ENSSER comments on EFSA Draft guidance document for the environmental risk assessment of genetically modified plants

 29 Apr 2010 – The European Network of Scientists for Social and Environmental Responsibility (ENSSER) was founded with the aim to advance science and research for the protection of the environment, biological diversity and human health against negative impacts of new technologies and their products. Consequently, ENSSER promotes the critical European and international discourse on new technologies, their impacts and their regulation. One specific aim of ENSSER in this context is to improve the quality of basic and regulatory science used in the risk analysis of existing and emerging technologies and their products such as genetically modified organisms, chemicals, food technologies, geo-engineering, nanomaterials, and synthetic biology, including the risk of their military use.

Several of ENSSER’s members are participating in GMO risk research, assessment and communication since many years. They also participate in the current debate within the EU, but also within the international Cartagena Protocol on Biosafety, how to develop GMO and specifically GM plant risk assessment to base it on sound methodology that aims at effectively minimising or avoiding risks for the environment and human health. The ENSSER GMO Consultation Task Force was formed to study the draft guidance document and to comment on its various sections. The following pages contain the ENSSER input which has been submitted on April 29 2010 to the EFSA. ENSSER will continue to participate in this process and to inform the public about outcome of the consultations.

In general, the guidance document represents a considerable progress in moving the risk assessment towards the current state-of-the-art of scientific investigation – with exception of the parts on problem formulation and monitoring for which great room for improvement remain. What would improve the overall approach is an introductory development of a system of hypotheses of potential effects departing from the genetic modification through all levels of biotic organisation as a starting point for the subject specific categories explained in Chapter 3. An overall elaboration of relevant cause-effect chains in which the GM organism is involved would make all subsequent steps more targeted. However, also a number serious scientific deficits remain that we detail below. ENSSER considers particularly grave a number of serious cases of selective citing of scientific publications and the type and kind of studies that were favoured over others. We strongly urge EFSA to correct this serious deficit as it will jeopardize the entire GD and even overrule the recognized improvements.