Protest (2) against GM potato application by BASF
Press Notice from GM Free Cymru Date: 19 October 2006 14:41:27 BDT
To: gm-regulation@defra.gsi.gov.uk
APPLICATION FOR A PART B CONSENT FROM BASF PLANT SCIENCE TO RELEASE GENETICALLY
MODIFIED POTATOES WITH IMPROVED RESISTANCE TO Phytophthora infestans
APPLICATION REFERENCE: 06/R42/01
BASF Plant Science has applied to Defra for consent to perform a deliberate release of genetically modified organism for research and development purposes.
Dear GM Unit,
We have been looking at information gathered by Anthony Jackson of the Munlochy GM Vigil relating to the proposed monitoring and reporting requirements outlined by ACRE for the growing of this GM potato crop. We dare say that you have this on file, but we append it below, just in case you have not seen it.
We had not previously homed in on these differences, but they do not surprise us, given ACRE's long history of complacency and connivance in the unauthorised release of GM materials into the environment.
We are appalled at what Anthony Jackson has discovered in this piece of careful research, and we congratulate him for it.
The Irish EPA, which does not have a great reputation for caution when it comes to GM matters, placed requirements on BASF which the company obviously found unacceptable; but when one looks at them they are eminently sensible, and not at all disproportionate to the risks involved. These risks are substantial, as we indicated in our earlier submission.
We therefore protest on the grounds that there are at present totally unacceptable proposals in place for the control and containment of the proposed GM releases into the environment. We believe that it is incumbent upon ACRE and DEFRA to put in place requirements and conditions at least as rigorous as those imposed in Ireland before this application should be given a moment's thought.
Please register this second protest, send us an acknowledgement, and keep us informed of the progress of this application.
Yours sincerely,
Dr Brian John
GM Free Cymru
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Appendix:
DIFFERENCES BETWEEN ACRE AND THE IRISH EPA RELATING TO MONITORING, REPORTING,
LIABILITY ETC
EPA: The GM potato lines can be planted in the years 2006 to 2010 with planting taking place during April/May and harvesting in October of each year. Each experimental site must be monitored for a minimum of four (4) years post planting and the site planted in 2010 must be monitored until the Autumn of 2014.
ACRE: The applicant proposed to monitor volunteer potatoes at release sites until none had been found for two years. ACRE was content with this proposal and advised that BASF should provide details of groundkeeper and volunteer presence in annually submitted post-release monitoring reports.
EPA:
Condition 5 Management of the Field Trial
(i) The notifier shall provide detailed written instructions and procedures on trial management, operations and maintenance for the trial site for each growing season, which must include information on the following:
a. site plan,
b. methods of planting, harvesting and trial termination,
c. relocation (within the designated field) in years 2-5,
d. methods to minimise seed dispersal from the experimental
site,
e. storage (before planting and post harvest),
f. monitoring plan for the duration of the trials
g. monitoring for groundkeepers and True Potato Seed (TPS),
h. transportation off-site,
i. site security and
j. emergency plans.
Instructions and procedures as outlined above must be made available to and used by the staff involved in the execution of the trial. A copy of the instructions and procedures must be forwarded to the Agency for agreement at least one week in advance of planting.
ACRE: do not as yet seem to demand this level of information.
EPA: (ii) The trial crop must be examined on a weekly basis during the growing season. Any tubers exposed above the soil surface must be removed or covered as soon as practicable.
ACRE: do not as yet seem to demand this level of oversight or safety.
EPA:
(iii) Any berries formed on any of the potato plants must be removed, before
destruction of the potato haulms by spraying, and stored in a safe manner
until they are transported off-site as per condition 5 (v).
ACRE: do not as yet seem to demand this level of safety.
EPA:
(iv) All tubers must be removed from the soil surface post-harvest to
prevent possible dispersal to areas outside the trial area. A number of harvest
cultivations of the trial site should be carried out
immediately after the initial harvest to minimise the number of tubers
remaining in the soil.
(v) All tubers (GM and non-GM) including any excess tubers from the plantings and berries from the experimental site must be collected in labelled bags and placed in labelled sealed containers before being transported outside of Ireland. The chopping of potato tubers on site is prohibited.
ACRE:
ACRE concluded that once the GM potatoes had been harvested on each trial
site, the ground should be left fallow to encourage the germination of true
potato seed. This strategy also enables the identification and early treatment
of potato groundkeepers and volunteers by hand-pulling before viable tubers
have set or by herbicide treatment with a systemic herbicide. The committee
also advised that the land should not be ploughed after the potato trial harvest
but that shallow tillage should be used on the release site for the next 2
years.
The company proposes to chop or heat-treat the potato tubers following
harvest and removal to an off-site location and ACRE was content with this
proposal. The company also plans to leave parts of the potato plants other
than
tubers on the soil surface at each site to decompose. ACRE was content with
this
proposal if the fallow cropping and herbicide regime proposed by the
committee is followed.
EPA:
(vi) All GM potatoes must be stored both prior to planting and after harvest
in a secure place separate from any non-GM commercial potatoes. An accurate
detailed record must be maintained at the storage location of all containers,
used for the storage of harvested tubers from the experimental site.
(vii) The time and date of the transfer off site (outside of Ireland) of all
potatoes (GM, non-GM and berries) from the experimental site must be
documented and maintained by the notifier. The details of such records shall
be
submitted to the Agency within one week of the transfer off site.
ACRE: do not as yet seem to require this level of oversight and information
EPA:
(viii) All farm machinery and equipment must be thoroughly cleaned prior to,
and after, sowing, field operations and harvesting. All vehicles used for
the transport of all potatoes (GM, non-GM and
including berries) must be checked to ensure that spillage does not occur
during transport to storage facilities and during export outside of Ireland.
ACRE: do not as yet seem to require this level of safety.
EPA:
(ix) A spring cereal crop must be planted in the trial area in the year
after each potato trial. All potato tubers arising during this cultivation
must
be destroyed through the application of a
commercially approved herbicide.
(x) The trial site must be defined and measured in respect of fixed points
in the environment, such that it can be identified in subsequent years.
Details of this measurement must be recorded and
a copy of the record provided to the Agency at least one week prior to
planting.
(xi) Each trial site must be monitored for at least four years post harvest
for any sign of emergence of groundkeepers or True Potato Seed (TPS), and for
longer periods if so required by the Agency should groundkeepers or TPS
persist. The post-release monitoring strategy, which includes both a
case-specific and a general surveillance component as outlined in Section G
of the
notification and subsequent information submitted to the Agency on 22nd March
2006,
must be implemented.
ACRE:
The applicant proposed to monitor volunteer potatoes at release sites until
none had been found for two years. ACRE was content with this proposal and
advised that BASF should provide details of groundkeeper and volunteer presence
in annually submitted post-release monitoring reports.
EPA:
(xii) A separation distance of 40 metres must be used to separate the
experimental trial from any commercial potato planting including organic production
that might take place in or around the trial area. The potato trial area in
year 2 and subsequent years shall have a 6 metre separation border,
separating the new trial site from the previous trial site.
ACRE:
BASF has proposed a separation distance of 20 metres and ACRE considers that
this distance is sufficient to ensure that potatoes containing GM events
have an extremely low probability of entering the food chain.
EPA:
(xiii) The planting of commercial non-GM potato crops in the trial area is
prohibited for a minimum of 4 years after the trial has concluded. The
planting of a seed potato crop in the experimental site area is prohibited
for a
minimum of 6 years after the trial has concluded.
ACRE: do not as yet seem to demand this level of safety.
EPA:
(xiv) Animal feeding studies based on EFSA guidance (Guidance document of
the Scientific Panel on Genetically Modified Organisms for the risk assessment
of genetically modified plants and derived food and feed, the EFSA Journal
(2004) 99, 1-94) and other appropriate International standards including the
publication by Prescott et. al. 2005, J. Agric. Food Chem. 2005, 9023-9030,
must be carried out prior to second year’s planting using tubers from
the first
year's GM potato harvest at this site. The results of the animal feeding
studies shall be forwarded within one month of completion to the Agency.
(xv) The GM and non-GM potatoes from this field trial shall not be used for
food or feed other than in the context of the animal feeding trials referred
to in (xiv) above.
ACRE: do not as yet seem to demand this level of safety.
EPA:
(xvi) The trial sites must be secured adequately to prevent, minimise and
reduce ingress by small and large animals and unauthorised access to the site.
Details of the measures to be taken are to be agreed in writing by the Agency
prior to planting.
Should it prove necessary, the notifier shall carry out the emergency plans
outlined in Section G of the notification.
(xvii) The notifier shall provide details of measures, to be agreed in
advance by the Agency, to protect tubers (during planting, growing and harvesting)
from possible bird intrusion at the experimental
site.
ACRE: concluded that fencing of the trial site for this purpose should not be required.
EPA:
Condition 6 Reporting to the Agency
The Agency shall be informed in writing of the planting and harvesting dates
for each planting season at least one week prior to planting and harvest.
A copy of the experimental plan for each site shall also be sent (one week
prior to planting) to the Agency indicating the location of the GM tubers in
the experimental plots.
A report on the monitoring activities outlined in the notification, trial
results and the notifier's conclusions must be submitted to the Agency on a
monthly basis during the growing season for 2006,
2007, 2008, 2009, 2010 up to and including 2014 (post release monitoring)
and summarised in an annual report by 31st December of each calendar year.
For
the 2nd, 3rd and 4th year monitoring
programme on sites that were planted with GM potatoes, a report must be sent
in the Spring, Summer and Autumn of each year.
ACRE: as yet do not seem to require this level of information.
EPA:
Condition 7 Provide Detection method for identification of the GM potatoes
Prior to planting the notifier shall provide a validated protocol for the
identification of the GM potato plants (leaf and tuber) based on conventional
PCR. All stages of the procedure including initial sample preparation and DNA
extraction in this protocol of detection shall be included. The protocol
shall also include a species specific endogenous control procedure for
conventional PCR. The protocol should be fully documented in standard operating
procedure format to ensure consistent application so that a laboratory can
easily
replicate the exact procedure used. Refer to ISO 17025 for the type of
information that should be included in such a detection method. The notifier
must
provide positive and negative control samples if requested by the Agency.
ACRE: do not as yet seem to demand this level of information
EPA:
Condition 8 Sampling the trial site.
Leaf or tuber tissue may be collected from the trial site at any time post
planting by the Agency, or its Agent, in order to verify that released potato
lines carry the t-DNA described in the notification. Any costs incurred by
the Agency for this testing will be charged to the notifier. The Agency, or
its
Agent, shall be allowed to take other samples from the experimental site for
the purpose of post release monitoring.
ACRE: do not as yet seem to demand these powers or any costs recovered from
BASF.
EPA:
Condition 9 Post-release Monitoring studies connected the GM potato trial
site
Post release monitoring studies, outlined below, shall be carried out by an
independent contractor (to be agreed by the Agency) on behalf of the
notifier. All costs incurred in carrying out these studies will be borne by
the
notifier. This monitoring is in addition to the monitoring plan detailed in
Section G of the notification and the further information submitted to the
Agency
on 24th February 2006. The studies shall include:
Measurement of indicators of biodiversity (to include a baseline
comparision) that might be affected by the deliberate release (direct or indirect,
immediate or delayed) both above and below ground (e.g., the potential effects,
both positive and negative, of the GM potatoes on beneficial soil microbes).
Potential pollen flow to adjacent crops, e.g., planting both male sterile
and fertile potato bait lines at different distances around the perimeter of
the GM trial for each year of the trial. Berries that
form on any bait plant shall be tested for the presence of viable true
potato seed. Any resulting seedlings shall be analysed for the presence of
the
transgene.
The potential for the GM tubers to persist both inside and outside the agricultural system over a period of 4 years.
Plans for these studies must be submitted to, and agreed in advance by, the
Agency prior to planting. Results of these studies shall be sent to the
Agency within one month of completion. The results of these studies will be
made
publicly available.
ACRE: do not as yet seem to demand this level of monitoring, information or
safety.
ACRE: do not as yet seem to demand associated costs to be recovered from
BASF.
EPA:
Condition10 Charges for carrying out site inspections, auditing & monitoring
The company shall pay the Agency a contribution of [Euro]55,506.00 per year
(2006-2010) and a total of [Euro]3,600.00 per year for the years 2011-2014.
The amount for 2006 shall be paid within one month of issue of this consent
and by January 31st in subsequent years.
ACRE: do not seem to require BASF to cover these costs.
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Source: Munlochy GM Vigil