TWN Info Service on Biosafety
6 January 2023
Third World Network
www.twn.my
Dear Friends and Colleagues
New Genomic Techniques Must Be Assessed According to the Precautionary Principle
An advisory report on the risks of new genetic engineering commissioned by the Federation of German Consumer Organisations (vzbv) concludes that new genomic techniques (NGTs) e.g. CRISPR/Cas, have huge potential to alter the genome but this potential does not easily translate into real benefits.
Technology assessments should be carried out in accordance with the precautionary principle and, at the same time, evaluate the actual need to apply the technology and also to consider alternatives. A comprehensive and prospective technology assessment is essential prior to use in an agricultural setting in order to address systemic risks to biodiversity, socio-economic impacts and effects in regard to sustainability.
According to the report, all NGT-GMOs need to undergo a mandatory approval process before being released into the environment or brought to market.
We reproduce below the Abstract of the report, which includes its recommendations. The full report is available at: https://www.vzbv.de/sites/default/files/2022-11/vzbv-report_final_final.pdf
With best wishes,
Third World Network
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NEW GENOMIC TECHNIQUES (NGTS): AGRICULTURE, FOOD PRODUCTION AND CRUCIAL REGULATORY ISSUES
Christoph Then
Testbiotech
https://www.vzbv.de/sites/default/files/2022-11/vzbv-report_final_final.pdf
September 2022
Abstract
This report was compiled to answer questions raised by the Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband, vzbv) in regard to EU regulation of new genomic techniques (NGTs, also known as new genetic engineering or genome editing). For this purpose, it provides an overview of several aspects of NGTs which are especially relevant in the context of agriculture and food production.
The questions posed by vzbv arose from EU Commission initiatives to change the current EU GMO regulation. vzbv’s most important (overarching) question is: “What are the crucial requirements for an ideal regulation of NGTs from the perspective of the consumers and the protection goals regarding health, the environment and animal welfare?” Details of the technical characteristics as well as possible NGT applications in agriculture and food production are provided in the report, including several examples. It further examines risks and hazards in regard to plants, animals and microorganisms. Finally, it includes an overview of requirements for the regulation of NGTs and the assessment of associated risks.
The report presents the following conclusions and answers:
EU regulation of NGTs should prevent:
› uncontrolled marketing or releases of NGT-GMOs into the environment;
› damage to biological diversity, ecosystems and agriculture;
› health hazards from being introduced unnoticed into the food system where they might accumulate;
› data needed for risk assessment by independent experts being treated as confidential business information;
› contamination of organic and other food or seed production systems that exclude the use of genetically engineered organisms.
EU regulation of NGTs must ensure:
› a case-by-case risk assessment and an approval process for each NGT ‘event’, including taking accumulated effects into account;
› the further development of data requirements, guidelines and methods of risk assessment to achieve the highest safety standards, including cut-off criteria in cases where uncertainty is too great;
› the availability of information to track and trace the NGT-GMOs and food products derived thereof;
› measures are in place to prevent the uncontrolled spread of NGT-GMOs in the environment;
› consumer choice and coexistence with organic and GE free food production;
› animal welfare is fully respected at all stages of the NGT processes;
› prospective and comprehensive TA is carried out before NGTs are brought to market.
Consequently, all NGT-GMOs need to undergo a mandatory approval process before being released into the environment or brought to market. Risk assessment should (as currently requested by EU legislation) aim to identify the intended and unintended changes resulting from the technical processes of genetic engineering and should evaluate their potential to cause adverse effects on human health and the environment. The differences between conventional breeding and NGTs can be easily overlooked, but can have serious consequences. In this context, direct and indirect effects which may be immediate, delayed or cumulative have to be taken into account.
Furthermore, a comprehensive and prospective technology assessment is essential prior to use in an agricultural setting in order to address systemic risks to biodiversity, socio-economic impacts and effects in regard to sustainability. There are no mechanisms in place and no data available to distinguish ‘empty promises’ from ‘real benefits’. In summary, NGTs, e.g. CRISPR/Cas, have huge potential to alter the genome but this potential does not easily translate into real benefits. Technology assessment should be carried out in accordance with the precautionary principle and, at the same time, evaluate the actual need to apply the technology and also to consider alternatives that could be made available. The single overarching principle should be to generally restrict releases of NGT-GMOs into the environment to avoid, e.g. passing potential tipping points leading to irreversible damage in ecosystems.