GenØk, as a National Competence Center for Biosafety, aims at providing independent, holistic and useful analysis of technical and scientific information/reasoning in order to assist authorities in the safety evaluation of biotechnologies proposed for use in the public sphere.
The information in this assessment is respectfully submitted for consideration in the evaluation of product safety and corresponding impact assessment of event GHB614 x T304-40 x GHB119 cotton, setting out the risk of adverse effects on the environment and health, including other consequences of proposed release under the pertinent Norwegian regulations.
In order to meet the requirements for the NGTA, the regulator is encouraged to ask the Applicant to submit information relevant for the assessment of the social utility of GHB614 x T304-40 x GHB119 and its contribution to sustainable development. The information provided by the Applicant must be relevant for the agricultural context in the producing country/countries, and for Norway as a potential importing country. The information should include issues such as:
• changes in pesticide use,
• development of pest resistance in target populations,
• impacts on non-target organisms,
• potential for adjuvancy effects
• potential for gene flow
• possible impacts among poor and/or small-scale farmers in producing countries,
• share of the benefits among sectors of the society, and
• meeting a need among consumers or industry.
Furthermore, due to the event T303-40, GHB614 x T304-40 x GHB119 is tolerant to glufosinate-ammonium which is banned for use in Norway due to health and environmental concerns. How the use of this herbicide contribute to sustainable development in the producing country needs therefore to be demonstrated by the applicant. Moreover, the applicant does not attempt to identify ethical implications, nor demonstrate a benefit to the community in Norway or in the producing country from the use GHB614 x T304-40 x GHB119 and does therefore not provide sufficient information as required by the NGTA.