When GMOs become dangerous goods on the road

The transport of genetically modified organisms (GMOs) makes many collaborations with national or international research groups possible. A distinction is generally made between two transport routes. First, there is the internal transport of GMOs, which constitutes genetic engineering work according to the Genetic Engineering Act (GenTG). The measures that must be observed when handling GMOs are usually regulated by the relevant state authorities. These are listed in the approval notices (if approval has been obtained) or in the statements on genetic engineering work, some of which are prepared by the approval authorities. But what exactly is "internal"? It is clear that this refers, for example, to transport within a facility. But what if, for example, a university has several genetic engineering facilities and GMOs are transported from one facility to another? This is the case, for example, if working group A cooperates with another working group B. Working group A has cloned a gene, and this gene is to be biochemically characterized in B. B needs the recombinant GMO for larger-scale analyses and wants to produce the microorganisms themselves. The E. coli must therefore change groups. This is genetic engineering work, even if it takes place within the company (i.e., the university's premises). Universities are usually the operators of the genetic engineering facilities. Important: The E. coli not only change groups, but also the project manager. This genetic engineering work must be documented in both groups. How a GMO is to be packaged depends, of course, on the risk group. If different working groups cooperate in technology parks, the GMOs may not be transported within the company, because the genetic engineering facilities are located at different companies, i.e., operators. The GMOs are therefore transported outside the company and are subject to the guidelines for the transport of dangerous goods. In technology parks, this may only be a few hundred meters. It is important that the receiving laboratory obtain any necessary registrations or permits for carrying out the intended genetic engineering work before transport. The ZKBS has compiled helpful documentation on this topic on its website under the heading "Transport of Genetically Modified Organisms." One of the most important is the information sheet "Transport of Genetically Modified Organisms in Accordance with the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR). Accordingly, GMOs are subject to dangerous goods transport regulations if they meet the criteria for dangerous goods class 6.2 or 9. For classification, the individual criteria can be found in the aforementioned information sheet. It should be noted here that there are also GMOs that are not subject to dangerous goods regulations. Quote: "Furthermore, those GMOs that fall under neither the definition of Class 6.2 nor that of Class 9 are not subject to the ADR. These would be those GMOs that are neither infectious (Class 6.2) nor capable of altering animals, plants, or microbiological substances in a way that does not normally result from natural reproduction. For example, this could apply to plants that are propagated purely vegetatively. Microorganisms in Risk Group 1, which are recognized as a biological safety measure, or waste and wastewater from genetic engineering facilities, if they meet certain requirements, could also fall under this category. This would have to be decided on a case-by-case basis."