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Application A592 – Food Derived from Glyphosate-tolerant Soybean MON 89788 – Draft Assessment Report

18 September 2007

Dear Sir/Madam

Thank you for the opportunity to comment on this application. The New Zealand Food Safety Authority (NZFSA) has the following comments to make.

NZFSA has had the report reviewed by the Institute of Environmental Science and Research Limited (ESR). As a result of this review, we have a comment to make concerning the data provided. The only issue in the characterisation of the gene construct and analysis of the novel protein in MON 89733 relates to the chloroplast targeting peptide utilised to deliver the CP4 EPSPS protein to the chloroplast. It is stated in the assessment that after delivery the peptide is rapidly degraded and that no residual targeting peptide is expected to remain in the tissues of MON 89788. However, no statement is provided in the report to indicate whether any assessment for residual targeting peptide was actually undertaken. Comment needs to be included in the FAR on whether any assessments were performed, and if not a justification for the assumption that the peptide was fully degraded should be provided.

Yours sincerely