Australia’s Gene Technology Regulator invites comments on commercial release of insecticidal (INGARD̉) cotton

January 31, 2003

Invitation to comment on a risk assessment & risk management plan for an intentional release of genetically modified cotton

Australia’s Gene Technology Regulator (the Regulator) is responsible for administering the national regulatory system that seeks to protect the health and safety of people and the environment by identifying risks posed by, or as a result of, gene technology and managing those risks.

The Regulator has received an application from Monsanto Australia Limited (Monsanto) for a licence which, if approved, would enable the continued commercial release of a genetically modified cotton:

  • DIR 022/2002 proposes continued commercial release of a genetically modified insecticidal (INGARD̉) cotton (Gossypium hirsutum) into the environment in the existing cotton growing areas of New South Wales and Queensland, south of latitude 22° South. INGARD® cotton contains an insecticidal gene, derived from a common soil bacterium. This gene produces a protein that is toxic to certain insects, including the major caterpillar pests of cotton. INGARD® cotton also contains a selectable maker gene that codes for antibiotic resistance. The commercial release of INGARD̉  cotton was originally approved under the previous voluntary system. The ‘deemed’ licence (GR-3) that was issued as part of the transitional arrangements to the new regulatory system is due to expire in June 2003.

Following consultation with the expert groups and authorities prescribed in the Gene Technology Act 2000 (the Act), the Regulator has prepared a risk assessment and risk management plan, including proposed licence conditions, in respect of the proposed activities for the licence application.

In accordance with the Act, the Regulator invites written submissions from the public and interested organisations on matters relating to the protection of human health and the environment in order to finalise this plan. Please note that issues such as food labelling, the use and safety of insecticides and herbicides, marketability and trade implications do NOT fall within the scope of the evaluations conducted under the Act as these are the responsibility of other agencies and authorities.

Copies of the risk assessment and risk management plan, as well as summary information, can be obtained from the Office of the Gene Technology Regulator’s website or from the address below. Copies and summaries of the licence application are also available from the Office of the Gene Technology Regulator. Please quote the relevant application number.

Submissions should be forwarded to the Regulator by close of business on 14 March 2003.

Office of the Gene Technology Regulator
MDP 54, PO Box 100
WODEN ACT 2600

Telephone: 1800 181 030
Facsimile: 02 6271 4202
http://www.ogtr.gov.au


 

Office of the Gene Technology Regulator

APPLICATION FOR LICENCE FOR INTENTIONAL RELEASE OF A GMO INTO THE ENVIRONMENT: Application No. DIR 022/2002

SUMMARY INFORMATION

Project Title: Commercial release of insecticidal (INGARDâ ) cotton*
Applicant: Monsanto Australia Ltd
PO Box 6051
Melbourne, VIC 8008
Common name of the parent organism:

Scientific name of the parent organism:

Modified trait(s):

Identity of the gene(s) responsible for the modified trait(s):

 

Cotton

Gossypium hirsutum L.

Insecticidal action and antibiotic resistance

  • cry1Ac gene from the bacterium Bacillus thuringiensis (insecticidal gene)
  • nptII gene from bacterial Tn5 transposon (antibiotic resistance gene)
Proposed Release Location: Cotton growing regions of New South Wales (NSW) and Queensland (Qld) south of latitude 22º South (see Appendix for possible release sites).
Proposed Release Size: A size limit is imposed on the area of INGARDâ that can be grown as part of the Insecticide Resistance Management Strategy for INGARDâ  cotton, regulated by the NRA. Currently a maximum of 30% of the total cotton area can be planted to INGARDâ cotton.

The applicant proposes the phasing-out of INGARDâ cotton to coincide with the phased introduction of Bollgard IIâ cotton over the next 3 years.

Proposed Release Date: First cotton growing season after issuing of the licence (August 2003) and ongoing thereafter

* Approval of this application would enable the continued commercial-scale the release of the GMO that was authorised to proceed under the previous voluntary system and a ‘deemed’ licence, which expires in June 2003, issued when the new regulatory system came into effect.

Introduction

The Gene Technology Act 2000 (the Act) took effect on 21 June 2001. The Act, supported by the Gene Technology Regulations 2001, an inter-governmental agreement and corresponding legislation that is being enacted in each State and Territory, underpins Australia’s nationally consistent regulatory system for gene technology. Its objective is to protect the health and safety of people, and the environment, by identifying risks posed by or as a result of gene technology, and managing those risks by regulating certain dealings with genetically modified organisms (GMOs).

The Act establishes a statutory officer, the Gene Technology Regulator (the Regulator), to administer the legislation and make decisions under the legislation. The Regulator is supported by the Office of the Gene Technology Regulator (OGTR), a Commonwealth regulatory agency located within the Health and Ageing portfolio.

The legislation sets out the requirements for considering applications for licences for dealings with GMOs and the matters that the Regulator must take into account before deciding whether, or not, to issue a licence.

The application and the proposed dealings

In accordance with section 190 of the Act, a ‘deemed’ licence (GR-3) for the general (commercial) release of INGARD® cotton was issued to Monsanto Australia Ltd (Monsanto) ), before the commencement of the Act on 21 June 2001, based on an approval issued under the previous voluntary system administered by the Genetic Manipulation Advisory Committee (GMAC). The deemed licence is effective during the transition period, i.e. 2 years from the commencement of the Act. The deemed approval for commercial cultivation of INGARD® cotton will expire in June 2003.

The OGTR has received a licence application from Monsanto for the intentional release of INGARD® cotton into the environment in the cotton growing regions of NSW and Qld south of latitude 22º South. Approval would enable the continued commercial release of the genetically modified cotton. Monsanto also proposes the phasing-out of INGARD® cotton over the next three years while Bollgard II® cotton (which was approved for commercial release in September 2002, DIR 012/2002) is phased-in over the same period.

INGARD® cotton is resistant to lepidopteran caterpillar pests that attack cotton. It contains an insecticidal gene that produces a protein that is toxic to specific insects.

It is intended that GM cotton plants and their by-products, including cottonseed, be used in the same manner as conventional cotton, including for human food and stockfeed. Cottonseed is processed for oil that is used in a variety of food products and for cotton linters (a type of fibre that does not contain any genetic material) that are used as a cellulose base for several consumer food products. Food Standards Australia New Zealand, FSANZ, (formerly the Australia New Zealand Food Authority, ANZFA) has already approved the use of oil and linters from INGARD® cotton in human food.

As the applicant seeks approval for commercial release of the GM cotton in all Australian cotton growing regions south of latitude 22º South, no limitations on transportation or storage are proposed (see below for further explanation). However, the NRA remains responsible for determining the total planting area each season of INGARD® cotton and currently allows up to 30% of the cotton crop to be planted to this GM cotton to guard against the emergence of resistant insects.

Previous releases of the GMO

INGARD® cotton was approved for general (commercial) release in 1996 (GR-3), by the National Registration Authority for Agricultural and Veterinary Chemicals (NRA), on the basis of advice from GMAC. This commercial release was restricted to the cotton-growing regions of NSW and Qld south of latitude 22° South because of concerns about the potential weediness of the cotton in tropical areas, as well as the potential for out-crossing to feral and native cotton species in these areas.

Prior to commercial release, numerous limited and controlled releases involving INGARD̉ cotton were conducted under the voluntary system overseen by GMAC, as listed below:

INGARD® – 44 limited and controlled releases undertaken by;

  • Qld Department of Primary Industries (PR-141),
  • Deltapine Australia Pty Ltd (PR-17, PR-31, PR-33, PR-34, PR-47, PR-47X, PR-47X2, PR-47X3, PR-47X4, PR-50, PR-50X, PR-51, PR-51X, PR-51X2, PR-51X3, PR-51X5, PR-98, PR-98X, PR-112X and PR-112X2),
  • CSIRO Plant Industry (PR-20, PR-36, PR-36X, PR-36X2, PR-36X3, PR-36X4, PR-36X6, PR-38, PR-38X, PR-44, PR-44X, PR-44X2, PR-56, PR-89, PR-89X, PR-89X2, PR-131, PR-131X and PR-131X2) and
  • Western Australian Department of Agriculture (PR-87, PR-87X, PR-87X2 and PR-144).

INGARD®/Roundup Ready® - 12 limited and controlled releases undertaken by;

  • Deltapine Australia Pty Ltd (PR-83, PR-83X, PR-83X3, PR-109, PR-109X, PR-140, PR-140X and PR-143),
  • CSIRO Division of Plant Industry (PR-94) and
  • Cotton Seed Distributors (PR94X, PR-94X2 and PR-94X3).

On 28 March 2002 the Regulator issued a licence to the Western Australian Department of Agriculture for a limited and controlled release of INGARD̉ cotton (licence number DIR 008/2002) in Western Australia under the new regulatory system.

There have been no reports of adverse effects on human health or the environment resulting from any of these releases.

Parent organism

The parent organism is cultivated cotton (Gossypium hirsutum L.), which is exotic to Australia and is grown as an agricultural crop NSW and Queensland and on a trial basis in Western Australia and the Northern Territory.

Genetic modification and its effect

INGARD® cotton contains an insecticidal gene, cry1Ac, derived from a common soil bacterium, Bacillus thuringiensis (Bt). This gene produces a protein that is toxic to lepidopteran caterpillars, including the two key Helicoverpa pests of cotton.

INGARD® cotton plants also contain bacterial genes conferring resistance to the antibiotics kanamycin and neomycin (nptII), and streptomycin and spectinomycin (aad). The nptII gene was used as a selectable marker in the initial laboratory stages to select cotton plants that were genetically modified. The aad gene was used in the laboratory prior to the production of the genetically modified plants to select for bacteria containing the modified DNA. The aad gene is not expressed in the GM cotton plants because the promoter that is required for its expression is not active in plants.

Short regulatory sequences that control expression of the genes are also present in the genetically modified cotton. These sequences are derived from; the cauliflower mosaic virus, Agrobacterium tumefaciens and soybean. Although the first two organisms are plant pathogens, the regulatory sequences comprise only a small part of their total genome and are not in themselves capable of causing disease.

Method of gene transfer

INGARD® cotton is generated by inserting the cry1Ac, nptII and aad genes into cotton on a plasmid vector carried by A. tumefaciens (a bacterium). The vector is ‘disarmed’ since it lacks the genes that encode the tumour-inducing functions of A. tumefaciens.

Consultation on draft Risk Assessment and Risk Management Plan

The Regulator has made an initial assessment as to whether the proposed release may pose significant risks to human health or the environment, in accordance with section 49 of the Act. The Regulator has decided that the proposed release does not pose a significant risk to human health or the environment for the following reasons:

  • there has been extensive experience with the release of this GMO at commercial scale with no reported adverse effects on human health and safety or the environment; and
  • the potential risk of toxicity, allergenicity, pathogenicity weediness and out- crossing to native cottons and other plant species has been demonstrated to be very low south of latitude 22° South.

 

This means that the Regulator is not required to seek public comment on the assessment of this proposal until the risk assessment and risk management plan has been prepared.

As required by section 50 of the Act, the Regulator is preparing a risk assessment and risk management plan in relation to the licence application and will seek input from a wide range of key stakeholders and expert groups comprising State and Territory Governments, relevant Commonwealth agencies, the Environment Minister, the Gene Technology Technical Advisory Committee and appropriate local councils.

As required by section 52 of the Act, the Regulator will again consult with these prescribed agencies and authorities in finalising the risk assessment and risk management plan that is expected to be issued in early 2003. The public will also be invited to provide comment on the risk assessment and risk management plan over a 30 day consultation period, via advertisements in the media and direct mail to anyone registered on the OGTR mailing list. Summaries and copies of the risk assessment and risk management plan will be available from the OGTR, or on the OGTR website.

Issues to be considered by the Regulator

In making a decision on whether to issue a licence for the proposed release, the Regulator is required to consider applications and submissions within the context of the object of the Act, which focuses upon protecting the health and safety of people and the environment.

Please note that issues such as food labelling, the use and safety of insecticides and herbicides, marketability and trade implications do NOT fall within the scope of the evaluations conducted under the Act as these are the responsibility of other agencies and authorities.

Further information about food safety assessments and food labelling, and the use and safety of insecticides and herbicides are available from FSANZ and the NRA, respectively:

Food Standards Australia New Zealand
PO Box 7186
Canberra Mail Centre ACT 2610
Phone: (02) 6271 2222
Fax: (02) 6271 2278
E-mail: info@foodstandards.gov.au
http://www.foodstandards.gov.au
 

National Registration Authority for Agricultural and Veterinary Chemicals
PO Box E240
KINGSTON ACT 2604
Phone: (02) 6272 5158
Fax: (02) 6272 4753
Email: nra.contact@nra.gov.au
http://www.nra.gov.au

Issues such as marketability and trade implications posed by the commercialisation of GM crops in Australia are being actively considered by the Commonwealth, State and Territory Governments (both individually and through forums such as the Primary Industries Ministerial Council and its Plant Industries Committee), by the Department of Agriculture, Fisheries and Forestry Australia through its Supply Chain Management for Genetically Modified Products Project, and by industry through groups such as the Gene Technology Grains Committee.

If you have any questions abut the application or the assessment process, please contact the OGTR at:

The Office of the Gene Technology Regulator
MDP 54
PO Box 100
WODEN ACT 2606
Tel: 1800 181 030
Fax: 02 6271 4202
Email: ogtr@health.gov.au
Website www.ogtr.gov.au
 

Appendix

Possible release shires for Licence application DIR 022/2002

NSW QLD
Balranald Aramac
Barraba Balonne
Berrigan Banana
Bingara Bauhinia
Bland Belyando
Bogan Broadsound
Bourke Bungil
Brewarrina Cambooya
Broken Hill Chinchilla
Carrathool Clifton
Central Darling Dalby
Cobar Duaringa
Conargo Emerald
Coolah Fitzroy
Coonabarabran Gatton
Coonamble Inglewood
Deniliquin Inglewood
Dubbo Kingaroy
Forbes Milmerran
Griffith Monto
Gunnedah Murilla
Hay Murweh
Jerilderie Peak Downs
Lachlan Pittsworth
Manilla Quilpie
Moree Plains Rosalie
Murray Tara
Murrumbidgee Taroom
Narrabri Toowoomba
Narromine Waggamba
Parkes Wambo
Parry Warroo
Quirindi Warwick
Tamworth Wondai
Urana
Wakool
Walgett
Warren
Wellington
Wentworth
Yallaroi

Full information on the OGTR website at http://www.ogtr.gov.au

News release
5290

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