Our Suntory Blue Rose arrived! November 12th, 2009

The complete set at Flickr.

Unlike the blue carnation, the blue rose smells – well – like a rose. And – good news for Common Flowers – axillary buds are clearly present.

The Woody Plant Medium is in the post, anyone got any experience with home made medium for tissue-culturing roses?

Public Comments from the Assessment Report of the Netherlands Competent Authority in accordance with Directive 2001/18/EC – Notification C/NL/04/02 October 8th, 2009

Public comments

The Summary Notification Information Format (SNIF) was initially published on the Joint Research Center (JRC) website on September 29 (2004). Public comments were received during 30 days, and originated from the Netherlands (3), Italy (1), Ireland (1) and the UK (1). On December 2004, a revised SNIF was published on the JRC website due to the limitation of the scope, i.e. the withdrawal of line 123.2.2. Only public comments originating from Dutch persons are addressed by the Netherlands CA in this assessment report, and are summarized below, under points 1 to 3. Public comments originating from other member states are to be addressed by the relevant CA’s under the 2001/18/EC, during their national assessment in the 60-day period.

Public comments on the notification C/NL/04/02 and reaction of the Netherlands CA

Public comments which were addressed by the Netherlands CA were submitted by:
- Ms. Van Dort, Den Haag, The Netherlands;
- Mr. Schöttelndreier, Groenekan, The Netherlands;
- Mr. Stellingwerf, Ede, The Netherlands.

1. Ms. Van Dort is of the opinion that nature is beautiful enough and therefore sees no reason for colour modification.

Answer: Comments of an ideological nature fall outside the scope of the legal framework of Directive 2001/18/EC. A notification under Directive 2001/18/EC is assessed on possible risks for human health and the environment.

2. Mr. Schöttelndreier objects to the notification because the long term ecological consequences of introducing GMO’s in nature have not been fully assessed.

Answer: The scope of the notification is import only, so no cultivation will take place in the EU. Therefore, there is no reason to assess long term ecological effects as a result of cultivation of the colour modified carnation within the territory of the EU.

3. Mr. Stellingwerf is of the opinion that consents for the deliberate releases of GMO’s should be based on a ‘no, unless..’-basis and regards a colour modification of flowers not a legitimate ground. He also states that other alternatives are available.

Answer: A notification under Directive 2001/18/EC is assessed on possible risks for human health and the environment. If no risks are identified, there is no legal basis to withhold admission of GMO’s to the European market.
A consideration of alternatives is beyond the scope of Directive 2001/18/EC.

From Notification C/NL/04/02

Any more comments? Any more questions?

Public Comments from the Assessment Report Notification C/NL/09/02 of the Dutch Competent Authority in accordance with Directive 2001/18/EC October 7th, 2009

Public comments

The Summary Notification Information Format (SNIF) was initially published on the Joint Research Center (JRC) website on March 26 (2009). Public comments were received during 30 days, and originated from the Netherlands. One public comment is addressed by the Dutch CA in this assessment report, and is summarized below. No public comments originating from other member states were received during the abovementioned 30 days.

Public comments on the notification C/NL/09/02 and reaction of the Dutch CA

Public comments (anonymous) which were addressed by the Dutch CA were:

1. A member of the public asks what would happen if bees are attracted to the genetically modified carnation flowers and would carry away modified pollen. It is known that a German beekeeper could not sell its biological honey because of the presence of genetically engineered ingredients in the honey.

Answer: The scope of the notification is for import of cut flowers for ornamental use, and excludes cultivation. Therefore bees will not come in contact with the flowers. Even if they would come in contact, potential spread of pollen will be negligible since domesticated carnations produce only a few anthers and little pollen.

2. The person asks what would happen with butterflies that are mainly attracted to purple flowers. Purple flowers seem to carry much nectar, this seems to be important for the flower since butterflies are involved in pollination of flowers.

Answer: See also the reaction above.
Butterflies that are mostly attracted to purple flowers will not be affected by the ornamental use of the carnations, since there will be no direct contact. Even in case a butterfly will come in contact with a few purple carnations, this will have no effect on populations of butterflies.

3. A member of the public asks if as a result of the changed flower color the bees, butterflies and other useful insects still recognize the color. What do we know about the function of flower color anyway? According to this person a certain color represents a certain property or functionality, which is unknown.

Answer: See also the reaction above. The scope of the notification is for import of cut flowers for ornamental use, and excludes cultivation. Therefore bees or butterflies will not come in contact with the flowers. The question whether insects still recognize the color of the flower or the question what the function is of flower color is therefore not of relevance for this notification.

4. A member of the public notes that carnation flowers may form roots or may be otherwise propagated. Therefore it can not be ruled out that the material will be propagated by third parties.

Answer: The Committee on Genetic Modification (COGEM) has reviewed this aspect in her advice CGM/090429-01. Carnation is not able to spread vegetatively and cut flowers are not able to form roots. It cannot be completely ruled out that buyers will propagate material to plant in their gardens. However, carnation has no weedy characteristics. Although carnation has been cultivated for decades, it has never been found outside the cultivation areas. The introduced traits (modified flower color and herbicide tolerance) do not introduce a potential for weediness. It is therefore highly unlikely that the genetically modified carnation line IFD-26407-2 will spread in the environment after potential propagation by third parties.

5. A member of the public asks what happens with the function of the aromatic substances, flavorings and toxic substances when the flower color is changed?

Answer: Potential effects of color changed carnation lines on incidental human consumption, allergenicity and (soil) toxicity were assessed using several assays. The results of these assays did not indicate any differences in comparison with the parental strains and are sufficient to conclude on the environmental safety of the product (cut flowers). Potential effects on other aspects like aromatic substances and flavorings of these flowers are not considered to be of importance for the safety assessment since the notification only covers import of cut flowers and no cultivation.

6. A member of the public asks if Florigene also used human embryonic intestinal cells, just like the genetically engineered carnation C/NL/04/02, to determine the toxicity of the flower for humans.

Answer: No, an Ames/6DOPRQHOOD test was performed. The results of this test and all other assays performed with similar carnation lines are sufficient to conclude on the safety of cut flowers of this carnation line for human health and the environment.

7. A member of the public protests against this market approval on ethical grounds. This person requests to take into account ethical considerations of the European consumers. Respect for ethical principles recognized in a Member State is particularly important. According to this person, Member States may take into consideration ethical aspects when GMOs are deliberately released or placed on the market as or in products

Answer: According to Annex VI of Directive 2001/18/EC a notification has to be assessed on potential risks for human health and the environment only. Therefore comments not related to the environmental safety of the product are not taken into account in the assessment of this notification on genetically modified carnation.

8. A member of the public protests against the genetic manipulation of cut flowers (as well as all other forms of genetic manipulation) for ethical reasons. It is not necessary, undesirable and not entirely without risks.

Answer: Like stated before, according to Annex VI of Directive 2001/18/EC a notification has to be assessed on potential risks for human health and the environment only. Therefore comments not related to the environmental safety of the product are not taken into account in the assessment of this notification on genetically modified carnation.

From Notification C/NL/09/02

Any more comments? Any more questions?

“We do this in our lab every day” September 5th, 2009

Interview conducted and provided by the Biopresence Press Office. Part 1. Part 2.

Q. Wait as second. You released genetically-modified plants into the environment? Isn’t that highly illegal?

Georg Tremmel. As mentioned before, the company who originally made the carnation had to get the permission to grow, cultivate and sell the flowers. And of course they got it for the markets they want to sell the flowers, and therefore it is legal in these countries to grow the flowers.
So by releasing the flowers we do nothing that is illegal. Because the permission exists, the plants are declared harmless, despite being GMOs.
The goal of the project is to create “Flower Commons”, that means shared, common places, marked by the presence of “Common Flowers”. On a more poetic level, one could say, that we are trying to return the flower ‘back to nature’, to give the flowers a change to discover and create their own nature.

SF. Like probably all cut-flowers, the plants are grown – or better: produced – in large greenhouses. They are harvested before the develop seeds, so the have to chance of sexual reproduction. What we are trying to do, is to give the flowers this ability back. And only because they transgene plants, we should not discriminate against them.

Q. Hmm. I am still not convinced that this is legal?

GT. Well. We believe so, OK Center does not believe so. Or maybe they believe, but being a public institution they have to insure themselves.
Another aspect of the work, which is maybe a bit more dark-gray is the fact, that we are basically violating the copyright of Suntory by growing the plants.

Q. What exactly do you mean by that. Please elaborate a bit more on this?

GT. Well, Suntory created the blue carnation with genes for blue pedal colour and longer shelf-life. The have the copyright on the blue carnation and it’s DNA. But by re-animating the carnations from cut-flowers, by bringing them back, we basically are growing them again. And of course, growth means cell division and cell division means DNA duplication. So basically, we are making illegal copies of the carnation’s DNA. The question is, whether these are copies for private use (“Privatkopie”), or whether it counts are piracy? And is it reverse bio-piracy if we “pirate” the carnations?

Shiho Fukuhara. We don’t have answers to that yet. Maybe it’s also more important to ask questions rather than answering questions at this stage.

Q. Can you talk a bit about the DIY aspect of your project. The plants in the installation look quite professional, whereas the plants in the video have a more ‘home-brew’ feeling to it…?

GT. The plants are the same. Only the containers are different. Whereas the AEC have their own BioLab where they were so kind to cultivate the flowers, we don’t really have access to a well-equipped bio lab. But that’s actually part of the project. We are deliberately using a very low-biotech approach. The purpose of this is to lower the barrier of access to the technology. And access can create understanding.

SF. I think Freeman Dyson mentioned in a quite recent essay, that Biotechnology is currently at a stage at which the Computer Industry was in the late 70ies/ early 80ies. Computer Laboratories were still quite big, only accessible to Universities and large Corporations. But a bottom-up ‘Home-brew’ Computing scene was blossoming, it seemed everybody tried to build their own “Personal Computer”. Of course then came the PC revolution and ignited a democratized access to Computer technology. I guess with biotech we are still in the late 1970ies, but it will be interesting to see where a possible Personal Biotech explosion can take us.

Q. So your artistic interest is in the biotechnology itself?

Well, our interest in biotechnology is on several level. Of course on the one hand on the practical aspects of manual laboratory work, but the conversion between bio- and info-science means, that most of biotech works is actually done in-silico, that means in a computer simulation rather than in-vivo, in the actual physical experiment. The level of code is an important bridge between the two worlds, but maybe most important from an artistic point of view are the social implications and ethical consequences that the technology evokes.
As artists, we feel we have the obligation to engage with the technology. And the best we to engage is to immerse, that why we are trying to get access to the lab work protocols and also try to communicate this bits of knowledge we hopefully gain.
It’s a bit like learning a new computer programming language. Or actually the learning of a new IDE, a new developing environment.

Q. I saw your installation at the OK Center in Linz? Is there a specific reason for the high security there? I mean, a permanent guard, several layers of bullet-proof glass, and titanium locks to secure the plant containers. Isn’t that a bit excessive?

SF. We were quite surprised too. But it seems the OK Center had to take all possible precautions to prevent the accidental spread of the flowers. We were told, that after the Ars Exhibition, they are even going to seal the room off, so if you want to get a close look at the plants, better be there soon.
Apparently the politicians of this region (Upper Austria) have adopted a highly negative view on GM plants, the goal is to make the region “free of genetic modification” (“Gentechnikfrei”). But of course, there are EU laws and legislation that clearly states, that if plants pass the test and obtain permission, then they are legal.
Of course, the so-called “fight against GMO” is mainly an emotional issue, where the facts get twisted quite a lot. One has to consider, that – for example – with canned tomato or tomato paste there is certain threshold…

GT. … I think it’s 5%.

SF. Yeah. 5 percent. So if 5% of the product is made up from genetically modified plants, it is not necessary to label is as GM.

GT. … Basically if it does not say, that no GMO are used for the product, you can be 100% sure, that GMO are used.

SF. Only if it say “No GMO used”, then there are really no GMOs inside.

Q. It sounds you have a positive attitude to GM. What exactly is your stance on Biotechnology. Are you for or against it?

SF. I don’t think it’s question of being for or against it. Biotechnology is a technology and nothing else. It is the same question, if one is for or against Computertechnology, or for or against Writing-technology. I hope this shows, that the question is absurd. It depends what the technology is used for, it depends how we deal with this emerging technology in a responsible way.

A good friend of ours – and probably the most interesting artist working with biotechnology – , Joe Davis, once said that “There are a lot of bad dreams about biotechnology, but somebody also need to have some good dreams.” We are here to dream the good dreams.

Q. I was told that your work is the only living GMO in the exhibition at the OK Center. Is that true?

GT. Yes, it seems that way. I just heart before, that the other work dealing with plants (Eduardo Kac’s Petunia) is just shown as a documentation. Apparently they could not get the legal procedures of importing the flower sorted out. I think it’s particularly funny, because Kac has a certain – shall we say – ‘history’ of presenting his artworks to the public. Especially the controversy about his Bunny project, which evolved around whether he actually made the bunny or just took ownership of it as some kind of found footage. Anyway, he did not really do enough to dispel the doubts some are having.

Watch out for Part 3 for more about hypothetical biotechnology, blue roses and the genetic modification of already genetically-modified plants.Coming soon.

Part 1: “ComFlow at Ars Electronica

ISEA Artist Talk July 28th, 2008

We will have our ISEA Artist Talk today, Monday 28th July at 4.30 at the Singapore Management University, opposite the National Museum in room SMU SR 2-3.
The official annoucement says, that the talk will be about “Common Flowers – Reverse Engineering, Open Sourcing and Cultural Hacking of GM plants”, but we hope we will also find time to talk about our ISEA AIR project, “Sourcing Water”.

Come along and bring some friends. We bring the food and the drinks. (Well, ISEA is doing that.)