USDA Docket APHIS-2018-0034-0037
The “Coordinated Framework for the Regulation of Biotechnology” fails to account for the unique risks of genetic engineering, using existing laws like the Plant Protection Act to address issues for which they were not designed. This proposal weakens the APHIS regulations even more.
All genetically engineered (GE) organisms—plants, animals, or microorganisms—should be subjected to systematic assessments of human and environmental effects and indirect economic effects (such as contamination of organic or non-GE crops leading to rejection in foreign markets, spread of resistant pests, etc.) before being allowed on the market. These assessments must be made available to the public for comment. All products from GE organisms in the marketplace must be labeled as such to allow consumer choice and to permit tracking of unintended health effects. Companies that develop GE organisms should be required to disclose any GE trait, marker genes, or other genetic constructs that might be present in a commercial GE seed product, including traits and genes for obsolete, no longer marketed traits. In addition, the definition of genetic engineering should be broad enough to include all the newer genetic engineering techniques such as RNAi or the new gene-editing technologies (such as CRISPR-cas9, TALEN, ZNF, and meganucleases).
In particular, APHIS regulations should: