2nd September 1998,
Dublin, Ireland.
Environment Policy Section, Department of the Environment & Local Government, Custom House, Dublin 1.
Re: Genetically
Modified Organisms and the Environment, Public Consultation.
Dear Sir,
Following publication of the 'Consultation
Paper on Genetically Modified Organisms and the Environment' I would
like to make the following points as part of the consultation
process:
- Ireland has a reputation as an
ecologically friendly country. Dairy and meat exports benefit
from this image. This image could be eroded or possibly even
destroyed by acceptance of GMOs in Ireland.
- Developers of GMOs may be keen to test
their products in Ireland precisely to benefit from the
environmental image.
- Research on environmental effects of
genetically modified plants expressing foreign insect resistance
toxins will also need to consider the effect of these toxins on
natural predators of these insects, including predators which
are insects. This does not currently appear to be part of the
intended impact assessment.
- The difficulty of proving an organism
is a GMO could in effect remove choice from consumers wishing to
opt out. To use an analogy, it may be as difficult and expensive
to prove that a given organism is a GMO, where the precise modification is not known in advance,
as to prove that a given athlete has used performance
enhancing drugs where there is doubt as to what drugs have been
used. GMOs do not necessarily introduce readily identifiable
foreign genes, rather they may modify expression of existing
genes.
- GMMs for delivery of antigens for
vaccination using modified Lactococcus lactis run the
risk of additionally causing an unintended immune reaction
against that bacterium. This in turn could lead to widespread
milk intolerance with disastrous effect on Ireland's dairy
industry.
- Research into GMMs and GMOs for
agricultural purposes provides 'free' R&D for biological
warfare.
Yours sincerely,
James Crook, Phd.
(Doctorate for Research in Molecular
Biology, DNA Comparisons, Edinburgh University, 1991)
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