Comment to the APVMA – Draft Operational Notice – Data requirements for herbicides used in GM crops

    29 January 2013

    CropLife’s submission in respect of the APVMA’s ‘Draft Operational Notice – Data requirements for herbicides used in genetically modified crops’ raises a number of concerns, including:

    1. The APVMA has provided no scientific justification for limiting the Operational Notice to GM herbicide tolerant crops when the three areas of risk identified in the Operational Notice are relevant to all herbicide tolerant crops, regardless of production method.
    2. The scope of the Operational Notice does not accurately identify the range of applications that would be subject to the Notice.
    3. The Notice presently lacks consistency in regard to how it describes the method by which the herbicide is to be applied to the crop.