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?