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  • Writer's pictureDave Black

Engineering Solutions

The practice of genetic engineering, or modification, was recently thrust prominently into the public discourse when the National Party announced a desire to make its use more available to the science community. Science writer Dave Black assesses the situation with a beekeeping lens, detailing the potential for beekeepers and scientists to benefit from a loosening of restrictions around ‘GE’ rules and the current minefield of legislation, while also exploring public opinion on the much-debated subject.

By Dave Black

The microsporidians we know as Nosemas (now being referred to as Vairimorpha) come pretty near the top of the list of things we don’t want in beehives, and the antibiotics that might once have held the tiny parasitic fungi in check can be both ineffective and harmful to humans. The search for a new way of protecting honey bees from the pest has tried a number of things.

‘Baggies’ of sugar syrup, which include modified RNAi to hinder the reproduction of varroa, are being administered to beehives as part of an ongoing research project at Victoria University. The RNAi method, which is not deemed to be ‘genetic modification’ as constituted in New Zealand, is showing great potential.

Employing technology we already have, various new molecules have been suggested, some quite novel inorganic chemicals, and some repurposing of current bee treatments, like thymol and the various organic acids. Less potentially toxic are a growing list of natural extracts or dietary supplements – Beewell, Nozevit, HiveAlive, Nosetat Vitafeed, ApiHerb, to name a few, but it’s not clear that they constrain the nosemas. The use of microbes and antimicrobials to either compete with, or mitigate the effects of, nosemas has so far also proved uncertain, let’s say they’re still ‘under investigation’.

New Ways of Doing Things

A rather modern approach has investigated ways to disrupt the protein-building nucleic acids that make up the genetic code of the parasite, causing a sort of internal sabotage. Arguably still ‘chemistry’, but just not as you know it. One method is being tried out here by Victoria University of Wellington using a ‘baggie’[i] to deliver the active ingredient. RNA molecules (Ribo-Nucleic Acid) are used to convey information within the genetic ‘machinery’ about the construction of proteins and we now have the ability to simply feed one we made earlier in a sugar syrup and ‘Hey presto…’

Well, of course it’s not that simple, you have to figure out what the pest’s proteins do and therefore what to target, you have to make sure nothing you value uses the same proteins (oops!), and these ‘messenger’ molecules are naturally and rapidly degraded. It has been shown to work, though whether beekeeping could afford the price of a continuous supply of short lived, state-of-the-art medicines is not in doubt, is it?

There is new technology around of course. There is a clever way to achieve the same thing developed (and patented) by a team working with Nancy Moran in North Carolina, one of about half-a-dozen such applications in recent years[ii]. In this case the scientists co-opted bacteria that normally live in the honey bee gut (the symbiotic bacteria Snodgrassella alvi) and re-engineered its genetic code to produce the RNA molecule they needed to ensure the pest’s self-destruction. The bacteria now produce a constant supply of the necessary molecule, and better still, the bacteria reproduce with the new machinery, colonise ‘new’ honey bees, and potentially neighbouring hives, all by themselves. Manufacturing and supply in one tiny package.

So, we could optimistically say genetically engineered honey bee gut symbionts have the potential to control all sorts of bee pathogens, including nosema and varroa, in which case, what are we going to do about that? New Zealand has heard more than usual about the ‘potential’ of genetic engineering[iii] lately. In the US and Canada this treatment, already with patents granted, might not raise any eyebrows, but here (and in Europe) the situation is not as straightforward. There has been a similar, but different, case here to illustrate the potential issues at play…

Currently, in New Zealand, the tools leading to genetic modification are regulated, but not the outcomes. Professor Peter Dearden of Otago University, a geneticist with a focus on bees, believes that needs to change, and he's not alone.

Too Many Hoops?

In 2018 a Research Technician from Landcare Research applied for a determination from the Environmental Protection Authority (EPA) as to whether an organism they had been working with, Caenorhabditis elegans, was a genetically modified organism, given that they had used a synthetic RNA to alter the expression of a protein it produces[iv]. Landcare argued it was not. The first decision the EPA considered was whether (legally) it was an ‘organism’, and, if an ‘in vitro’ (lab) technique was being used, was it acting on ‘genetic material’? The judgement was that the organism was not genetically modified, essentially, RNA is not part of that organism’s genome, the protein expression was ‘transitory’, and the organism’s genome was actually unaltered. The decision was rapidly appealed and then reconsidered after the submission of more evidence, but eventually confirmed three years later in 2021.

Since then most (but not all) people who follow this subject have started to think the legislation we use to manage the issues surrounding our ability to engineer genetic modifications is no longer fit for purpose. At the time it was created, we literally had no idea what we [would be] talking about! The main piece of legislation enacted, the Hazardous Substances and New Organisms Act 1996, is approaching its 30th birthday and nestles amongst a suite of other Acts that govern biosecurity, food safety, animal welfare, conservation, resource management, veterinary medicines, and wildlife, to name a few. Nothing happens in isolation.

An Example

Imagine you are the ‘inventor’ of some useful honey bee gut bacteria or pest-killing molecules and have leapt all the Intellectual Property hurdles. You’re ready to have all the following decisions contested. You will be looking for EPA approval (see above, your case might be different) for the new organism (HSNO Act 1996), your lawyers will in all probability be checking compliance with (for animal ethics approval) the Animal Welfare Act 1999, a pest management plan (‘cos Resource Management Amendment Act 2005, Biosecurity Act 1993, Conservation Act 1987), the Imports and Exports (Living Modified Organisms) Prohibition Order 2005 and the Cartagena Protocol. Prepare your risk assessments for food safety, apicultural industry, and trade (Agricultural Compounds and Veterinary Medicines Act 1977, the Food Act 2014 shared with Australia, and the Animal Products Act 1999), and all of these don’t necessarily align with the laws of our trading partners or the Treaty of Waitangi partnership. Created in different circumstances and time periods they have inconsistent definitions of words like genetic modification, animal, or pest too.

Tools, Outcomes and Man v Nature

The next problem we had was a bit of a strategic blunder. For Genetic Modifications (GM, and now Gene Editing - GE) we decided to regulate the tools, rather than the outcome, and now we have very different tools. We have processes that are regulated very differently, but produce the same outcome. More than that, especially with the newer ‘tools’, in some cases the ‘outcomes’ are not distinguishable from natural changes, making the regulatory provisions unenforceable. The example often provided is the absence of regulation for some ‘conventional’ plant breeding techniques, like irradiation or chemical mutagenesis, which speed up the production of new plant variants (i.e. ‘new organisms’!) that can be used for selection and cross-breeding.

For some ‘natural’ means unmodified by ‘Man’ (even if ‘Man’ is part of Nature), while other people regard ‘natural’ as something similar, or the same, as something from Nature. In Australia, Food Standards Australia and New Zealand (FSANZ) already evaluate food products using the second definition, the emphasis clearly on the product and not on the manipulation. They have so far approved soyabean, maize, canola, wheat, potato, and lucerne developed with a variety of ‘gene technologies’ conferring herbicide and pest tolerance, or enhanced product characteristics[v].

A Public ‘Licence to Operate’

The noisy actors making the more public case for a review of the regulations, to put it simply, are more concerned that we are missing an opportunity to make more money. That’s quite a different outcome, but still an outcome, and, if we can learn anything from the studies about public attitudes to genetic engineering, it’s that the outcomes matter.

The surveys undertaken come up with a far more nuanced views about GM than a simple ‘for’ or ‘against’. For example, it matters if the work is being undertaken with our Predator Free 2050 goals in mind, it matters if it’s a critical health or biosecurity issue. If we are going to review our legislation and take advantage of new technical advances that will ‘save our bees’ or ‘save our trees’, or whatever, what will matter in the new legislation is why we are changing things; what we value and what we aspire to do. Who are these new opportunities for? It’s not about the technology; it’s about whether we allow new technology to be used to perpetuate inequity across both communities and commerce, or invest it in a sustainable future fit for all of us.

Dave Black is a commercial-beekeeper-turned-hobbyist, now working in the kiwifruit industry. He is a regular science writer providing commentary on “what the books don't tell you”, via his Substack Beyond Bee Books, to which you can subscribe here.


[i] Baggie; more common in N. America, a plastic feeding bag or pouch containing liquid sugar [ii] Qiang Huanga, Patrick J. Lariviere, J. Elijah Powell, and Nancy A. Moran. Engineered gut symbiont inhibits microsporidian parasite and improves honey bee survival. PNAS 2023 Vol.120 No.25 [iii] Genetic Modification (GM) is achieved using Genetic Engineering (GE), that employs tools/techniques like Gene Editing (GE). These are used interchangeably as both nouns and verbs everywhere. Confused at all? [iv] EPA, APP203395 2018. [v] John Caradus (2022): Impacts of growing and utilising genetically modified crops and forages – a New Zealand perspective, New Zealand Journal of Agricultural Research,

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