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.

Overall comment

The most obvious overall consideration that is absent from the 5 topic areas is a review of the precision of the scientific basis of genetic modification and our understanding of the process of genetic expression and control. There are numerous statements by scientists about the imprecision of genetic manipulation and the consequent difficulty in tying down unintended or pleiotropic effects, particularly in the areas of, for example, post transcriptional control of gene expression, the role of non-coding RNAs. This is, at least at a technical level, one of the key uncertainties that gives a legitimate basis to public concern over uncertain and unforeseen risks. What is missing is the linkage between the inevitable uncertainties that this introduces and the impact for policy frameworks. Such a review would impact on the environmental harm, food safety, future developments and regulatory process areas.

One review of this was done by Plant Breeding International:
de Visser, E.H. Nijhuis, J.D. van Elsas and T.A. Dueck Crops of Uncertain Nature?: Controversies and Knowledge Gaps Concerning Genetically Modified Crops: An Inventory, 1999. Wageningen, Netherlands

We are unaware of any others.

A further element of such a review would be that of unpredictable behaviour observed in existing crop usage or new molecular data on the GM event that only comes to light after approvals have been given. To our knowledge virtually none of this exists in the peer-reviewed literature but to suggest this is not considered would be absurd. Britain has experienced heavy flooding in early January 2003 but this has not found its way into the peer-reviewed literature; limiting a review to only peer-reviewed journal articles would imply that 'scientifically' such flooding never happened.

Dr. Douglas Parr
Chief Scientific Adviser
Greenpeace UK
www.greenpeace.org.uk