Submission file 2 on scientific and other matters made to the New Zealand Environmental Protection Authority Decision-Making Committee for reconsideration of APP203395

Simple item page
dc.contributor.authorHeinemann J
dc.date.accessioned2020-01-07T01:13:42Z
dc.date.available2020-01-07T01:13:42Z
dc.date.issued2019en
dc.date.updated2019-11-01T02:58:23Z
dc.descriptionSummary: 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.en
dc.identifier.citationHeinemann 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.en
dc.identifier.urihttp://hdl.handle.net/10092/17811
dc.language.isoen
dc.subject.anzsrcField of Research::10 - Technology::1002 - Environmental Biotechnology::100206 - Environmental Molecular Engineering of Nucleic Acids and Proteinsen
dc.subject.anzsrcFields of Research::41 - Environmental sciences::4104 - Environmental management::410402 - Environmental assessment and monitoringen
dc.subject.anzsrcFields of Research::41 - Environmental sciences::4103 - Environmental biotechnology::410302 - Biological controlen
dc.subject.anzsrcFields of Research::31 - Biological sciences::3105 - Genetics::310509 - Genomicsen
dc.subject.anzsrcFields of Research::31 - Biological sciences::3101 - Biochemistry and cell biology::310113 - Synthetic biologyen
dc.titleSubmission file 2 on scientific and other matters made to the New Zealand Environmental Protection Authority Decision-Making Committee for reconsideration of APP203395en
dc.title.alternativeSubmission on scientific and other matters made to the Decision-Making Committee for reconsideration of APP203395en
dc.title.alternativeShould dsRNA treatments applied in outdoor environments be regulated?en
dc.typeReportsen
Files
Original bundle
Now showing 1 - 1 of 1
Thumbnail Image
Name:
submission file 2 to dmc.pdf
Size:
1.69 MB
Format:
Adobe Portable Document Format
Download
Collections
Science: Reports