The Netherlands Commission on Genetic Modification (COGEM) is an independent scientific advisory committee composed of scientists. The main functions of COGEM are to give statutory advice to the Dutch Minister of Environment on the risks to human health and the environment from experiments under contained conditions (laboratories, greenhouse, production facilities) with Genetically Modified Organisms (GMOs), and the release and marketing of GMOs, and to inform the Dutch government of ethical and societal issues linked to genetic modification.
On the 19th of August we visited COGEM in Bilthoven to discuss the ethical and legal implications of our project. Frank Van der Wilk was our host.
Frank noted that application of our project near the Waddenzee is impossible since the Waddenverdrag (Convention of the Wadden Sea) does not allow any genetically modified organisms in the protected nature reserve that is the Waddenzee. If this was not the case, there are three level levels on which genetically modified organisms can be allowed in the Netherlands.
Contained use. This covers activities involving the use of GMOs in laboratories, production facilities, greenhouses or animal houses.
Deliberate release. Any intentional introduction of a GMO into the environment for which no specific containment measures are used to limit the contact of the GMO with the environment. These are mainly field experiments with GMOs, like field experiments with genetically modified plants or clinical gene therapy experiments.
Placing on the market. Making GMOs available to third parties, whether in return for payment or free of charge. Placing on the market of GMOs is regulated in a centralised European procedure.
Since Blue Bio Energy would fit the third category, its use would have to be allowed at the European level. This would require extensive analysis of risks. If a genetically modified organism can be proven to be harmless, its escape into nature would probably be deemed acceptable. For any organism to fit this description it should certainly not be pathogenic. Sometimes the organism to which modifications are applied is already present in the environment. This is considered a strong argument in favor of allowing the modified organism, if the modifications can be shown to be harmless.
If it can be proven that modifications of an organism do not lead to a “gain of function”, chances of it being allowed on the market are further increased. In any case, it has to be proven by reasoning or by experiment that the organism is harmless to the environment in which it is released. Frank notes that our organism might not fit this description. For example, the antimicrobial properties we wish to give our biofilm might harm other microorganisms. The increased biofilm formation might also cause the bacteria to aggregate in (for example) mussels, which are an important part of the Waddenzee ecosystem (not to mention the local economy).
COGEM does not just consider strict pathogenicity of organisms, which is usually meant to apply only to people, plants and animals. Instead, they prefer to look at the total environmental impact an organism has.
Frank knows of no regulations governing the spreading of genetically modified organisms to international waters.
Finally, biological containment is considered. This would mean the engineering of some kind of dependence on the factory environment or the carrier surface, such that if the bacteria leaves the plant it will not survive. Such a construction would have to be non-reversible (it should not be deactivated by random mutations) and its efficiency has to be no less than 100% --- a small number of escaped bacteria quickly grow to a large colony.
One final consideration is the origin of the DNA that is used in the modified organisms. It is considered a big bonus if the DNA is taken from an organism found in the environment in which the modified bacteria will be released; this decreases the risks involved in horizontal transfer of DNA. In fact, if your host organism is also found in the environment, it is likely that a version of it with the extra DNA already exists somewhere in the environment.