Submission

Submission on
Hazardous Substances and New Organisms
(Genetically Modified Organisms)
Amendment Bill

Rural Women New Zealand represents the interests of more than 4000 members from over 300 branches located in rural areas throughout New Zealand. Our organisation works at local, regional and national levels to strengthen the social, economic and environmental wellbeing of rural communities.

Rural Women New Zealand was given interested party status by the Royal Commission last year: key tenets of our submission included the need to maintain New Zealand's position in agricultural export markets through a dual commitment to :

· Leading edge science underpinning sustainable, competitive agribusiness; and
· Leading edge food safety and environmental risk management systems,

recognising that growth opportunities for New Zealand lie less with commodity products, more with those segments of international markets which are concerned not only with product attributes, but also with integrity and sustainability of process.

Rural Women New Zealand recommended that the moratorium on releases be continued, pending the development of a "Biotechnology Strategy" which would serve to guide the responsible development and use of GMOs, and which would explicitly attempt to balance economic, environmental, ethical and cultural imperatives. We welcomed the extension of the moratorium and support the intent of this bill to provide for continued research, but not field release, of GMOs. Accordingly, we emphasise the need for this legislation to:

· Ensure that any field trials are fully contained; and to
· Extract maximum value from the research opportunity

In this context we raise the following concerns and recommendations:

· 45A makes provision for the destruction of the reproductive material of plants.
We recommend it similarly make explicit provision for the sterilisation of any research animals; along with specific requirements for the ultimate disposal of any research animals ,eg, humanely destroyed and incinerated ( with no possibility in the short or longterm of research animals entering the food chain).

· 45A further makes provision for controls to ensure that all material associated with the test is capable of being removed or destroyed.
This provision is inadequate in the absence of other provisions requiring information that the GMO, and any inseparable organism, cannot persist viably in the physical environment.

· Rural Women New Zealand recommends that the additional information required in 73D ( persistence) and 73E (safety and ecological effects) be required for all applications; not just for the medicinal and pharmaceutical category.

We emphasise that the information required in these sections presupposes a commitment to safety and environmental research which may well extend in time and space beyond the immediate boundaries of the field trial. The wider the uncertainty gap about unintended, indirect or longterm effects, the more important it will be to extend the boundaries of trial and post-trial monitoring and controls

· Rural Women New Zealand recommends that the bill be extended to provide that the penalties for failing to comply with any compliance order, or for knowingly failing to report significant new information of adverse effects of GMOs be applied in accordance with s114(1) of the main Act ( fine not exceeding $500,000 ) rather than s 114(2),ie, fine not exceeding $50,000.

Thank you for the opportunity to comment.

Ellen Ramsay
National President
February 2002