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. 6 of the GenTSV stipulates that the project manager, upon appointment, is responsible for informing the BBS/Committee for Biological Safety. Section 38 of the GenTG does not provide for fines for errors or failure to inform the BBS. Section 20 of the GenTSV also does not provide for fines for errors in informing the BBS or for the lack of such information. Therefore, the genetic engineering authority cannot impose a fine on the project manager if the project manager fails to inform the BBS or fails to inform the BBS adequately.