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Sub-working Group on the Roadmap for Risk Assessment

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Re: New draft version of the Roadmap, including a draft Flowchart (2) [#1624]


Dear All,

Highly appreciate the efforts that lead to this good version. Sorry for the delay in my response. I have only several concerns:

Line 41-43: the sentence ‘What is considered adverse effects depends on protection goals and risk assessment end-points as chosen by the Party and set out in existing policies and strategies ‘ may lead to dispution between parties when they have different opinion on the adverse effects of LMOs upon transboundary movement. The overall assessment in step 5 could work for setting up a kind of standards for adverse or not.

Line 198: management could be ‘manageable’.

Line 281: point (d), Commercial release some time may also need the information of the receiving environment when the commercialization is only granted in a limited area (region).

Line 292-294: step 3, Why not also include the new characteristics here as we did not evaluate the risk level of new characteristics of LMOs in the before steps. Perhaps it is not necessary to do that but I would like to draw your attention in this aspect.

Line 330: points to consider: Again, we may have to consider also the new characteristics of the LMOs that may have adverse effect.

Line 356: the recommendations may also include proposed management strategies.

Line 366: could also include the new characteristics that probably cause adverse effect in the points to consider here?

Best regards

(edited on 2010-03-15 12:18 UTC by Manoela Miranda)
posted on 2010-03-15 12:18 UTC by Ms. Manoela Miranda, UNEP/SCBD
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