Advice on import and processing of GT73 oilseed rape

This advice concerns an application for import and processing of genetically modified GT73 oilseed rape. GT73 expresses the goxv247 and cp4 epsps genes conferring tolerance and resistance to glyphosate containing herbicides.
Oilseed rape has established itself in the Netherlands and is present across the country in small, local populations that are nearly always located on highly disturbed soil. Oilseed rape is present close to locations where seed spillage occurs or where oilseed rape is cultivated and does not establish well in existing vegetations.
Oilseed rape is mainly a self-pollinating species, but outcrossing (30%) may occur. Controlled pollination studies have pointed out that oilseed rape can outcross with several of the wild relatives that occur in the Netherlands. Most hybrids have a severely reduced fertility. Exceptions are hybrids obtained from crosses between oilseed rape (B. napus) and B. rapa.
The establishment of small populations of GT73 oilseed rape on locations where glyphosate is frequently applied to control weeds e.g. on railway tracks, cannot be excluded. Apart from the tolerance to glyphosate containing herbicides, GT73 does not differ from conventional oilseed rape. If small GT73 populations would become established, these could cross-fertilize other oilseed rape (B. napus) plants and/or wild relatives, in particular B. rapa. Apart from the glyphosate tolerance trait, the resulting progeny does not possess a higher fitness and is not different from progeny arising from cross-fertilization with conventional oilseed rape varieties.
The molecular characterization of GT73 does not give any reason to expect adverse effects. It is adequately performed and meets the criteria laid down by COGEM.
However, since the application does not contain a post-market monitoring plan COGEM considers the application to be incomplete.
COGEM recommends involving railway companies and/or companies in charge of the maintenance of railway tracks in the post-market monitoring plan in order to monitor the occurrence of GM oilseed rape along railway tracks. There is a small chance that cross-fertilizaton could lead in the future to the ‘stacking’ of several transgenes in a single oilseed rape plant. COGEM is of the opinion that stacking of the traits present in currently authorized oilseed rape varieties will not lead to an environmental risk because under natural conditions these traits are unlikely to lead to an increased fitness or a selective advantage. However, in view of future applications and to increase knowledge it is important to know whether stacked events arise in order to allow future risk assessments to take the putative presence of established GM oilseed rape with stacked traits into account. A putative stacked event would most likely occur in a location where herbicides are frequently used, such as railway tracks. Therefore, COGEM advises to monitor the occurrence of GM oilseed rape along railway tracks in addition to the monitoring of industrial sites that is usually carried out by operators involved in import and processing of GM crops.
In conclusion, although COGEM is of the opinion that in view of the present conditions import and processing of GT73 oilseed rape poses a negligible risk to the environment, COGEM cannot finalize its opinion on import and processing of GT73 due to the absence of a post-market monitoring plan.