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SGW on Monitoring of LMOs Released into the Environment

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3rd draft for discussion by the SWG [#2884]
Dear Monitoring SWG members,

Please find attached the proposed 3rd draft of the guidance document “Monitoring LMOs released into the environment”. I believe we have achieved a significant improvement in this round.

This 3rd draft takes into account text input from SWG members, along with a consolidation of the comments and concrete text proposals coming from the last round of the online forum.

I also want to thank Helmut and Manoela for providing useful feedback on this draft.

As a reminder of the workplan, we will spend the next week (and it should be excellent holiday reading material!) reading the draft until December 28th, when we begin a 2 week comment and discussion period for refinement of this draft, ending on January 11th. The comments and suggestions will then be consolidated for inclusion in the final 3rd draft to go to the online forum on January 16th.

Further, I am very pleased we will likely have the opportunity for a face to face meeting to further develop this guidance in February. I very much hope all SWG members can make time in their schedules to attend.

I look forward to the coming discussion starting on December 28th, and your continued active participation.

Best wishes and a nice holdiay season to all,

David
posted on 2011-12-22 11:00 UTC by David Quist
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RE: 3rd draft for discussion by the SWG [#2908]
Dear Monitoring SWG members,


A gentle reminder that the comment period for the 3rd draft of the monitoring guidance by the sub-working group is soon coming to a close, at 01:00 GMT on Wednesday, January 11.

We have made excellent progress on the document over the course of the multiple discussions and drafts, however your continued discussion and input is very important for its further development.


Kind regards,

David
posted on 2012-01-08 07:58 UTC by David Quist
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RE: 3rd draft for discussion by the SWG [#2909]
Please find enclose my commets to the 3er draft on monitoring.

Best regards

Elizabeth Bravo
posted on 2012-01-09 21:02 UTC by Dr. Elizabeth Bravo, Acción Ecológica, Ecuador
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RE: 3rd draft for discussion by the SWG [#2910]
Dear colleagues,

Attached I send you my comments on the 3rd draft of the monitoring document.
I have tried to stick to the following conventions:
Some changes are marked as straightforward tracked changes in word.
Many of the proposed deletions have been marked by strikethrough in the text (so that the text can still be read easily 'in situ'), yellow shading, and a comment on the reason for deletion including, in a number of cases, a prioposal how to get a new text.
Some comments are indicated right in the text.

I hope this helps, rather than creating confusion.

Best wishes,

Hans
posted on 2012-01-10 09:31 UTC by Mr. Hans Bergmans, PRRI
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RE: 3rd draft for discussion by the SWG [#2911]
Dear David and members of the SWG on monitoring

The best possible new year to you all! This document has progressed considerably over the months and clearly has benefitted from a lot of hard work.

I have made a few remarks using track changes in the attached. The document is easy to read and clear with a good flow, except in my opinion section 7, which doesn't sound like guidance.

Jack
posted on 2012-01-10 10:51 UTC by Mr. Jack Heinemann, University of Canterbury
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RE: 3rd draft for discussion by the SWG [#2912]
David,

Having gone through the draft of the monitoring guidance document, I realise how good it is that we will – hopefully - have a face to face meeting, where we can discuss the draft in more detail, because I still sense that there are very different perspectives with regard to monitoring.

In addition, I find the document still not easy to get through, in part because of the language used, the repetitions and the mixing of CSM and GS, and of monitoring and RA. Moreover, the text conveys the notion that it will be hardly possible to do sensible and effective monitoring and that the main purpose of monitoring is to provide information about the limitations of the monitoring plan.

Attached some comments as track changes in which I have indicated examples of duplications and mixing.

Broader issues such as GS/CSM and monitoring/RA are best discussed in person in the face to face meeting,

Regards from Bangkok,

Piet
posted on 2012-01-10 17:42 UTC by Mr. Piet van der Meer, Ghent University, Belgium
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RE: 3rd draft for discussion by the SWG [#2913]
Dear David and all:

I hope this time I  am not over due on the timeline.
First of all, thank you for the efforts to assemble the diverse views and information on monitoring.
However, having discussion and information sharing with Asian partners, my qualitative assessment of the present draft is a kind of complication for beginners.
I understand that face-to-face meeting which will be in Feb would alleviate the disparity of the direction on how to proceed forming an integrated document, and with the occasion further discussion shall be made that the  structure of the document can be simplified.
Unfortunately, I cannot attend the Feb session, and further specific comments shall be sent prior to the session.

Also the SWGs and AHTEG are made for consultation by experts with relevant experiences, and not negotiation.  Modality of process  of the discussion shall be participatory, and not biased to the party driven manner.  Also the outcome shall be reflection of expert consultation, not party driven.

Monitoring must have relevant feedback from the practices, and yet I see more room to accommodate experiences from the present members.

Kind regards,


Kazuo
posted on 2012-01-11 02:47 UTC by Dr. Kazuo Watanabe, University of Tsukuba
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RE: 3rd draft for discussion by the SWG [#2914]
POSTED ON BEHALF OF LETICIA CHIRINO

-----


Dear David and colleagues of SWG.
 
First of all I would like to thanks David for performing an excellent work as a head of the sub group. I believe that monitoring is an extremely important and , at the same time,  very complex issue. I think that the fact of having so much valuable information  gathering so different points of view  in just one document, should be considered as a success. We have now a 2nd draft more complete on the table which will make our work easier. Thanks once more David.  
 
Best regards
 
Dra. Leticia Pastor Chirino MSc.
Head Authorization Department.
National Center of Biological Safety. Cuba
 
Now my comments.
 
I agree with Piet regarding the reiteration in some parts of the text.
 
1. Line 56, page ___ to use the word is  an early warning mechanism instead of serve as...... I think that one of the most important objectives of the monitoring systems is, precisely , the timely detection.

2. The paragraph containing lines 60 to 62 can be deleted (from In this way.... to the end of the sentence). What is written here is already said in the previous paragraph.

3. From line 63 to 65. I think that any finding resulting from the implementation of the monitoring system, can lead to the revision of  any decision, not only  a decision concerning the import, so, this possibility should not be limited.

4. Line 67:  for the annex 1 my proposal is as stated below:
.
The aspects listed below can be found among the different uses of the monitoring.
 Timely detection of the possible adverse effects identified or not in the risk assessment process.
 Implementation of risk management measures , if necessary, in order to minimize the consequences.
 Identification of the necessity of complementary researches.
 Confirming the hypothesis  of the risk assessment.
 Assessing the effectiveness of the risk management measures.
 Avoiding uncertainties.
 Revision of the decisions already made.
 
5. From line 73 to 79. the text reflected here is not clear and is kind of ambiguous. The wording must be revised or the text should be deleted.
 
6. Line 155, I suggest the deletion of the word likelihood.
 
7. No change is proposed by lines from 152 to 175.
 
8. Adding in a line 204 the following phrase:  In addition, a behavior of an organism released into a receiving environment can be followed, but in different moments and for a predetermined period of time.To combine the lines 210 and 211.
 
9. Remove the lines 212 and 213.
 
10. To clarify the lines from 217 to 222, because they are confusing.

11. Add line 225 the frequency besides of the duration and scale, as this also varies in correspondence with the adverse effect, the organism's life cycle to monitor the time it takes to manifest adverse effect or display the parameter changes or indicator, etc.
 
12. Add in the line 251 the natural ability of the released organism spread beyond the release area, climatic and geographical factors that support growth, for eg. the wind direction).
 
13. Remove the lines 255 and 256.
 
14. Add from the line 253 The location where the release has occurred.
 
15. Remove the lines 282; 285 and 289.
 
Leticia
posted on 2012-01-12 02:09 UTC by Ms. Manoela Miranda, UNEP/SCBD
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RE: 3rd draft for discussion by the SWG [#2915]
Dear Monitoring SWG members,

I wanted to take the opportunity to extend my appreciation to those who provided input in the last round of our SWG dicussions.

As before, every comment was taken into consideration, regardless of affiliation or Party status of the contributor. Many of the comments provided valuable improvements in clarity and were taken on board.

Suggestions that were a large departure from the structure or fundamental concepts of the existing draft, however, would benefit from discussion in the face to face meeting. I encourage contributors to take up these points, in upcoming discussions of the Open-ended online forum, which starts today and lasts for 2 weeks, and in the face-to face meeting in February.

Once again, thank you for you continued interest and active contributions.

Kind regards,

David
posted on 2012-01-16 20:00 UTC by David Quist
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RE: 3rd draft for discussion by the SWG [#2916]
POSTED ON BEHALF OD DAVID HERON

* Please note that this message was received on 11 January 2012 at 16:17 PM.

----

I had some difficulty with sending comments in the usual way, so I hope this will be acceptable.  My apologies to David and others for sending this almost two days past the deadline earlier this week.  I thought it was important to share these comments with the group, even though they are arriving late.

I started making track changes to the attached document, but soon stopped when I realized that there would be many more comments of a similar nature on the document.  Instead, for ease in communication I have put some of my thoughts here to share at this stage.  Like others, I think that many of these issues will be easier to resolve in face-to-face discussions.  I thank you, Manoela, and other members of the Secretariat for making the effort to make such a meeting possible.

Here are some of my main concerns with the document in its current form.\

1. Throughout the document  the  choice of words appears to be inconsistent with the term “monitoring” is actually used in the Protocol.  The term monitoring in the Protocol is used in Article 33 to describe the obligations of Parties to monitor their compliance with their obligations under the Protocol.  Monitoring of LMOs is actually very limited – only where there is uncertainty regarding the level of risk, not all circumstances as the current draft text implies.  In addition, as the Protocol text below indicates, monitoring LMOs is only one of several approaches that might be used.  “(f)            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. 

2. There is a blurring of the Protocol and the Convention.  The work of the AHTEG is supposed to be with the Annex III of the Protocol.

3. Throughout the text the relationship of national legislation to the Protocol  is misleading.  If a Party has a national legal framework, the monitoring with respect to Party obligations under the Protocol are not removed.  Monitoring as an option in risk assessment may or may not be affected.

4. This is not the charge from the Parties to develop a “living document”.  Here and elsewhere, the description of the documents as “living documents” should be removed.  They would be living documents only if adopted by the Parties as living documents (not done yet nor part of the original charge to the AHTEG).


Thanks for considering these brief comments and others to come in our discussions over the weeks and months ahead.

Dave
posted on 2012-01-20 20:33 UTC by Ms. Manoela Miranda, UNEP/SCBD
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