With the anticipated learn more development of biopesticides and other agents containing dsRNAs intended to transverse epidermal layers of plants or target insects ( Monsanto and Zhang et al., 2013), contact exposure may

also have to be considered. CTNBio is a consulting and deliberating multidisciplinary collegiate body that establishes safety technical norms for the authorization of research-related activities and the commercial use of GMOs and their by-products, based on Biosafety Law 11.105/2005 and their normatives (e.g. Normative Resolution no 5 regarding risk assessments rules). In its deliberations, CTNBio uses information given to it from the developer of the technology as well as submissions sent by independent scientists and the community (Ordinance no. 373, article 2nd). Independent scientists raised safety questions to this body during the decision making process for approval in Brazil of a GM variety of pinto bean (Phaseolus vulgaris) event 5.1. The bean was made virus resistant through induced RNAi ( Aragão and Faria, 2009). In this example, we will focus our discussion on the scientific arguments presented by researchers at the Federal University of Santa Catarina (UFSC) (Agapito-Tenfen and Nodari, 2011) that were submitted to CTNBio and CTNBio’s technical report (CTNBio, 2011). The transgenic pinto bean was genetically modified using particle bombardment, which introduced an insert of about 50 kbp into

the bean genome (Aragão and Faria, 2010b). From this insert an intron-hairpin construction (i.e., a rep cassette) was transcribed to induce post-transcriptional DAPT cost gene silencing against the AC1 gene of the Bean Gold Mosaic virus ( Bonfim et al., 2007). Similar to the wheat example above, the hairpin RNA mimics a miRNA. In this case, the dsRNA Teicoplanin is capable of silencing the viral mRNA for the replication protein. However, the mechanism by

which the viral protection occurs in this specific event is unknown (see page 12 of Aragão and Faria, 2010b). Similar to the case of FSANZ, CTNBio has accepted uncertainties about the underlying biochemistry of the trait in their decision to grant approval. The Brazilian Agricultural Research Corporation (Embrapa) claimed confidentiality about the details of the DNA sequence and associated molecular characterizations of the product (see page 12 of Aragão and Faria, 2010b). This was agreed by CTNBio (see pages 1 and 6 of CTNBio, 2011). As with the case described in Example 2 above, an independent evaluation of the actual sequences used in the GM pinto beans was impossible. In addition, there appear to be more details granted confidentiality than just the DNA sequence, further complicating attempts to provide the regulator with external opinions (Supplementary Data). The Embrapa 5.1 event that was assessed has truncated copies of the rep cassette, including one copy in the anti-sense orientation, and plant genome sequences incorporated adjacent to the rep cassette ( Aragão, 2011 and Aragão and Faria, 2010a).