Agriculture Reference
In-Depth Information
Policy Challenges Posed to the EU
Pharm crop operations will be similar to production facilities and will
primarily be designed for maximum yield of intact proteins. Risk char-
acteristics are likely to differ from first-generation GM crops, and risk
mitigation requirements will become a focal issue. These specifics are
likely to pose a number of challenges to policy makers and regulators in
the EU. 47
First, there is the need to thoroughly review and update current risk
assessment approaches and guidelines established for first-generation
GM crops. Possible challenges for risk assessment approaches include
the applicability of the concepts of substantial equivalence and familiar-
ity, discussed in Chapters 3 and 4, which play important roles for struc-
turing risk assessment of current GM crops. Familiarity, for instance,
also refers to environmental and agricultural experiences gathered with
the host crop in conventional agriculture. 48 Familiarity might however
be less important if the crops have been subjected to multiple and
perhaps more substantial changes of genotype (see above) or if non-
food/nonfeed plants with which there is less experience are used, such
as safflower in Canada. Likewise, “substantial equivalence” understood
as referring to the degree of compositional, morphological, and agro-
nomic differences between the GM crop and its conventional counter-
part might no longer be considered appropriate to guide risk assessment.
Furthermore, with PMPs another step might be added to risk assess-
ment: to thoroughly assess and to advise on the appropriate level of
47 A. Sauter & B. Husing, Gr une Gentechnik - Transgene Pflanzen der 2. und 3. Gen-
eration (2006), available at www.tab.fzk.de/de/projekt/zusammenfassung/ab104.pdf;
A. Sp ok & M. Klade, Molecular Farming. Novel Challenges for Risk Manage-
ment and Legislation (Office of Technology Assessment at the German Parliament
2005).
48 K. Barret & E. Abergel, Genetically engineered crops. Breeding familiarity: environ-
mental risk assessment for genetically engineered crops in Canada. 27 (1) Science and
Public Policy 2-12 (2000).
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