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Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6541]
Dear members of the AHTEG sub-group,

I am pleased to announce that the sub-group discussion for “Reviewing the grouping of comments done by the Secretariat and revising it as needed” is now open. 

An Excel file containing 7 tables with the grouped comments as well as the “Guidance on Risk Assessment of LMOs” are available in the page of the discussion at http://bch.cbd.int/onlineconferences/RA_ahteg_subgroup. Below is a set of guidelines to assist the sub-group in its task.

As noted by Helmut, the sub-group will organize its own work and carry out discussions without a Chair. The Secretariat will be available throughout the discussions to provide assistance.

Please note that this discussion end on 23 March 2015.

We look forward to your contributions.

Thank you and best wishes,
Manoela


-> Guidelines for this discussion:

• The AHTEG sub-group is invited to evaluate whether each comment was placed in the most appropriate category, and to propose changes as needed;

• Proposals for changes may include moving a comment to another category, splitting a comment in several sub-comments, or merging different comments by the same author;

• Proposals for changes must include the section of the Guidance (e.g. Roadmap, Stacked genes, etc.) and the ID for each comment being referred to;

• In cases where the proposal for changes concerns only to part of a comment, the proposal should clearly indicate the specific part of the comment it refers to (e.g. in comment Roadmap IDXX, move the following sentence “xxxx xxx xxx xxx xxx” from category “Y” to category “Z”);

• Members of the sub-group are kindly requested, at this point in time, not to make changes directly to the Excel tables but rather to explain their proposals in the online discussion.
posted on 2015-03-09 01:09 UTC by Ms. Manoela Miranda, UNEP/SCBD
This is a reply to 6541 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6543]
Dear members of the AHTEG sub-group,

Nearly a week has passed since the opening of this discussion and, so far, no comments have been posted, which brings me to believe that you are deeply immersed in the task at hand!

I would like to reiterate that the objective of this round of discussion is to evaluate whether each comment provided through the testing of the Guidance was placed in the most appropriate category, and proposing revisions as needed. The excel file containing the categorized comments is available at the page of the discussion (http://bch.cbd.int/onlineconferences/RA_ahteg_subgroup/). Alternatively, it may be downloaded directly from  http://bch.cbd.int/forum/ahteg/ra_guidance_testing/grouped_comments.xlsx

While evaluating the categorization of each comment, I would like to invite you to also consider the suggestions made by Patricia at http://bch.cbd.int/onlineconferences/ahteg_ra.shtml?threadid=6490#6504 .

Let me end this message by wishing you a good weekend and emphasizing the importance of your current task which will lay the foundation for all the work ahead.

I look forward to your comments. Please do not hesitate to contact me if you have any question or need assistance posting your comments.

Best wishes,
Manoela
posted on 2015-03-13 18:21 UTC by Ms. Manoela Miranda, UNEP/SCBD
This is a reply to 6543 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6544]
Dear Subgroup and Dear Secretariat!!!!!!!!!
I am very sorry for not have had the time to work on this as scheduled……….but I am now reporting back on some of the work that we were asked to be done. I have looked into all the grouping in the "roadmap section" and "general comment section", Y have not yet been able to look into the rest, but I will between today and tomorrow.
When I looked into the comments, I decided to make the "submission column" invisible to my eyes so as to try being more objective.
Roadmap section:
ID 295 copy (not delete) a sentence in category A and add it to category C. The sentence  "...Since this Roadmap has limited utility for risk assessment related to field trials, we suggest removing the paragraph beginning at line 184….".
ID 437 copy (not delete) a sentence in category A and add it to category C. "...b) The concept of uncertainty and the description of the nature of uncertainty as: (i) lack of information (in the Spanish version it says ‘pérdida,’ which is ‘loss,’ and it should be changed to ‘falta’)…"
General comment section:
ID 4 move from A to B
ID 8 move part from B to D copying but not deleting the idea from B. The two sentences are: "...In that respect, the Guidance could be more efficient by proposing specific examples of adequately formulated risk hypotheses, including selection of assessment endpoints and ways of collecting relevant data supporting the risk assessment. In addition, examples illustrating the implementation of the guidance and the risk assessment methodology for specific cases could be a way forward to improve the utility of the guidance…."
ID 10 move part from B to C, copying but not deleting from B, where it says: "...As for the discussion on the subject contained in lines 525 through 529, this would be more appropriately addressed in the working group on social and economical aspects…"
ID 11 move suggestions from B to D but not deleting from B, where it says:
"..The document could be improved by supplementing the text with overview tables and/ or figures showing the elements to consider in the risk assessment. Specific guidance on how to investigate and quantify the effect of transgenes on biotic interactions is needed. A possible method has previously been suggested (Damgaard and Kjær, 2009). Rosemary Hails recommended in an earlier guidance document the adoption of the method of Damgaard & Kjær (2009) Damgaard & Kjær 2009. Competitive interactions and the effect of herbivory on Bt-Brassica napus, Brassica rapa and Lolium perenne. Journal of Applied Ecology, 46, 1073-1079"
ID 12 move suggestions from B to D, where it says "...Nevertheless, we would like to suggest the following improvements to the guidance: - The Part I should be more detailed - Although Part II has not been tested by our working group, we welcome the deepening of risk assessment on specific traits of organisms, and we consider useful to provide additional specific cases. - About Part III, our evaluation is very positive and we considered important to include also the General Monitoring in the guidance. - We suggest to include the 'background materials' at the end of each part of the guidance. In order to improve the 'practicality' of this online bibliography we suggest to add a search bar in order to filter documents for keywords such as LMOs, Genes or Organisms. Furthermore, the references can be further implemented and updated."
ID 16 move from B to D or E, where it says: "...Some of the information in the part I of the Roadmap are specific for plants only such as 'Agricultural practices ' or 'Pest management ' practice while the scope of this part is for LMOs in general."
I looked into Patricia Gadaletas´suggestions and the ones which I agreed with are already taken above. In a first instance I also thought of proposing several changes from B to D, but I then realized that B section also can trigger changes on the whole, so I refrained from proposing changes I originally had identified.
I have some general comments while reading all the categories in these two sections that I will add in a second reply message.

Un abrazo a todos!!!!!!!!
Francisca
posted on 2015-03-15 17:49 UTC by Ms. Francisca Acevedo, Mexico
This is a reply to 6543 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6545]
Dear Subgroup and Secretariat!
As I mentioned in my previous message, I am adding some general comments and/or issues that I have identified through reading the two sections (roadmap and general comments). I hope these might be helpful in following discussions with the whole AHTEG and with the online forum at due time…..
1.-Scope. There seems to be a need on explicitly recapitulating on scope of the roadmap and targeted audience, I feel there is not an agreement on these issues.
2.- I found out that some of those who went through the testing process did it in a way that to my eyes may have been not too useful. They designed a methodology that included testing the guidance by using BCH reports on previous risk assessments, but expecting them to be aligned and consistent with the guidance (or vice versa?). This is circular in nature, the analysis is then confusing because he or she who analyses is probably expecting something beforehand that the guidance will not provide.
3.-Several information gaps were identified and it might be useful to analyze them.
4.- Some comments are related to a lack of logical linkage (in spanish we say "hilo conductor") between the different steps&sections in the roadmap and how these also relate to the different sections with the specific documents (trees, mosquitoes, stacked genes, etc).
5.- Several comments deal with an absence on "human health issues".
6.- The Roadmap should be more general and less focussed on plants.
7.- The need of including examples.
8.- Several comments talk about the need of mentioning the benefits derived from LMOs and not only focussing on the possible risks…….this is not convincing to me in particular because the whole point of the guidance is trying to "guide" on what the Cartagena Protocol calls on for in relation to "risk assessment"….i.e., benefits are not the point in this exercise all together (that does not mean that the Protocol does not recognize that potential benefits are to be expected and welcomed, but it should´t be part of this guidance)…
9.- Several comments advice taking into account in a formal manner in the guidance all the accumulated knowledge on non LMOs, as for comparative approach when doing the risk assessment.

I hope these comments or identified issues are useful later on in our work.

Un abrazo,
Fran
posted on 2015-03-15 18:19 UTC by Ms. Francisca Acevedo, Mexico
This is a reply to 6541 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6547]
POSTED ON BEHALF OF ANGELA LOZAN

-----

Dear Manoela, Dear All,

Thank you for guiding questions that help us to check the place of comments in the documents.

Thank you Francesca to being a pioneer and starting this round of discussion with a good analysis and suggestions. The proposed task is a bit difficult due to the large document containing a big number of comments, so this is why I was late with my contribution.

As it was proposed to work in the sub-group, I tried to revise the comments provided by the countries participated in the testing exercise on Roadmap that we had in the CEE region last year, and submitted their comments, including Belarus, Moldova (Ministry of Environment, Academy of Sciences, State University and NGO “Eco-Tiras”), Tajikistan, Turkey and Ukraine.

1. In mainly the comments of the mentioned countries are distributed correct under the proposed categories and correspond to the criteria of grouping.

2. I just wish to propose replacing of the ID 402 and ID421 (suggestions made by Moldova) from the category D to the document: General comments section, as they do not propose any needs in changing of the text of Roadmap, but have a confirmation character explaining that the Roadmap is an open document, and the reference materials can be updated in any time.

3. Many of the proposed from the region suggestions that are under category D and E are referred to the needs to involve the human health issues in the risk assessment.

4. Some of suggestions refer to the terminology and editorial improvements.

5. There is a proposal of Belarus to provide the text with specific examples or illustrations.

6. Ukraine proposed to take into consideration the amendments of the Alma-Ata amendments to the Aarhus Convention. 

7. I find the proposal made by Turkey very interesting and I am of view that we can give attention for the following improvement of the Guidance: “All questions in the road map needs to be taken out and presented as a questionnaire at the end or beginning of the guidance. Wording should be used to give explanation for the questions. … All related things should be in the questionnaire as stated above, across them related references needs to be given in parenthesis like (1, 2, 5). Therefore for risk assessment a standard application would be possible.”

Best wishes,
Angela
MD
posted on 2015-03-18 16:10 UTC by Ms. Manoela Miranda, UNEP/SCBD
This is a reply to 6541 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6549]
Dear Francisca and Angela,

Many thanks for your valuable contribution and thoughtful comments.


Dear members of the AHTEG sub-group,

This is a gentle reminder that this discussion will close in a little more than 24 hours (i.e. at 1:00 a.m. GMT of Monday, 23 March, which corresponds to the night from Sunday to Monday for most).

Best wishes,
Manoela
posted on 2015-03-21 23:19 UTC by Ms. Manoela Miranda, UNEP/SCBD
This is a reply to 6541 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6550]
Dear colleagues and Secretariat:
Good afternoon to all! I was able yesterday to take some time and look into the categories in the rest of the sections (stacks, GM trees, abiotic conditions, LM mosquitoes and monitoring). As I did with the previous sections, I decided to be "blind" regarding who made the comments so as to try being a bit more objective.

Most of the comments were in the the right category according to what I reviewed. I am only adding a couple of suggestions to some of the sections.

Stacks:
ID 63 should probably go in D so as be taken into account.
ID 21 not really the precise translation….should say "….sus parientes silvestres no modificados…" instead of what was proposed as the correction.

LM mosquitoes:
ID 1 the suggestion is not correct.

LM trees:
ID 27 should be moved to a different section, it´s talking about LM mosquitoes.

One of the comments that I saw now and then and that might be worth reviewing and discussing a  bit is that some of the guideline developed for these specific sections could be already reflected in the roadmap as is. A interesting way forward could be identifying them and somehow linking them and the roadmap.

It was also observed that the logic behind these specific guidelines didn´t always follow the same logical steps as the roadmap…….and we should maybe look into this.

I identified many useful comments that should be taken on board in our discussions promptly, but will wait until the following discussions open.

Kind regards to all!
Un abrazo,
Fran
posted on 2015-03-22 00:03 UTC by Ms. Francisca Acevedo, Mexico
This is a reply to 6550 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6551]
Dear Secretariat, Helmut and AHTEG sub-group colleagues,

Sorry for being so late with my comments. This has been quite time-consuming (not a surprise) but very interesting. And many, many thanks to Francisca and Angela for their comments and analysis. Also Patricia Gadaleta provided helpful, specific comments during the February discussions. Many thanks for those comments and analysis too.

Here are my comments on the Roadmap. I will send my comments on the other parts before closure of the discussions tonight.

Please note, that in most cases, with the exception on ID 295, I suggest copying the text to another category, not to delete. In the case of copying, I suggest that this is stated in parenthesis after the copied text (copied from ID xx, category y) to ease cross-checking afterwards. I think this copying will help us when we later work on specific suggestion the text.

ID 75, category B: Copy the following sentence: ”For example, it poses no questions regarding the type of pathogen …” to category D.
(In this comment there seems to be a duplication of text?)

ID150, category B: Copy the following two sentences: ”A good example is the extensive list …is well characterized.” to category E.

ID 159, category B: Copy the following sentence: ”The documents says that some …” to category D.

ID 166, category B: Copy the following sentence: ”For example in Step 1, the Guidance lists the points to consider …” to category D.

ID 167, category B: Copy the following sentence: ”In addition, the text gives the wrong impression …” to category D.

ID 295, category B: Move the sentences (8 sentences if I calculated correctly): ”Speculative hazards such as those … are not included at all in the document.” to category E.
Move the sentences: ”In general, considerations of larger landscape … monitoring and risk management.” to category D.
With the sentence: ”Since this document …” I agree with Francisca’s suggestion.

ID 437, category B: My comment is the same as Francisca’s (”The concept of uncertainty …changed to falta” – copy from B to C).

ID 126, category D: Copy the following two sentences: ”Part I states that …(lines 181-2).” to category E.

ID 161, category D: Copy the following sentence: ”Perhaps the most striking …” to category E.

ID 185, category D: Copy the following sentence: ”Although this point …” to category E.

ID 192, category D: Copy the following sentence: ”The iterative nature …” to category E.

ID 219, category D: Copy the following sentence: ”The Article 15, 16 …” to category E.

ID 391, category D: Copy the following sentence: ”The guidance document …” to category E.

ID 414, category D: Copy the following two sentences: ”The discussion on centers …” to category E.

ID 336 and ID 337 (in category E) should be copied to the comments on Monitoring (category B or D).

ID 383, category E: Copy the following sentence: ”For instance, for RA of LMO …” to the comments on Stacked genes (category D).

These are all my comments on the Roadmap. Further comments on other sections later today/tonight.

All the best, Marja
posted on 2015-03-22 12:03 UTC by Marja Ruohonen-Lehto
This is a reply to 6551 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6552]
Dear all,

here are my comments on the rest of the Guidance.
In my earlier intervention from today, I explained my reasoning for copying.
All copied comments should be marked as copied comments, with reference to their original grouping.

General comments:

I agree with Francisca’s suggested changes on
ID 4, ID 8, ID 11, ID 12 and ID 16.

ID 10, category B: Copy the two sentences: ”As for the discussion  … than in the guidance.” to category D.

ID 17, category B: Copy the sentences: ”The process described for …look like shopping lists.” to category D.


LM trees:

As Francisca stated, ID 27 belongs to the Mosquitoes document.

ID 32, category B: Copy the sentences: “The fact that … part 1) to category D.

ID 2, category D: Copy the sentence: “This is evident …” to category E

ID 4, category D: Is this comment specific for LM trees?

ID 12, category D: Also this comment seems general and not specific for LM trees.

ID 24, category D: Copy the sentences: “The problem of scope … than non-trees” to category E.

ID 30, category D: Copy the sentence: “As mentioned above …” to category E.

ID 13, category E: Move the comment to category D.

ID 14, category E: Move the comment to category D.

ID 17, category E: May contain elements also for category D. Copy to category D with this note.

ID 42, category E: May contain elements also for category D. Copy to category D with this note.


LM Mosquitoes:

ID 12, category E. May contain elements also for category D. Copy to category D with this note.

ID 31, category E. May contain elements also for category D. Copy to category D with this note.


Abiotic stress:

ID 9, category B: copy the sentences: “In the introduction … to tolerate abiotic stress.” to category E.

ID 16, category B: copy the comment to category D.

ID 26, category D: copy the comment to category E.

ID 28, category D: copy the sentence: “In practice these …” to category E.

ID 31, category E: May contain elements also for category D. Copy to category D with this note.


Stacked genes:

ID 2, category B: is this comment specific for stacked genes?

ID 5, category B: Copy this comment also to category E

ID 61, category E: This comment may be useful also in category D. Copy to category D with this note.


Monitoring:

ID 8, category B: This comment may be useful also in category E. Copy to category E with this note.

ID 48, category D: This comment should be copied to the Roadmap comments (category E) – for cross-reference.

ID 44, category E: Copy the first sentence “A more detailed description …” to category D.

ID 66, category E: This comment may contain elements for category D. Copy to category D with this note.

ID 90, category E: This comment contains elements for category D. Copy to category D with this note.


Dear friends, these are my comments.
Until next discussions,
best wishes and take care,

Marja
posted on 2015-03-22 19:39 UTC by Marja Ruohonen-Lehto
This is a reply to 6541 RE: Opening of the discussion (AHTEG sub-group): “Reviewing the grouping of comments done by the Secretariat and revising it as needed” [#6553]
Dear members of the sub-group,

Thank you very much for your contribution and incredible amount of work you have put into this task. Your comments are very helpful and lay the foundation for the work ahead.

During the coming week, the Secretariat will, in consultation with the Chair of the AHTEG, consider and implement your suggestions, as appropriate, in preparation for the next round of discussion of the sub-group which will start in a week from now on 30 March 2015. A revised version of the Excel file containing the grouped comments from the testing will be made available during the next few days.

I once again thank the AHTEG sub-group for its dedication and valuable contribution. This discussion is now closed.

Best wishes,
Manoela
posted on 2015-03-23 02:22 UTC by Ms. Manoela Miranda, UNEP/SCBD