Fines for the project manager’s duties

We reiterate: If a task or its failure to comply with it does not constitute an offense punishable by a fine, it cannot be punished with a fine. In this respect, it is worthwhile to compare Section 14 of the GenTSV and Section 38 of the GenTG.

Section 14 (1) No. 8 GenTSV stipulates that the project manager is responsible for immediately notifying the operator of any incident that does not correspond to the expected course of the genetic engineering work or release and where there is a suspicion of a threat to the legal interests designated in Section 1 No. 1 of the Genetic Engineering Act. Section 38 GenTG does not contain any fines for errors or failure to report by the project manager to the operator. Section 20 GenTSV also does not provide for fines for errors or failure to report by the project manager to the operator. Therefore, the genetic engineering authority cannot impose a fine on the operator if the project manager fails to report incidents or fails to report them properly. It is undisputed that such behavior can have consequences under employment law.