The participatory procedure initiated by theWZB was too costly in terms of time and moneyfor all those involved to become incorporated inthe routines of giving expert advice to politicaldecision makers. The procedure would eitherhave to be simplified drastically or confined toselected conflicts which are particularly signifi-cant.    REFERENCES Ahmad, I., J. Bisset and D. Malloch (1995): \"Effect of phosphinotricin on nitrogen metabolism of  Trichoderma species and its implication for their control of phytopathogenic fungi\",  Pestic. Biochem. Physiolog., 53,  49-59. Ammann, Klaus, Yolande Jacot and Pia Rufener Al Mazyad (1996): \"Field release of transgenic crops in Switzerland-an ecological risk assessment of vertical gene flow\", in Schulte, Elisabeth and Oth-mar K\u00e4ppeli (eds),  Gentechnisch ver\u00e4nderte krankheits- und sch\u00e4dlingsresistente Nutzpflanzen. 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B\u00f6ger : \"M\u00f6gliche pflanzenphysiologische Ver\u00e4nderungen in herbizidresistenten und transgenen Pflanzen und durch den Kontakt mitKomplement\u00e4rherbiziden\" Kommentar: WZB discussion paper FS II 94-302R.A. Weidhase Heft 3: Risiken eines horizontalen Gentransfers aus transgenen PflanzenGutachten:  A. P\u00fchler, I. Broer : \"Stabilit\u00e4t von HR-Genen in transgenen Pflanzen und ihr spontaner horizontaler Gentransfer auf andere Organis-men\" Kommentar: WZB discussion paper FS II 94-303B. Tappeser Heft 4: Risiken der Verwilderung von transgenen PflanzenGutachten:  H. Sukopp, U. Sukopp : \"\u00d6kologische Langzeit-Effekte der Verwilderung von Kulturpflanzen\"Kommentar:  H. Scholz WZB discussion paper FS II 94-304 Heft 5: \"Evolution\u00e4re Risiken\" und die besondere Qualit\u00e4t gentechnischer Eingriffe:Kontextst\u00f6rungen, PositionseffekteGutachten:  B. Weber : \"Evolutionsbiologische Argumente in der Risikodiskussion am Beispiel der transgenen herbizidresistenten Pflanzen\"Kommentargutachten:  A. Heyer ,  H. Saedler, L. Willmitzer WZB discussion paper FS II 94-305 Heft 6: Toxikologische Risiken der R\u00fcckst\u00e4nde von Komplement\u00e4rherbiziden.Entwicklung der Aufwandmengen beim HerbizideinsatzGutachten:  H. Sandermann,K.-F. Ohnesorge : \"Nutzpflanzen mit k\u00fcnstlicher Herbizidresistenz: Verbessert sich die R\u00fcckstandssituation? Biochemischeund toxikologische Aspekte\" Kommentar: WZB discussion paper FS II 94-306V. Haas, L. Peters Heft 7: Auswirkungen auf den BodenGutachten:  B.-M. Wilke : \"Verhalten der Komplement\u00e4rherbizide im Boden\" Kommentar: WZB discussion paper FS II 94-307Ch. Siewert Heft 8: Probleme der BodenerosionGutachten:  K. Auerswald : \"Auswirkungen des Anbaus von Kulturpflanzen mit gentechnisch erzeugter Herbizidresistenz auf das Ausma\u00df der Bodener-osion und der Pestizidabschwemmung\"Kommentar: WZB discussion paper FS II 94-308L. Ebner Heft 9: Auswirkungen der Komplement\u00e4rherbizide auf Gew\u00e4sserGutachten:  G. Klein : \"Auswirkungen der HR-Technik auf aquatische \u00d6kosysteme\"Kommentar: E. Dorn WZB discussion paper FS II 94-309  102 Herbicide-resistant crops Heft 10: Auswirkungen der Komplement\u00e4rherbizide auf Agrar\u00f6kosystemeGutachten:  sistenter Kulturpflanzen auf \u00d6kosysteme\"E.-G. Mahn : \"Zu den Auswirkungen der Einf\u00fchrung herbizidreKommentar: WZB discussion paper FS II 94-310M. Reschke Heft 11: Genetische Verarmung: M\u00f6gliche Auswirkungen des Einsatzes der HR-Technik auf die Vielfalt von Kulturpflanzen und der AckerbegleitfloraGutachten:  H. Umbach , J. Zeddies, R. von Broock : \"Auswirkungen der Herbizidresistenz-Technik auf die Z\u00fcchtungspraxis und die genetischen Res-sourcen\" Kommentar: WZB discussion paper FS II 94-311C. Freudling Heft 12: Pflanzenbauliche Ver\u00e4nderungen durch die HR-Technik.Gutachten:  Das Problem der Entwicklung resistenter Unkr\u00e4uterK. Hurle : \"M\u00f6gliche Ver\u00e4nderungen in der landwirtschaftlichen Praxis durch die HR-Technik\"Kommentar:  WZB discussion paper FS II 94-312P. Niemann Heft 13: HR-Technik und integrierter Pflanzenschutz Gutachten: grierter Pflanzenschutz\"R. Heitefu\u00df ,  B. Gerowitt, H. Steinmann : \"HR-Technik und inteKommentar: WZB discussion paper FS II 94-313A. Gnekow-Metz Heft 14: Nicht-chemische Methoden der Unkrautbek\u00e4mpfung: \"Die nicht-chemische Regulierung des Wildpflanzenbesatzes im \u00f6kologischen Landbau als Alternative zum Her-Gutachten:  H. St\u00f6ppler-Zimmer bizideinsatz\"Kommentar:  WZB discussion paper FS II 94-314G. Bauer Heft 15: Betriebs- und volkswirtschaftliche Auswirkungen der HR-TechnikGutachten:  gen des Einsatzes herbizidresistenter Nutzpflanzen (HR-Technik)\"V. Beusmann : \"Betriebs- und volkswirtschaftliche AuswirkunKommentar: WZB discussion paper FS II 94-315R.A.E. M\u00fcller Heft 16: Der Beitrag des Anbaus herbizidresistenter Kulturpflanzen f\u00fcr dieErn\u00e4hrungssicherung in der Dritten WeltGutachten:  S. Neubert,J. Knirsch : \"Der Beitrag des Anbaus herbizidresistenter Kulturpflanzen f\u00fcr die Ern\u00e4hrungssicherung in der Dritten Welt\" WZB discussion paper FS II 94-316Kommentargutachten:  K. Leisinger Heft 17: Ethische Aspekte der gentechnischen Ver\u00e4nderung von PflanzenGutachten:  von Pflanzen\" G. Altner : \"Ethische Aspekte der gentechnischen Ver\u00e4nderung Kommentar: WZB discussion paper FS II 94-317A. Stanger Heft 18: Bewertung und Regulierung der HR-TechnikI. Gutachten:  bizidresistenter Pflanzen\"; Kommentar: E. 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An analysis of the US Department of Agriculture's environmental assessments\". APPENDIX: Materialien zur Technikfolgenabsch\u00e4tzung Heft 1: Einf\u00fchrung in das TA-Verfahren W. van den Daele: Technikfolgenabsch\u00e4tzung als politisches Experiment WZB discussion paper FS, 42 pp. 280-289.","pdf_url":""},{"view":"<a href=\"https:\/\/onlinelibrary.wiley.com\/doi\/10.1002\/9783527624584.ch5\" target=\"_blank\">P\u00fchler, I. B. (n.d.). Heft 3: Risiken eines horizontalen Gentransfers aus transgenen Pflanzen Gutachten: A. Tappeser WZB discussion paper FS, pp. 94-303.<\/a> ","pdf_url":""},{"view":"Sukopp, U. S. (n.d.). Heft 4: Risiken der Verwilderung von transgenen Pflanzen Gutachten: H. Scholz WZB discussion paper FS, pp. 94-304.","pdf_url":""},{"view":"Komplement\u00e4rherbiziden, T. R. (n.d.). Entwicklung der Aufwandmengen beim Herbizideinsatz Gutachten: H. Kommentar: V. Sandermann,K.-F. 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Heft 16: Der Beitrag des Anbaus herbizidresistenter Kulturpflanzen f\u00fcr die Ern\u00e4hrungssicherung in der Dritten Welt Gutachten: S. Kommentargutachten: K. Verfahren zur Technikfolgenabsch\u00e4tzung des Anbaus von Kul- turpflanzen mit gentechnisch erzeugter Herbizidresis- tenz,(16).<\/a> ","pdf_url":""},{"view":". (n.d.). Heft 18: Bewertung und Regulierung der HR-Technik I. Bewertung und Regulierung von Kulturpflanzen mit gentechnisch erzeugter Herbizidresistenz (HR-Technik) WZB discussion paper FS, pp. 94-318.","pdf_url":""}]},"system_type":"EXP","doc_rank":2,"rid":29029818},{"_index":"gesis-22-05-2026-02-01-51","_id":"gesis-bib-26518","_version":1,"_seq_no":3743,"_primary_term":1,"found":true,"_source":{"coreAuthor":["Daele, Wolfgang van den"],"coredoctypelitadd":["Monographie"],"coreJournalTitle":"WZB - Papers, FS II 94-301.","coreLanguage":["Deutsch (DE)"],"database":"GESIS - Bibliothek","data_source":"GESIS-BIB","document_type":"Zeitschriftenaufsatz","fulltext":0,"gesis_own":1,"library_location":["K\u00f6ln Zeitschriftenaufsatz"],"person":["Daele, Wolfgang van den"],"person_sort":"Daele","publisher":"GESIS","source":"In: WZB - Papers, FS II 94-301., 1994 ","subtype":"journal_article","title":"Technikfolgenabsch\u00e4tzung als politisches Experiment. Diskursives Verfahren zur Technikfolgenabsch\u00e4tzung des Anbaus von Kulturpflanzen mit gentechnisch erzeugter Herbizidresistenz","topic":["Zeitschriftenartikel"],"type":"gesis_bib","id":"gesis-bib-26518","index_source":"GESIS-BIB"},"system_type":"BASE","doc_rank":3,"rid":29029818},{"_index":"gesis-22-05-2026-02-01-51","_id":"wzb-bib-166132","_version":1,"_seq_no":89963,"_primary_term":1,"found":true,"_source":{"title":"Von rechtlicher Risikovorsorge zu politischer Planung. Begrundungen fur Innovationskontrollen in einer partizipativen Technikfolgenabschatzung zu gentechnisch erzeugten herbizidresistenten Pflanzen ","id":"wzb-bib-166132","date":"1999","date_recency":"1999","portal_url":"http:\/\/sowiport.gesis.org\/search\/id\/wzb-bib-166132","type":"publication","person":["Daele, Wolfgang van den"],"person_sort":"Daele","links":[],"publisher":"WZB","database":"WZB - Wissenschaftszentrum Berlin f\u00fcr Sozialforschung","coreAuthor":["Daele, Wolfgang van den"],"data_source":"GESIS-Literaturpool","link_count":0,"gesis_own":1,"fulltext":0,"index_source":"OUTCITE","literature_collection":"GESIS-Literaturpool"},"system_type":"EXP","doc_rank":4,"rid":29029818},{"_index":"gesis-22-05-2026-02-01-51","_id":"gesis-bib-42028","_version":1,"_seq_no":6873,"_primary_term":1,"found":true,"_source":{"coreAuthor":["Bora, Alfons","D\u00f6bert, Rainer"],"coredoctypelitadd":["Monographie"],"coreJournalTitle":"Soziale Welt","coreLanguage":["Deutsch (DE)"],"database":"GESIS - Bibliothek","data_source":"GESIS-BIB","document_type":"Zeitschriftenaufsatz","fulltext":0,"gesis_own":1,"library_location":["K\u00f6ln Zeitschriftenaufsatz"],"person":["Bora, Alfons","D\u00f6bert, Rainer"],"person_sort":"BoraD\u00f6bert","publisher":"GESIS","source":"In: Soziale Welt, Jg. 44, 1993, Nr. 1, S. 75 ff.. ISSN 0038-6073","subtype":"journal_article","title":"Konkurrierende Rationalit\u00e4ten. Politischer und technisch-wissenschaftlicher Diskurs im Rahmen einer Technikfolgenabsch\u00e4tzung von genetisch erzeugter Herbizidresistenz in Kulturpflanzen","topic":["Zeitschriftenartikel"],"type":"gesis_bib","id":"gesis-bib-42028","index_source":"GESIS-BIB"},"system_type":"BASE","doc_rank":5,"rid":29029818},{"_index":"gesis-22-05-2026-02-01-51","_id":"wzb-bib-167356","_version":1,"_seq_no":89967,"_primary_term":1,"found":true,"_source":{"title":"Urteile uber die Gentechnik im Lichte von Ergebnissen der Technologiefolgenabschatzung ","id":"wzb-bib-167356","date":"2001","date_recency":"2001","portal_url":"http:\/\/sowiport.gesis.org\/search\/id\/wzb-bib-167356","type":"publication","person":["Daele, Wolfgang van den"],"person_sort":"Daele","links":[],"publisher":"WZB","database":"WZB - Wissenschaftszentrum Berlin f\u00fcr Sozialforschung","coreAuthor":["Daele, Wolfgang van den"],"data_source":"GESIS-Literaturpool","link_count":0,"gesis_own":1,"fulltext":0,"index_source":"OUTCITE","literature_collection":"GESIS-Literaturpool"},"system_type":"EXP","doc_rank":6,"rid":29029818},{"_index":"gesis-22-05-2026-02-01-51","_id":"wzb-bib-166415","_version":1,"_seq_no":89235,"_primary_term":1,"found":true,"_source":{"title":"Risk prevention and the political control of genetic engineering. Lessons from a participatory technology assessment on transgenic herbicide-resistant crops ","id":"wzb-bib-166415","date":"1998","date_recency":"1998","portal_url":"http:\/\/sowiport.gesis.org\/search\/id\/wzb-bib-166415","type":"publication","person":["Daele, Wolfgang van den"],"person_sort":"Daele","links":[],"publisher":"WZB","database":"WZB - Wissenschaftszentrum Berlin f\u00fcr Sozialforschung","coreAuthor":["Daele, Wolfgang van den"],"data_source":"GESIS-Literaturpool","link_count":0,"gesis_own":1,"fulltext":0,"index_source":"OUTCITE","literature_collection":"GESIS-Literaturpool"},"system_type":"BASE","doc_rank":7,"rid":29029818},{"_index":"gesis-22-05-2026-02-01-51","_id":"wzb-bib-105792","_version":1,"_seq_no":80537,"_primary_term":1,"found":true,"_source":{"title":"Transgene Pflanzen. Herstellung, Anwendung, Risiken und Richtlinien","id":"wzb-bib-105792","date":"1995","date_recency":"1995","portal_url":"http:\/\/sowiport.gesis.org\/search\/id\/wzb-bib-105792","type":"publication","person":["Brandt, Peter"],"person_sort":"Brandt","links":[],"publisher":"WZB","database":"WZB - Wissenschaftszentrum Berlin f\u00fcr Sozialforschung","coreAuthor":["Brandt, Peter"],"corePublisher":"Birkhauser","data_source":"GESIS-Literaturpool","link_count":0,"gesis_own":1,"fulltext":0,"index_source":"OUTCITE","literature_collection":"GESIS-Literaturpool"},"system_type":"EXP","doc_rank":8,"rid":29029818},{"_index":"gesis-22-05-2026-02-01-51","_id":"gesis-solis-00185856","_version":1,"_seq_no":89117,"_primary_term":1,"found":true,"_source":{"title":"Technikfolgenabsch\u00e4tzung als politisches Experiment : diskursives Verfahren zur Technikfolgenabsch\u00e4tzung des Anbaus von Kulturpflanzen mit gentechnisch erzeugter Herbizidresistenz","id":"gesis-solis-00185856","date":"1994","date_recency":"1994","abstract":"Die Abteilung \"Normbildung und Umwelt\" im Wissenschaftszentrum Berlin hat von 1991 bis 1993 ein Verfahren zur Technikfolgenabsch\u00e4tzung f\u00fcr den Anbau von Kulturpflanzen mit gentechnisch erzeugter Herbizidresistenz mitorganisiert und begleitet. In dem Verfahren wurden alle wichtigen Problemfelder der Herbizidresistenztechnik mit Hilfe von Gutachten untersucht und in kontinuierlichen Diskursen von den Beteiligten (unter Einschlu\u00df von Bef\u00fcrwortern und Gegnern der Technik) er\u00f6rtert. Die Abteilung \"Normbildung und Umwelt\" ver\u00f6ffentlicht die Materialien des Verfahrens. In Heft 1 stellt Wolfgang van den Daele die Struktur und den Ablauf des Technikfolgenabsch\u00e4tzungsverfahrens dar. Insbesondere wird beschrieben, wie die Partizipation der Beteiligten organisiert war und wie man im Verfahren aus den oft kontroversen Diskussionen Schlu\u00dffolgerungen f\u00fcr die Beurteilung der Herbizidresistenztechnik abgeleitet hat. Diese Beschreibung wird durch eine Reihe von Dokumenten im Anhang zu Heft 1 erg\u00e4nzt. Die Vertreter innen der Umweltverb\u00e4nde haben das Verfahren zu Beginn der Abschlu\u00dfkonferenz verlassen. Die \u00d6ffentlichkeit kann sich anhand dieses Heftes und der in den folgenden Heften ver\u00f6ffentlichten Materialien der Technikfolgenabsch\u00e4tzung selbst ein Urteil dar\u00fcber bilden, ob das Verfahren fair war und die Schlu\u00dffolgerungen gerechtfertigt sind. 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