Online discussion 2015 - Discussion Groups
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Open discussion
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Dear Participants,
You are now invited to add any other comments or suggestions that may be relevant to the discussions held over the last weeks or that may assist the AHTEG in its work on:
(i) the further development of conceptual clarity on socio-economic considerations arising from the impact of living modified organisms on the conservation and sustainable use of biological diversity; and
(ii) developing an outline for guidance with a view to making progress towards achieving operational objective 1.7 of the Strategic Plan and its outcomes.
Open discussions will be held until 7 May 2015 at 1:00pm GMT.
Kind regards,
Paola
(edited on 2015-05-04 13:56 UTC by Paola Scarone)
posted on 2015-05-04 13:56 UTC by Ms. Paola Scarone, Secretariat of the Convention on Biological Diversity
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RE: Open discussion
[#6990]
Dear Colleagues,
By its very nature, the production of food impacts the environment and hence, biodiversity. This is equally applied to conventional, GM and organic means of producing food. Simply put, agriculture has an impact on the environment. Regulations regarding the risk assessment of crops and foods have to be equally applied to all. For example, chemicals applied to the production of organic foods can have a much higher level of eco-toxicity than GM crops. Consistent agriculture regulations are the cornerstone of international agreements.
We have witnessed a very thorough discussion of multiple aspects of SECs and the regulation of LMOs. To provide clarity in this final week of discourse, I would like to highlight a couple of key observations.
First, with no formal ability to resolve disputes, the Protocol has to rely on the WTO to resolve trade disputes. In the event of a trade dispute, the CPB identifies that the parties are to try to negotiate a resolution, failing this the dispute is to be referred to the CBD, where negotiation is the only option available. If the CBD is unable to resolve the dispute, the case is to be referred to the International Court of Justice. However, following WWII, the GATT was established to resolve all international disputes involving trade, so that the ICJ wouldn’t have to be involved in trade related cases. It is doubtful that the ICJ would even hear a case from the CBD based on a trade dispute over GM crops. The case would be referred to the WTO. The CPB has no formal ability to rule on disputes, the only global mechanism capable of doing so is the Dispute Settlement Panel of the WTO.
Second, any trade dispute that will arise from the inclusion of SECs involving Argentina, Canada and/or the US, will be resolved by the WTO, as was the case by these 3 countries against the EU. The panel ruling in this case relied on the definition of risk assessment as defined by the SPS Agreement. Environmentalists and opponents of GM crops can imply all they want, but I want to be very clear, the SPS Agreement will be used as the final arbiter in trade disputes involving the implementation of SECs that result in trade barriers. The WTO’s dispute settlement panel has also clearly identified what constitutes risk assessment and the quality of science-based evidence required to justify a trade barrier. Peer-reviewed, scientific-based evidence is the only information that will be allowed to be entered into any resolution of a trade dispute. Online reports by environmental groups opposed to biotech does not constitute evidence and as the WTO has already established, these kinds of reports are not submitable as support for a trade barriers.
Finally, as Art. 26 so clearly states, Parties to the CPB must be consistent with their international obligations. Given that the CPB allows the use of trade barriers and the WTO does not, any nation that is a party to the WTO has to ensure that any SEC considered to be part of a domestic biosafety regulatory framework, has to comply with the WTO. Any SEC that impedes trade, will be a violation of the WTO, which CPB parties have already agreed to adhere to. As a point of clarity, nations considering implementing SECs must proceed knowing that only direct-impact, science-based assessments will be WTO compliant. The reference to speculative and hypothetical risks that have been rampant in this dialogue are in clear violation of a countries obligation to uphold its commitment to the SPS Agreement.
I thank the Secretariat for organizing this event and the opportunity to participate.
Sincerely, Stuart
posted on 2015-05-04 15:45 UTC by Dr. Stuart Smyth, Dr.
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RE: Open discussion
[#6991]
Dear All
The CBD is an environmentally-focussed agreement. We are trying to use our collective wisdom to limit negative impacts to the biodiversity. In the case of the CPB and LMOs, we want to stop the trajectory of harmful agriculture and turn it into more 'environmentally friendly' crops/animal production systems, that - despite a burgeoning human population - reduce our (human) impact on ecosystems.
With a touch of melodrama, we are trying to save the planet here, and we must be pragmatic. Fiddling while the planet burns, to be 200% sure that any LMO to be released has had an exhaustive assessment of all and any possible outcomes, is not the purpose of the discussion. Rather we want sufficient pragmatic information (and associated methodologies) to allow a decision to be taken, harnessing the technology as one means of reducing our biodiversity impact - before we reach a tipping point (if not already there). Countries should manage the implications of the roll out of the technology - if such is the decision - as they do with any other technology: with rational national policy and regulation.
I am of the view that we are seeking the pragmatic lower limits to guidelines on SECs, which all signatory countries can accept, and the management of the LMOs must be left up to the sovereign states.
Ben
posted on 2015-05-04 15:57 UTC by Mr. Ben David Durham, South Africa
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RE: Open discussion
[#7031]
The impacts of GMOs on biodiversity , livelihoods of local and indigenous communities and human health include direct and indirect impacts . It should be possible for socio economic considerations to form the basis for measures that restrict or ban GM crops. It is necessary to explore how the views and experiences of farmers, local and indigenous communities and any group impacted by GMOs may be taken into account in decision making proccedures.
The possible mechanisms for taking socioeconomic considerations into account could be : - The creation of a specific socioeconomic evaluation in decision making for impacts. - Public consultation on socioeconomic aspects that ensures effective access to information and public participation prior to decisions We need to apply the precautionary Principe for protecting the environment , the biodiversity and our planet . The biosafety Protocol is based on that.
Koffi
posted on 2015-05-05 20:07 UTC by Ing. Koffi Edinam Dantsey, Togo
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RE: Open discussion
[#7035]
It is a great mistake to think that GM plants are intrinsically different from plants obtained by conventional breeding.
The National Academies of Sciences for more than a decade have reached this consensus and therefore disagree with a scientific consensus does not make sense.
Even the discussion of socio-economic issues should employ as a parameter varieties obtained by breeding.
Any socio-economic problems of the use of GM plants are not fundamentally different from those arising from the traditional varieties. For example, the consequences arising from an oligopoly that controls the GM seed market are not fundamentally different from the consequences resulting from non-GM seeds oligopoly.
So create specific forums to GM plants does not seem to make sense.
posted on 2015-05-05 21:02 UTC by Dr. Eduardo Romano de Campos Pinto, Brazil
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RE: Open discussion
[#7037]
Dear Koffi, I fail to understand why you would want to use SECs and the CPB to ban GM crops when they have been proven to be the highest yielding and most environmentally sustainable form of food production available. GM crops have the ability to contribute more to improving food security than any other form of food production. Even the Bill and Melinda Gates Foundation acknowledged this in the Foundation’s 2012 report, highlighting that every technology available to increase the pace of developing new plant varieties needs to be funded. In parallel to this is the removal of regulatory barriers that only serve to deny food security to those most vulnerable, needs to be properly addressed. This would include the mandatory inclusion of SECs that are really simply nothing more than disguised trade barriers. One of the most widely cited and acknowledged peer-reviewed publication on the impacts of GM crops is by Drs. Wilhelm Klümper and Matin Qaim in the journal PLOS One ( http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0111629). Their meta-analysis of 147 publications found that on average farmers using GM crops experienced 68% higher profits, increased yields by 22% and reduced chemical use by 37% compared to those not using GM crops. Organic crops produce on average, 30% less than conventional crops. Comparing organic crop and food production with that from GM crops, highlights that GM crops yield 65% more than organic crops. Using SECs and the CPB to ban such an environmentally sustainable technology, while improving human health through reduced chemical exposure will only serve to enhance food insecurity and result in subsistence farmers remaining that way. The Precautionary Principle is a cornerstone of the CPB, but as I have clearly identified, such an approach to the regulation of LMOs is a clear violation of a country’s obligations to comply with the WTO. Every party to the CPB has its own sovereign right to regulate a technology as it so prefers, however, it proceeds in the knowledge that there are rules that have to be adhered to. In this case, the definition of risk assessment will be that provided by the WTO’s SPS Agreement as every party to the CPB has agreed to comply with the WTO and all of its ancillary agreements. Sincerely, Stuart
posted on 2015-05-05 21:36 UTC by Dr. Stuart Smyth, Dr.
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RE: Open discussion
[#7072]
It is no more possible to make blanket statements about LMOs than it is to say the "all acids are good" or to ignore the realities of the receiving environment ("because we have HCl in our guts, HCl must be harmless.")
There would not be lively discussions of "low level presence" of unapproved LMOs contaminating shipments, (as is the case--and a whole Codex annex to deal with such a situation) if all LMOs are equally good.
One fundamental principle in the negotiations of the Protocol (and the Codex) is "case-by-case" analysis. Let's not try to abandon that principle here.
Philip L Bereano Prof Emeritus
posted on 2015-05-06 20:38 UTC by Dr. Philip L. Bereano, University of Washington
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RE: Open discussion
[#7033]
Dear Participants, Most positions externalized during this online forum sought to establish just theories about the possible negative impacts of living modified organisms on the conservation and sustainable use of biological diversity, excluding, however, the potential positive impact of this activity. In fact, one must take into account what constitutes nuclear purpose of all LMOs developers offer only those who actually will result in positive impacts in such contexts. Otherwise, they would not get the introduction of its GM products in the consumer market of interest. The development of conceptual clarity in SEC resulting from this impact will only be possible, therefore, within the experiences of concrete scenarios already experienced by traditional communities that make use of GM crops. Best regards
posted on 2015-05-05 20:52 UTC by Ms. Lidia Miranda de Lima, Brazil
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RE: Open discussion
[#7034]
Dear Participants, Most positions externalized during this online forum sought to establish just theories about the possible negative impacts of living modified organisms on the conservation and sustainable use of biological diversity, excluding, however, the potential positive impact of this activity. In fact, one must take into account what constitutes nuclear purpose of all LMOs developers offer only those who actually will result in positive impacts in such contexts. Otherwise, they would not get the introduction of its GM products in the consumer market of interest. The development of conceptual clarity in SEC resulting from this impact will only be possible, therefore, within the experiences of concrete scenarios already experienced by traditional communities that make use of GM crops. Best regards
posted on 2015-05-05 20:54 UTC by Ms. Lidia Miranda de Lima, Brazil
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RE: Open discussion
[#7038]
Dear participants,
Sorry for not interacting on the latest question regarding the relevance of health issues to SEC, but I have been following the whole discussion with great interest and curiosity. Like other participants, I believe that the discussion and arguments raised have certainly elucidated many aspects that would be helpful to the ATHEG in his work on the topic. So, thanks to all.
In my point of view, it is off course legitimate to consider human health as part of SEC when trying to reach a decision regarding the use, trade, or release of a GMO in the environment. However, some practical limitations should not be overlooked or left out: 1- the health issues to be taken into account in relation to SEC should be clearly defined and not having dealt with in any other risk assessments conducted as prerequisites for the first release of a GMO. Yet, many of the concerns raised in this forum, especially the indirect adverse effects, are in fact dealt with either in food safety risk or environmental RA, or refuted on an account that they are not specific to GMOs, insufficient proofs, or due to inadequate utilization by end-users. And I do not think it is the task of the AHTEG to settle this long lasting debate. 2- after being clearly define, if any, their evaluation should be done according to a standardized methodology that can be accepted by all Parties and systematically used for the conclusions to be meaningful and convincing. Otherwise, any non-permit outcome will be considered as a mere speculation or deliberate barrier to trade on the basis of the argument that SEC should be “consistent with other obligations”. We cannot just ignore Dr. Smyth argumentative discussions, regardless of whether or not we agree with him.
Please allow me to make three more small comments that I hope relevant to the whole discussion:
1- Regarding the influence of GMO on the nutritional status of some local and indigenous communities, I would like to mention that the CPB, by specifying that it aims to provide “adequate level of protection” accepts GMO foods on the basis of substantial equivalence”. NO GMO is release if it is not judged substantially equivalent to its conventional parent, unless the alteration of the composition is purposely done and regarded as advantageous/beneficial. Therefore, it would be hard to prove that a product that does not differ substantially from the “natural” counterpart would be more harmful to a given population or a group. On the other hand, some GMOs are purposely designed to have fewer anti-nutrients in its composition to in some countries to the benefit of some population suffering from malnutrition. 2- Another concern was raised by some colleagues consisting on the fact that the outcome of a RA study done in one country or a region, is not necessarily valid for another country; and this is a fact. However, by definition, RA provides a framework and the outcome is specific to each country or a region due to difference in exposure (certainly not the same of all countries) which influences the outcome of risk characterisation, which is true for both food safety and environmental RA. This is specified by CPB where the importing Parties should perform their own RA before permitting the introduction of 3- Finally colleagues have raised the concern that GMO introduction may result in the irradiation of some animal or plant species typical of a given region or locality, some of which may be used as typical food source. This is also a great concern indeed from both health and environmental standpoints, but I believe that is dealt with in other international and regional instances including GATT (Article XX: General Exceptions). Such an issues has been a matter of disputes between State-Members (e.g., the case of the USA and Mexico on the impact yellowfin fishing on dauphins)
Regards to all
posted on 2015-05-05 21:42 UTC by Mr. Noreddine Benkerroum, Morocco
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RE: Open discussion
[#7039]
PS: in my latest posting (N. Benkerroum)
Please read: Parties should perform their own RA before permitting the introduction of a GMO in the importing country (Notification provisions).
Please read: "eradication" instead of "irradiation"
posted on 2015-05-05 21:59 UTC by Mr. Noreddine Benkerroum, Morocco
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RE: Open discussion
[#7044]
Dear All,
I’ve followed fervently the online discussions and I believe that at this stage, the AHTEG on SECs has more than enough intellectual inputs to define with conceptual clarity SECs (Article 26) of the Protocol.
During the course of the intellectual exchanges, I’ve observed that a possible source of difficulties in tackling the SECs issues is the fact that Member countries of the Protocol are generally divided into two groups:
a) Member countries which have gone thru the actual commercialization process of LMOs, did actual risk assessment and management, undertook ex-ante analysis and consequently monitored ex-post their commercial approvals, and b) Member countries which have not yet approved any LMO propagation, or are still in the process of commercial approvals of LMO releases.
This state of differences in terms of LMO commercialization experience partly fueled the lively online discussion on SECs the past few weeks!
Hopefully, Member countries that are still contemplating to commercialize LMO can learn from the actual experiences of their counterparts which were ahead in adopting LMOs for commercial propagation.
At the end of the day, we recognize that Article 26 is not mandatory but voluntary, and closely embedded in the policy decision making processes of the Sovereign States under the Protocol! So let us all be “socially and economically considerate” to each other!
Cheers! Leo
posted on 2015-05-06 05:58 UTC by Dr. Leonardo Gonzales, Philippines
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RE: Open discussion
[#7052]
Dear colleagues I share some thoughts on this open discussion on article 26 of CPB
Scope of Article 26 of CPB The pertinent question here is If SECs are relevant only in relation to international trade? The first part of the article -26.1 is about trade, when it says, ‘…a decision on import under this Protocol…’. The second part of the article 26.2 is more of general in nature, which says “The Parties are encouraged to cooperate on research and information exchange on any socio-economic impacts of living modified organisms, especially on indigenous and local communities”. That means even if there is no trade involved, SECs of LMOs are relevant. In the general description of the CPB also, trade is only one of many components. CPB is described as is ‘an international agreement which aims to ensure the safe handling, transport and use of living modified organisms (LMOs) resulting from modern biotechnology that may have adverse effects on biological diversity, taking also into account risks to human health’. So the SECs are as much relevant and important for domestic production and use of LMOs as it is for international trade.
Article 26 of CPB and International Obligations
When the article 26 says, ‘……..consistent with their international obligations’ it means not only obligations under WTO. Every country has several international obligations like, bilateral, multilateral, within regional trade blocks etc.CPB is also an international agreement ratified by 170 countries (though according to article 27 of CPB rules on liability and redress shall be complete within four years). Resolving /settlement of conflict of interests among such several agreements or fixing precedence /priorities in applicability of such obligations or on the issues of infringement of sovereign rights are in the domain of international laws and negotiations and it is certainly not in the domain of SECs.
SECs vis-a vis Precautionary Principle
SECs, for that matter RARM vis-a vis Precautionary Principle is certainly a grey area. Both proponents and opponents have reasonable grounds for their stand. I feel the extreme views on both sides will not help for any practical solutions and to move forward. A middle path would be ideal. One reason that we should also take into account precautionary principle comes from the history of adoption of scientific technologies in agriculture and its subsequent withdrawal citing harm to health or environment. The green revolution in agriculture in India during late 1960s advocated, through Government machinery, use of hybrid seeds and chemical inputs. Later many scientific studies proved ground water contamination due to fertilizers, and harmful effects of many pesticides which were then banned. Some studies found chemical and physical properties of soils changed adversely due to excess dependence of chemical fertilizers. Even though all the ill effects could not be prevented, with little more precaution, certainly, some of them could be avoided and to that extent the principle is relevant.
Thank you
posted on 2015-05-06 09:40 UTC by Prof. Ashok Krishan Radha, India
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RE: Open discussion
[#7060]
Dear participants,
In my opinion to comply with the two tasks fixed in the Decision BS-VII/13 (conceptual clarity and an outline for guidance) the follow points are important and should be reflected in any document elaborated by the AHTEG:
- any language used should reflect the voluntary nature of the Art. 26
- is not every single SEC aspect related with LMOs that falls in the scope of Art. 26, only those related with the impacts (both positive and negative) of LMOs in the biological diversity, specially to indigenous and local communities
- to apply a SEC for decision-making under the CPB a Party should adopt a science-based approach to analyse the risks according to relevant international obligations
- the process of taking into consideration the comments and suggestions under the on line forum should be clear and transparente
In this context I support Ben Durham´s comment to seek for ´the pragmatic lower limits to guidelines on SECs, which all signatory countries can accept, and the management of the LMOs must be left up to the sovereign states`. Best regards, Luciana / Ministry of Agriculture - Brazil
posted on 2015-05-06 13:41 UTC by Ms. Luciana Ambrozevicius, Brazil
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RE: Open discussion
[#7063]
Dear colleagues! In my role of co-chair of the AHTEG I first want to thank all of you for your participation and the lively discussion on the different topics. I believe that the AHTEG will profit from the different issues and opinions raised and I’m positive that the group can build upon the outcome of this forum. However, I also have the feeling that on several points the views are still rather divided and that it will not be an easy task to reach a compromise, especially with regard to “conceptual clarity”. As one participant already said: we need to find a “middle path” in order to make progress. In my point of view this will be the main challenge for our next meeting and the next COP/MOP.
I can assure you that based on the outcome of last weeks’ discussion, the outcome of the study and the input from Parties at the last COP/MOP I will work together with my co-chair and the Secretariat on the preparation of the next AHTEG meeting in order to fulfil the mandate of the AHTEG and to enable the next steps towards reaching the objectives of the Strategic Plan.
I will not raise any point on the different issues already discussed, but one thing which came up several times I cannot leave without comment: The WTO/SPS/GATT and the EC/Biotech-case. One reason for this is, that I’m from Austria, which was one country directly involved in the case. First it needs to be clearly stated that the authorisation system as such (including the whole very strict risk assessment process) was neither challenged by USA/Canada/Argentina nor did the panel deal with it. The three issues dealt with were: a “de facto” moratorium for authorisations, the undue delay in the authorisation process of LMOS, and finally bans on LMOs invoked by several Member States of the EU. It is completely correct that the EU lost the case, mainly because the first two points were against its own regulations. It is also correct that the reasons for banning LMOs were not based on an SPS-conform risk assessment – they never were intended to be, as they needed to comply with the internal rules of the EU and - at least not at the moment they were invoked - with the WTO-rules. Therefore it is not correct to say, that an improper assessment (especially NOT during the authorisation process) lead to the outcome of the case. It also has to be mentioned that socio-economic considerations were NOT dealt with at all in the EC/Biotech case. Even if the topics of this case were the authorisation and bans of LMOs, the situation was a very special one, and in my point of view the transferability to other LMO-issues, especially the ones dealing with socio-economic considerations is rather limited. This point of view is also based on the analysis of several lawyers, including the legal services of the European Institutions.
Finally, recognizing that we are in a quite difficult situation (regarding e.g. the voluntary nature, the link (or not) to the risk assessment, and the limited experience we have with SEC-assessment), I hope for a spirit of compromise and an open discussion in the future, because if we all persist on our own viewpoint, we will not be able to reach the objectives of the Strategic Plan – which all Parties agreed upon.
Thanks again to all of you and looking forward to fruitful discussions in the future. Andreas
posted on 2015-05-06 15:32 UTC by Mr. Andreas Heissenberger, Austria
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RE: Open discussion
[#7071]
Thank you Dr H for some definitive clarification of the WTO case.
As to experience, speaking just of my own country, the USA has conducted thousands of SECs as part of national, state, and local environmental impact statements--what are likely effects on employment, on health, on population movements, etc , etc. I made this point in a paper distributed in Hyderabad. There is nothing strange or novel about assessing SECs--we KNOW how to do it.
Finally as to claims that a SEC must be separate from the risk assessment. Just what risks do we assess in the RA? And why do we pick some and not others? It is because the society feels that some outcomes are more important (positive or negative) than others. I do understand how one can (artificially) have 2 different processes. If an LMO would reduce biodiversity, whether a State would take action to prevent that would surely depend on how important it saw that reduction--eg, would it lead to a loss of local food source? of a cultural icon? of a sourced of gainful employment> etc. The "risk" of interest is not defined by science, it is defined by the society's values. The assessment must be "scientific" in the sense of unbiased, using the best info, etc, but the determination of what is a possible risk to an SEC worthy of devoting assessment resources is qualitative judgment.
Philip L Bereano Prof Emeritus
Philip L. Bereano
posted on 2015-05-06 20:17 UTC by Dr. Philip L. Bereano, University of Washington
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RE: Open discussion
[#7075]
Dear Colleagues,
Attempting to cavalierly dismiss the WTO ruling in the case of GM crop regulations against the EU as having no precedence on the current discussions regarding the applicability of SECs and their inclusion through the CPB, is a deliberate attempt to mislead participants and confuse them as it pertains to their nation’s international obligations. Environmentalists and opponents to biotechnology are famous for their lack of clarity and ability to obfuscate the subject, but what I’ve witnessed in this dialogue is a cry from policy-makers for increased clarity about the facts of international obligations and the potential impact of SEC-based regulations.
Dr. Bereano casually suggests that a science-based risk assessment is an arbitrary thing that can be randomly decided. The reality is that the OECD established science-based guidelines for rDNA technologies in 1986, nearly 30 years ago. Scientists and regulators around the world have implemented and followed these guidelines to ensure that there was consistency on how rDNA products would be regulated. These OECD guidelines provide a methodology for assessing risks, determining whether one product has a higher level of risk than another and that is repeatable.
In the expert examination of SECs and their impact on the regulation of products of biotechnology that was collaboratively undertaken with Drs. Ludlow and Falck-Zepeda, one glaring consistency that was highlighted was the lack of methodologies to undertake the SEC assessment in a standardized format. The efforts of those opposed to the benefits of biotechnology, suggest that there is value in having an increasingly random process for SECs, yet the experts that contributed to our collaborative book reported the opposite. Policy-makers have a challenging enough time making informed regulatory decisions and what they do not need is further efforts to cloud and mask the situation.
The OECD risk assessment process is the cornerstone of the WTO’s SPS Agreement, which has become embedded in numerous other international agencies, such as the WHO, FAO, IPPC, OIE, WIPO and NAFTA, not to mention Art. 15 of the CPB. To suggest that deviation from methodologies that provide quantified information that aids policy-makers in making difficult decisions to an SEC-based process with proven lack of methodologies, no benchmark or baseline data, the ability to include speculative or hypothetical risks and multiple order impacts will only result in an increasingly complex black-box of LMO regulation.
Clarity for policy-makers is based on repeatable methodologies that provide quantified results. The OECD rDNA guidelines have resulted in the safe regulation of GM crops for 20 years now. To date, there is no evidence to suggest that risk assessments are incomplete and that environmental harms are taking place in the nearly 30 countries producing GM crops. The clarity that the SECs experts revealed in our book is that the incorporation of SECs into a biosafety regulatory framework, result in less clarity, not more.
Sincerely, Stuart
posted on 2015-05-06 21:55 UTC by Dr. Stuart Smyth, Dr.
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RE: Open discussion
[#7065]
Dear participants
I want to add one comment about the question 4:
The decision to accept or deny an LMO should be scientific due to the context of the Protocol. The Protocol regulates some specific techniques applied to a technology.
In this context, the Risk Assessment should be independent of the socio-economic considerations, however, when in the ERA it identifies some considerable impact on biodiversity that can affect directly the socio-economic context of a region, the SEC should be boarded to decide if the possible impact can be managed, or definitively the LMO should not be approved. That means only a scientific criteria should lead to SEC in the decision making process.
If the SEC´s are not tied together with a scientific cause and specifically derived of the transgen (the characteristic conferred to LMO), the SEC´s lose impartiality, applying only to LMO´s evaluations that should be applied to all technologies and kinds of products and production systems (i.e. conventional hybrids, landraces, organics, etc.)
Many of the SE impacts listed in the forum are related to policies that governments should establish in general for the production systems and the biodiversity conservation.
I think the ecosystem services are a good approach to think how and when to conduct a SEC´s specifically for GM products.
Thanks
posted on 2015-05-06 16:45 UTC by Mrs Carolina Villafañe, Colombia
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RE: Open discussion
[#7068]
Dear colleagues, Thank you all for your comments; they certainly enrich the knowledge and the opinions of all the participants to this forum. An essential point I wish to mention to determine the extent of socio-economic considerations is the public participation. We need to take into account the views of the communities that are directly involved, and whom can be directly affected by those activities that make use of GMOs. The challenge is precisely how to determine that there is indeed an affectation associated to GMOs. Within the sovereignty of each state, participation and consultation mechanisms should be recognized and established, in order to allow the decision makers to know the opinion, requirements, knowledge and effects, in a case by case manner. Having said that, the process is casuistic as every situation will be depending on the type of GMO, the site and the community involved. It is relevant that the context is well established, therefore is important to consider that the information should come from both parts: the opinions form those who pretend to use the technology, and those who cohabit the place or region which aims to be used for deliberate release of GMOs once the risk evaluation has been performed. With these elements, we can set realistic parameters that point out the additional needs of the communities, and allow us to determine if there would be possible affectations, ponder the necessities or refine the measures for carrying out the GMO release, as well as providing valuable information for the development of guidelines for coexistence and even crop protection programs. In addition to the technical and scientific information accumulated over the years, it would be possible to take better decisions taking into consideration these results. Recognizing that each state has its own characteristics, requirements and different priorities, it becomes necessary that each Party evaluates according to their national legislation the effects that might be associated to GMOs, taking into account socio-economic aspects with the community participation. In the case of Mexico, a megadiverse country, the National Law on biosafety explicitly takes into account provisions for restricted GMOs zones, such as origin centers and genetic diversity, protected natural areas, free zones for organic production and other areas of the community interest where it is demonstrated scientifically that coexistence is not possible; it also considers general public consultation and a special consultation to indigenous communities established in those areas where the release of GMOs is intended, as part of the recognition of the relevance of socio-economic aspects. Studies and solid research about the socioeconomic effects associated with GMO is therefore useful, but the crucial part is to identify clear criteria that merit consideration. To summarize, we consider that further discussions have to center on which components of the socioeconomic considerations are common to the Parties, because as we mentioned before, differences will be inevitable due to the case by case scenarios, yet the sovereignty of each country to reach a decision has to be respected. We also consider that some of the concerns exchanged in this forum are (if regulatory systems are in place) or can be addressed with the implementation of a good regulatory framework that makes the inclusion of SECs according to the legislation from each country. Finally, we have to clarify that to date there is not prohibition to cultivate genetically modified soy in Mexico and that it has not been returned any shipment of Mexican honey from the European Community due to GMO presence. It’s important to mention that Mexico's government has financed research about socio-economic considerations from public universities that provide . Best regards.
posted on 2015-05-06 19:07 UTC by Marco Antonio Ramírez Velázquez, Mexico
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RE: Open discussion
[#7069]
Dear colleagues,
A rich and proactive forum! Just only several few comments for integration SEC issues in the context of the current discussion. As we can see and followed for several comments, the “conventional economical approach” for valuation nature, environmental services and of course, the interaction of valuation several aspects related with transgenic organisms, biodiversity and society is an essential aspect, but this is not enough for the complete valuation of the different aspects. Several issues involved are related with complexity, and we need to use science for given a better understanding for mid and long term decisions for policy making. “Cost/Benefit approach” as we can see, after results of the comments of several colleagues here, is no enough. Just only give us, direct and current results. If the market change, the valuation too and the results will be others. This is a part, but no a complete approach. On these considerations, we need more scientific (and no less or simplify just only with a conventional tool such are those very well known by economists) approach and integrate holistic and multicriterial approaches. Complexity in terms of society and nature could be a relevant approach that we need to keep in mind in terms of the decisions and the analysis we are tackling. The simplification of the methodologies that could be use, just only give us a “simplify result” that is no taking in consideration the long term aspects of releasing new events. Scientists need more deep and concrete approach, avoiding the situations and positions that has been see in several comments, where as commented ours colleague from Philippines are showing more a position of a country than a real analysis in terms of what we need: scientific and integrate discussions, and no only enthusiastic comments in pro or con any proposal. Risks cost of new technologies, and benefits of course, could study be under an integrate analysis. My suggestion is that perhaps, we can share and discuss in the future, methods, methodologies, instruments and elements coming from a more complete and concrete approach for putting in value these particular situations, and, I find that ECOLOGICAL ECONOMICS, ENVIRONMENTAL ECONOMICS, AGROECOLOGY, EMERGY ANALYSIS, MFA (Disciplines that are direct related with Environmental and Economical Analysis), could give several colleagues, new perspectives and approaches. Thank you very much for the opportunity, for sharing the knowledge and the proactive comments that we have been reading. Regards, Walter Pengue
posted on 2015-05-06 19:42 UTC by Prof Walter Pengue, UNIVERSIDAD NACIONAL DE GENERAL SARMIENTO
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RE: Open discussion
[#7086]
Summarizing the discussion on the conceptual clarity of SEC –LMOs and the context, I am of the opinion that we can conclude that the followings: 1. The SEC-LMOs is requested by the CPB by a number of articles and annexes. There was reference made to the agreements directly related to the CPB, namely the Convention on Biodiversity (CBD), the Nagoya Protocol, and the Nagoya-Kuala Lumpur Supplementary Protocol. The debate at hand, follows a line of command that starts with Agenda 21 ( Chapters 15 and 16), the Rio Declaration (Principles 6, 8, 9, 10 and 22 in particular) and the Convention on Biological Diversity (Article 19), which are the direct antecedents of the Cartagena Protocol.
2. The WTO’s SPS Agreement and other mentioned conventions have their specific tasks and issues (trade barriers) that do not have the environmental and biodiversity connotation and could not be considered as the argument against the SEC for biosafety. The precautionary principle/approach is part of both agreements.
3. Given the multi-dimensional nature of SEC, I would just listing the discussed issues that have to be considered while the SEC for LMOs: - broader impact to biodiversity which are representative, unique or associated with key evolutionary or other biological processes - loss of agricultural diversity - food supply and food safety - diets and nutrition have an impact on socio-economic considerations because they affect the overall health and hence the productivity of human resources - bioaccumulation of the herbicides related to the management of LM crops tolerant to herbicides, and its potential effects on wild flora, wild and domesticated fauna, and human health. Changes in the soil biota. - public health associated effects and costs - harm to ecosystem services - the customs and traditions (indigenous or local community) - reduced employment - cultural, religious and ethical values surrounding food and agriculture - loss of traditional market - centres of origin of the likely potential receiving environment - geographical, climatic and ecological characteristics should be part of SEC 4. We agree on the importance, not only of food supply, but also on the heritage for future generations, especially as the environment is concerned.
5. There is strong connection of SEC with the risk assessment results that can be interpreted in a broader context of overall risks (second-and-higher-order-effects) and the management strategies.
6. It is stated that there is no agreed specific methodology for SEC-LMOs available. The countries –producers of biotechnologies have developed mostly socio-economic assessment related to the positive impact and cost-effectiveness, and have less experiences to the assessment of broader or associated consequences to the environment/ecosystems/public health/cultural-ethical aspects. The absence of a methodology does not relieve us of the responsibility to consider SEC in our decisions at national level. The capacity building needs for SEC procedures should be addressed.
7. Some participants are agree and emphasize ” that SECs should be an integral part of the decision making process regarding LMOs and for this ex ante and ex post analyses done with sound methodologies would serve the purpose.
I am of the opinion that we could not ignore importance of the SEC in the context of the CBD and the Protocol as it has the environmental and biodiversity dimension. I am of view that in the discussion there is a strong lobby of the biotechnological circles that make attempt to influence deviate from the scope to have useful instruments to ensure safety of the biotechnology in the CBD scope. Some of the provided arguments in favor of not to consider SEC-LMOs are frankly speculative and tendentious. My strong understanding is that it is wrong to think that the salvation of mankind from malnutrition and poverty by spreading the biotechnology can be successful without a broader consideration on possible social and economic impact under the environmental scopes. Kind regards, Angela
posted on 2015-05-07 11:38 UTC by Angela Lozan
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RE: Open discussion
[#7089]
Dear Participants,
Thank you for your final comments over these last few days and your very active participation during these past weeks. As has been mentioned by several of you, the AHTEG will certainly benefit from the many opinions expressed in these discussions. We invite you to visit the portal on socio-economic considerations over the next months where we will be updating information about upcoming activities.
Lastly, we express our gratitude once again to the moderators that have collaborated to facilitate these discussions.
Kind regards,
Paola
posted on 2015-05-07 13:47 UTC by Ms. Paola Scarone, Secretariat of the Convention on Biological Diversity
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