Thank you for an additional opportunity for FAWC to comment on the draft GMO (deliberate release) Regulations for England.

We are disappointed to see that applications for consent to release GMOs still do not require the applicant to carry out a "Welfare risk assessment" where the GMO involves live animals (mature or reproductive material). We would re-iterate the point made in our earlier submission that animal welfare protection for GM animals, and those coming into contact with them in domestic or wild populations, must be included in risk assessments before any release of GM animals should be approved.

This point is expressed in paragraph 6 of the Overview of Responses to your first consultation (page 69 of the second consultation) and we would support the call to take note of the work of the Royal Society, the Animals Procedures Committee (APC) and the Agriculture and Environment Biotechnology Commission (AEBC).

The APC Biotechnology Report (2000) suggested that GM techniques should not be used for frivolous ends or in ways that disrespected the integrity of animal kinds, treating them as if they were merely toys to be rearranged at our whim. So it is unlikely that any research licences will be issued in the UK for the production of such animals. Unfortunately this doesn't prevent their being produced elsewhere, and introduced into the UK environment. This should be resisted if it is at all possible.

We would therefore draw your attention to two relevant recommendations in the recently published AEBC Report on Animals and Biotechnology (3rd September 2002). These recommend that: Post-commercialisation monitoring of GM and cloned farm animals should be planned to look for unexpected welfare or health problems; and The international movement of GM and cloned animals and reproductive material should be monitored. A comprehensive welfare risk assessment prior to release of GM animals is an essential component in such a control system.

FAWC Secretariat
September 2002