Whereas I find all topics identified as important for desserving some
specific guidance, I agree with some priorities already mentionned, find
it difficult to establish a order of priority, but would propose the
following order on basis of urgency:
1. Post-release monitoring and long-term effects of LMOs released into
Long-term effects of LMOs should be evaluated in the RA, but it is still
more recognized that, because of lack of methodologies to apprehend all
indirect and complex interactions of the evolving ecosystems, it is not
possible to foresee all potential long-term impacts. Moreover monitoring
should early detect the eventual appearance of impacts foreseen in the
RA as being possible, and thus allow to avoid their extension. Despite
the importance of post-release monitoring, no precise guidance exist
presently in the Protocol for monitoring.
2. RA of LM microorganisms and viruses.
These organisms have very different life characteristics than
macro-eukaryotes. Are invisible. Some have been and are in development
for vaccines or other medical and veterinary use, or for biomonitoring
or remediation. Environmental monitoring should also be very necessary.
3. RA of LM trees.
Various LM trees are in field trials since years, and some of them are
already on the market, if I am not wrong ( ? In China, in particular ?
). LM trees need specific RA on the basis of their long life-time
compared to annual plants and of other characteristics ( difficulty of
green-house trials, are part of very complex terrestrial and soil
ecosystems,..... ) .
4. RA of LM plants for production of pharmaceutical, industrial
Like other participants, I do not quite understand the difference made
between some topics identified in the presented list. I find in any case
that the risk for LMOs producing such materials is, in the context of
the Protocol, to consider in priority for plants released into the
environment ( if in confined use, would it be plants, algas,
microorganisms, the risk is different ).
It seems to me that LM plants producing pharmaceuticals, biofuels or
other industrial products could be handled together for a big part of
their RA concerns different from the RA for LM plants aimed as food or
5. RA of LM fishes.
Various LM fishes are in development and some are close to
commercilaization. Fishes "escape" more easily than plants in a poorly
visible and complex ecosystem and food chain.
I find, like other participants, that the "Canada-Norway Workshop on RA
for emerging Applications of LMOs" is a good basis of reflexion for the
AHTEG on some new topics.
I find the following topics also very important presently, but they
should logically be treated in the general roadmap:
Uncertainty analysis. Uncertainty is part of the RAs, has been often
mentionned during the online discussions these last weeks, but is a sort
of " tabou " poorly treated in practice during the RAs of LMOs, whereas
it is closely linked to the precautionary principle application.
Risk assessment ( and risk management ) in specific receiving
environments. I do agree with Beatrix Tappeser comments on this topic.
Concerning " Coexistence", as reminded several times, this topic does
not per se concern the RA if meant following the EU interpretation ( at
least if uncertainty is not taken into account ), but " contamination "
does well concern the RA; as previously discussed, this could be treated
more deeply, but also in the context of the general roadmap.
I thank already the members of the AHTEG and hope they will be able to
manage with new topics while bringing the wished improvements in the
previous roadmap and guidances !
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