GTEC recommends that the definition of “environment” not be amended to expand the scope of the GT Act.
Definition of “health”
GTEC notes that “health” is currently not defined within the GT Act. If it is to be defined in the Act then it should be defined narrowly. The World Health Organization (WHO) defines health as “a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity” (1948 - not amended). While this is an appropriately broad definition of health for many public health purposes GTEC considers that it is too broad for the GT Act if the Act is to remain consistent with its current risk analysis function.
The GT Act and the OGTR currently includes in an assessment of dealings with GMOs physical health aspects such as: allergenicity, and toxicity in the scientific risk assessment as evidenced in the RARMPs prepared pursuant to the GT Act. Consideration of mental and social health and well-being from, for example, fear and anxiety due to a real perception of risk from genetically modified organisms (regardless of whether those perceptions are grounded in facts supported by natural science) are beyond the scope of the current GT Act. GTEC does not discount the importance of the mental and social well-being of individuals in the community but does considers that this should not form part of the risk analysis of genetically modified organisms pursuant to the GT Act. However, all aspects of mental and social well-being relating to genetically modified organisms might be assessed and responded to within the broader national health and regulatory framework. GTEC also notes that some aspects of fear and anxiety can be potentially mitigated through appropriate risk management and risk communication and, especially, through attention to ethical communication of information within a scientific risk analysis process, such as that pursuant to the GT Act. GTEC considers that these issues are appropriate for general consideration by expert advisory committees such as GTEC and GTCCC and, particularly, through the use by OGTR of regulatory expertise on risk perception, risk management and risk communication in the RARMPs.
GTEC also notes the WHO draft definition of “environmental health” which “comprises those aspects of human health, including quality of life, that are determined by physical, chemical, biological, social, and psychosocial factors in the environment.” The definition also refers to the theory and practice of assessing, correcting, controlling, and preventing those factors in the environment that can potentially affect adversely the health of present and future generations. Many other definitions of “environmental health” exist from a diverse array of sources and GTEC considers that a modified or adapted definition of environmental health has the potential to be consistent with the current objects of the GT Act.