Introduction
What is your first name?
First name
Owen
What is your surname?
Surname
Gwilliam
Are you providing a submission as a representative of, or in support of, an organisation?
Please select one item
(Required)
Radio button:
Ticked
Yes
Radio button:
Unticked
No
If yes, what is the name of the organisation?
Australian Organic Limited
What is your position in the organisation (if relevant)?
Chief Technical Officer
Part 1 - Definitions to Support the National Gene Technology Scheme
Q1: What other objectives might guide the updating of definitions?
Response
Nothing to add
Q2: How might we improve the regulatory flexibility of definitions within the National Gene Technology Scheme, whilst maintaining protections for human health and the environment?
Response
It is vital that collaboration between the Scheme and the Departments of Agriculture, and Foreign Affairs and Trade occurs to ensure producers' and processors' production methods are considered, and to thoroughly assess trade implications – including certified organic produce exports.
Q3: What other issues should be taken into account when considering how best to ensure that humans are not regulated as GMOs?
Response
Nothing to add
Q4: Given the benefits and challenges of defining terms in legislation, what other mechanisms might be used to provide the clarity required?
Response
Nothing to add
Part 2 - Risk-Proportionate Regulation Through Risk Tiering and Appropriate Regulatory Approaches
Q5: Are there any other key objectives/considerations that should be taken into account in designing a risk-proportionate approach to regulation?
Response
The objective of not impinging upon a producer’s choice to farm organically if they wish, and similarly, a consumers choice to buy and consume organic produce, should they wish to do so.
While gene technology advocates may consider the release of certain modified or edited genetic material into the environment as low risk, organic producers and consumers should have available a means to avoid these technologies, as is their right to do so.
Organic certification has provided this means thus far, and the regulation of this technology has facilitated this. We request that regulations help the organic industry track, and avoid this technology (and progeny organisms), as our farmers and consumers demand.
While gene technology advocates may consider the release of certain modified or edited genetic material into the environment as low risk, organic producers and consumers should have available a means to avoid these technologies, as is their right to do so.
Organic certification has provided this means thus far, and the regulation of this technology has facilitated this. We request that regulations help the organic industry track, and avoid this technology (and progeny organisms), as our farmers and consumers demand.
Q6: What additonal risk tiers could be considered and what criteria could be applied to determining what falls in or out of any required tiers?
Response
Regardless of risk tier classifications, a mechanism to allow organic producers, and organic consumers to avoid this technology, and produce derived from this technology, must be available. Methods for traceability and testing will be required, even for those deemed by the Scheme to be low risk.
Q7: Is the introduction of additional risk tiers the only way to ensure regulation is proportionate to the level of risk?
Response
Nothing to add
Q8: What principles or criteria should be applied in moving an organism/technique across risk-tiers?
Response
Nothing to add
Q9: Are there any elements of the Scheme that would NOT benefit from a principles/outcome-based approach?
Response
Nothing to add
Part 3 - Streamlining Regulatory Requirements and Processes to Reduce Regulatory Burden
Q10: What other objectives might guide streamlining of regulatory requirements?
Response
The objective of maintaining lucrative export markets for produce that can be verified to have been produced without the use of these technologies. Any streamlining must ensure organic and non-organic produce export markets are not negatively impacted.
Q11: Are there any particular issues to be considered when streamlining any of these regulatory requirements?
Response
A means of tracking, tracing, and testing for these technologies must be available to allow maintenance of lucrative export markets, to allow organic farmers, and organic consumers their right to choose to avoid these technologies
Q12: What mechanisms or tools would reduce the regulatory burden and administrative burden on the end user interacting with the regulator/regulatory system?
Response
Nothing to add
Q13: Are there any particular issues to be considered when streamlining any of these regulatory processes?
Response
Nothing to add
Q14: Are there any other key processes that might be streamlined without impacting the safety of people or the environment?
Response
Nothing to add
Q15: What specific areas are suitable for harmonisation between regulators? Are there any overlaps that could be removed?
Response
The Department of Agriculture regulates the export of organic produce from Australia. This facilitates market access that may not be available without this strong regulation. Consideration of the requirements of the National Standard for Organic and Bio-Dynamic Produce, and collaboration with the Department’s Organic Program will be required to prevent exports to these markets being negatively impacted.
Q16: What are some of the ways in which the role of IBCs could be strengthened to achieve efficiencies in a co-regulatory model?
Response
Nothing to add
Q17: What could be some avenues that would empower the Regulator to make decisions about changes to regulatory requirements and processes deemed low-risk?
Response
Nothing to add