Leaking From The Lab

9. RECOMMENDATIONS

In taking decisions about GMMs - and given the uncertainties involved and the potential for serious irreversible harm - a precautionary approach must be adopted

There should be no releases of living GMMs into the environment

To address the issues identified in this report, the following measures should be included in the new regulations.

More information must be obtained:

The HSE must backdate the public register to pre-1992 to include all centres registered as using GMMs. Information on the commercial use of GMMs must be collected and include data on the products manufactured from them. The proposed interim arrangements should be extended to include this.

Annual returns must be continued and extended to include lists of all risk assessments undertaken to enable scrutiny of the evaluations conducted by users of GMMs.

The public register must be made available via the Internet, should include a search engine and be comprehensive. Information must include details of the organisms involved, how they are modified, why the modification is being undertaken, how the risk assessment has been arrived at, the dates use started and finished, what precautions are being taken to prevent release, and what monitoring takes place.

Risk evaluations must be improved:

In taking decisions about GMMs - and given the uncertainties involved and the potential for serious irreversible harm - a precautionary approach must be adopted.

Plasmids and naked DNA should be brought within the scope of the regulations.

Users must be required to present a worst case scenario when notifying the use of a GMM to reveal the full extent of the uncertainties.

The requirement for physical barriers to the release of GMMs should remain, together with the presumption (for all classes of GMMs) that there should be no releases of living GMMs into the environment. No discharges should be allowed unless reliable monitoring is available, a detailed risk assessment is presented which takes into account the local environment and the use of other GMMs, and a full justification for the need to discharge live GMMs or intact DNA is given.

Provisions for liability for any environmental harm arising from the use of GMMs should be included in the new regulations.

Pollution from GMMs must be monitored, policed and appropriate controls enforced:

The development of effective monitoring techniques must be a priority.

A legal system specifying the levels of GMM pollution that can be released in waste should be established. This would be consistent with other approaches to pollution control (e.g. chemicals), allow for prosecutions if breaches arise and drive a proper monitoring system.

The Environment Agency should be made responsible for independent monitoring of environmental releases of GMMs via waste streams and air and for the policing of discharges.

In addition, users of GMMs must be required to monitor to verify containment procedures and to implement systems for the detection of sudden leaks.

There must be increased investment in policing and enforcement.

Refusal to disclose information about releases of GMMs to the environment on the grounds of commercial confidentiality must not be allowed under any circumstances

Openness and transparency of the regulatory system must be established:

Refusal to disclose information about releases of GMMs to the environment on the grounds of commercial confidentiality must not be allowed under any circumstances. Users must supply details of any GMMs (including the species and how and why they have been genetically modified), the levels of release to the environment in waste and the monitoring systems in place.

Representation of public interest groups should be increased on the advisory committees, meetings should take place in public, and annual reports summarising each year’s activities should be produced.

There should be greater public involvement in decision-making about the use of GMMs.

APPENDIX 1: ADVISORY COMMITTEE MEMBERSHIP

Members of the Advisory Committee on Genetic Modification (May 1999)

Professor K Davies	(Chairman)	University of Oxford
Professor J Beringer		University of Bristol
Professor T M Roberts		Institute of Terrestrial Ecology
Mr S Vranch		Jacobs Engineering
Mrs D Carey	(TUC nominee)	Institute of Virology
Dr J Kinderlerer	(TUC nominee)	University of Sheffield
Dr R Owen	(TUC nominee)	TUC Medical Advisor
Mr R Spiller	(TUC nominee)	MSFU
Dr K Edwards	(CVCP nominee)	University of Leicester
Dr M Gale	(Research Councils’ nominee)	John Innes Centre
Professor S Hughes	(CBI nominee)	University of Exeter

Members of the Technical Sub-Committee of the Advisory

Committee on Genetic Modification (May 1999)

Mr S Vranch	(Chairman)	Jacobs Engineering
Professor D Young		Imperial College
Dr J Marshall		University of Oxford
Mr S Eley		Defence Evaluation and Research Agency
Professor A Minson		University of Cambridge
Dr M Mackett		Christie Hospital, Manchester
Dr P Hirsch		Institute of Arable Crops Research
Dr P Minor		National Institute for Biological Standards and Control
Professor D Onions		Glasgow University
Professor D Jeffries		St Bartholomew’s Hospital
Dr R Randall		University of St Andrew’s
Dr I Cooper		Institute of Virology and Environmental Microbiology
Mr J Thorley	(CBI nominee)	Consultant
Dr J Kinderlerer	(TUC nominee)	University of Sheffield