Fines for the project manager’s duties

Upon appointment by the operator, the project manager assumes the obligations under Section 14 of the Genetic Engineering Act (GenTG) by operation of law. We have already reported on this in various newsletters. However, the assumption that a violation of these statutory obligations is always subject to fines is incorrect. This is already clear from a comparison of the fines referred to in Section 38 of the Genetic Engineering Act. In this respect, it should be pointed out again that the offenses listed in Section 38 Nos. 1 - 12 of the Genetic Engineering Act are exhaustive. If a violation is not included there, it cannot be punished with a fine under the Genetic Engineering Act. In this respect, a comparison between Section 14 of the Genetic Engineering Act and Section 38 of the Genetic Engineering Act is worthwhile. In the following newsletters – beginning in February 2019 – the individual obligations of the project manager under Section 14 of the Genetic Engineering Act will be discussed again in a series with regard to the fines they carry.