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.

• In what way should judgements about harm and adverse impacts be made in the scientific risk assessment process, given the thorough documentation of how such judgements are made which involve socio-political elements?
• Is it possible to make this process of assumptions and judgement more transparent and make them open to public scrutiny and challenge?

References

Levidow and Carr, 2000. Unsound Science? Trans-Atlantic Regulatory Disputes over GM Crops

International Journal of Biotechnology 2(1/2/3): 257-273

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