APHIS has an opportunity, through this Request for Information (RFI), to reaffirm and refine a risk-based approach to the regulation of GE organisms under the Plant Protection Act and Coordinated Framework. We strongly recommend that APHIS (1) continue to maintain risk-based oversight of GE plants, insects, and microorganisms under 7 CFR part 340; (2) refrain from shifting oversight to 7 CFR part 330 unless and until PPQ has developed a transparent, science-based framework comparable to BRS’s; and (3) ensure that any future changes to regulatory responsibilities preserve protections for public health, international trade, and public trust while enabling timely deployment of beneficial innovations. Read Full Letter
