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.

Key issues to be evaluated

• What limitation on scientific practice and potential GM products is the international intellectual property rights regime having?
• What is the driving interest behind the majority of research funding? What are the funders, in the vast bulk of cases, looking to get out of GM research and how will this affect and limit the actual applications that appear?
• How adequate is the existing level of scientific safety assessment, and even the proposed new tools, to future GM products proposing to reorganise the biochemistry of crop plants?
• How good is the basic nutritional and biochemical science on the topic of specific chemical enhancement? One study looking at Vitamin C showed that although this vitamin is an anti-oxidant people were more likely to develop cancer as a result of consumption of large quantities, not less

References

For a discussion on how patents limit research in an article otherwise enthusiastic about the potential of Genetic engineering see Conway, G., and Toenniessen, G., Nature 402 Supplement, 2 Dec 1999, p.C55-C58)

Barling , D. and Henderson R. (2000). Safety First? A map of public sector research into GM food and food crops in the UK, Discussion Paper 12, Centre for Food Policy, Thames Valley University.

Lee, S.H. , Oe, T., Blair, I. A. (2001). Vitamin C-induced decomposition of lipid hydroperoxides to endogenous genotoxins . Science 292, p.5524.

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