ENVIRONMENTAL RISK MANAGEMENT AUTHORITY DECISION Amended under s67A on 16 August 2007 21 April 2006 GMD06008 To develop in containment genetically modified organisms under sections 40(1)(b) and 42A of the Hazardous Substances and New Organisms (HSNO) Act 1996. HortResearch, Palmerston North Applicant The aim of the research is to understand insect gene function Purpose and regulatory elements, such as promoters, terminators and enhancers, involved in insect growth, development, behaviour, digestion, olfaction and other traits. 20 21 March 2006 Date received Consideration date 22 21 April 2006 Chief Executive, ERMA New Zealand Considered by Application code Application type 1 Summary of decision 1.1 The application to develop, as a project, genetically modified organisms in containment is approved, with controls, having been considered in accordance with the relevant provisions of the Hazardous Substances and New Organisms (HSNO) Act 1996 (the Act), the HSNO (Low-Risk Genetic Modification) Regulations 2003 (the Low-Risk Regulations), and the HSNO (Methodology) Order 1998 (the Methodology). The organisms approved are: 1.2 The organisms approved for development are described in Table 1: Table 1: Organisms as recorded on ERMA New Zealand Register For the purposes of creating insect gene libraries: Bacteriophage lambda (Enterobacteria phage λ)1 Non-pathogenic Name of the host organism: Category of the host organism: What the organism is modified with: commercially available laboratory strains of bacteriophage lambda. 1 Genomic DNA or complementary DNA (cDNA) isolated from lepidopteran, coleopteran, hemipteran, orthopteran, hymenopteran and dipteran insects. Category of the modification: Donor DNA will be derived from the insect families listed below the table but will exclude genetic material derived from species listed by the Convention on International Trade in Endangered Species (CITES). A Containment level: PC1 Name of the host organism: Escherichia coli (Migula 1895) Castellani & Chalmers 1919 non-pathogenic laboratory strains. 1 Category of the host organism: What the organism is modified with: Standard Escherichia coli bacteriophage lambda vectors containing genomic DNA or complementary DNA (cDNA) isolated from lepidopteran, coleopteran, hemipteran, orthopteran, hymenopteran and dipteran insects. Category of the modification: Donor DNA will be derived from the insect families listed below the table but will exclude genetic material derived from species listed by the Convention on International Trade in Endangered Species (CITES). A Containment level: PC1 1 International Committee on Taxonomy of Viruses (ICTV) approved name. Environmental Risk Management Authority Decision: GMD06008 Page 2 of 14 For the purposes of insect gene cloning and expression: Names of the host organisms: Escherichia coli (Migula 1895) Castellani & Chalmers 1919 non-pathogenic laboratory strains. Category of the host organisms: What the organisms are modified with: Autographa californica nucleopolyhedrovirus2 (Chapman and Glasier 1915, Allen 1921) AcMNPV nonpathogenic laboratory strains. 1 Standard Escherichia coli and insect cloning and expression plasmid vectors containing genomic DNA or cDNA as sense or antisense constructs. The genetic material will consist of genes and regulatory elements involved in insect development, olfaction such as pheromone receptors, gustation, insecticide resistance and response such as esterase genes, host resistance, digestion and gene regulation. Donor DNA will be derived from the insect families listed below the table. The genetic material may be modified by insertion3, deletion, alteration of sequences or site-directed mutagenesis, and by the addition of regulatory elements such as promoter and terminator sequences derived from baculoviruses, (Autographa californica nucleopolyhedrovirus (AcMNPV) and Epiphyas postvittana nucleopolyhedrovirus (EppoNPV)) or from the list of donor insects described below. Vectors will include promoters and other gene regulatory elements, reporter and selectable marker genes, protein purification tags and origins of replication, but the modifications will exclude any of the following: Material from species listed by the Convention on International Trade in Endangered Species (CITES). Genes encoding known or suspected vertebrate toxins with an LD50 < 100 µg/kg. Category of the modification: A Containment level: PC1 Names of the host organisms: Spodoptera frugiperda (JE Smith, 1797) cell lines, such as Sf9 and Sf26. Trichoplusia ni (Hübner 1803) cell lines, such as Tn5. Epiphyas postvittana (Walker, 1863) cell lines. 1 Category of the host organisms: 2 3 International Committee on Taxonomy of Viruses (ICTV) approved name. Insertion of up to 250 bp of artificially created DNA Environmental Risk Management Authority Decision: GMD06008 Page 3 of 14 What the organisms are modified with: Standard Escherichia coli and insect cloning and expression plasmid vectors, and Autographa californica nucleopolyhedrovirus vectors containing genomic DNA or cDNA as sense or antisense constructs. The genetic material will consist of genes and regulatory elements involved in insect development, olfaction such as pheromone receptors, gustation, insecticide resistance and response such as esterase genes, host resistance, digestion and gene regulation. Donor DNA will be derived from the insect families listed below the table. The genetic material may be modified by insertion4, deletion, alteration of sequences or site-directed mutagenesis, and by the addition of regulatory elements such as promoter and terminator sequences derived from baculoviruses, (Autographa californica nucleopolyhedrovirus (AcMNPV) and Epiphyas postvittana nucleopolyhedrovirus (EppoNPV)) or from the list of donor insects described below. Vectors will include promoters and other gene regulatory elements, reporter and selectable marker genes, protein purification tags and origins of replication, but the modifications will exclude any of the following: Material from species listed by the Convention on International Trade in Endangered Species (CITES). Genes encoding known or suspected vertebrate toxins with an LD50 < 100 µg/kg. Category of the modification: A Containment level: PC1 Names of the host organisms: Apis mellifera (Linnaeus, 1758), Cydia pomonella (Linnaeus, 1758), Drosophila melanogaster (Meigen, 1830), Epiphyas postvittana (Walker, 1863), Helicoverpa armigera (Hübner, 1808), Hofmannophila pseudospretella (Stainton, 1849), Myzus persicae (Sulzer, 1776), Phthorimaea operculella (Zeller, 1873), Scolypopa australis (Walker, 1851), Spodoptera litura (Fabricius, 1775), Teleogryllus commodus (Walker), Tineola bisselliella (Hummel, 1823) – whole insects 2 Category of the host organisms: What the organisms are modified with: 4 Autographa californica nucleopolyhedrovirus vectors containing genomic DNA or cDNA as sense or antisense constructs. The genetic material will consist of genes and regulatory elements involved in insect development, olfaction such as pheromone receptors, gustation, insecticide resistance and response such as esterase genes, host resistance, digestion and gene regulation. Insertion of up to 250 bp of artificially created DNA. Environmental Risk Management Authority Decision: GMD06008 Page 4 of 14 Donor DNA will be derived from the insect families listed below the table. The genetic material may be modified by insertion5, deletion, alteration of sequences or site-directed mutagenesis, and by the addition of regulatory elements such as promoter and terminator sequences derived from baculoviruses, (Autographa californica nucleopolyhedrovirus, AcMNPV and Epiphyas postvittana nucleopolyhedrovirus, EppoNPV) or from the list of donor insects. Vectors will include promoters and other gene regulatory elements, reporter and selectable marker genes, protein purification tags and origins of replication, but the modifications will exclude any of the following: Material from species listed by the Convention on International Trade in Endangered Species (CITES). Genes encoding known or suspected vertebrate toxins with an LD50 < 100 µg/kg. Category of the modification: B Containment level: PC2 Donor DNA will be derived from the following insect families: Lepidopteran insects: Tortricid family including Epiphyas postvittana and Cydia pomonella. Noctuid family including Helicoverpa armigera and Spodoptera litura. Oecophorid family including Hofmannophila pseudospretella. Teneid family including Tineola bisselliella. Gelechilid family including Phthorimaea operculella. Lymantrid family including Teia anartoides Bombyxicid family including Bombyx mori Orygid, Hyponomeutid, Pierid, Hepialid, Geometrid and Pyralid families Coleopteran insects: Scarabaeid, Cerambycid, Chrysomelid, Bruchid, Tenebrionid and Curculonid families Hemipteran insects: Aphidid, Pentatomid, Ricaniid, Mirid, Eriococcid, Coccid and Diaspid families including Scolypopa australis and Myzus persicae Orthopteran insects: Gryllid and Acridid families including Telleogryllus commodus Hymenopteran insects: Siricid, Formicid, Vespid and Apid families including Apis mellifera Dipteran insects: Cecidomycid, Calliphorid, Muscid, Drosophilid and Culicid families including Drosophila melanogaster 5 Insertion of up to 250 bp of artificially created DNA Environmental Risk Management Authority Decision: GMD06008 Page 5 of 14 2 Legislative Criteria for Application 2.1 The application was lodged pursuant to section 40(1)(b) of the Act and determined according to the rapid assessment provisions of section 42A of the Act. 2.2 The application has been approved with controls by Mr Rob Forlong, Chief Executive of ERMA New Zealand, under delegation from the Authority as provided for in section 19 of the Act. 3 Consideration Sequence of the consideration 3.1 The application was formally received and verified as containing sufficient information on 21 March 2006. 3.2 The decision was based on the information supplied by the applicant in their application form: Develop in containment a project of low risk genetically modified organisms by rapid assessment (ER-AF-NO3P-1). 3.3 It was determined that further information was required to complete the assessment of this application. The Authority authorised the obtaining of this information under section 58(1)(b) of the HSNO Act 1996, and the applicant was notified accordingly. The consideration of this application was postponed under section 58(3) of the HSNO Act 1996, until the information was obtained. 3.4 The application was considered by the Chief Executive of ERMA New Zealand. Relevant staff within ERMA New Zealand, including the Acting Manager Māori, were involved in providing advice on the consideration of the application. 3.5 The development of the genetically modified organism described above (Table 1) meets the criteria of a low-risk genetic modification specified in the Regulations made under section 41 of the Act, being the HSNO (LowRisk Genetic Modification) Regulations 2003. 3.6 In reaching my decision I have used information that is relevant and appropriate to the scale and significance of the risks, costs, and benefits associated with the genetic modifications and matters relevant to the purpose of the Act, as specified in Part II, and followed the relevant provisions of the Methodology. 3.7 In accordance with section 42A of the Act for rapid assessment, the approach adopted was to identify the circumstances of the genetic modification, to evaluate these against the criteria specified in section 41 of the Act, and to consider whether there are any residual risks that require further consideration. This approach covered the following issues: Purpose of the application (section 39 of the Act) Environmental Risk Management Authority Decision: GMD06008 Page 6 of 14 Assessment against the criteria for low-risk genetic modification (section 42A of the Act) Identification and assessment of the risks and other impacts of the organism Precedents Proposed controls 3.8 The Department of Conservation (DoC) was notified upon receipt of this application. 3.9 DoC responded with comments on the application by email on 27 March 2006 , and concluded with the following statement: “The Department considers that the containment system is adequate to contain the host organisms and the modifications are not expected to change the ability of the host organisms to escape containment. Therefore, based on the low likelihood of escape from containment, the Department considers that the overall risk to its mission from the developed microorganisms to be negligible”. Purpose of the application 3.10 The purpose of this project is to analyse insect genes, and DNA elements regulating expression such as promoters, transcriptional and translational enhancers, to determine their function in insect development and biochemical processes. The genes of interest will be genes which have been identified via a bioinformatics approach as being likely to be involved in: insect development, olfaction such as pheromone receptors, gustation, insecticide resistance and response such as esterase genes, host resistance and gene regulation. 3.11 Transient, stable and viral expression studies will be carried out in insect cell lines, and transient expression of genes or parts of genes may also be performed in whole insects by injecting these insects with modified baculoviruses. The host insects for these experiments have been specifically chosen as ones in which the virus (AcMNPV baculovirus) cannot replicate, with the exceptions of Helicoverpa armigera and Spodoptera litura, in which the AcMNPV baculovirus can establish an infection. Understanding the function of insect genes and regulatory elements will offer the potential to develop new methods of influencing insect development, behaviour, physiology and other traits and thus allow the control of pest species. 3.12 I have determined that this application is for a valid purpose being the development of any [new] organism as provided for in section 39(1)(a) of the Act. Environmental Risk Management Authority Decision: GMD06008 Page 7 of 14 Assessment against the criteria for low-risk genetic modification 3.13 Category of host organisms: Laboratory strains of Escherichia coli (non-pathogenic), bacteriophage lambda, Autographa californica nucleopolyhedrovirus (AcMNPV) (nonpathogenic strains) and insect cell lines from Spodoptera frugiperda, Trichoplusia ni, and Epiphyas postvittana, are Category 1 host organisms as defined in clause 7(1) of the HSNO (Low-Risk Genetic Modification) Regulations 2003. These organisms are not capable of causing disease in humans, animals, plants or fungi nor do they produce desiccation-resistant structures, such as spores or cysts. Non-pathogenic laboratory strains of bacteriophage lambda are viral hosts, frequently used for the establishment of genomic DNA and cDNA libraries as these vectors can contain large fragments of genetic material. The host organism Autographa californica nucleopolyhedrovirus (AcMNPV) can be infectious to insect cell lines. It is noted that the laboratory strains have been disarmed, by having the polyhedrin gene deleted. These strains are unable to infect moths or survive outside the laboratory. The insects, Epiphyas postvittana, Spodoptera litura, Helicoverpa armigera, Drosophila melanogaster, Cydia pomonella, Hofmannophila pseudospretella, Tineola bisselliella, Phthorimaea operculella, Scolypopa australis, Myzus persicae, Teleogryllus commodus, and Apis mellifera, are category 2 host organisms as defined by clause 7(2)(iii) of the HSNO (LowRisk Genetic Modification) Regulations 2003, as these are whole insects. 3.14 Category of genetic modification: The proposed genetic modifications to established laboratory strains of Escherichia coli, bacteriophage lambda, Autographa californica nucleopolyhedrovirus and insect cell lines from Spodoptera frugiperda, Trichoplusia ni, and Epiphyas postivittana, are not expected to increase the pathogenicity, virulence or infectivity of the organisms to laboratory personnel, the community, or the environment. In addition, the developments will not result in the organisms having a greater ability to escape from containment than the unmodified organisms. Therefore, the genetic modifications as described in Table 1 of this decision are Category A genetic modifications as defined in clause 5(1) of the HSNO (Low-Risk Genetic Modification) Regulations 2003 and require a minimum of Physical Containment Level 1 (PC1). The proposed injection of genetically modifed baculoviruses into whole insects will not increase the pathogenicity, virulence, infectivity or the ability of the insects to escape from containment. Therefore, the genetic modifications as described in Table 1 of this decision are Category B genetic Environmental Risk Management Authority Decision: GMD06008 Page 8 of 14 modifications as defined in clause 5(4)(b) of the HSNO (Low-Risk Genetic Modification) Regulations 2003 and require a minimum of Physical Containment Level 2 (PC2). 3.15 I am satisfied that the development meets the criteria for low-risk genetic modification specified in the Regulations, made under section 41 of the Act. The experiments on Escherichia coli, bacteriophage lambda, Autographa californica nucleopolyhedrovirus and the insect cell lines, meet the requirements of Category A modifications as defined in clause 5 of the Regulations in that the modification involves a category 1 host organism and is to be carried out under a minimum of PC1 containment. 3.16 Injection of Autographa californica nucleopolyhedrovirus into the whole insects meet the requirement of Category B genetic modifications as defined in clause 5(4)(b) of the HSNO (Low-Risk Genetic Modification) Regulations 2003 and require a minimum of PC2 containment under the MAF/ERMA New Zealand Standard 154.02.08 ‘Transitional and Containment Facilities for Invertebrates’. Identification and assessment of the risks, costs and other impacts of the organisms 3.17 I consider that the information provided by the applicant is relevant and appropriate to the scale and significance of the risks, costs, and benefits associated with the application (as required by clause 8 of the Methodology). In accordance with clauses 9 and 10 of the Methodology the information supplied by the applicant has been evaluated as follows: 3.18 I consider that, given the controls attached to this approval, there is no evidence for, nor any reason to expect, any non-negligible adverse effects of the proposed genetically modified organism on humans, animals, plants, other organisms or the environment. 3.19 I have considered the potential Māori cultural effects in accordance with sections 6(d) and 8 of the Act and clauses 9(b)(i), 9(c)(iv) of the Methodology, in consultation with the Acting Manager, Māori. 3.20 As this application does not involve the use of genetic material from native or valued flora and fauna from New Zealand or DNA sourced from Māori, and as this application is for a development in containment, there is no requirement for the applicant to consult with Māori. 3.21 Although recognising that iwi/Māori maintain an ongoing interest and concern in the potential long term cultural implications of genetic modification generally, I consider that this application poses negligible risk of adverse effects to the relationship of Māori culture and traditions with their ancestral lands, water, sites, waahi tapu, valued flora and fauna, and other taonga. Environmental Risk Management Authority Decision: GMD06008 Page 9 of 14 Precedents 3.22 I must consider each application on its merits, and am therefore not bound by the stance taken in previous decisions. However, in reflecting on previous decisions that involved similar genetic modifications to those proposed by this application, I note that low-risk genetic developments of non-pathogenic Escherichia coli, bacteriophage lambda, Autographa californica nucleopolyhedrovirus, and insect cell lines, have been considered and approved on many occasions by Institutional Biological Safety Committees (IBSCs) under delegated authority and by the Chief Executive of ERMA New Zealand. 3.23 I consider that this current application does not raise any novel issues that would warrant it not to be considered via section 42A of the Act. However, several issues have been raised as to whether in the process of infection of whole insects with a genetically modified virus, the insect becomes genetically modified for the purposes of the HSNO Act. Different conclusions can be reached depending on how section 2 of the HSNO Act which defines a genetically modified organism is interpreted and also on how the HSNO (Organisms Not Genetically Modified) Regulations 1998, is interpreted. I note though, that the classification of the insects as being either genetically modified or non genetically modified makes no difference to the ability to contain the insects or the containment standards and controls imposed. 3.24 Previous applications have taken the approach that organisms involved in transient transfections of recombinant DNA molecules meet the definition of genetically modified organisms for the purposes of the HSNO Act. I consider that this issue would benefit from further policy work. For this application, these insects will be considered as category 2 host organisms which are genetically modified by infection with the modified baculoviruses. This decision however, does not set a precedent as to how the Authority will consider future decisions with regard to this issue. Containment 3.25 The proposed genetic modifications on category 1 hosts, Esherichia coli, bacteriophage lambda, Autographa californica nucleopolyhedrovirus and the insect cell lines, meet the requirements of Category A genetic modifications as defined in clause 5 of the HSNO (Low-Risk Genetic Modification) Regulations 2003. Category A experiments are required to be contained within a Physical Containment level 1 facility (PC1) registered under MAF/ERMA New Zealand Standard 154.03.02 ‘Containment Facilities for Microorganisms’. The containment regime contains clear guidelines for the safe handling and disposal of bacterial cultures and biological wastes. 3.26 The facility in which the organisms will be maintained shall comply with the requirements of the Australian New Zealand Standard AS/NZS 2243.3:2002 Safety in Laboratories: Part 3: Microbiological aspects of containment and facilities, except for the deviations specified in the MAF/ERMA New Zealand Standard 154.03.02. The laboratory proposed to Environmental Risk Management Authority Decision: GMD06008 Page 10 of 14 be used by the applicant is currently approved and registered as a containment facility under section 39 of the Biosecurity Act, in accordance with the MAF/ERMA New Zealand Standard 154.03.02. 3.27 Transient expression of insect genes will be studied by injecting genetically modified baculoviruses into whole insects. This procedure meets the requirements of Category B genetic modification as defined in clause 5(2) of the HSNO (Low-Risk Genetic Modification) Regulations 2003. Category B experiments are required to be contained within a Physical Containment level 2 facility (PC2). The facility to be used shall be registered to the MAF/ERMA New Zealand Standard 154.02.08 ‘Transitional and Containment Facilities for Invertebrates’, and comply with the requirements within the relevant sections of the Australian New Zealand Standard AS/NZS 2243.3:2002. I consider the provisions within that Standard requiring all insect and biological waste to be made non-viable prior to disposal, to be adequate to ensure that the experimental organisms approved by this decision, are fully contained. 4 Decision 4.1 I am satisfied that this application is for one of the purposes specified in section 39(1) of the Hazardous Substances and New Organisms Act 1996, being section 39(1)(a): the development of any [new] organism. 4.2 Based on consideration and analysis of the information provided, and having considered the characteristics of the organism that is the subject of this approval, the modification and the criteria for low-risk genetic modification detailed in the HSNO (Low-Risk Genetic Modification) Regulations 2003, I am of the view that these organisms meet the criteria for rapid assessment under section 42A of the Hazardous Substances and New Organisms Act 1996. 4.3 I am satisfied that the proposed containment regime and the controls imposed in accordance with section 42A(3)(b) of the Hazardous Substances and New Organisms Act 1996, as set out below, will adequately contain the organism. 4.4 Pursuant to section 42A(3)(a) of the Hazardous Substances and New Organisms Act 1996, and acting under delegation from the Authority provided for in section 19 of the Act, I have approved this project application for the genetically modified organisms described in Table 1 of this decision, subject to the controls specified herein. 4.5 In reaching this decision I have relied upon the following criteria in the Act and the Methodology: Criteria for assessing the purpose of the application (section 39 of the Act) Criteria for rapid assessment of adverse effects for the development of a genetically modified organism in containment (section 42A of the Act). Environmental Risk Management Authority Decision: GMD06008 Page 11 of 14 Criteria for a low-risk genetic modification specified in the HSNO (Low-Risk Genetic Modification) Regulations 2003, made under section 41 of the Act. The information provided by the applicant was assessed against the criteria in clauses 9, 10 and 12 of the HSNO (Methodology) Order 1998. Matters to be addressed by containment controls for developing genetically modified organisms specified in Part 1 of the Third Schedule to the Act. 5 Controls In order to provide for the matters detailed in Part 1 of the Third Schedule of the Act6, Containment Controls for Importation, Development and Field Testing of Genetically Modified Organisms, and other matters in order to give effect to the purpose of the Act, the approved organism is subject to the following controls: 1 To limit the likelihood of any accidental release of any organism or any viable genetic material7. 1.1 The approved organisms shall be developed and maintained within a containment facility which complies with these controls. 1.2 The person responsible for a particular research area and/or the person responsible for the operation of the containment facility shall inform all personnel involved in the handling of the organism of the Authority’s controls. 1.3 The facility shall be approved and registered by MAF as a containment facility under section 39 of the Biosecurity Act, in accordance with the MAF/ERMA New Zealand Standard (below), and controls imposed by the Authority (as follows): 1.4 The construction and operation of the containment facility shall be in accordance with: a) MAF Biosecurity Authority/ERMA New Zealand Standard 154.03.028: Containment Facilities for Microorganisms. b) Australian New Zealand Standard AS/NZS 2243.3:20028: Safety in Laboratories: Part 3: Microbiological Aspects and Containment Facilities. 6 Bold headings in the following text refer to Matters to be Addressed by Containment Controls for Import, Development and Field Testing of Genetically Modified Organisms, specified in the Third Schedule of the Act. 7 Viable Genetic Material is biological material that can be resuscitated to grow into tissues or organisms. It can be defined to mean biological material capable of growth even though resuscitation procedures may be required, e.g. when organisms or parts thereof are sub-lethally damaged by being frozen, dried, heated, or affected by chemical. 8 Any reference to this standard in these controls refers to any subsequent version approved or endorsed by ERMA New Zealand Environmental Risk Management Authority Decision: GMD06008 Page 12 of 14 c) Physical Containment Level 1 (PC1) requirements of the above standards for Escherichia coli, bacteriophage lambda, Autographa californica nucleopolyhedrovirus (AcMNPV), and insect cell lines from Spodoptera frugiperda, Trichoplusia ni, and Epiphyas postvittana. 1.5 The construction and operation of the containment facility shall be in accordance with: d) MAF Biosecurity Authority/ERMA New Zealand Standard 154.02.088: Transitional and Containment Facilities for Invertebrates. e) Australian New Zealand Standard AS/NZS 2243.3:20028: Safety in Laboratories: Part 3: Microbiological Aspects and Containment Facilities. f) Physical Containment Level 2 (PC2) requirements of the above standards for Epiphyas postvittana, Spodoptera litura, Helicoverpa armigera, Drosophila melanogaster, Cydia pomonella, Hofmannophila pseudospretella, Tineola bisselliella, Phthorimaea operculella, Scolypopa australis, Myzus persicae, Teleogryllus commodus, and Apis mellifera 2 To exclude unauthorised people from the facility. 2.1 Construction and operation of the containment facility shall comply with the requirements of the standards listed in control 1.4 and 1.5 relating to the identification of entrances, numbers of and access to entrances and security requirements for the entrances and the facility. 3 To exclude other organisms from the facility and to control undesirable and unwanted organisms within the facility. 3.1 Construction and operation of the containment facility shall comply with the requirements of the standards listed in control 1.4 and 1.5 relating to the exclusion of other organisms from the facility and the control of undesirable and unwanted organisms within the facility. 4 To prevent unintended release of the organism by experimenters working with the organism. 4.1 Construction and operation of the containment facility shall comply with the requirements of the standards listed in control 1.4 and 1.5 relating to the prevention of unintended release of the organism by experimenters working with the organism. 5 To control the effects of any accidental release or escape of an organism. 5.1 Construction and operation of the containment facility shall comply with the requirements of the standards listed in control 1.4 and 1.5 relating to controlling the effects of any accidental release or escape of an organism. Environmental Risk Management Authority Decision: GMD06008 Page 13 of 14 5.2 If a breach of containment occurs, the facility operator must ensure that the MAF Inspector responsible for supervision of the facility has received notification of the breach within 24 hours. 5.3 In the event of any breach of containment of the organism, the contingency plan for the attempted retrieval or destruction of any viable material of the organism that has escaped shall be implemented immediately. The contingency plan shall be included in the containment manual in accordance with the requirements of standards listed in control 1.4 and 1.5. 6 Inspection and monitoring requirements for containment facilities. 6.1 The operation of the containment facilities shall comply with the requirements contained in the standards listed in control 1.4 and 1.5 relating to the inspection and monitoring requirements for containment facilities. 6.2 The containment manual shall be updated, as necessary, to address the implementation of the controls imposed by this approval, in accordance with the standards listed in control 1.4 and 1.5. 7 Qualifications required of the persons responsible for implementing those controls. 7.1 The training of personnel working in the facility shall be in compliance with the standards listed in control 1.4 and 1.5. _____________________ _____________ Rob Forlong Date Chief Executive, ERMA New Zealand Approval code (BCH code): GMD004226 – GMD004242 (12181 – 12197) Amendment: November 2006 Changes to controls: Addition of footnotes to the containment facility references and the Australian/New Zealand containment facility references to “future proof” the decision Standardise the wording of the breach of containment control Removal of the control regarding inspection of facilities by the Authority, its agent or enforcement officers ____________________________ Mr Rob Forlong Chief Executive, ERMA New Zealand Environmental Risk Management Authority Decision: GMD06008 16 August 2007 Date: Page 14 of 14