GE Wheat trial by Rothamsted Research

Submission on Rothamsted Research application for consent to release genetically modified wheat in the UK

Publication type:

7 pages

I thus wish to register my objection to the field trial (environmental release) planned for 2012 and 2013 and wish to provide the regulator with my points of concern, based on my knowledge and experience as a biologist and geneticist and on my expertise in risk assessment of GMOs, due to which I currently serve as a member of the ad hoc technical expert group (AHTEG) on risk assessment and risk management of LMOs under the Cartagena Protocol on Biosafety.

Main points of concerns are:

  1. Underlying hypothesis not developed or robust enough and also disputed by recent findings, as to scientifically require or warrant an outdoor step (which introduces more variables and the risks).
  2. Lack in molecular and phenotypic characterisation.
  3. Presence of antibiotic resistance marker genes.
  4. Lack of proper safety assessment concerning human and animal health - as risks cannot be estimated without data, and no guarantee can be given that no escape or mix-up by any route will take place.
  5. Could the use of the GM wheat increase rather than reduce pesticide applications?
  6. Risk assessment provided does not cover all potential hazards (step 1) and fails in a number of cases/points to fully elaborate steps 2 and 3, thus arriving at an underestimation of the overall risks (here step 6).
  7. Lack of uncertainty analysis throughout the document, including the risk assessment.

Some of the point are expanded in the document.

In Conclusion: I have wanted to highlight and list a few points that elucidate the shortcomings of the data provided and the risk assessment carried out and provided. These, in my view, give evidence to the necessity to do further indoor trials, reassess the hypothesis and test for health consequences before any open environmental release should or could take place. It should further be deliberated whether the approach taken to address the aphid problem does not in itself cause new problems.

Submission regarding Reference number 11/R8/01: GM Wheat

July, 2011

Dr. Ricarda A. Steinbrecher