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SGW on Monitoring of LMOs Released into the Environment

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Item 10: The interpretation of 7(f) from Annex III and the Precautionary Principle in the context of our monitoring guidance [#2603]
Item 10: The interpretation of 7(f) from Annex III and the Precautionary Principle in the context of our monitoring guidance

I invite your views here.
posted on 2011-08-11 20:13 UTC by David Quist
RE: Item 10: The interpretation of 7(f) from Annex III and the Precautionary Principle in the context of our monitoring guidance (reply of Hans Bergmans) [#2616]
7(f) says: Where there is uncertainty regarding the level of risk, it may be
addressed by requesting further information on the specific issues of concern or
by implementing appropriate risk management strategies and/or monitoring the
living modified organism in the receiving environment.
The Precautionary Approach starts from the supposition that there is a scientifically underpinned hypothesis about how a risk might occur. It then says that, if this risk is a serious one, the fact that the hypothesis has not been proven (yet), is no reason not to do (a cost effective) risk management. What monitoring can do is provide data to (un)prove a hypothesis in CSM, or find a hypothesis in GS (see Item 6). But, neither proving or finding a hypothesis are part of the precautionary principle.
So, CSM is simply part of the risk assessment where in general the precautionary principle applies. What it aims at is reducing uncertainty, but that is not essential in the precautionary approach, or what the precautionary approach aims at.
GS is ultimately there to find a hypothesis and bring your uncertainty back to a case of CSM.
So, I don’t see the direct relation between the precautionary approach and the concept of monitoring.
posted on 2011-08-18 15:16 UTC by Mr. Hans Bergmans, PRRI
RE: Item 10: The interpretation of 7(f) from Annex III and the Precautionary Principle in the context of our monitoring guidance (reply of Hans Bergmans) [#2621]
Dear colleagues
I certainly would like to reflect more on what Hans has said with respect to the precautionary approach and 7(f) of Annex 3. My first impression is a bit different from Hans’, and I may need more discussion to understand the key insights that lead him to divorce the approach from monitoring.
The Rio declaration simply says of the precautionary approach that “Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.” Monitoring may be this measure. In this regard, the monitoring isn’t only of value in perhaps (un)proving a hypothesis or discovering a hypothesis, it is intended to prevent an adverse effect from becoming an unacceptable harm to the environment or human health. In other words, I see that the use of monitoring is to detect an adverse effect of the LMO. At that time, the construction of a post hoc hypothesis relating the LMO to the adverse effect is largely mute (although in some cases still possibly valuable).
posted on 2011-08-18 21:46 UTC by Mr. Jack Heinemann, University of Canterbury
RE: Item 10: The interpretation of 7(f) from Annex III and the Precautionary Principle in the context of our monitoring guidance (reply of Hans Bergmans) [#2630]
I agree with Hans
posted on 2011-08-18 22:16 UTC by Ms. Esmeralda Prat, CLI representation
RE: Item 10: The interpretation of 7(f) from Annex III and the Precautionary Principle in the context of our monitoring guidance [#2641]
7(f) of Annex III is not an interpretation of the Precautionary approach as outlined in Principle 15 of the Rio Declaration,
which looks at risk management and mitigation measures in very specific cases where there are threats of serious or irreversible damage.

While monitoring can in theory lead to the discovery of a threat of serious or irreversible damage, the PA has no place in guidance on how to do monitoring.

Piet
posted on 2011-08-18 22:53 UTC by Mr. Piet van der Meer, Ghent University, Belgium
RE: Item 10: The interpretation of 7(f) from Annex III and the Precautionary Principle in the context of our monitoring guidance [#2648]
Paragraph 7(f) suggests that it may be possible to address uncertainties concerning a particular level of risk by obtaining further information, for resolving that uncertainty, or by implementing appropriate risks management strategies and /or monitoring. So this provision is relevant for the recommendation that comes from the risk assessment.  Also paragraph 4 states that when there is lack of knowledge or scientific consensus, should not necessarily be interpreted as indicating a particular level of risk. So uncertainly is related to the issue that you cannot be sure about a level of risk (it could be low, or medium or high but you do not know), then you may want to monitor so you can generate information to tackle this uncertainty. In contrast, as Hans pointed out, the precautionary approach departs from the supposition that there are threads of serious or irreversible damage, then, lack of full scientific certainty shall not be a reason to pospone taking cost effective measures to prevent that damage. But the precautionary approach is not providing any guidance on how to do monitoring.

From my point of view monitoring per se is not not a tool to prevent or minimize damage, monitoring is a tool to generate information that could inform (among other things) if the measures to avoid or minimize or to prevent damage are apropiate or not. Monitoring activities by themselves shoul not be the measures that the precautionary approach refers to prevent the damage.

So I agree with Piet in the sense that the precautionary approach has no place in this guidance on when or how to do monitoring.
posted on 2011-08-19 04:49 UTC by Ms. Sol Ortiz García, Mexico