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IN THE MATTER of the Judicature Amendment Act 1972 AND IN THE MATTER of the Hazardous Substances and
New Organisms Act 1996 |
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BETWEEN
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MOTHERS
AGAINST GENETIC ENGINEERING INCORPORATED
Applicant
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AND
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THE MINISTER FOR THE ENVIRONMENT
First Respondent |
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AND |
THE ENVIRONMENTAL RISK MANAGEMENT AUTHORITY
Second Respondent |
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AND |
AgRESEARCH LIMITED
Third Respondent |
______________________________________________________________________________
______________________________________________________________________________
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Solicitor Acting: J P Ferguson Walters Williams
& Co Level 7 Axon House 1 Willeston Street P O Box 1654 Wellington Telephone: (04) 495 9999 Facsimile: (04) 495 9990 |
Barrister Acting: Peter Andrew Level 3, The Annex, 41 Shortland Street P O Box 31 Auckland Telephone: (09) 300 7215 Facsimile: (09) 300 7219 |
I, Judith Anne
Carman, swear as follows:
1.
I am an Affiliate Senior Lecturer in the
Department of Public Health at the University of Adelaide, South
Australia. I am the spokesperson on GM
foods for the Public Health Association of Australia. I am a Director of the Institute of Health and Environmental
Research Inc.
2.
In 1989 I graduated with a PhD dDegree in Medicine
(University of Adelaide) in the field of Metabolic Regulation/Nutritional
Biochemistry, particularly in relation to cancer. In 1998 I obtained a Master of Public Health from the University
of Sydney specialising in Epidemiology and Biostatistics. I have worked in a number of positions with
those relevant to this affidavit being: I have taught at Roseworthy
Agricultural College (now part of the University of Adelaide); I worked at the
CSIRO (Commonwealth
Scientific and Industrial Research Organisation) Division of Human
Nutrition (this is now the Division of Health Sciences and Nutrition); worked
in HIV/AIDS in Sydney and was the Senior Epidemiologist in the Communicable
Disease Control Branch of the South Australian Department of Human Services
investigating outbreaks of disease.
While in this position, I was the chief investigator into the
multi-institutional investigation in Australia into whether Rabbit Calicivirus
(Viral Haemorrhagic Disease of Rabbits) was able to infect people.
3.
I am making this affidavit on behalf of
myself and my fellow Directors of the Institute of Health and Environmental
Research Inc. This Institute is a
private institution for health and environmental research, whose principal
current focus is on GE foods. My fellow
Directors of the Instituteinclude are Dr Catherine Anne Clinch-Jones and Dr
Phillip Andrew Davies. Dr Clinch-Jones
is a Medical Practitioner who obtained a medical degree (BMBS) from Flinders
University in 1988 and has practised as a General Practitioner for 12
years. Dr Davies obtained an Honours
Degree in Agricultural Science in 1984 from the University of Adelaide, and a
PhD Ddegree in genetics in 1989
from the Australian National University, Canberra. He is a plant geneticist, specialising in the application of
biotechnology to plant breeding.
4.
We have read the decision of the second respondent,
the Environmental Risk Management Authority (“ERMA”), Application No. GMD02028,
the subject of these proceedings. We
have also read the affidavits of Dr Neil Macgregor, Professor Adrian Gibbs and
Associate Professor Peter Wills.
5.
This affidavit addresses some serious
concerns we have about the adequacy of ERMA’s risk assessment in GMD02028
decision, and the controls it has imposed on AgResearch, the third
respondent. In particular, we contend
that the possible adverse effects of horizontal gene transfer (HGT) have not
been adequately assessed or quantified and that both the AgResearch application
and the description of the approved organism (as contained at Annex 1 of the
ERMA decision) are too broad and general to adequately and responsibly determine
the level of risk.
6.
We also have very serious misgivings about
the containment capability of the field site and control 1.3 imposed by ERMA
(page 54 – Annex 2 – of the ERMA decision).
We conclude by recommending, amongst other things, that transgenic
animal containment should be a purpose-built building in which nothing of potential transgenic origin
is to leave, and that incarceration of all unwanted material should become
mandatory.
7.
At page 12 of its decision ERMA complains
about the lack of information contained in the AgResearch application by
stating “a bare minimum level of information had been provided in some
respects”. ERMA also notes that the
broadness and lack of specificity of the organism description, and the fact
that the organisms were to be outside rather than in a contained laboratory,
made assessment of all possible adverse effects on the environment very
difficult. (Page 12). However, despite registering these concerns, ERMA then decided that
they had sufficient information, expertise and knowledge, not only to actually
to assess the risks but to conclude that the benefits outweighed the risks and
the costs. (Page 2).
8.
Our understanding is that an applicant for
approval to develop a genetically modified organism (in this case, of course,
AgResearch) is required to provide information on all the possible adverse
effects of the organism on the environment.
9.
From a scientific perspective, we cannot
understand how ERMA can have concluded that AgResearch had met this burden in
circumstances where it was complaining that a bare minimum level of information
had been provided and where the broadness and lack of specificity of the
organism description essentially meant that an assessment of all possible
adverse effects was not really achievable.
In our view, this application required a very clear understanding of the
risks arising from HGT and that ERMA’s consideration of the possible risks
arising from this issue is seriously wanting.
We believe that ERMA has not properly informed itself on this
issue. We believe it was incumbent on
the applicant, AgResearch, to have provided full information on this important
issue in the first instance.
10.
In our view, the difficulties associated
with the breadth and lack of specificity of the organism description has meant
that many of the risks identified by ERMA have been determined by conjecture
and assumption, and that in the process, ERMA has under-estimated the risks. We contend that many of these risks are in
fact currently unquantifiable and that ERMA has erred in believing that it can
quantify the unquantifiable. ERMA has
taken many of these unquantifiable risk forecasts and tied them into one
cumulative measure that the risks are low.
If ERMA is wrong on any one of these many risks, the cumulative effect
on humans, animals and the environment could be very significant. This is particularly important as the
application by AgResearch deals with self-replicating genetic material, which
when incorporated into living things (animal, plant or microbioligical) may
persist for thousands of years.
(a)
Decomposition
and disposal
11.
ERMA contends that the decomposition of
carcasses on site in unlined offal pits will ensure “that any genetically
modified animals are likely to remain on-site until they decompose” and that
the disposal of GM cattle in unlined offal pits “does not pose “any significant additional
likelihood of adverse effects attributable to horizontal gene transfer” (page
17 of the Decision). In our view this
is hard to justify given that decomposition will actually be effected by
billions of micro-organisms. This can
only increase the possibility of horizontal gene transfer. Furthermore, some
leaching of decomposing body fluids is inevitable from an unlined pit, even
with run-off to ground water apparently minimised. We also note that ERMA did not specify any design requirements
for these pits in order to minimise run- off to ground water but has left the
design to AgResearch. Cremation would
be a safer method of disposal. We
believe that if a safe method of disposal cannot be permitted due to cultural
sensitivity, then the entire project needs to be reconsidered.
12.
ERMA believes that conventional cattle that
fail to implant a GM embryo carry so little risk that they may be disposed of
off-site. This may also include being
sold (page 18 of the Decision),
presumably for breeding, milking and consumption purposes. AgResearch has made it clear that being
unable to sell these animals would affect their profits. We are concerned about the implication that
profits may have been placed before safety.
We also fail to see how ERMA can maintain this position in the face of
known scientific facts. That is, for
many years it has been accepted medical practice to administer anti-D
immunoglobulin to Rhesus negative women (to prevent their development of anti-D
antibodies, which may affect subsequent pregnancies) who bleed or miscarry even
very early in pregnancy, on the grounds that any bleeding or pregnancy loss
exposes women to antigens (proteins) from the foetus. This is clear evidence that proteins from the embryo/foetus can
cross into the tissues of the parent animal and it is therefore important that
cattle that reject or fail to implant a GM embryo be disposed-of on site and
not be permitted to be sold.
Additionally, consideration should be given to whether failure to
implant the embryo may result from a transmissible or toxic effect of the
transformation. That is, some of the
genetic elements such as the SV40 promoter in combination with other genetic
elements, may have killed the embryos, and if this happens, it is possible that
this toxic element could be transmitted to the cow and hence to humans
consuming products from that cow.
13.
ERMA contends that disposal of milk via
treatment and spraying onto pasture cannot be a route for the escape of
heritable material, principally because autoclaving, while it does not
completely destroy DNA, is likely to break it down into small random fragments
and the risk from horizontal gene transfer of such fragments is considered to
be “negligible” (page 19 of the Decision).
However, autoclaving also does not destroy prions and it appears that
small naked DNA fragments may be potentially more available to horizontal gene transfer
than intact DNA. In addition, it has
long been known that sprayed substances (e.g. herbicides) can drift for
kilometres. Furthermore, the milk that
remains on site will come into contact with micro-organisms in the soil and
faeces on site and can move off-site through wind (after desiccation), surface
water and ground water. ERMA also
suggested that the digestion of the milk in an effluent digester was reasonable
and that it may be done off-site.
However, this would require the transportation of milk and this would
pose risks in the event of a spill or vehicle accident. In addition, the milk carrying
compartment(s) in the transportation vehicle could be a site of movement of GM
DNA out of containment. That is, there
is a history that milk compartments that were not sufficiently rigorously
cleaned from one load to the next contaminated subsequent loads of milk with
salmonella, creating an outbreak of
disease. As GM DNA is expected to be
present in milk (at least in the white cells which milk normally contains but
also in other cells in milk such as adipocytes or red blood cells, or in
extracellular form), and the above example shows how hard it is to sufficiently
remove similar material through cleaning, milk transport containers should be
used only for the transportation of milk from these cows. For similar reasons, the water and detergent
used for cleaning would all need to be disposed-of on-site. Furthermore, it is
our understanding that an effluent digester would bring huge numbers of micro-organisms
into contact with GM DNA present in the milk, thereby posing the same problems
as an offal pit. This is likely to increase the probability of horizontal gene
transfer.
14.
ERMA has determined that effluent from
cattle could be collected and sprayed onto pasture, and faeces and urine from
grazing animals would be left to decompose in the field, on the basis that “the
likelihood of HGT and unintended production of toxins to both [is] very low”
(page 20 of the Decision). However, it
has long been known that sprayed substances (e.g. herbicides) can drift for
kilometres and that faecal material on pastures can pollute both above-ground
and below-ground water systems.
Outbreaks of disease have occurred in this manner. In addition, it is also well known that
faecal material can desiccate and be blown off-site resulting in the microbes
infecting people. Outbreaks of Q-fever
in people have occurred in this manner.
This is of particular concern as horizontal gene transfer involving
transgenic DNA has recently been demonstrated to occur in the human gut. That is, HGT in the mammalian gut is a real
phenomenon, not a hypothetical one. For
these reasons, staff working with these animals should also be prevented from
coming into contact with these animals, and their products. This is because outbreaks of disease show
that people are very good at transmitting disease through the oral-anal
route. This includes the transmission
of microbes from animals to humans via human mouths, and the subsequent spread
from human to human.
15.
ERMA has determined that the likelihood of
HGT could be substantially reduced by controls on the nature of the DNA to be
used. In particular, without the use of
“inherently mobile genetic elements (such as (transposable elements) and viruses)” (page 24 of the Decision), the “escape
of infectious genetic elements is very unlikely to occur” (page 24 of the Decision). This assumes that we know enough about HGT
to be able to assess these risks.
However, this area is in its infancy and accurate assessments cannot be
made based on so little knowledge. It
has recently been determined, for example, that GM DNA can transfer into
bacteria in the gut of people after just one meal containing GM soy. This was an unexpected finding.
16.
ERMA states that without a selective advantage
occurring, HGT is unlikely to lead to the establishment of a new trait in the
population. This is not necessarily
true: organisms carry many genes which are not required in most circumstances,
but can become active in times of unforeseen stress or different environmental
conditions. ERMA also states (page 25) that “given the broad scope of the
organism description in the application it is possible that some sequences to
be introduced could provide selective advantages”. In spite of this, ERMA still assesses the HGT risk to be low,
even with the uncertainty involved (page 25).
17.
ERMA considered that “the risk of a new
prion disease forming was negligible because genes associated with
prion-diseases are excluded from the approval” and “pathogenic proteins that
develop from mis-folding are generally well-known” (page 28 of the
Decision). Such apparent certainty
ignores the fact that prion diseases (and their pathogenic proteins) are a
recent discovery and our knowledge about them is in its infancy. In fact many prion diseases may not even
have been recognised at this time.
Furthermore, it is recognised that we all contain prion-like proteins in
our bodies. In order to be activated
they only need to have their structure folded in a different way. If this ERMA-sanctioned research were to extend
beyond simple protein expression in milk, to altering the physical structure of
the proteins by folding them differently, for example to ensure they would be
active in a human subject, then the chance of causing prion diseases would likely increase, even if no
prion proteins are used in the transformation.
18.
ERMA’s view is that it is unlikely that the
proposed experiments would result in any unknown toxins developing, and “if any
unknown mammalian toxins were produced the effects would be manifested in cattle first, and so very unlikely to pose a human health
risk” (page 28 of the
Decision). This assumes that the
toxins would not be preferentially expressed in milk. It also runs counter to common experience that some toxins have
very slow mechanisms of action and may take many years before showing their
effects, for example, the substances in tobacco smoke. In addition, if there is a high turnover of
cattle and few are kept into middle or old age, some toxic effects are likely
to be missed. Furthermore, thousands of
genetic permutations are allowed under this application. Simple mathematics informs us that a small
risk, multiplied by several thousand, can become a significant risk. For example, if the overall risk is low at 1
in 10,000, and 1,000 experiments are undertaken, then the overall risk becomes
1 in 10, which is a significant risk.
(b)
Viral
Cell Receptors
19.
ERMA believes that their requirement that
all introduced sequences must be characterised reduces the likelihood of viral
cell receptors being introduced and that well-characterised sequences,
particularly those derived from a common bacterium will reduce uncertainty
associated with potential consequences of HGT. However, knowing the sequence of these elements is not the same as
knowing the effect of such sequences on mammalian cells (including cattle
cells), thousands of different types of bacteria and the environment. Such a restriction is intended to
reduce the risk of HGT. That is, ERMA recognises the risk of HGT, and presumably viral
recombination. However, without
objective scientific evidence, it has been assumed that restricting sequences
will control this risk. Given the
similarity between many genes in different species, this is unlikely to be the
case. In addition, excluding known
human and animal viral cell receptors indicates that ERMA recognises the risks
of development of interspecies and new viral pathogens being facilitated by the
GM process. However, current scientific
knowledge has not identified many, and perhaps most, viral receptors. New viruses may be able to use new proteins
as receptors. Therefore, this control
is unlikely to have a significant effect on the risk of developing new viral
pathogens. Furthermore, requiring
characterisation of genetic sequences so that only elements of known function
are inserted similarly relies on the current level of scientific
knowledge. Given the scope of potential
genes and elements permitted by this application, and the current deficiencies
in understanding of gene function, this is likely to be an ineffective control. In addition,
knowing the sequence of these elements is not the same as knowing the effect of
such sequences on mammalian cells (including cattle cells), thousands of
different types of bacteria and the environment.
20.
Under “viral cell receptors” (pages 23- 24 of the Decision), ERMA
recognises that incorporation of viral cell receptors from other species has
the potential to create a new disease in cattle, or a new reservoir for an
existing virus. It is also aware of the
potential to include genes for currently unknown viral receptors, and that biting insects could
move that
viruses off-site. Then there is
an assumption They then assume that other cattle
would not be affected, as they would not contain the necessary receptors. Unfortunately, this may not be the
case. There is widespread awareness
that inter-species transfer of viruses can result in new disease outbreaks, and
that viruses can mutate in animal hosts to broaden their range of hosts. In addition, animals from the specified gene
donor species (cattle, mice, deer, goats, sheep and humans) are all endemic to
New Zealand, and could be susceptible to a mutated virus that could bind to
their receptors.
1.ERMA states
that without a selective advantage occurring, HGT is unlikely to lead to the
establishment of a new trait in the population. This is not necessarily true: organisms carry many genes which
are not required in most circumstances, but can become active in times of
unforeseen stress or different environmental conditions. ERMA also states (page
25) that “given the broad scope of the organism description in the application
it is possible that some sequences to be introduced could provide selective
advantage”. In spite of this, ERMA
still assesses the HGT risk to be low, even with the uncertainty involved (page
25).
(c) Promoters
21.
ERMA states that the SV40 “virus as a whole
rather than this [SV40] promoter can cause pathogenic effects” and “the
promoter itself has no inherent ability for independent movement or infection”
(page 26 of the Decision). However,
viral fragments have been shown to be able to recombine with other viruses in
the host or the environment, including inactivated viruses, regaining their
pathogenesis, and potentially changing their host range. It is also important
to note that simian virus 40 already infects monkeys, our close genetic
relatives.
(d)
Antibiotic
resistance
22.
ERMA believes that risk will be reduced by
only using antibiotic resistance marker genes that are not of clinical
significance in human
medicine (page 51 of the Decision).
However, in our view, the specific antibiotics that can be used should
have been of no clinical
significance to human or veterinary medicine and should have been determined
by medical and veterinary practitioners and then listed by ERMA and not left to
the discretion of AgResearch. Moreover,
two specific antibiotics are mentioned, in the context of already having
resistance associated with them: kanamycin and ampicillin. The way in which they are discussed suggests
that these have been identified as suitable antibiotics to use. In fact, there would be implications for
human medicine if either of these were used.
Kanamycin resistance is, as stated, conferred by the gene nptII. This gene also confers resistance to
neomycin, which has occasional use as a topical antibiotic, but more
importantly, to gentamicin. Gentamicin
is used as an intra-venous antibiotic to fight serious gram-negative infections
in hospitalised patients with septicaemia, burns and kidney infections, for
example. Ampicillin is closely related
to amoxycillin, and ampicillin resistance would most likely also confer
amoxicillin resistance. Amoxycillin is increasingly
being used in human medical practice, in an effort to restrict exposure to
wider spectrum antibiotics and minimise the development of resistance to newer
antibiotics. Clearly neither of these
antibiotics should be jeopardised by the use of marker genes.
23.
In addition, ERMA admitted that “there is
little information available on the occurrence of antibiotic resistance in New
Zealand” and that “mechanisms for resistance have not been studied” in soils,
thereby admitting to the scientific ignorance about antibiotic resistance (page 27 of the Decision). Yet on the basis of this ignorance, ERMA
still concluded that the risk of increased levels of antibiotic resistance
associated with this application was “negligible” (page 27 of the Decision). However, in our view, ERMA needs to understand that there is some
evidence that once a bacterium has acquired one gene for antibiotic resistance
it is more likely to be able to acquire others. The significance of this finding is that even using a gene for resistance
to an obscure antibiotic, may ultimately increase resistance to clinically
significant antibiotics. ERMA also
seems to be of the view that as antibiotic resistance already occurs, there is
less reason to be concerned about it. This runs counter to recent moves to
limit practices that promote antibiotic resistance in medicine and agriculture
in order to prevent further antibiotic resistance and thereby prevent a looming
crisis.
24.
We understand that ERMA has determined that
all of the six steps proposed for the AgResearch work constitute a development
(at page 9 of the dDecision).
In order to comply with the legal development of “development”, it
appears that the AgResearch project is to be limited to “preclude statistically
valid research on the effects of the organism”. (Page 10 of the decision).
This appears to me us to mean that in an effort to prove that
this is application is not a field test, any assessment of environmental impact
is forbidden, except for monitoring the HGT.
This is of particular concern.
From a scientific perspective, we contend that this application is in
fact a field trial because the GE cattle will be released into a field to graze
like normal cattle, rather than be kept in secure laboratory facilities. Therefore, in our view, it is clear that, as
in a field trial, one of the tests being undertaken, whether explicitly stated
or not, is whether the GE cattle will be able to survive, grow and be viable in
the open, away from the intensive animal husbandry of the laboratory. In addition, the cattle and their wastes
will be exposed to the air, soil and water systems, and the creatures which
inhabit them, such as micro-organisms, birds, rabbits, mice, rats, mosquitoes,
ticks, flies, insects which feed on manure and detritus, earthworms, unintended
predators, etc. It should be remembered
that in Australia, Rabbit Calicivirus (Viral Haemorrhagic Disease of Rabbits) was
spread for hundreds of kilometres at a time by the action of mosquitoes and
flies. Each and all of these creatures
must be considered in a risk assessment, and this application should be
considered as a field trial.
25.
Even though ERMA believed that “monitoring
should be as extensive as possible”, it approved the application without
thorough independent monitoring or auditing of the processes and outputs. For example, there appear to be no
procedures or capability to monitor insertion sites or the genetic material. There were also no controls requiring
monitoring of insertion sites (page 21).
Therefore, there is no monitoring of insertion sites, the genetic insert
to determine if it stays in place (or moves) or of movement from unlined offal
pits. There is also a need for
monitoring to determine if any cattle have received any unintended gene
sequences (e.g. those from EBV), on the basis that there are examples of
unintended gene sequences ending up in transgenic plants. There are also no studies on HGT in cattle
intestinal bacteria and parasites (page 21) or soil biota. ERMA stated that these controls were
“impractical” (page 21). We contend
that they are not impracticable impractical. Rather, they are necessary controls that simply require a little
time and effort to undertake. If they
are deemed to be unreasonable due to cost or practicality, we consider that it
is unreasonable to approve the application.
In addition, monitoring for HGT at the disposal sites will be done by
AgResearch. Self monitoring has rarely
resulted in full, accurate and timely disclosure by groups with a vested
interest in being quiet. All monitoring
needs to be done by independent experts on a monthly basis. ERMA requires that if HGT is detected, the
project will be halted and a remediation plan developed. However, a remediation plan should be
created before the experiments begin, covering all possible adverse
eventualities. Such a plan would also
highlight any impracticalities in remediation which may in turn limit the
project. It would also prevent a lag
time of possibly months between finding a problem and determining a remediation
plan, precious time during which GM micro-organisms could be growing
exponentially and the problem could become seriously worse irretrievably worsen.
26.
ERMA has given a seven and a half year
approval to this broad application. A
year-by-year re-approval process should have been instigated, after monthly
monitoring and a thorough yearly inspection and audit, so that if AgResearch
was found to not be following controls, the operation could be shut-down.
27.
When
considering the “establishment of an undesirable self-sustaining
population and ease of eradication” (page23 22 of the Decision), ERMA limits its context
to feral cattle populations only. This
is a serious oversight, as management strategies for dealing with
micro-organisms having undergone HGT should also be is also mandatory. Furthermore, medical experience, such as
hospitals trying to eradicate multi-resistant staphylococcus aureus should be
drawn upon. Such experience shows that
even closed indoor facilities have problems in managing microbial populations,
and hence it is ill advised to even consider managing GM animals in open
environments, such as fields.
CONCLUSION
28.
On the basis of the above, we believe that
AgResearch’s application should be reconsidered, and that at this time,
relevant medical, scientific and public health information and advice should be
used to determine the outcome of the application. If the application goes ahead, we recommend that more substantial
containment be undertaken in order to reduce the risks. This has the advantages of permitting
scientific research whilst substantially reducing the risks of exposure of GM
DNA and organisms to humans and the environment. In particular, we recommend:
(a)
A secure containment building(s) be built to
hold these animals and their products.
(b)
Once in the facility, all animals and their
products stay in and are not permitted to leave. This includes all cows, bulls, semen, ova, embryos, foetuses,
faeces, urine, skin, meat, milk etc.
(c)
All dead animals and their products listed
above, when no longer required are to be incinerated at temperatures high
enough to eliminate all prions and DNA.
As a result of their recent experiences with Mad Cow Disease, the UK has
procedures for this. This incinerator
would be built on-site to prevent the escape of any DNA or prions from the site.
(d)
All humans when in contact with these
animals and their products wear gowns, gloves and masks and are not permitted
to eat or drink.
(e)
All windows have fine mesh screens on them
to prevent the entry of flying insects such as flies, mosquitoes, and midges.
(f)
Measures be taken to prevent the entry and
breeding of mice, rats, cockroaches, etc, and these measures to include the
laying of poisons to eradicate them from the site.
(g)
Ideally, no antibody resistant marker genes
be used. If this is not possible, then
only those coding for antibiotics defined to be of no clinical importance by a
panel of medical and veterinary clinicians would be used.
(h)
Monitoring of insertion sites, genetic
material, unintended gene sequences etc, as well as processes and procedures by
a team of independent experts on a monthly basis and heavy penalties be imposed
for breaches. The licence would be
reviewed every year, and any breaches result in the removal of the licence.
(i)
A remediation plan would be developed by a
team of independent experts before the facility is permitted to begin
operation.
29.
I have read the Code of Conduct for Expert
Witnesses contained in Schedule 4 of the High Court Rules and agree to comply
with the Code.
SWORN
at Adelaide )
this day of April 2003 )
before me: ) ______________________________
Judith
Anne Carman
____________________________________
A
Solicitor of the High Court of New Zealand/Notary Public