Further drafting of the guidance on risk assessment and risk management of LMOs with stacked genes or traits

Dear participants of the discussion forum
I would like to draw your attention once more to our discussion forum. It would be of utmost importance to get your input to our discussions at AHTEG and the subworking groups. I think it will be appreciated by all AHTEG members to get further comments on the different topics.

Plants with stacked genes are on the market place and it is important to have an exchange upon an understanding and approaches how to describe and assess these multiple trait transgenic plants.

I am looking forward to your input

Beatrix Tappeser
chair of the subworking group

Dear colleagues,

Thank you for the opportunity to comment on this document. I have two main comments:

1) In the rationale for Point to consider 3, it is stated that "special focus should be given to unintentional stacks because of outcrossing to relatives in the likely receiving environment." Unintentional stacking of traits is a characteristic that must also be addressed in the initial assessment of an LMO with one of these traits, e.g. one must take into account other previously authorized traits when conducting a risk assessment on a new LMO. This includes a consideration of the likelihood of hybridisation and introgression and subsequent consequences of any gene flow. Since these components should already have been addressed, it may be worth mentionning in this document that previous risk assessments can be a valuable source of information on the likelihood and potential consequences of unintended stacking of traits in the environment, for these reasons.

2) When considering intentional stacking of traits, one should also take into consideration any risk management tools that are in place for any of the TraEvs. The risk assessment on the StaEv should take into account whether these risk management tools are compatible and/or need to be modified to to accomplish the same level of risk mitigation.

Best regards,
Cheryl Corbett

Dear all participants

I have two comments on the draft of the guidance on risk assessment/management of stacked genes/traits. I hope that they will help to improve the draft.

* Rationale and definition of “Unintentional stacked events”: I agree that taking into consideration of outcrossing to sexually compatible species is important. As the Step 2(h) in the draft Roadmap points out the unintentional outcrossing from LMO to other sexually compatible species, I think that it is unnecessary to repeatedly refer unintentional outcrossing to relatives in the document on “stacked events”. In other word, I think it better that the text “ Special focus should be given to unintentional stacks because of outcrossing to relatives in the likely receiving environment” in the “Rationale” of additional points to consider #3 and the term “or compatible relatives” in the definition of “Unintentional stacked events” should be deleted.

* Definitions: We recommend to select the later one “StaEv are the result of the consecutive crossing of two or more transgenic plants with different transgene events (TraEv)” because this text is simple.

Best regards
Yasuhiro YOGO