RA&RM of LMOs with Stacked Genes or Traits

Dear all
First of all I would to thank Beatrix for the efforts she made in making this draft document.

I would like also to emphasize that I find the draft very useful as a basis to build on.

As a general comment I think it would be better if we can stick in the draft to the same language used by the protocol and talk about LMOs rather than transgenic plant or GMOs

I am proposing the following definition for the stacked events:
Refers to the combination of two or more (trans)genes of interest in the genome of the host plant, i.e. the created LMOs carries two or more different new traits. This can be achieved either by (1) direct simultaneous introduction of several different transgenes in the genome or (2) iterative processes such as retransformation or conventional crossbreeding of LMOs (plants) bearing different genetic modifications.

I think in the step of Environmental assessment, In point to consider indirect effects should include cumulative, synergistic, combinatorial as well as antagonistic effects

I believe also we should mention the risk to human health somewhere in the document

I think we should not forget to give focus on gene products for all risk pathways that would derive from the stacked LMO

Finally would like to emphasize the importance of checking the stability and loci of inserts as well as testing for gene silencing