RA&RM of Living Modified Mosquitoes

Two issues have been raised in the Outline Guidance Document that are related to workplace safety and quality control/quality assurance. In summary, I believe both of these can be adequately addressed and one is outside the purview of this discussion.

1. Under the heading above, the following is described:

“Gene silencing or other production failures result in the release of non-sterile or competent mosquitoes and thus increasing the vector population.”

Because male mosquitoes cannot transmit disease and means are available to eliminate females from the released mosquitoes, it is unlikely that significant numbers of female mosquitoes would be released except in the event of a production failure. Drawing upon the general model for GM mosquito operations, Sterile Insect Technique (SIT), it is certain mosquito production facilities will implement even more stringent controls on production than these operations.

For example, medfly (and other insects) SIT production employs routine quality control and quality assurance procedures similar to that of many industries. These procedures are performed on a daily basis. While it is impossible to ensure that no aberrant mosquito occurs or is released, methods are anticipated and available for detecting them and preventing the release of large numbers.

Could accidental releases cause an increase in the vector population? Only if there is a combination of several factors of gross negligence: inadequate QC/QA, lack of monitoring the release material during preparation and absence of field monitoring post release.

If (female) mosquitoes were accidentally released that were competent vectors, the most likely result would be a transient return to the pre-release state of transmission. If males that were genetically competent were released, a similar effect would be seen assuming females would be present with which they could mate.

2. A second issue is raised:

“Production or release infrastructure causes human morbidity or mortality.”

This is a valid concern but one which has been addressed in numerous factories that produce far more hazardous materials than transgenic mosquitoes. National, state and local agencies, regulations and legal remedies are in place to ensure that personnel working in factories (including those producing LMOs) are not exposed to unacceptable risks. Furthermore, buildings, waste disposal etc. for GM mosquito release will be regulated for safety similarly, and likely even more cautiously, than is now the practice due to the measures described above. Because this item is addressed in other national regulations, it does not seem relevant in this discussion.

Further, as I understand it, workplace safety is not an issue of relevance to CBD so this should be stricken in this context. Accidental release however is a concern and should be addressed in the context of establishing production containment measures. SIT production facilities operating in quarantine zones serve as a useful model for the engineering and practices that are necessary to prevent escape.

(FAO/IAEA/USDA) Food and Agriculture Organization of the United Nations/International Atomic Energy Agency/United States Department of Agriculture. 2003. Product quality control and shipping procedures for sterile mass-reared tephritid fruit flies. Manual, Version 5.0. IAEA, Vienna, Austria.
http://www.iaea.org/programmes/nafa/d4/index.html

It is important to provide information on workplace safety measures inplace in order to protect personnel from possible negative impacts of Genetically modified Mosquitoes.

  There is also the need to provide information on the life span of Genetically Modified Mosquitoes to prevent perpertuity of GE Mosquitoe in particular ecologically area which may make it difficuly to Control in the event is later discovered to possess negative impacts on humans .

Rufus Ebegba

Although workplace safety and how containment is maintained are very important considerations, there should not be part of this discussion that concentrates on the release of LM mosquitoes into the environment. But this would consider a potential accidental release from containment.