The Ministry of Infrastructure and the Environment wants to develop a comprehensive assessment framework for use in all its policy areas that involve risk and safety issues. In 2014, as part of this process the ministry published a policy paper called ‘A Considered Approach to Safety: Recurrent Themes’ [Bewust omgaan met veiligheid: rode draden]. As genetically modified organisms (GMOs) are one of the topics in the ministry’s ‘safety domain’, COGEM has investigated how the policy for GMO authorisation matches up to the ten principles set out in the policy paper.
COGEM concludes that the GMO authorisation procedures are fully or partially in line with some of the principles for a considered approach to safety (transparency, responsibility, precaution and future-proofing). However, they do not align, both in terms of policy and (logically) the implementation of that policy, with the principles of appraisal, security and safety, and integrating innovation with safety.
GMO policy leaves little or no room for political judgement on the balance between costs and benefits, because GMOs are only permitted if the risks are negligible. As a result, some potential gains for society may be missed and innovation frustrated.
In addition, GMO policy does not perform well against the principles of transparency and involvement. Some authorisation procedures are hardly transparent to third parties (for example, for contained use and marketing authorisation for GM medicines). The possibilities for involving citizens in the decision-making process are for practical purposes limited by the conditions on submitting representations.