Summary of issues raised in submissions received from prescribed experts, agencies and authorities1 on the consultation RARMP for DIR 092
The Regulator received several submissions from prescribed experts, agencies and authorities on the consultation RARMP. All issues raised in submissions relating to risks to the health and safety of people and the environment were considered in the context of the currently available scientific evidence that was used in finalising the RARMP that formed the basis of the Regulator’s decision to issue the licence. Several submissions received raised issues relating to risks to the health and safety of people and the environment as summarised below.
| Summary of issues raised | Comments |
|---|---|
| Is there evidence that the applicant's proposal to clean planting equipment with 1% sodium hypochlorite and 70% ethanol effectively removes all GM seed? | The applicant did not provide evidence of the efficacy of their proposed cleaning method, however it is considered unlikely to render wheat seed unviable unless treatment was prolonged. The proposed licence conditions did not specify a method of cleaning equipment, but rather the outcome which must be achieved - that the GMOs be removed from equipment and destroyed. |
| Supports the applicant's proposals to cover the location with bird-proof netting to further prevent the dispersal of seeds from the trial site and to maintain a 500 m isolation zone to separate the GM wheat lines from non-GM wheat breeding lines. | The control measures proposed by the applicant were considered in the RARMP and related background material is discussed in the reference document The Biology of Triticum aestivumL. em Thell. (Bread Wheat). Controls proposed by the applicant were considered in Chapter 3, Section 4.1.1 of the RARMP. It was concluded that dispersal of seed by birds was considered unlikely to occur, and that a 200 m isolation zone was considered adequate to limit gene flow to non-GM wheat, including wheat breeding lines. If seed dispersal or gene flow were to occur, the resulting plants would not represent a risk to human health and safety or the environment since neither the potential toxicity or allergenicity of the GM wheat (Event 1), or the potential for the genetic modifications to result in improved survival of the GM wheat plants (Event 2) were identified as risks. |
| Could other non-sexually compatible crops be grown at the Location when the GMOs are not being cultivated, provided that identification of volunteers is possible? | New discussion inserted into Chapter 3, Section 4.1.1 of the RARMP concludes that break crops of lucerne or forage brassica are suitable provided that volunteer wheat is controlled with herbicides, and noting that use of a herbicide precludes identification of volunteers and so may impact ability to sign off the site. Conditions have now been included in the licence allowing these plants to be grown as break crops, provided that a specific herbicide against wheat be used when the break crop is growing to prevent wheat volunteers flowering. |
| Are the measures aiming to clear GM wheat seed in the soil seed bank sufficient? The requirement for 6 months without detection of volunteers prior to site sign-off does not take into account whether conditions favourable for germination occur during this period. | To address the concern that the required volunteer-free period may fall during conditions not conducive to wheat germination, the licence conditions have been modified to require that each location and associated buffer zone be irrigated at least once during the 6 month volunteer-free period prior to site sign-off, to ensure that all remaining viable seeds have the opportunity to germinate. |
| Suggest inclusion of prescriptive requirements for post-harvest treatment of the sites, for example the amount of rain to count as an irrigation event, the timing of irrigation and tillage requirements. | Wheat seed dormancy and how it can be affected by environmental conditions was considered during the risk assessment. The licence conditions specify the required timing and depth of tillage, with the aim of preventing burial-induced dormancy of GM wheat seeds. The licence also specifies the timing of irrigation after harvest, and allows the applicant to seek permission from the Regulator should they wish a rainfall event to replace an irrigation requirement (in which case the amount of rainfall would be considered in the particular environmental conditions prevailing at the site). |
1GTTAC, State and Territory Governments, Australian Government agencies and the Minister for the Environment, Heritage & the Arts.