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Name: Jean Saunders Location: Faringdon Date: 11/02/03
Topic 1: Regulatory process Topic 2: Topic 3:
Topic 4: Topic 5:  
Title:
Black holes in regulations
Full comment:

One of our major concerns regarding the regulations to control GMO releases, to assess the implications of novel proteins in the diet and the impact of management of farming GM crops, is the "black hole" in the legislation where considerations do not fall under one regulatory body. These "black holes" need to be identified and some sort of risk assessment should be conducted.

The assessment of GMOs on a case by case basis is a good example of creating a "black hole" void where the potential to do harm might slip through un-noticed by any regulatory control. For example, with regard to cultivating a promiscuous crop that also has wild relatives there is no assessment at any stage of the impact of multiple gene stacking of transgenic material. The costs of controlling the GM hybrid and assessing the potential impact on health and the environment, will increase as the complexity of the GMO builds up. So too are the dangers created by the new super crop that may have new unintended and unforeseen characteristics. There is potential for a GM crop to exhibit multiple herbicide tolerance, insecticide producing genes, fungal & viral resistance as well as industrial and pharmaceutical use genes. The possibilities are endless. The combination impact of GM hybrids that will not have been assessed in their own right by any regulatory body is a matter of considerable concern.

We cannot point you to any research or references on this subject, as we believe that none has been carried out.

Background: Swindon Friends of the Earth

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