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The information in this assessment is respectfully submitted for consideration in the evaluation of product safety and corresponding impact assessment of events MS8, RF3 and MS8xRF3 oilseed rape, setting out the risk of adverse effects on the environment and health, including other consequences of proposed release under the pertinent Norwegian regulations.

Summary
We have assessed the documents available, and highlights in particular the following points for the current application for renewal of MS8, RF3 and MS8xRF3 oilseed rape:

• None of the oilseed rape events are approved for any of the applications in Norway.
• The Norwegian Food Safety Authority has commented that the oilseed rape eventsMS8, RF3 and MS8xRF3 are as safe as non-modified oilseed rape for use in feed and foodstuffs (1).
• The Biotechnology Advisory Board recommended in July 2013 that the application on oilseed rape events MS8, RF3 and MS8xRF3 for food, feed import and processing should be declined due to “not contributing to sustainable development or social utility”. In addition, they commented it was “not ethically justified” (2).
• The Norwegian Scientific Comittee for Food Safety commented in 2014 through their environmental risk assessment of seed dispersal from transport, storage and handling of oilseed rape events MS8, RF3 and MS8xRF3, that there is a potential for outcrossing and spread to conventional and wild oilseed rape species in Norway. They also commented that there was a low likelihood for a change in the risk for environment and agriculture as compared to other oilseed rape species in Norway with the intended use (3).
• In the report from 2014 on the evaluation on gene modified oilseed rape events MS8, RF3 and MS8xRF3 , the Norwegian Environment Agency recommend to lay down prohibitions against these oilseed rape events based on the following (4): o There is an environmental risk from spills of viable oilseed rape seed from these events as they have wild relatives that transgenes can be transferred to.
  • The oilseed rape events do not have traits that are wanted or solves any societal problems among consumers in Norway.
  • These oilseed rape events are considered to have both negative and positive economical consequences for the producers but this is not decisive on the question on sustainability.
  • Production and use of these oilseed rape events can lead to spread of the gene encoding glufosinate ammonium resistance. This can have a negative effect on biodiversity and ecosystems and does not promote sustainability.
  • In addition, these oilseed rape events are not considered to be ethically justifiable.
• Glufosinate ammonium – has health and environmental dangers upon use.

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Assessed by Idun Grønsberg and Lilian van Hove