Submission file 2 on scientific and other matters made to the New Zealand Environmental Protection Authority Decision-Making Committee for reconsideration of APP203395
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2019
Authors
Heinemann J
Abstract
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Summary: The decision reached by the DMC in May 2018 failed in my view to demonstrate proper regard for the
purpose and principles of the HSNO Act. The barriers that EPA relied upon to prevent the effects of in vitro
techniques from modifying genes or other genetic material in cells or organisms are not reliable and do not
exist in all eukaryotes that may be exposed. Furthermore, the effects on prokaryotes were not even
considered despite the certainty of exposure when this technology is used outside of contained facilities.
The interpretations of key terms from the HSNO Act explicitly or implicitly used by staff and the DMC were
inconsistent with previous use by EPA or disconnected without good reasons from formal uses that are in
relevant international agreements. Moreover, the decision was taken in a short timeframe with limited
input from other government agencies and no input from the public or specialist scientific community.
While that may have been EPA’s legal prerogative, as laid out in paragraph 18 (below) the decision-making
process did not reflect the seriousness of the decision.
External treatments of cells and organisms with dsRNA is an important research technique and valuable
biotechnology. In time external treatments of organisms with dsRNA in the out-of-doors may prove to be
effective, provide benefits and may be done at acceptable risks to human health and the environment.
Regulation on a case-by-case basis will help to accomplish this. However, ensuring New Zealand the benefits
of responsible and safe biotechnological applications is not what this EPA decision will achieve.
Citation
Heinemann J (2019). Submission file 2 on scientific and other matters made to the New Zealand Environmental Protection Authority Decision-Making Committee for reconsideration of APP203395.
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ANZSRC fields of research
Field of Research::10 - Technology::1002 - Environmental Biotechnology::100206 - Environmental Molecular Engineering of Nucleic Acids and Proteins
Fields of Research::41 - Environmental sciences::4104 - Environmental management::410402 - Environmental assessment and monitoring
Fields of Research::41 - Environmental sciences::4103 - Environmental biotechnology::410302 - Biological control
Fields of Research::31 - Biological sciences::3105 - Genetics::310509 - Genomics
Fields of Research::31 - Biological sciences::3101 - Biochemistry and cell biology::310113 - Synthetic biology
Fields of Research::41 - Environmental sciences::4104 - Environmental management::410402 - Environmental assessment and monitoring
Fields of Research::41 - Environmental sciences::4103 - Environmental biotechnology::410302 - Biological control
Fields of Research::31 - Biological sciences::3105 - Genetics::310509 - Genomics
Fields of Research::31 - Biological sciences::3101 - Biochemistry and cell biology::310113 - Synthetic biology