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Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7692]
POSTED ON BEHALF OF JANNE ØVREBØ BOHNHORST ----- Dear participants of the Online Forum, It is an honour to me to moderate this discussion on “Risk assessment of living modified fish” (22 February – 7 March) and I thank the Secretariat for the invitation. Before embarking on the objective of the discussion, let me please draw your attention to the following excerpts from two documents that provide the frame and scope for our discussion: **From the AHTEG terms of reference in decision BSVII/12** “While revising and improving the Guidance, an attempt should be made to take into account the topics prioritized by the AHTEG, on the basis of the needs indicated by the Parties with a view to moving towards operational objectives 1.3 and 1.4 of the Strategic Plan and its outcomes, for the development of further guidance.” **From the report of the AHTEG meeting** The AHTEG decided to recommend to the COP-MOP the development of additional guidance on ‘risk assessment of LM fish’ and ‘risk assessment of LMOs produced through synthetic biology’. The Group will prepare outlines on the two topics for the COP-MOP in order to facilitate its consideration and further development of the topics as separate guidance. In accordance with what was agreed upon at the last AHTEG meeting, our present discussion will focus on gathering views, information and sources of information or references on risk assessment of living modified fish. The objective is to use this space to gather views on how an annotated outline for standalone guidance on risk assessment of LM fish in accordance with the Cartagena Protocol would look like. This outline will be submitted to the COP-MOP at its meeting in December 2016, and the Parties will decide whether or not this guidance is needed and, if so, how it could be developed. Please note that the focus of this discussion is NOT on whether additional guidance should be developed on this topic. Therefore, with a view to moving forward and not going back to what was already decided by the AHTEG, I kindly ask you to refrain from sharing views on whether or not you support the development of such guidance. For instance, we could start with a basic skeleton of the outline consisting of the following elements: 1. Background 2. Overview of the current status of development of living modified fish 3. Potential positive impacts of living modified fish 4. Potential negative impacts of living modified fish 5. Assessing the risks of living modified fish 6. Conclusions 7. References My specific questions to you are: - How would you improve the outline above? - What considerations would you like to see under each of the main sections of the outline? - Can you recommend reference materials that are “directly” relevant to the risk assessment of LM fish? In preparing your interventions, I encourage you to visit an earlier discussion that was held under this forum on risk assessment of LM fish, including an introduction to the topic, which is available at http://bch.cbd.int/onlineconferences/lmofish_ra.shtml as well as the selected readings on the topic at http://bch.cbd.int/onlineconferences/readings_ra.shtml#fish. I look very much forward to the discussion and your valuable input. Best regards, Janne
posted on 2016-02-22 00:33 UTC by Ms. Manoela Miranda, UNEP/SCBD
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7693]
Dear Janne A very quick response to the proposed skeleton. I think we need to be more consitent with the already produced guidance documents under the AHTEG if we envisage merging all the work done in a single document at later stage.
This is the skeleton that has been used for the SPECIFIC TYPES OF LMOS AND TRAITS
1. Introduction 2. Objective and Scope 3. Planning Phase of the Risk Assessment 4. Conducting the Risk Assessment 5. References
and I propose we start with it. Regards, O.A.El-Kawy
posted on 2016-02-22 18:32 UTC by Mr. Ossama AbdelKawy, Mauritania
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7695]
Dear Janne,
Thank you for moderating this forum.
A very quick response from my side too. I support Mr. AbdelKawy (7693) that the GDs need to be consistent, not only for possible future merging but also for their practicality when applied by the end-users. Different structures will only create confusion.
Kind regards, Maria
posted on 2016-02-23 08:28 UTC by Maria Kammenou
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7701]
Dear Janne, Dear all,
Thank you for the opportunity to contribute to this forum.
In line with posts made by previous participants (see [#7693] and [#7695]) I would like to feed this discussion with some comments about its objectives and the underlying process. And I will end with a concrete proposal.
What we have in front of us at this point of time is a RECOMMENDATION of the AHTEG to develop an additional guidance on “risk assessment of LM fish”. The final decision whether or not such a specific guidance should effectively be developed is the responsibility of the COP-MOP. I fully agree that we should refrain from sharing views on whether or not the development of such guidance is needed. But I am of the opinion that the primary objective of this forum should be to provide views, relevant elements and sources of information to help the COP-MOP to consider whether the risk assessment of LM fish should be the topic of a specific guidance.
As stated in the introductory post ([#7692]), para 37 of the last AHTEG report states that the Group will prepare an outline on this topic for the COP-MOP in order to facilitate its consideration and further development of the topic as separate guidance. I think we should focus our exchanges of views on the first aspect (“to facilitate the consideration of the topic as a separate guidance”), knowing that the views expressed in that context will be useful anyway if a separate guidance should finally be developed. Indeed it does not make sense to collect views on how a guidance would look like without knowing whether a specific guidance is the best way to support the risk assessment of LM fish in the context of the Protocol.
I would also like to add that it is unclear to me on which basis the AHTEG, in the context of the risk assessment of LM fish, recommends to the COP-MOP the development of additional guidance vs. addressing specific risk assessments aspects of this topic (in any) through the improvement of the existing Roadmap. It would be beneficial for the discussion to have this information.
In my opinion, the basic skeleton of the outline as proposed in the introductory post is not appropriate for this discussion. It is too broad and goes beyond the context and scope of Annex III of the Protocol. We should keep in mind that a separate guidance (if any) should be used as an addendum to the Roadmap which itself is an explanatory tool showing how to proceed in the steps and points to consider described in paragraphs 8 and 9 of Annex III of the CPB. We should also keep in mind that an important objective of the Roadmap and any specific guidance attached to it is to provide users with a structured document pointing them to relevant background materials (references).
I therefore propose to use an outline similar to what has been used in previous discussions (e.g. for the guidance on GM trees). The basic skeleton of the outline could consist of the following elements: 1. Experiences (in general) in conducting risk assessment of LM fish 2. Experiences in using the latest version of the Roadmap in conducting risk assessment of LM fish 3. Difficulties in using the latest version of the Roadmap in conducting risk assessment of LM fish 4. Risk assessment aspects that are unique to this topic (if any) 5. Recommendations on how to address these unique aspects (if any) in the context of the CPB 6. Reference materials that are “directly” relevant to the risk assessment of LM fish
This kind of approach should inform the COP-MOP on (i) whether the risk assessment of LM fish deserves specific considerations that are not covered by the Roadmap and the relevant background materials that are currently available, and (ii) how these specific considerations (if any) should be addressed (better access to background documents, improvement of the Roadmap, standalone guidance…).
Thank you again Janne for your hard work in moderating this forum.
Best regards,
Didier Breyer Scientific Institute of Public Health Brussels, Belgium
posted on 2016-02-24 19:03 UTC by Didier Breyer
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This is a reply to 7701
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7702]
Dear All,
WE SHOULD FOCUS ON THE FOLLOWING:
1. Earlier experiences in conductingthe risk assessment of LM fish 2. Experiences in conducting risk assessment of LMOs 3. Difficulties in conducting risk assessment of LM fish 4. Risk assessment aspects that are unique to LM fish 5. Recommendations to address the unique aspects
Thanks,
HARI Sharma
posted on 2016-02-25 11:42 UTC by Hari Sharma, India
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7703]
Dear all
We consider important this forum concerning to the guidance on risk assessment of LM fish, because at least in México there are so many question about it, but also, we consider important do not forget that the risk assessment of GM fish should follow the methodologies established in documents like the “Guidance on Risk Assessment of Living Modified Organisms” that includes: 1) An identification of any novel genotypic and phenotypic characteristics associated with the living modified organism, 2) An evaluation of the likelihood of adverse effects being realized, 3) An evaluation of the consequences should these adverse effects be realized, 4) An estimation of the overall risk posed by the living modified organism based on the evaluation of the likelihood and consequences of the identified adverse effects and 5) A recommendation as to whether or not the risks are acceptable or manageable.
Besides, it is important to define clear protection goals, taking into account the receiving environment and the changes that may occur in it.
Best regards,
posted on 2016-02-25 16:10 UTC by Mr. Rafael Romero, Mexico
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7707]
First of all I want to express my gratitude to Janne. Thanks for moderate this online set of discussions.
I want to share some thoughts. Last year we had a workshop on GM fish, where it was clear to me that there is still a wide concern on its release and use not only in Mexico but worldwide. I am not particularly specialized in GM fish but I have been working in risk assessment and biosafety issues since 2006 in Colombia and Mexico, and I am involved in research projects about the centers of origin and diversity of useful species. There has been important scientific progress in the last decades on species that are involved in GMO projects, and this has led to more complex analyses on their potential impacts. I believe it is really important to follow the original line of the other guidelines, as Ossama said in his intervention. However, it is also important to accept that for each group of species (or maybe technologies, synthetic biology for example) it will be necessary to take some additional points into account regarding the case by case approach, which is a keystone of the Cartagena Protocol.
Regarding GM fish, I think that two additional aspects must be considered and included in the guideline: * Monitoring strategies; and * Traceability mechanisms.
Finally, I am particularly concerned on the invasiveness capacity of this kind of organisms. There are some eficientefficient methodologies to assess invasiveness, which could be used and taken into account before the authorization and release of any GM species.
Best regards,
M. Andrea
posted on 2016-02-25 17:30 UTC by Ms. María Andrea Orjuela Restrepo, Mexico
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This is a reply to 7702
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7709]
POSTED ON BEHALF OF DAVID A. MBAH -------------------------------------------------- Dear All, Yes, some focus on experiences in conducting risk assessment(and risk management) of LMOs may be useful particularly for those(like Cameroon) just getting into the process. David A. Mbah.
posted on 2016-02-25 18:52 UTC by Dina Abdelhakim, SCBD
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This is a reply to 7709
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7710]
The AHTEG discussed whether there was a need of a separate guidance document for LM fish or if it was sufficient to add language to the Roadmap in the form of text boxes, references or other, if needed, to address the risk assessment of LM fish. In the end there was no agreement among all the members that a separate guidance was necessary. Some considered that the Roadmap did not provide enough elements to assess LM fish, those that considered that a separate document was not needed based this on the understanding that a good Roadmap should be a document that guides on the assessment of any LMO. But should finally be a decision taken by the Parties at the next COP-MOP
To facilitate this task for the COP-MOP, I concur with the points to consider proposed by Didier Breyer in post #7701.
Esmeralda Prat
posted on 2016-02-28 19:45 UTC by Ms. Esmeralda Prat, CLI representation
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This is a reply to 7702
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7711]
Dear All,
Thanks to Janne for making time to moderate this forum.
Thanks also to Didier Breyer for focusing on the task ahead: i.e. to provide views and materials that can help the COP-MOP to decide whether the risk assessment of LM fish should be the topic of a specific guidance annexed (in whatever way) to the road map.
I agree with the specific points that Didier and Hari Sharma suggested as the elements for the COP-MOP to take into consideration.
In addition, I would the following elements: 1) The number of cases of releases of LM fish that are currently in preparation 2) Relevant work of other relevant international bodies in this field
This forum is an excellent opportunity to collect data regarding point 1.
I trust that the Secretariat is in contact with other relevant bodies that will allow it to collect information regarding point 2.
Regards to all
Piet
posted on 2016-02-29 07:42 UTC by Mr. Piet van der Meer, Ghent University, Belgium
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This is a reply to 7711
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7714]
Dear colleagues,
thank you very much Janne for chairing this important discussion and for guiding us through the debate.
I would also like to thank all the experts who have provided their thoughts so far.
Didier Breyer (7701) has raised some questions concerning the discussion of the AHTEG on that matter and to some extent Esmeralda Prat (7710) and Piet van der Meer (7711) have followed up on that.
As AHTEG chair and hopefully for the benefit of the discussion I would like to provide some clarification on what the AHTEG has discussed on that matter and which recommendations have been reached in Brasilia:
The discussion centered as to whether to develop separate guidance on specific topics (e.g. risk assessment of LM fish and of LMOs developed through synthetic biology; the latter pending the outcomes of the SBSTTA meeting) or to continue to work on developing the Roadmap in such a manner that it would be applicable and sufficient to address all types of LMOs, traits and receiving environments so that no additional guidance on specific topics would be needed.
As a compromise, the AHTEG then decided to recommend to the COPMOP the development of additional guidance on the two topics mentioned above, while for other topics it was decided to make an attempt to add relevant information in the Roadmap (see AHTEG Report and previous round of online discussion). To make use of the ramaining time up to the COPMOP, the AHTEG also decided that outlines should be developed by the Group on the two topics. These two outline should facilitate the final decision of the COPMOP on whether to develop specific guidance on risk assessment of LM fish and of LMOs developed through synthetic biology.
At the AHTEG meeting we also recalled an earlier COPMOP decision - BS-IV/11 of COPMOP 4 in 2008 - where the COP-MOP mandated the AHTEG to:
"(ii) Taking into consideration the identified need for further guidance on specific aspects of risk assessment, including particular types of (i) living modified organisms (for example, fish, invertebrates, trees, pharmaplants and algae); (ii) introduced traits; and (iii) receiving environments, as well as monitoring of the long-term effects of living modified organisms released in the environment, prioritize the need for further guidance on specific aspects of risk assessment and define which such aspects should be addressed first, taking also into account the need for and relevance of such guidance, and availability of scientific information;"
I hope with this I have provided some more insight into the discussions of the AHTEG in Brasilia. I am looking forward to further posts in this discussion round. Kind regards
Helmut Gaugitsch (AHTEG Chair)
posted on 2016-02-29 17:27 UTC by Mr. Helmut Gaugitsch, Austria
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This is a reply to 7714
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7720]
Dear all, Thanks to Janne for accepting to moderate this important topic in risk assessment and risk management. I also thank the members that have expressed their views so far and also Helmut for the clarifying post about the outcomes of the AHTEG meeting in Brasilia. I would like to share with you the report called 'Uncertainty and Knowledge Gaps related to Environmental Risk Assessment of GMOs', published late last year with a title that explains itself but also containing a dedicated chapter for the analysis of GM salmon. The report has been developed by GenOk Center for Biosafety in Norway, the National Competence in Biosafety and also a research institution with long experience in aquatic systems. The report is freely available at http://genok.no/wp-content/uploads/2015/11/16102015_Uncertainties_and_Knowledge_gaps_related_to_Environmetal_Risk_Assessment_of_GMOs.pdf and also contains several other references to the literature. I am not a fish specialist but as a plant biologist working with molecular biology I see the importance of the freely available genomic databases we have for several crop species. Although in vivo experiments are crucial in supporting risk assessment studies, bioinformatics analysis can be also fundamental in many ways from predicting allergens to basically identifying any protein or transcripts being expressed and accumulated in a plant cell. From my readings of the 2008 discussions (I am sure the field has evolved) I would like to see the issue of lack of genomic information for fish species being treated in the proposed section of the guidance. The Guidance already deals with the identification and consideration of uncertainty already in part I Roadmap in section ‘Overarching issues in the risk assessment process’. However, part II brings concrete cases of potential lack of information and how to handle it for several types of LMOs and I see a dedicated space there for LM fish being of major usefulness. Thank you for this opportunity once again. Best regards sarah
posted on 2016-03-02 18:40 UTC by Dr. Sarah Agapito-Tenfen, NORCE Norwegian Research Centre
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This is a reply to 7720
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7721]
Dear Participants,
In my experience with the risk assessment (RA) of LM fish, much of our framework has been in line with the Roadmap (though we did not specifically set out to do so), including the basic elements expected from any thorough scientific risk assessment, such as a problem formulation, exposure and hazard assessments, and an appropriate scientific peer review of the RA and its conclusions.
However, there are also several additional elements and special considerations that may be particular to LM fish, and may warrant additional and distinct guidance under Part II of the CBD Guidance on RA of LMOs. Here are some examples from my own experiences that I can share with the group, and may help to address some of the points and issues that have been put forward by Piet, Maria and Didier (7711, 7707, and 7701).
One important consideration is that once the LM fish has entered the environment, it is difficult, if not impossible, to retrieve. Consequently, there can be no field trials and there will be no historical data regarding the fate of the LM fish in the environment, nor is there likely to be any empirical evidence regarding its invasiveness. Instead, all data relevant to a regulatory risk assessment will only be available from the manufacturer of the LM fish, or from data acquired through experiments conducted under conditions of closed containment using a surrogate model organism. Strong genetic x environmental (GxE) effects of the phenotypes of fish in general will also result in high uncertainty regarding the fate of LM fish in the environment.
With no data regarding the impacts of LM fish in the environment, the hazard assessment becomes an exercise in hazard identification, producing a list of “potential” impacts that must be addressed with respect to all of the potential use scenarios. Given the limited knowledge and high uncertainty surrounding the hazard assessment of LM fish, greater emphasis is placed on the exposure assessment, when concluding on overall risk.
The exposure assessment may also be a bit unusual, since consideration must be given to the efficacy of physical containment and biocontainment, as well as the geographical distance from the natural range of the LMO. In our experience, the exposure assessment included the likelihood of the LM fish to enter, survive and reproduce under a specific scenario, or in a scenario specific environment. The greater the distance from any center of origin for the species, the less likely are genetic impacts from the release of the ML fish. Though there are few examples of LM fish in the pipeline, now that the US FDA has given its approval to the growth-enhanced transgenic Atlantic salmon, it will not be too long before new LM fish, such as rainbow trout, catfish and tilapia, will begin to seek market approval. The higher efficiency and lower feed conversion ratios in fish relative to terrestrial vertebrates, makes aquaculture a potential solution to increasing global protein demand. Genetic engineering will likely be used to push those efficiencies further in a variety of fish species.
Another international group that is working on issues related to the risk assessment of LM fish is the OECD Working Group on the Harmonisation of Regulatory Oversight in Biotechnology. The group is preparing a consensus document on the biology of the Atlantic salmon that can act as a reference document for evaluators. I believe it will include reference materials that are directly relevant to the risk assessment of LM fish, as well as LM Atlantic salmon.
The best reference I know of for the risk assessment of LM fish is Kapuscinski et al. 2007 Environmental Risk Assessment of Genetically Modified Organisms Volume 3: Methodologies for Transgenic Fish, published by CAB International.
Regarding monitoring and traceability, this is a big issue for trade that is much broader than fish, and is currently being debated at the executive level. With the new gene editing technologies that have crashed onto the scene, the concern is that there will be no way of monitoring LMOs or even knowing if an organism has been genetically engineered. Again this issue is being addressed at a high level in the US, Canada and the EU, and may have more to do with trade policy than with the scientific environmental and human health risk assessment of LM fish.
Thank you all for giving me the time and space, and thank you very much Janne for acting as Chair for this session. Hopefully my comments can stir some discussion among the participants.
Best regards, Colin
posted on 2016-03-02 20:23 UTC by Dr Colin McGowan, Canada
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This is a reply to 7721
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7722]
Another big difference between fish and other organisms is that they can often live right on the border of two or more jurisdictions and keeping a LM fish that enters the environment from dispersing into a neighboring jurisdiction may be close to impossible. Separate guidance on LM fish may help to align the various risk assessment frameworks that originate from different jurisdictions.
Colin
posted on 2016-03-03 15:35 UTC by Dr Colin McGowan, Canada
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7723]
POSTED ON BEHALF OF DAVID A. MBAH --------------------------------------------------
Thank you Sarah and Colin for sharing of information/experience on RA of LM fish. David Mbah
posted on 2016-03-03 21:36 UTC by Dina Abdelhakim, SCBD
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7724]
POSTED ON BEHALF OF VERONICA SINOHIN -------------------------------------------------- Thank you for accepting my participation on this on line forum. The messages posted by Collin are worth that needs great attention during the meeting. I would like to register my concern on ornamental LM fish. Although their uses are just for collection as pet, little information can be found on their RA & RM. Please consider this for discussion. Thank you. Veronica O. Sinohin, PHilippines
posted on 2016-03-03 21:37 UTC by Dina Abdelhakim, SCBD
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7725]
Dear Janne: First of all, thanks for chairing this extremely important session! Our experience at CONABIO in Mexico through sponsoring a Workshop on risk assessment on LM fish is that we definetily need to build capacity in this area which is highly challenging due to the nature of fish and their interaction with the environment. We had the great fortune to have most of the authors of the book Colin mentioned of Professor Anne Kapuscinski with us at the workshop. I recommend we use this book as guidance as well as the expertise of the authors during the process of deciding what an outline of a standalone doc would look like and its development. The book is in the BCH and I add the record here so that you can directly visit and download the pdf copy: https://bch.cbd.int/database/record.shtml?documentid=44302Thank you once again! Francisca
posted on 2016-03-04 04:12 UTC by Ms. Francisca Acevedo, Mexico
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This is a reply to 7692
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7727]
Dear colleagues,
Thank you for giving me this opportunity to participate in the forum.
I would like to echo the comment of #7701 that we should collect information which is helpful to decide whether to develop a separate guidance on LM fish such as unique aspects to the topic, rather than to develop an outline. The Roadmap should indicate the basic framework of environmental risk assessment for all types of LMOs. As Collin suggested, I think the basic concepts for RA of LM fish, including monitoring, genomic information and the efficacy of physical/bio- containment, has been already provided in the Roadmap, though the Roadmap could be more user friendly.
I also respect the comment of #7721 and understand that it is extremely difficult to control living area of a LM fish after releasing it into the environment. I think, however, that the potential ability to move from a jurisdiction to others may not be limited to fish but common to other organisms such as animals and insects, in varying degrees. In addition, as indicated in the comment, how to address trans-boundary movement of LMOs including those naturally occurred should be addressed in risk management.
I hope the AHTEG will provide useful, rational and scientific information which help to decide whether or not the separate guidance is needed for LM fish in the MOP8.
Best regards, Ayako
posted on 2016-03-04 08:51 UTC by Ayako Yoshio
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This is a reply to 7727
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7731]
Dear all,
Thank you for the opportunity to contribute.
I appreciate the information that the topic of LM fish is part of Decision BS-IV/11 of COPMOP 4 in 2008 (#7714) and that 8 years after being selected by Parties is being considered by AHTEG as an option for additional guidance. I have two main considerations about the topic:
- the Decision BS-IV/11 was based on Canada-Norway Workshop (doc UNEP/CBD/BS/COP-MOP/4/INF/13). The document presents many considerations for ERA of LM fish and should be considered but as a document elaborated in 2007 there was no Roadmap at that time and needed to be reevaluated in the light of a existing Roadmap.
- experience in using the latest version of the Roadmap in conducting ERA of LM fish is essential to outline a proposal with concrete elements that suport Parties decision about an additional guidance. As presented in the post #7721 there are few examples of LM fish in the pipeline but the recent approval of the growth-enhanced transgenic Atlantic salmon in USA could be used as a study case
Finally I agree with Boet (# 7730) and others that “it will be the COP-MOP who will decide on additional guidance. In this respect it should be made very clear to the COP-MOP why this guidance is needed”.
Best regards,
Luciana P. Ambrozevicius Ministry of Agriculture / Brasil
posted on 2016-03-05 17:07 UTC by Ms. Luciana Ambrozevicius, Brazil
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This is a reply to 7731
RE: Opening of the discussion: views, relevant guidance and sources of information on risk assessment of LM fish
[#7733]
Dear participants, I would like to thank the moderator and to the Secretariat for the constructive discussion we had during this last week. Regarding the agenda of this Forum and the comments already posted, I would like to support the position of Luciana [#7731] in the two topics indicated at that post, and specially on her argument that “it will be the COP-MOP who will decide on additional guidance".
Finally I would add that I entirely agree with the indication of the Book on LM fish posted by Francisca [#7725]. It is a comprehensive and complete document that could guide discussions on the safety of LM fish as well as could help building a good ERA for such a product.
With my best regards
Deise Capalbo
posted on 2016-03-06 09:26 UTC by Dr. Deise Maria Fontana Capalbo, Brazil
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