Action Templates - Call to Action
FSANZ Proposal P1055 – Definitions for gene technology and new breeding techniques
Please make a submission on FSANZ's proposals for changes in Definitions that will effectively deregulate new forms of Genetic Engineering. Under the term 'New Breeding Techniques' (NBT) some foods produced with existing (and future) Gene Editing techniques will be exempt from safety evaluation required for GMO foods. In the consultation document FSANZ wrongly conclude that more targeted Gene Editing means products from NBTs need no oversight for safety. FSANZ believe the use of a Gene Editing process is irrelevant for safety purposes if the end product is 'the same', concluding that current and future NBT products require no additional oversight. This view is flawed and ignores important lessons from current peer reviewed science on unpredicted and off-target effects in the gene repairs in NBTs. FSANZ trusts that in future the developers of NBT plants and animals will effectively screen Gene Editing products before release, as companies have done in the past for conventional breeding. But this ignores the emerging risks that many other users of 'cheap, new' Gene Editing techniques may not necessarily be competent. FSANZ's approach is a loss of control of food safety and the integrity of the food supply, with negative impacts for consumers, producers, farmers, exporters and public health.
Submission to FSANZ on Proposal P1055
Definitions and the Need for Continued Regulation of current and future New Breeding Techniques (NBTs)
We have suggested a definition - Gene technology:The use of genomic technologies to delete, replace, or insert RNA/DNA sequences, altering the heritable genetic material of living cells or organisms.
Future gene technology processes of Gene Editing in NBTs are substantially different from conventional breeding and thus need regulatory oversight of safety
Similarity of a product of NBT to a conventional bred product is inadequate to justify exemption of the NBT product. Unexpected genomic changes may have occurred but safety implications would not be considered and assumed always to be negligible
FSANZ should keep 'process' as their trigger and should not exempt any more NBT products from risk assessment by simply 'redefining' the inconvenient as ‘not gene technology’ (as led to FSANZ exemption for SDN-1
I oppose FSANZ's previous exemption of 'SDN1' products from safety regulations and further exemptions being made
FSANZ should keep a more expansive process-based trigger eject the exemptions, (and not use the flawed USDA definition which undermines this)
Gene Editing techniques are new and rely on cell processes of gene repair that are not yet fully understood. FSANZ and industry views that this is precise and controlled is not necessarily the case, with unexpected outcomes from the NBT processes
FSANZ believe the use of a Gene Editing process is irrelevant for safety purposes if the end product is 'the same', concluding that current and future NBT products require no additional oversight. This view is flawed and ignores important lessons from current peer reviewed science on unpredicted and off-target effects in the gene repairs in NBTs.
FSANZ mentions, but fails to accept the importance of unexpected changes such as those in Gene Edited Polled Cows found after commercialisation. FSANZ are wrong to accept such risks (based on hope of later remediation to remove the unwanted genetic material
The lesson for food safety is that the PROCESS must trigger oversight for unexpected changes. This is important for food safety where issues cannot be remediated or are only identified after commercial release as a risk to public health.
Future NBTs may also have different process and potential disruptions of genomes and also cannot be exempted from regulation
FSANZ has erred in approving all previous applications for GMO foods as 'overwhelmingly' safe, without requiring safety testing. Exemptions must not be made that weaken this even further
The changing environment of Gene Editing as 'cheap', 'fast', 'easy' (and official assumptions that they are precise and without safety relevance) is expanding the range of risk
Gene Editing NBTs are promoted as more targeted than mutagenesis but should also be recognised to potentially much more disruptive of the genome than mutagenesis by the capacity to override preserved areas of the genome that are for some reason resistant to damage through mutagenesis.
FSANZ proposal to rely on producers to screen products for undesirable qualities is wholly inadequate and makes the future food system vulnerable
Commercial pressure for innovation is creating a new level of risk appetite for NBTs to be rapidly deployed and costs reduced by exempting them from regulatory oversight, safety evaluation, tracking/labelling, and liability
The public do not want these risks to be ignored or transferred from the producer/ manufacturer to the consumer, farmers or the environment
A mandatory register of products from NBTs processes will support Intellectual Property systems, downstream tracking and research across government and civil society to monitor and understand the impact of novel introductions into the existing varied gene pool
Use of NBT processes should trigger safety oversight of all Gene Editing products, including those similar to conventional breeding.
NBTs as defined in FSANZ's proposal must not be given exemptions and must be subject to case by case safety evaluation.
NBT products should require genome sequencing and inclusion of the product on a register
The data must be used to allow 'Omics' safety evaluation in order to identify areas of concern or further action needed, prior to any approval by FSANZ
FSANZ's previous exemption of SDN1 products should be reversed.
Submissions close Sunday 14 November 2021.
Please make your own individual comments. We have made some suggestions to place in your submission comments -
- Open and balanced debate with a whole spectrum people, and deeper engagement with the scientific issues that demand a critical and precautionary view.
- Respect for the need for the global community to together consider the emerging new issues of synthetic biology, gene drive and microbial GE organisms, before any individual countries consider development or deployment
- The Treaty O Waitangi responsibilities’ need to be paramount. Further, debate across all cultures in civil society and the scientific arena must open for all voices to be heard.
- The removal of any monetary influence from the people who hold patents or rely on their income from these biotechnological developments
- Journalists must declare if they have been trained or taken courses in how to present the information to the public.
- Clear parameters on declaring conflicts of interest in discussions and debates.
- What else should we consider?
- Existing solutions and protections to the environment should be considered before novel biotechnologies like gene editing.
- Ensuring that HSNO regulation includes GE technologies. The precautionary principle and effects are considered and promoted in any decision-making.
- A programme that is regenerative, organic increases habitats for indigenous species.
- Addresses anthropogenic activities as well as domestic animal destruction on the sensitive environment.
- Does not introduce any product through health and veterinary sources that can spread live organisms into the environment.
- Drone, ADI platforms and mechanical engineering also have potential for tools that are not permanently invasive to ecosystems.
- Address the conflict around DOC responsibilities around the need to have the tourist dollar but preserve the environment.
Nga mihi, .....
Make a submission : Submissions close: 3 October 2021
I would like to be heard (optional)
It is vital for the public interest that there be transparency and accountability around decisions. I oppose the removal of the notification of decisions and reasons for the decision.
- This is undermined by the proposed repeal of the clauses – 29(3), 32(3), 38(5), 45(3) and 48(3) Determination of Applications.
- The clauses are necessary for the accountability of any decision-making by the bodies that carry out approvals, and removal of these clauses will create a lack of transparency and accountability.
Regarding Genetically Modified Organisms - There should be a further addition to HSNO Sec: 62 Reassessment of 62 (d) any new organism released without controls.
- There should be text change to move 62 (d) Any hazardous substance
To meet the purpose of the Act authorities need to be able to consider new information relevant to managing risks of any new organisms released without controls.
- The Bill needs to it made clear who is responsible for recalling or reassessing new organism that has been released without controls if new information arises regarding their risk.
- If a new organism that has undergone approval for release without controls is found to be harming the environment, affecting livelihoods or economic viability of communities, an avenue for reassessment must be in place.
- As the experts in new organisms are in the Environmental Protection Authority (EPA), it is most appropriate for the HSNO Act to be the legislation for the necessary safety reassessment to occur.
- This requires that a clause in HSNO Sec: 62 be included to address the omission.
Engagement and Local Government Information
- It is important that all local authorities be given notification of applications and be permitted to decide there own level of interest.
The wording in HSNO amendment Bill sec: 53 4 (c) ii) "if, in the opinion of the Authority, the local authority is likely to have an interest in the application" is subjective and limiting to those councils who may have a new or unidentified interest.
- The wording should be amended so the clause reads –
53 The Authority shall, upon receipt of the application, notify 4 (c) ii) all local authorities (within the meaning of the Local Government Act 2002).
Emerging biopesticide products
- The Act must be fit for purpose to address risks in emerging novel techniques used in products e.g synthetic biology, nanotechnology and new RNAi biopesticides
- To address this the Act should have an addition to Section 26 (3) a new clause (d)
- 26 (3) (d) A hazardous substance that has been approved but is re formulated to contain or act like a genetically modified organism or contain nanoparticles must be publicly notified.
Nga mihi, ........
We have put together our concerns regarding the Natural and Built Environment Bill. Calls for submissions are due 4 August.
Details on how to make contact: phone: 04 817 9520 email direct firstname.lastname@example.org and online submission here
Please add you own lead in and thoughts these are just a guideline.
do you want to be heard Yes/No
- Community democracy, decision making, and recourse to the Environment court must be restored.
- The RMA Natural and Built Environment Bill must allow communities and local councils to regulate land use activities relating to Genetically Modified Organisms within their region.
- GE is a contentious issue that must be defined to allow the ability of communities to decide what types of land and water use they want.
- Local councils are the only place that communities can actively participate in civic democracy and have the power to submit on what type of land use and regional policies are best for their livelihoods, economy and future generations
- The RMA's overarching Precautionary policy needs to be strengthened to include the important precautionary GE/GM section in the current Act Section 360d
- There must be a retention of the 30 years of case law that the Environment and High Courts have ruled. These have set out clarification of the intention and responsibilities between central government and local government
- Based on past experiences, centralisation of all local assets leads to privatisation. This prospect of loss of public interest and oversight must be prevented.
- The new legislation (NBER Bill) proposes more national direction through a National Planning Framework. Local Bodies must be able to place higher standards than those set by a NPW.
- The role of Māori is a major issue for the Resource Governance legislation and local bodies must give tangata whenua the power to vote when engaging in decision making. Membership of Committees should have 2 local members: a tangata whenua member elected by the iwi and a member elected by the the local community
- Wording in relation to Genetically Engineered activities must be in the new Act and be defined to include Gene Edited organisms (which are GMOs as defined in Law in NZ and as ruled by the highest EU court) and organisms from synthetic biology.
- Wording on Council's rights should be added to refer to GMO animals and forestry in addition to GMO crops (currently mentioned in 360d)
- Climate Change policy and replacement /changes to the RMA need to include:
- Promoting sustainable food growing using regenerative organic agriculture methods.
- Include Nature-based solutions to enhance and restore biodiversity and ecosystems (wetlands, soil, regenerative agriculture, native forests).
- Reinserting and updating wording allowing the ability of local councils to make rules and policies.
- The Purpose (Part 2, 5 (2 b)) should include biodiversity as a recognised priority alongside climate change. and should be safeguarding and restoring ecosystems, protecting ecological integrity in nature and protecting biodiversity
- Environmental outcomes ( 8 (n) - protection and sustainable use of the marine environmen should include mention of not just plastic pollutants to be: (n) Ensuring plastic and other persistent pollutants including living genetically modified organisms and organisms from synthetic biology do not enter waterways and coastal marine areas.
- Implementation Principles P(art 18 B ) should include: Allowing local bodies to place rules or types of rules that regulate the growing of crops, forestry and animals that are genetically modified organisms or organisms of synthetic biology.
Indicate if you would like to be heard in any stakeholder engagement regarding the Natural and Built Environment Bill.
Whangarei District Council Long Term Plans 2021-2031, closing date for submissions 1 April
and Kaipara District Council Long Term Plans 2021-2031, closing date for submissions 1 April email@example.com
Far North District Council Long Term Plans, closing date 6 April 2021-2031.https://www.fndc.govt.nz/Whats-new/Have-your-say/Long-Term-Plan-2021-31.
Email your submission to:firstname.lastname@example.org
Northland Regional Council LTP, closing date 16 April 2021l
Please click on the link to GE Free NZ e-petition on the FSANZ Act review. and sign this important petition.
The New Zealand Australia Food Standards Authority is reviewing the FSANZ Act. This is the Act that governs genetically engineered (GM and gene edited) organisms into the food chain. FSANZ has signalled that they are looking at exempting certain GE foods from assessment. This means that without labelling we will not know what is in the food chain all choice to avoid GE food will be removed food. We, GE Free NZ have launched an e-petition which will be open until November 29th. The wording of the petition is -
That the House of Representatives urge the Minister of Food Safety to advocate for the regulation, safety trials and full labeling of GM and gene edited food in the current review of the FSANZ Act.
I believe New Zealand consumers are concerned about the approval process of genetically modified and gene edited (GM/GE) food, particularly the signaled GE deregulation and lack of safety trials for GM food. We ask the review:
-regulates and labels all GM and GE food
-requires 90 day feeding trials on GM food
-ensures submitters can challenge GM decisions
-consults with stakeholders before ministerial forum approvals of GM decisions, and
-requires full assessment of pesticide residues in GM food
Thank you for your support.
We are calling on our members to make a submission to A1192 the latest GE Corn application received by Food Standards Australia New Zealand (FSANZ), who is the trans Tasman food regulatory body that assesses GE foods.
Application A1192 Safety Assessment supporting document
Details on how to make and send your submission on A1192 are here
DEADLINE FOR SUBMISSIONS- 6pm (Canberra time) 21 May
Submission are best sent electronically through the FSANZ website via the link on documents for public comment
You can also email your submission directly to email@example.com
FSANZ received an application from Monsanto Australia Proprietary Limited asking for approval for food derived from a herbicide-tolerant corn line MON87429 to enter the food chain.
Corn line MON87429 has been genetically modified to tolerate the spraying of glyphosate, glufosinate, dicamba,2,4-D and the aryloxyphenoxypropionate group of herbicides (known as FOPs) 8 in all, throughout the plants growing life.
POINTS TO MAKE - Please personalise your individual submission
The corn is developed to survive spraying with up to twelve different pesticides risks exposing consumers in New Zealand or Australia to increased levels of toxic chemicals.
The seed is coated with a neonicotinoid insecticide.
FSANZ has made its assessment wthout safety data on potential impacts of the GE corn absorbing multiple chemicals, or unintended mutations from gene editing and transgenic engineering
FSANZ assessment of MON 87429 is based on insufficient research and relies on inaccurate and purely theoretical data.
FSANZ has missed or selectively overlooks data that reveals problems.
Allowing a food to be sprayed with a cocktail of toxic herbicides which have a history of chronic health effects is irresponsible and endangers public health.
Data cited in Bayer’s application came from Monsanto, who have shown they cannot be trusted to avoid manipulation or not to omit data
FSANZ should prioritise standards that ensure food is fresh and pesticide free. Foods that are genetically modified, highly processed, and grown with pesticides are known to undermine the human immune system making us more vulnerable to illness.
Keep regulations on all GM methods including new CRISPR
Please support our Australian Friends who are asking people to write to the Australian Government to say No to the deregulation and exemption of GMO's.
All GMOs are now regulated. The Morrison government wants to exempt many GM animals, plants and microbes so they do not need to be assessed by the OGTR. They will go under the radar, unregulated, unlicensed and untraceable. There will be a GM free for all, with the OGTR, governments and the public in the dark.
We need the Greens, ALP, and the cross-bench to say NO!! to deregulation in the Senate on September 17th. The ALP will decide its position next Tuesday, September 10th, so please take action now. Without them we won't have the numbers to keep GM regulated.
Message the ALP to back the Greens disallowance (before Tuesday)
Food Standards Australia and New Zealand (FSANZ) is reviewing the Food Standards code and calling for submissions on whether "New Genetic Breeding Technologies" should be regulated.
Comments to FSANZ on New Breeding Techniques consultation paper has been extended until 6pm (Canberra time) 19 April 2018 FSANZ Submissions Portal:
Or email your submission to: NBTConsultSubmissions@foodstandards.gov.au
Please also contact the Minister for Food Safety, Hon Damien O'Connor - firstname.lastname@example.org or email@example.com and cc. Secretariat@foodregulation.gov.au Jenny Reid, she is on the Forum that oversees our food regulator FSANZ who want to allow this new GM into our food. Ask her to ensure these new GM techniques are regulated.
Further submissions to the Northland Regional Plan Deadline: 3pm, Monday 26 March 2018.
Please make a "further submission" supporting the original submissions made by, GE Free NZ, GE Free Tai Tokerau, Whangarei District Council, the Soil & Health Association Aotearoa NZ, Organics Aotearoa NZ (OANZ) and Te Waka Kai Ora on the important GE/GMO issue.
How to make your further submission in response to the NRC proposed Regional Plan
- Email: firstname.lastname@example.org
- Post: PRP Further Submissions, Northland Regional Council, Private Bag 9021, Whangārei Mail Centre, Whangārei 0148
- Drop it in to one of the NRC offices (ring 0800 002 004 to find your local NRC office)
- or, you can Go to the NRC consultation site to make your further submission online (but DO remember to save a copy of your further submission!)
Further information can be found here: GE Free Northland
GE Free NZ is considering a Judicial Review over the approval for A1138 GM rice (17.3.2018)
GM rice correspondance and OIA reports on the GM rice.
Food Standards Australia New Zealand (FSANZ) has just approved and gazetted GM rice (A1138) in case it contaminates the rice supply. Threats of trade issues if contamination occurred, were alluded to if not approved. There are no safety data provided by the applicants and only their unpublished data was relied on. The Minister chose to ignore the absence of food safety studies when he did not call for a review.
Please write to express your concerns over the lack of action to the Minister, Hon Damien O'Connor - email@example.com or firstname.lastname@example.org
cc. Secretariat: Secretariat@foodregulation.gov.au
Free Post: Private Bag 18888, Parliament Buildings, Wellington 6160
Submission - A1139 - GE potatoes.
Food Standards Australia New Zealand (FSANZ)
FSANZ approved the GE potato into the food chain.
FSANZ decision (29 September 2017)
GE Free comment press release Food Standards Approval Ignores Possible Dangers Of GE Potatoes.
Name of submitter
(address, email phone)
I ask that FSANZ decline the approval of application A1139 - Food derived from Potato Lines E56, F10, J3, W8, X17 & Y9.
I strongly object to FSANZ approving application A1139 - Food derived from Potato Lines E56, F10, J3, W8, X17 & Y9. I ask that FSANZ decline the application.
There is no comprehensive data showing evidence of unintended effects of the transgenic potato lines. It makes it mandatory for FSANZ to decline the approval.
- It is necessary for FSANZ to require whole genome sequencing to identify off-target mutations and also essential to ascertain the effects of unintended changes on global patterns of gene function.
FSANZ must require sequencing using molecular profiling analyses or 'omics"-
- transcriptomics "” gene expression profiling,
- protein composition profiling,
- profiling of metabolites,
- miR-omics – microRNA profiling
The best evidence available for effective safety assessment also requires long-term toxicity studies in established animal model systems. In the absence of these data to inform FSANZ, there can be no legal approval of A1139.
The APHIS documentation shows that these GE potato lines offer no nutritional advantage, as there are non-GE potato varieties that are naturally low in the desired profiles. This demonstrates that there is no need for approval of the GE potatoes.
- Instead of approving this application, FSANZ could instead recommend non-GE potato varieties that have naturally-occurring low levels of compounds responsible for acrylamide production. They could also educate food businesses on storing and cooking procedures that minimize acrylamide production..
- The FSANZ assessment is compromised with respect to rigorous scientifc procedure. These GE potato lines cannot be approved for the human or animal consumption, without the provision of comprehensive information regarding compositional differences to their non-GE counterparts. Compostional analyses are very limited in that they can only assay for known compounds. Any novel compounds would not be detected in such analyses.
- FSANZ must provide evidence of safety, when eaten, in the lines that have significant variations in nutrients, or more importantly anti-nutrients. Anti nutrients such as glycoalkyloids can be highly toxic for consumers.
- The afore-mentioned studies have not been carried out and in their absence, there should be no legal approval of the A1139 application.
SIGNED/YOURS SINCERELY etc
Other risks from an approval by FSANZ that must be recognised as unacceptable to the public.
- There is no consumer benefit or nutritional benefit from the GE potatoes listed in this application to outweigh known and unknown risks, compared to existing potato varieties that industry can use.
- Whole or even very small parts of any uncooked (raw) tubers endanger New Zealand's biosecurity. GE potatoes could either potentially be planted without regulation or establish themselves as wild populations.
- Approval will constitute a total disregard for the health of consumers, by denying them their right to know what they are eating. There is no requirement for GE foods sold by fast food and other restaurants to be labelled as such, so as to inform consumers.This would leave the public in the dark and result in unwilling and unwitting consumption of GE potatoes.
- The GE potato lines' compositions are significantly different to their parent line. This shows that the GE process has disrupted the cellular metabolism. As there are no feeding studies to evaluate these effects, it is not possible to conclude that there are no biologically relevant differences.
Resource Management (National Environmental Standards for Plantation Forestry) Regulations 2017
Environmental Guidance in Forestry Standards Is Welcomed (GE Free press release)
The NES -PF has been in front of Minister for Primary Industry since 27 July 2016. Update information says it is going to be considered in August 2017 - the GE clause still stands.
National Environment Standard on Plantation Forestry (NES-PF). GE Free NZ Stop GE Trees principles align to the Global Justice Ecology Project. We need to protect native forests, and to defend the rights of forest dependent communities and Indigenous Peoples against the uncontrollable and irreversible threats posed by the release of genetically engineered (GE) trees.
Protect the right of regions to choose to say NO to GE trees.
I am writing to you regarding the Resource Legislation Amendment Bill (RLA).
I would like to ask you to call for the deletion of the clauses 360D, 43A (3A) and 43(3B).
The clauses, if enacted, remove the democratic process around community protections for the environment through the RMA and would allow GE plants and animals to be a permitted activity if approved by the EPA. Any Council with precautionary GE provisions placed in their plans would have to remove them.
The damages from genetically modified organisms on New Zealand's ecosystems, including essential soil organisms, plants, birds and insects, could be both widespread, permanent and economically damaging. These effects could be detrimental to biodiversity and trophic systems, undermining what the RMA is designed to protect.
replicas of the 6.4 clause in the stalled National Environment Standard on plantation forestry (NES-PF). Ministry of Primary Industries (MPI) recieved
16,000 submissions calling for the removal of clause 6.4 and supporting councils in their right to regulate land use provisions on GMOs.
I urge you to ensure that these clauses are removed from the RLA.
The decision we would like the Minister to make<
1. Remove clause 360D
!! The Resource Management Act (RMA)!! updated 18 September 2017
Fantastic news, communities are now able to make GMO Free provisions in their regional policy statements and local council plans. The new wording (360D) the Maori Pary carved out in the RMA allows Councils to place precautionary policies on GMO's without the interference of Ministers. (April 17)
Local Body and Environment Select committee hearing
March 2017 URGENT Protect the right of Regions to say NO to GE". Please send an e-mail to Marama Fox and all Parties asking them to ensure that clauses, 360D, 43A (3A) & 43(3B)are removed from the RLA. This week the Bill will be debated clause by clause. Below is a template letter for you to use and add any of your own wording. Click here to find the email address of all MPs.
Communities want and should have a say in how their livelihoods will be affected, at the moment they can do this through the Resource Management Act. However, clauses have been added in the proposed RMA, by Minister for the Environment and supported by Federated Farmers, preventing councils and communities from placing precautionary controls on the management of GMO's in their region. Please write, meet with your Labour Party, Green Party, Maori Party, NZ First and United Future MP's to insist on removal of section 360D. Write to the select committee expressing your views. Below is a template you might like to follow. (You can also include other concerns you have with the planned RMA changes).
Update on Whangarei and Far North District Councils submission rounds, 2014.
This is now in front of the High Court for more information please go to GE Free Northlands page
Do you live in Northland or Auckland? (or do you have an interest greater than the general public?)
Do you want to protect the North's existing valuable GE-Free status? (GE=Genetic Engineering).
Do you support your local councils ensuring that those who may wish to undertake risky GE experiments in our region should be financially liable for any harm caused by their activities?
Do you want a complete ban on the release of all GMOs (Genetically Modified Organisms)?