Comment from OGM dangers
OGM dangersOpposeIndividual
Summary: The commenter opposes the proposed action, arguing that the regulatory framework favors companies over the public and fails to adequately address the risks of releasing genetically modified microorganisms (GMMs). They demand strict requirements, including unlimited liability for polluters, free detection kits for the public, and long-term biomonitoring.
Dear regulator,
Various questions are raised. I reply successively below.
Question 1
Should there be no difference, why could there be any patent? Do we agree that patent mustnot be given to any discovery? This is a pure dilemma. Either it is patentable and then it is different (by essence) with nature, or it is not patentable, and everything is possible.
You could object that GMMicroorganisms do differ in essence, but not « in plant risk ». Yes. It’s up to you to prove it.
You also could object that GMMicroorganisms do not differ in essence (from conventionnal ones) and so they would be riskless and so would need not any risk management. This is funny. Who would claim conventionnal microorganism are intrinsically riskless? Even the most stupid ecologists would never claim this. And APHIS would dare to support this?
Question 2
Even though we did not have any experience of managing the risk of releasing GMM, we hope never to have to do so. Do we ask the polluters to say whether the release of their pollution « could have been improved »? APHIS seems to be strongly in connection with those who release and not with those who will be polluted.
In any case, our strongest claim is that provided there is no liability (limitless!), and no management process with a detection and identification free of charge available to anyone, there should be no release.
Question 3
APHIS cares more about the costs of relase than about who will pay the damages. And please do not claim there will never be any damage. Unless, employees of APHIS will be charged for them;)
Question 4
On the roads, no velocity detection enables to overcome the velocity limits. But it is unsafe.
Question 5
What company does raise only the benefits and not the risks? Why the risks are not asked? Ah yes, they would be charged to the populations with the benefits for companies? Please say it frankly. Asking only for the benefits without asking for the damages is very biased.
Question 6
6.1) full risk assessment in containers (for the limited case of containers)
6.2) detection kit with the control samples available to all free of charge so as to detect and identify the GMM.
6.3) possibility to decontaminate any location (field or not) from the GMM at the expense of the releaser.
6.4) biomonitoring of all the release made by the company for at least 20 years. In case of bankruptcy, insurances must have been taken limitless.
Question 7
Why should « smaller entities » relase less risky GMM? APHIS is funny in its questions.
Question 8
Risks for those who did not ask for anything must not pay for the benefits of some companies (whether small or not). The State defends the citizens and not only the companies. Unless there will come a day when nobody will trust the State and nobody will profit by this (neither the State nor the citizens).