STEPS TOWARDS A COMPREHENSIVE POST MARKET ENVIRONMENTAL MONITORING OF GENETICALLY MODIFIED ORGANISMS Position Paper of the Joint ENCA / EPA Interest Group on Risk Assessment and Monitoring

The current implementation of post market environmental monitoring (PMEM) requires improvement. Monitoring possible changes due to the cultivation of genetically modified plants is highly important to protect our environment. The obligatory pre-release risk assessment of GMO products might not address all open questions and possible effects, due for instance to the complexity of receiving environments. Post market environmental monitoring (PMEM) (see figure) of GMO-induced changes is therefore crucial for the protection of the environment and mandatory in most European countries. However, the currently implemented PMEM plans do not meet the standards set by legal bases and existing guidelines, and need substantial improvement. PMEM must be appropriate to monitor environmental impacts of GMO. To achieve this goal, scientifically sound PMEM based on reliable data should be implemented in all receiving environments that might be affected by GM plants. The monitoring design, sampling methodology and data analysis have to comply with fundamental quality criteria like correctness, comparability and reproducibility. Authorisation holders as well as developers of PMEM guidelines need to consider all relevant protection goals (biodiversity, water and soil) in order to warrant