The Concept Of Natural: Implications For Biotechnology Regulation
Drew L. Kershen
University of Oklahoma College of Law
The General Synod Board for Social Responsibility of the Church of England
(1999) issued a report entitled Genetically Modified Organisms: A Briefing
Paper. In this report, that is cautiously favorable towards biotechnology,
1 the Synod Board states that enormous concern exists at the prospect of
genetically modifying organisms arising from a Asense that genetically
modified foods are radically unnatural.2 In this paper, I will explore
this concern that the genetic modification of organisms is unnatural as a
reflection of competing concepts about the natural world. As I undertake
this exploration, I acknowledge that the concept of the natural is
immensely complex and that my comments barely grapple with the
complexities. Despite these limitations, the concept of the natural B
discerning the boundary between the natural and the unnatural B appears to
be central to the debate about biotechnology.3
Competing Concepts About The Natural World
The Mother Nature or Gaia World View
From the reading, listening, and talking about biotechnology that I have
done over the past five years, a recurring theme among many who oppose
biotechnology is that the natural world is a stable, orderly, peaceful
world best described as Mother Nature or Gaia. Mother Nature is described
as a loving mother who cares for her land forms, water bodies, bacteria,
plants, and animals. Mother Nature nurtures these offspring as best she
can to protect them from extinction and pollution. Mother Nature intends
no harm and ordinarily does no harm to her offspring. Gaia is a
self-regulating living organism (the planet Earth) that provides each
ecosystem according to its physical needs. Gaia breathes in and breathes
out in an intricate, inter-twined harmony that supports life to the
fullest potential diversity. Gaia allows for the flowering and development
of life always in harmony and mutual reciprocity.
In this view of the natural, human beings should strive first, foremost,
and maybe only to live in balance with, in harmony with, and in rhythm
with nature. Any human activity that is not in balance with, in harmony
with, in rhythm with nature is unnatural. By their numbers, intelligence,
and science, human beings too frequently exceed the natural balance,
harmony, and rhythm of the natural world. Rather than co-existing with
nature, human beings too often strive to create an artificial world made
in their own image rather than reflecting the image of nature.
More specifically regarding biotechnology, many who believe in Mother
Nature or Gaia also believe that human arrogance is at the root of
biotechnology and that biotechnology is the final attempt to manipulate
the natural world into a human-created world. As expressed by many who
oppose biotechnology, biotechnology is playing God B the ultimate idolatry
and the first sin (Nuffield Council on Bioethics, 1999, Append. 4, Pts. 3
Less philosophically and more professionally, many environmentalists who
support the Mother Nature or Gaia view of the natural world consider
themselves deep ecologists seeking the balance, harmony, and rhythm of
habitats, watersheds, ecosystems, organisms, and other natural systems.
For them as believers in Mother Nature or Gaia, deep ecology is the
paradigmatic science of the future whether expressed in biology, medicine,
meteorology, immunology, or any other scientific endeavor.4
The Naturalist World View
Over these same past five years, it appears that a recurring theme among
many who favor biotechnology is that the natural world is a world of
constant change that has no stable balance, harmony, or rhythm. To many
who favor biotechnology, the natural world is not described metaphorically
as Mother Nature or Gaia. The natural world is an amoral -- please note
that I did not say immoral -- world that does not exhibit care or concern
for any existing thing whether inanimate or animate, living or dead. For
naturalists, nature does not know; nature does not feel; nature does not
have consciousness. While for naturalists, nature gives rise to wonder and
awe and is beautiful and bountiful, the natural world also produces
natural occurrences and natural disasters, such as famine and disease. The
natural world is not a pristine world that must be left untouched. Rather,
the natural world is a place of exploration in order to learn more fully
the laws of nature -- cycles, causes, effects. Nature simply is nature.
In this second view of the natural world, human beings using their
intelligence and their skills are part of nature. Human activities may
cause harm to nature but human activities might also prevent and alleviate
natural disasters. Human beings affect the natural world simply by
existing but, with proper stewardship and proper ethics, human beings can
improve welfare, achieve rights, and do good. As a consequence, quoting
the Nuffield Council on Bioethics (1999, Pt. 1.40), The
"natural/unnatural" distinction is one of which few practicing scientists
can make much sense. Whatever occurs, whether in a field or a test tube,
occurs as the result of natural processes, and can, in principle, be
explained in terms of natural science.
More specifically regarding biotechnology, those who adopt this naturalist
view of nature believe that biotechnology is an extension of scientific
principles that are well established and long-used in pharmacy, medicine,
chemistry, biology, environmental science, and agriculture. Moreover, the
scientific principles of biotechnology are different in technique, but not
different in kind, from genetic techniques that human beings have used for
thousands of years to create the bacteria, crops, and animals that produce
the foods, fibers, medicines, and household or commercial products used in
every culture in the world. In response to those who fear that
biotechnology is playing God, the naturalists might respond that
biotechnology does nothing more than use the Creator's gift of
intelligence to humankind -- as the Creator intended (Nuffield Council on
Bioethics, 1999, Pts.1.37 & 1.38).5
Less philosophically and more professionally, many who believe in the
naturalist view think that the twenty-first century will be the century of
biology. For them, the future paradigmatic sciences will be molecular
biology and genetics whether expressed in pharmacy, medicine,
environmental science, industrial production, agriculture, or any other
While the competition between the two worldviews that I have described has
implications for the public acceptance or rejection of biotechnology,
these two views also have practical implications for governmental
policies. Laws and regulations that reflect the Mother Nature or Gaia
world view would be significantly different from laws and regulations that
reflect the naturalist view of nature. I will discuss briefly an area in
which such significant differences may be obvious.
Bacillus thuringiensis (Bt) is a widely-occurring bacterium in the soil.
Bacillus thuringiensis has pesticidal properties against many insects. As
a consequence of these pesticidal properties, the Environmental Protection
Agency (EPA) regulates the manufacture and sale of Bt as a pesticide in
microbial natural products (Bt sprays) and in genetically modified plants
(e.g., Bt corn) under the Federal Insecticide, Fungicide, and Rodenticide
Act (FIFRA) and the Toxic Substances Control Act (TSCA) (EPA, 1986).
As a pesticide, Bt -- like almost all other pesticides -- will give rise
to insect resistance (Tabashnik et al., 1990; Tang et al., 1997). As a
pesticide is used, insects that have a resistance to the pesticide survive
at greater rates than insects of the same species that do not possess
resistance. Over time, the resistant genotypes of insects becomes the
dominant population in numbers. Thus, at some number of generations, the
insect population has become resistant to the pesticide. The pesticide
With respect to genetically modified crops, the EPA has specifically
considered the issue of insect resistance as an issue for regulatory
review as the EPA decides whether to grant a registration of the plant for
sale as a plant-pesticide (EPA/USDA, 1999). More recently, to manage pest
resistance, the EPA on January 14, 2000 announced a refuge policy that
requires growers of Bt corn to grow 20% or more corn acres as non-Bt corn.
By having refuges of non-Bt corn, the strategy is for any insects that
survive the dosage in the Bt corn to mate with non-affected insects in the
non-Bt corn to prevent the resistance from spreading in the insect
population. Moreover, the EPA will also require that the sale of Bt corn
be halted at the first sign of insect resistance (BNA, 2000; Weiss, 2000).
With respect to Bt sprays, however, the EPA has never considered pest
resistance to be an issue for regulatory review at the time of FIFRA
registration of the Bt spray as a pesticide (Anderson & Milewski, 1999).6
On searching regulatory announcements and regulations, no call for making
pest resistance a regulatory issue for FIFRA registration of microbial Bt
sprays could be found. This acceptance of Bt sprays -- created most often
through fermentation rather than genetic engineering7-- without concern
for pest resistance occurs even though the scientific articles cited
establish that Bt sprays do create and already have created pest
resistance (Tabashnik et al., 1990; Tang et al., 1997).
Furthermore, despite the established fact that pests have become resistant
to Bt sprays, there has been no public statement by the EPA (or anybody
else for that matter) that Bt sprays must be withdrawn from the market at
the first sign of the emergence of pest resistance. Despite ten years of
field insect resistance to Bt sprays, Bt sprays continue on the market.
Moreover, the EPA demand that Bt corn seed sales cease at the first sign
of pest resistance, with no similar demand for Bt sprays, occurs even
though a scientific study exists that Bt plants may often provide a
pesticide delivery system that better manages pest resistance than
pesticide delivered through Bt sprays (Roush, 1994).
What accounts for the regulatory policy of the EPA that treats pest
resistance to Bt in crops as a significant issue but does not consider
pest resistance to Bt sprays to be an issue at all? While assuredly many
influences affect this EPA stance, I suggest that an important factor is
the two differing views of the concept of natural. These differing views
have impact through two different influences.
One possible influence is the worldview of the EPA regulators themselves.
If the EPA regulators share the view of nature as Mother Nature or Gaia,
they may consider pest resistance from Bt crops to be unnatural but that
pest resistance from Bt sprays is normal in the natural world.
A second possible influence is the worldview of those who pressure EPA. If
environmental groups view nature as Mother Nature or Gaia, these
environmental groups likely will consider pest resistance from Bt crops as
unnatural while remaining relatively unconcerned about the pest resistance
caused by Bt sprays. If the EPA feels more akin emotionally to
environmental groups or feels more politically influenced by environmental
groups, the EPA may endorse the Mother Nature or Gaia view of nature with
concomitant consequences for regulatory policy.
The philosophical debate that I have tried to sketch in this commentary is
not the only factor affecting the regulation of biopesticides. Differences
between Bt-crops and Bt-sprays exist -- among others persistence in the
soil, longevity of effective action, and modes of action (living versus
killed pesticide) -- and are important considerations for appropriate
Yet, this underlying philosophical debate about the concept of natural
seems to me to be crucial to understanding the debate about biotechnology.
Furthermore, the policy implications that I discussed with respect to Bt
have similar echos with respect to issues relating to the safety of foods
from conventional farming as compared to the safety of foods from organic
farming; and with respect to the safety of pharmaceutical products as
compared to the safety of dietary supplement products. In each instance,
how the product is viewed (as natural or unnatural) significantly affects
the regulatory policy applied to the product. Concurrently, how the
product is labeled as natural or unnatural depends on the worldview of the
concept of natural of the person who is applying the label.
This commentary is a revision of a paper presented to the Conservation
Technology Information Center (CTIC), Forum on Biotechnology, February 2,
2000, in Colorado Springs, Colorado. The CTIC has its offices in West
Lafayette, Indiana. The author thanks those who asked questions at the
Forum and who read this paper in manuscript.
1 For example, the report states, "Wisdom is unlikely to lie either in an
unrestricted exploitation or in a total prohibition, but in careful
consideration of individual proposals. In this respect, genetic
engineering does not seem very different from other forms of scientific
advance Church of England (1999, Point 5. Theological Issues).
2 Rene Dubos, a microbiologist, environmentalist, and co-author of the
United Nations report Only One Earth, wrote an editorial for the New York
Times in 1977 that explained how his hostility to genetic modification as
unnatural changed to support because Athe potential benefits are large and
the dangers purely hypothetical. (as cited in Piel & Segerborg, 1990, p.
3 For an excellent discussion of biotechnology generally, read Nuffield
Council on Bioethics (1999). Chapter 1 of this book has two subsections
that are particularly relevant to this paper, The Natural/Unnatural
Boundary and Taboos and Moral Conservatism.
4 Deep ecology is my wording but I use this term with the meaning found in
the Nuffield Council on Bioethics (1999, Pt. 1.8) report, "'the
environment' [is] an object of ethical concern, regardless of how the
environment affects the interests of human and other animals. See also
Pts. 1.7 & 1.44.
5 Purposefully, I do not explore a view of nature that is devoid of ethics
and stewardship. Human beings can view nature as nothing more than the
domination and degradation of creation and creatures by the powerful and
the cunning. I posit that those who believe in Mother Nature or Gaia and
those who believe in the naturalistic view of nature are equally people of
good will and virtue. However, if my optimism about good will and virtue
is unwarranted, for those who desire to view nature as nothing more than
the setting within which to dominate and degrade, I see no reason why they
would not mask their designs equally well and as often in either view of
nature I have described. For those who desire purposefully to seek evil,
worldviews are adopted and propagandized simply as means to attain immoral
ends (see Shattuck, 1996, chap. VI & chap. VII).
6 Dr. Andersen, Director, Biopesticides and Pollution Prevention Division,
OPP, EPA stated in a presentation, AResistance management requirements
have only been placed on Bt plant-pesticides. (Andersen & Milewski, 1999).
7 Bt sprays can be produced by a combined process of fermentation and
genetic modification. The first genetically engineered biopesticide to
gain EPA/FIFRA registration was a Bt spray. (Gelernter & Schwab, 1993). It
is my understanding that organic farmers use this Bt spray. Indeed, it is
my understanding that until the advent of biotechnology that Bt sprays
were not as effectively nor as widely used in the United States as the
present (Chambers, 1999).
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current status. Paper presented to the International Conference on
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restrictions to prevent insect resistance announced for genetically
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Act and the Toxic Substances Control Act, 51 Fed. Reg. 23313, (1986, June
Environmental Protection Agency/United States Department of Agriculture
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