Reflecting on a recent meeting hosted by the British Society for Animal Science (BSAS) on the theme of ‘Gene editing in farm animals: the facts’, Dr Craig Lewis, chair of the European Forum of Farm Animal Breeders (EFFAB), says it is positive and encouraging that animal welfare NGOs such as the RSPCA and Compassion in World Farming (CiWF) have both acknowledged publicly that there may be welfare-positive applications of gene editing which they could support. This highlights the importance of keeping the conversation going, and for livestock breeders to explain the steps they are taking to promote transparent, responsible and balanced breeding programmes. Only through continued open dialogue can we hope to ensure ethical and other concerns around the use of these technologies can be addressed, and that over-precaution does not give rise to inaction, with even greater ethical consequences for animal health, welfare and food security, he argues.     

 

I was pleased to be invited to speak at a recent meeting hosted by the British Society for Animal Science (BSAS) in Manchester on the theme of ‘Gene editing in farm animals: the facts’.

 

It was a lively meeting, which for me highlighted above all the need to keep the dialogue going between those, like me, who want Government to move on with implementing the farmed animal provisions of the Genetic Technology (Precision Breeding) Act 2023, and those who favour a slower, more precautionary approach or, in some cases, an indefinite pause on moving ahead with the legislation. Bottom line, clarity is vitally important.  

 

A Defra representative at the meeting opened proceedings with a clear statement of the scope and intent of the Precision Breeding Act.

 

The Act seeks to free up access to potentially beneficial innovation in agriculture by diverging from restrictive GMO rules. The Act establishes a new category of ‘precision bred organism’, or PBO, in relation to the products of new breeding technologies such as CRISPR gene editing.

 

Defra explained that the Act defines a PBO as a plant or farmed animal (not pets or racing horses) developed using modern biotechnology which could equally have been produced using conventional or ‘traditional’ breeding methods, and which therefore – importantly – poses no greater risks.   

 

They also emphasised that it in addition to a requirement for confirmation of PBO status, overseen by Defra, and food marketing approval, overseen by the Food Standards Agency, the Act includes specific animal welfare conditions for the authorisation of a new precision bred farmed animal.

 

This is expected to involve the submission of an animal welfare declaration, with supporting evidence, confirming that the use of precision breeding would not have adverse effects on animal welfare, compared to a conventionally bred counterpart, and overseen by a new welfare advisory body, yet to be established.

 

We also heard why scientists in the field are so excited about the promise of these technologies, which are becoming more accessible and better targeted all the time. Potential benefits include step-change improvements in the prevention and control of devastating disease and welfare problems, such as porcine reproductive and respiratory syndrome (PRRS) virus in pigs, avian influenza in poultry, and sea lice infestation in farmed salmon. 

 

And we heard the latest thinking from SRUC, commissioned by Defra to develop recommendations for the PB animal welfare declaration process, on their holistic approach to assessing animal welfare, based on the five domains model (Nutrition, Environment, Health, Behaviour, Mental State).

 

In my view, there are genuine practical and scientific questions to be posed about a ‘holistic’ approach to animal welfare assessment – ie as opposed to a trait-based or hypothesis-driven approach – particularly in view of how such an approach relates to over-arching regulatory principles of proportionality, enforceability and non-discrimination.

 

A number of these questions were also raised at the BSAS meeting, but the first is simply one of practicality. How many animals might be required to provide scientifically valid comparisons of welfare outcomes in PB animals compared to their non-PB counterparts? Over how many generations? Under how many different farming systems, environments, or disease challenges? The permutations are, potentially, endless.

 

The second is one of enforcement. How might these requirements be applied to imported meat and livestock products, for example, when a number of countries around the world, including Colombia and Brazil, have already determined that precision breeding in animals will be regulated no differently from conventional breeding?

 

The third relates to proportionality. When the underpinning rationale of the Act, as explained by Defra, is that PB animals must be equivalent to conventionally bred, what possible scientific justification can there be for requiring welfare information which goes above and beyond the assessments breeding companies, in multiple species, already have in place?

   

The fourth relates to non-discrimination. When legislative provision already exists in relation to the welfare implications of “natural or artificial breeding or breeding procedures” under the Welfare of Farmed Animals (England) Regulations 2007, it is clearly discriminatory to single out PB animals for additional welfare checks which are not currently applied to non-PB animals. If existing regulations are viewed as inadequate or ineffective in some way, then that is where the legislative focus should be, not on discriminating against newer, more precise forms of genetic improvement.

 

Although billed as a scientific meeting to debate the ‘facts’, inevitably some of the more emotive and ideological concerns around the use of gene editing in farmed animals were also raised during the session. Indeed, these may go some way to explain the potential disconnect between science and politics in the framing of the Precision Breeding Act.    

 

So, we heard about the ‘yuk factor’ and the unnaturalness of taking a utilitarian approach to breeding and producing farmed animals. It was suggested that improved disease resistance might lead to farmers cramming animals together in more intensive conditions. We were warned of ‘unknown unknowns’ and unexpected off-target effects which might not be immediately evident. We heard that developments are being led by profit-motivated big business. And we were told that precision breeding should be more stringently regulated and permitted only as a ‘last resort’.       

  

Perhaps I could take each of those points in turn.

 

Yuk factor.

Honestly, to me there seems a lot more of a ‘yuk factor’ about watching how disease, such as PRRS impacted the my father’s family farming business over the years, which these technologies can help prevent.  

 

Unnatural and utilitarian.

What aspect of agriculture is not utilitarian? We rear farmed animals to produce meat and dairy products. By its very definition, agriculture (cultivation of the land or domestication of livestock) is disruptive of nature. Indeed, a 2015 report from the Nuffield Council on Bioethics cautioned against the use of the term ‘natural’ in food marketing precisely because of the potential to mislead.

 

Cramming animals together.

Aside from the fact that the industry must observe statutory codes of practice for animal welfare on issues such as stocking densities and housing conditions, this paints a picture of farmers as careless of welfare which is not reflected in reality. Standards of welfare on Britain’s farms are not poor and deteriorating, but high and constantly improving. Furthermore, the suggestion that improved disease resistance would lead to farmers cramming their animals together would surely be equally true of vaccination at present, yet there is simply no evidence for this, as was pointed out at the meeting.

 

Unknown unknowns.

This is a difficult one, because it is impossible to prove a negative, just as it is impossible to prove that there are no fairies at the bottom of the garden. We can never say that anything is 100% safe. But if we apply the precautionary principle to such an extreme then society would never benefit from any technological or scientific innovations. The overwhelming weight of scientific evidence at this point in time is that PBOs pose no greater risk than their conventionally bred counterparts.

 

Driven by profit-motivated, big business.

Why is profit such a loaded term? Successful businesses drive economic growth, which benefits society. Today, the more socially and ethically responsible businesses are likely to be more profitable. In terms of size, I would agree that more restrictive regulations are likely to favour larger corporations - it is a self-fulfilling prophecy as we have found with GMOs. But the technologies themselves are equally applicable to small-scale breeders and producers, given the social licence to use them. 

 

Use only as a last resort, with a higher regulatory bar.

From where I’m sitting, this simply suggests built-in prejudice against the technology. If PBOs could equally have been achieved through conventional breeding methods, and welfare regulations are in place covering all farmed animals, why discriminate against more precise and effective methods of genetic improvement in this way?

     

I had a worrying sense of déjà vu listening to many of these concerns, harking back to the early days of the GMO debate 25 years ago when there was strong opposition based on similar arguments – unknown effects, playing God, unnaturalness, corporate control, and encouraging greater intensification in agriculture.

 

But I genuinely believe there is a difference this time round.

 

The animal welfare organisations raising concerns about gene editing farmed animals are not, in my view, dogmatically opposed to the technology as was the case with opponents of GM crops.

 

Their primary concern is with improving the welfare of farmed animals, and welfare NGOs such as the RSPCA and Compassion in World Farming (CIWF) have both acknowledged publicly that there may be welfare-positive applications of gene editing which they could support – such as disease resistance and sexing in layer chicks.              

 

This is positive and encouraging, and motivates me to keep talking and explaining the steps the farmed animal breeding industry is taking, for example through the European CODE EFABAR protocols, to promote responsible and balanced breeding programmes, and to encourage greater transparency in innovation. Thanks to the BSAS for giving another platform for these important discussions.  

 

Only through continued open dialogue can we hope to ensure ethical and other concerns around the use of these technologies can be addressed, and that over-precaution does not give rise to inaction, with even greater ethical consequences for animal health, welfare and food security.   

 

Dr Craig Lewis was raised on a family farm in Herefordshire. He has advanced degrees in Animal Behaviour/Welfare and Animal Breeding/Genetics, including a PhD at the Roslin Institute, University of Edinburgh, after undertaking a research position in Australia. Craig currently oversees Genetic Dissemination for Genus PIC in the Europe/Middle East/Africa region working with pig producers from developing farmers in Africa to multinational integrated food businesses. He is also the current chair of the steering committee for the European Forum for Farm Animal Breeders (EFFAB).