Risk assessment and risk management of transgenic trees

My name is Marja Ruohonen-Lehto and I work as a Senior Adviser in the Finnish Environment Institute in Helsinki, Finland. I give expert advise to the competent authority and different ministries about biosafety and environmental risk assessment (ERA) of GMOs. I coordinate the small team at the institute that evaluates the ERA of national field releases and EU marketing applications. I have worked in this position since 1995.

Finland has had a few field releases on GM trees; two to be mentioned are the non-flowering modification in silver birch (Betula pendula) and the modification of carbon and nitrogen metabolism, also in silver birch. Both trials are small, strictly-confined trials (no flowering) that provide data on the growth behaviour, gene-expression, metabolic composition, herbivor behaviour and decompositon of detritus. In other words, data that can be used in risk assessment and is certainly very useful but must be considered in the context that it was derived from a confined, small-scale experiment.

68 % of Finland is covered by forest and 90 % of that is so-called production forest. The whole forest sector has a huge impact on Finland's economy but also biodiversity of our forests has gained a lot of attention during resent years. Several research programmes have been launched to investigate how to maintain biodiversity in our forests.

I have followed with great interest the discussions in this on-line forum. Many important issues have been brought up and I would like to add just a few comments.

1) We may already start to have plenty of experience with certain crop plants and certain inserted genes in them. But about the possible effects on biodiversity of modified trees (e.g. insect or fungal resistance or cold or draught tolerance), and especially if I may say so, modified forest trees is something we know very little about. Even if we can gain data on behaviour of certain genes in crop plants or even data on certain growth behaviour or metabolic changes in modified trees the estimation of possible long-term effects is hampered with considerable amount of uncertainty and lack of data. Basic research of forest ecology is still needed. Assessing long-living species like trees modelling is a tool that can be of great help and should be used. See e.g. work by Bjorn Tommeras and Jarle Tufto, Norway and Anna Kuparinen and co-workers, Finland.

2) ERA must be based on scientific knowledge. Identification of potential adverse effects is certainly value-laden to some extent (that can not be avoided) but even so the possible effects must be studied with sound scientific methods and well-designed experiments. Risk assessment is not a surrogate for basic research but must be based on basic research. How much uncertainty is acceptable is a political decision of each society and should not be mixed into the ERA. A scientist's or expert,s duty is to estimate the existing data, advice on how to gain more data if needed and try to evaluate the level of uncertainty that still exists.

A good example of how important it is to gather enough information was given in a talk by Professor Marvier at the last ISBGMO meeting in New Zealand about a week ago. She talked about meta-analysis of the effects of Bt crops on non-target organisms. She concluded that large open-access databases, that include data from all relevant RA studies is the future of risk assessment. I think this approach should be taken seriously into consideration.