ENVIRONMENTAL RISK MANAGEMENT AUTHORITY DECISION Amended under s67A on 16 August 2007 3 April 2006 GMD06009 To develop in containment genetically modified organisms under sections 40(1)(b) and 42A of the Hazardous Substances and New Organisms (HSNO) Act 1996. Victoria University of Wellington Applicant To mate and genetically modify gene deletion strains of Baker's Purpose yeast (Saccharomyces cerevisiae) ("YGDS") to study the gene networks underlying traits in organisms 20 20 March 2006 Date received Consideration date 22 3 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 1.3 Genetically modified Saccharomyces cerevisiae (non-pathogenic laboratory strains BY4741, BY4742 and BY4743) that have been imported under ERMA New Zealand approval GMC00128 (application code GMC05018) will be mated pair-wise, to develop genetically modified yeast strains carrying double deletions that are the subject of this approval. These pair-wise mated strains, and parental strains will be modified further as described in Table 1 below: The organisms approved for development are described in Table 1: Table 1: Organisms as recorded on ERMA New Zealand Register Host organism Category Modified by: of host organism Escherichia coli (Migula 1895) Castellani & Chalmers 1919 non-pathogenic laboratory strains Saccharomyces cerevisiae Meyen ex EC Hansen (1883) non-pathogenic laboratory strains 1 Cloning and expression yeast / E. coli shuttle plasmid vectors, E. coli bacterial matingassisted genetically integrated cloning (MAGIC)1 plasmids containing DNA fragments from E. coli, S. cerevisiae and mammalian sources (e.g. Homo sapiens, Mus musculus). Donor DNA will contain regulatory elements, non-coding regions and coding regions of genes encoding proteins belonging to the following functional families of proteins: Sensory proteins Gene expression regulators Kinases and phosphatases Nucleotide cyclases, phosphodiesterases and cyclic nucleotide binding proteins Sigma factors DNA replication and modification proteins Transcription and translation proteins Cell division proteins Cell cycle proteins Chaperones and stress-related proteins Protein and peptide secretory proteins Surface proteins, adhesins and antigens Signal transducers Cell envelope synthesis proteins Small molecule and macromolecule metabolism proteins Protein translocation and compartmentation proteins Secretory pathway and retrograde transport proteins Regulonic complexes Vector DNA will include selectable markers, reporter genes, protein purification tags, E. coli and yeast origins of replications. Genetic material from humans to be sourced from gene banks, or commercially available cell lines. 1 Utilises bacterial mating, in vivo site-specific endonuclease cleavage and homologous recombination to catalyse the transfer of a DNA fragment between a donor vector in one bacterial strain and a recipient plasmid in a separate bacterial strain (Li and Elledge, 2005). Environmental Risk Management Authority Decision: GMD06009 Page 2 of 11 Category of modification/ containment level A/PC1 Host organism Category of host organism Modified by: Saccharomyces cerevisiae Meyen ex EC Hansen (1883) - deletion strains derived from parental BY4741, BY4742 and BY4743 strains. 1 Yeast 2-microns cloning and expression plasmids containing yeast genes encoding proteins from the families of proteins listed below, and their specific regulatory elements, for the over-expression of these genes. Site-directed mutagenesis, homologous recombination of altered genes or gene deletions or mutations in genes encoding proteins belonging to the following functional families of proteins: Sensory proteins Gene expression regulators Kinases and phosphatases Nucleotide cyclases, phosphodiesterases and cyclic nucleotide binding proteins Sigma factors DNA replication and modification proteins Transcription and translation proteins Cell division proteins Cell cycle proteins Chaperones and stress-related proteins Protein and peptide secretory proteins Surface proteins, adhesins and antigens Signal transducers Cell envelope synthesis proteins Small molecule and macromolecule metabolism proteins Protein translocation and compartmentation proteins Secretory pathway and retrograde transport proteins Regulonic complexes Vector DNA will include selectable markers, reporter genes, protein purification tags, E. coli and yeast origins of replications, conditional (ts & tet-sensitive) promoters. Environmental Risk Management Authority Decision: GMD06009 Page 3 of 11 Category of modification/ containment level A/PC1 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 20 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 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. 3.4 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. 3.5 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. 3.6 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) 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 Environmental Risk Management Authority Decision: GMD06009 Page 4 of 11 3.7 The Department of Conservation (DoC) was notified upon receipt of this application. 3.8 DoC responded with comments on the application by email on 24 March 2006 , and concluded with the following statements: “The applicant proposes to contain the developed organisms in a facility that meets minimum of Physical Containment Level 1 (PC1) according to the Ministry of Agriculture Forestry (MAF) Standard 154.03.02 Containment Facilities for Microorganisms. The Department consider that the proposed containment system is adequate to contain the host organisms and the proposed modifications are not expected to change the ability of the host organisms to escape containment. Therefore, base 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 3.9 The purpose of this application is to develop and apply gene network analysis around fundamental cellular processes. The applicant proposes to characterise the role of Saccharomyces cerevisiae genes in the network specification of phenotypes, by genetic knockouts, gene mutations and overexpression of genes. 3.10 Modified strains of S. cerevisiae with every possible gene deletion within the yeast genome were imported into containment under ERMA New Zealand approval code GMC001288 (application code GMC05018). Gene networks underlying traits will be studied by examining the phenotypic effects in yeast strains when two knockout mutants are combined by pairwise mating. Synthetic lethality occurs when two knockouts having no observable phenotype on their own, are lethal when combined as a double deletion. When interactions between pairs of synthetically lethal genes overlap, gene networks can be identified. A complementary part of the project is the over-expression of certain genes to assess for compensation of deletion mutations. 3.11 Chemical inhibitors can ablate gene function by binding to the protein products of genes, serving in lieu of knockout mutations. The applicant also intends to characterise the role of S. cerevisiae genes in the susceptibility or resistance to small compound chemical inhibitors. 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: GMD06009 Page 5 of 11 Assessment against the criteria for low-risk genetic modification 3.13 Category of host organisms: The non-pathogenic laboratory strains of Saccharomyces cerevisiae and Escherichia coli to be used by the applicant are not capable of causing disease in humans, animals, plants or fungi nor do they produce desiccationresistant structures, such as spores or cysts. As such, these microorganisms are considered Category 1 host organisms as defined in clause 7(1) of the HSNO (Low-Risk Genetic Modification) Regulations 2003. 3.14 Category of genetic modification: The proposed genetic modifications to the non-pathogenic laboratory strains of S. cerevisiae and E. coli 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). 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 S. cerevisiae and E. coli 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. Identification and assessment of the risks, costs and other impacts of the organism 3.16 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: 3.17 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. 3.18 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. Environmental Risk Management Authority Decision: GMD06009 Page 6 of 11 3.19 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. 3.20 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. Precedents 3.21 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 S. cerevisiae and E. coli 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. 3.22 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. Containment 3.23 The proposed genetic modifications on category 1 hosts, S. cerevisiae and E. coli 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. 3.24 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 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. 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. Environmental Risk Management Authority Decision: GMD06009 Page 7 of 11 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 the organism meets 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 genetically modified non-pathogenic laboratory strains Saccharomyces cerevisiae and Escherichia coli as 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). 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. Environmental Risk Management Authority Decision: GMD06009 Page 8 of 11 5 Controls In order to provide for the matters detailed in Part 1 of the Third Schedule of the Act2, 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 material3. 1.1 The approved organism 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 154.03.02: Containment Facilities for Microorganisms4. b) Australian New Zealand Standard AS/NZS 2243.3:20024: Safety in Laboratories: Part 3: Microbiological Aspects and Containment Facilities. c) Physical Containment Level 1 (PC1) requirements of the above standards for S. cerevisiae and E. coli. 2 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. 3 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. 4 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: GMD06009 Page 9 of 11 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 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 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 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 relating to controlling the effects of any accidental release or escape of an organism. 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. 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 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. Environmental Risk Management Authority Decision: GMD06009 Page 10 of 11 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. _____________________ _____________ Rob Forlong Date Chief Executive, ERMA New Zealand Approval code (BCH code): GMD004217 – 18 (12071 – 72) 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: GMD06009 16 August 2007 Date: Page 11 of 11