Greenpeace is aware of other submissions, specifically those of Genewatch, outlining a number of key issues that need to be addressed. We agree that these are key issues and would like to put forward the following observations as additional comments on each of the areas.

Issues that should be additionally considered as "key issues"

Definition of harm. The debate is meant to be 'driven by public concerns' and one of the concerns often raised is that of contamination of wild flora or non-GM food by GM constructs. A decision has been taken within the current scientific assessment process that this gene flow is not a problem, but this is not necessarily a widely shared value-judgement. A prior question to be determined is whether society would see this gene flow as wrong or harmful in itself. This would provide the framework for scientific review.

What could be the impact of root exudates from GM crops and changes to soil metabolism as a result of genetic modification? What do we know about the impact of GM processes on the chemistry, biochemistry and ecology of the rhizoshpere? How can predictions be robust given our low level of knowledge of the soil microbiology?

What would be the impact of these changes on watercourses near where such GM crops could be grown?

Is there an adequate knowledge base to assess the impacts on soil of commonly used agrochemicals in association with GM crops?

What will be the further impacts on agricultural management if frequent applications of herbicide on GMHT crops accelerate resistance development?

References

Intrinsic Value and Integrity of Plants in the Context of Genetic Engineering, Proceedings of an Ifgene workshop on 9 - 11 May 2001; Eds Heaf, D and Wirz, J.

Houlder, V. (1999). Advisor rejects official findings, Financial Times, 20 January 1999, p.12

Pace, N.R. (1997). A molecular view of microbial diversity and the biosphere. Science 276, 734-740; Hugenholtz, P. and Pace N.R. (1996). Identifying microbial diversity in the natural environment: a molecular phylogenetic approach. Trends Biotechnol. 14, 190-197.

Donegan K.K., Palm, C.J., Fieland, V.J., Porteous L.A., Giano, L.M., Schaller, D.L., Bucao, L.Q. and Seidler, R.J. (1995), Appl. Soil Ecol. 2:111-124

DiGiovanni, G.D., Watrud, L.S., Seidler, R.J., Widmer, F. (1999) Microbial Ecology 37(2) p.129-139

Saxena, Flores and Stotsky (1999) 'Insecticidal toxin in root exudates from Bt corn' Nature 02.12.99

Ecostrat, 2001. Bt proteins in soils: Is enough known to assess the impact of Bt plants on soil ecosystems? Report to Greenpeace International, Amsterdam ,May 2001

Ahmad I. and Malloch D. (1995). Interaction of soil microflora with the bioherbicide phosphinothricin. Agriculture, Ecosystems and Environment 54 pp 165-174. Elsevier Science.

Giovani G.D. et al. (1999). Comparison of parental and transgenic alfalfa rhizosphere bacterial communities using BiologGN metabolic finger-printing and enterobacterial repetitive intergenic consensus sequence-PCR (EPIC-PCR). Microbial Ecology 37: pp129-139.

Seidler R.J. (1994). Evaluation of methods for detecting ecological effects from genetically engineered microorganisms and microbial pest control agents in terrestrial systems. In Environmental Gene Release, Eds M.J.Bazin and J.M.Lynch. OECD/Chapman Hall, London.

Dr. Douglas Parr
Chief Scientific Adviser
Greenpeace UK

www.greenpeace.org.uk