Risks of off-site transport

External transport is also common in work with genetically modified organisms (GMOs). ... The institute moves from point A to point B, taking the mice with it in the trunk of its car; a friendly research group provides a "surefire system" for infecting cells in the cafeteria; organisms are shipped from a parent company to a subsidiary for further processing, etc. ... The number of practical examples is endless.

It should be noted that the regime under which off-site transport must be carried out is completely different from that for on-site transport. The Genetic Engineering Act (GenTG) does not contain any regulations for purely off-site transport. This applies both to the question of who is responsible for it and to the question of how such transport must be carried out and where it may ultimately lead. In this respect, the GenTG is certainly clear: Section 3 No. 2b) GenTG states that the on-site transport of genetically modified organisms is also genetic engineering work; this, in turn, means that off-site transport is no longer genetic engineering work and is therefore no longer subject to the licensing regime and the liability regime (including administrative offenses and criminal offenses), nor to monitoring by the genetic engineering authorities. This applies at least as long as there is no release, i.e. no deliberate introduction of GMOs into the environment (Section 3 No. 5 GenTG).

To be on the safe side during off-site transport, the operator of a genetic engineering facility should be familiar with the regime that applies to off-site transport in order to avoid any omissions.