Development of the Roadmap for Risk Assessment
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co-existence or not
[#1209]
I highly can not agree with the statement in the suggested discussion item no.13 that coexistence only concerns the potential economic loss and the impact of the admixture of GM and non-GM crops and is not directly related to risk environmental. I also suggest that we should take care when we decide to give a definition in the glossary part in the roadmap.
From my personal view, co-existence is not only a compromise of European society but also has positive meanings. European people declared co-existence with the purpose of sustainable utilization of GM crops, which I really appreciate. The aims to minimize admixture is not only a concern to economy but also a kindly concern to environment.
I make my point with an example of insect resistant crops. Regarding spontaneous gene flow between GM and non-GM crops, admixture could happen in the field. Minimizing admixture will not only reduce the economic loss but also reduce the exposure opportunity of insect pests to the resistant products and thus could reduce the opportunity of resistance tolerance of insect. That will definitely contribute to the sustainability of GM crops.
That is only one of these benefits of co-existence to the environment. Biodiversity will be protected in this way. In conclusion, I propose that we really need to think co-existence as one part of risk assessment and management.
posted on 2009-06-28 19:46 UTC by Mr. Wei Wei, China
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RE: co-existence or not
[#1217]
First, I wish to thank Hans for proposing the discussion item # 13, and Wei and Thomas for opening the discussion on the issue of co-existence. I would agree with Thomas' view that this is really a point for discussion if co-existence should be regarded as risk assessment and management tool for decision-making. At the same time, as the roadmap bears the recommending character at this stage, co-existence could be considered in it. I would like to mention several important related aspects. Co-existence implies possible environmental risks and makes it possible to manage them through certain measures. For example, in case of GM crops (oil-seed rape) out-crossing with wild plants there is a need to define various measures to make co-existence possible.
Also it is necessary to look at all phases of agricultural plant production from crop planning to delivery of harvest. Co-existence measures allow to avoid exceeding the threshold value of 0.9% GM content, that is the requirement for labeling and commerce. The special study is needed to determine the crop-specific distances, isolation distances, to reveal the role of wind, insects, specifically the honey bees in carrying pollen over distances. Therefore, to my opinion, the issue of co-existence is significant in determining the risks on the stage of study and crops growing, harvesting, commercialization, labeling, transportation. I recognize that not all the countries have or will have co-existence laws, but if this issue is reflected in the roadmap, it will help to take the sufficient measures for segregation between GM and non GM production and thus to manage and reduce the adverse risks to human and environment.
In line with the view of Wei, I see the place of co-existence both in risk assessment and risk management steps.
Angela
posted on 2009-06-30 14:40 UTC by Angela Lozan
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RE: co-existence or not
[#1229]
‘Discussion item 13’ in the advance draft of the Roadmap has spurred a number of comments, and I am very grateful to those that have reacted. From the reactions I get the idea that in retrospect, I should have formulated this discussion item 13 differently, and that I should have explained my way of thinking better. Therefore, I try again here to contribute to the discussion on coexistence.
The term ‘coexistence’ has a special meaning in the discussion of this issue in the EC. It refers to situations that may occur when GM plants that have an approval for unlimited release into the environment are actually released.
If these GM plants may outcross with sexually compatible relatives, e.g. crop plants of the same species, the GM construct present in the GMO may be introduced into the non-GM crop plants. This would turn the non-modified plant into a GMO. This may have consequences for the product, e.g. if outcrossing leads to occurrence of GMOs crops that are grown organically, the product may not to be regarded as organic due to this.
What should be kept in mind is that the approval for the unlimited release, that causes the coexistence issues, can only be given based on the outcome of a risk assessment of the GM plant, and that his risk assessment should have taken into account all environmental issues. This risk assessment should therefore also have taken into account any adverse environmental effects of outcrossing from the GM plant to other (crop) plants. It follows that in the discussion on ‘coexistence’, that will only be started after the environmental risk assessment has been concluded, adverse environmental effects do not have to be taken into account again.
I have had a look at the roadmap to see whether adverse environmental effects due to outcrossing are taken into account explicitly enough, and I think there is room for improvement here. In the Netherlands, we have the following rationale for treating outcrossing in our environmental risk assessments: if outcrossing occurs successfully, it gives rise to a new GMO. So, if in the risk assessment we find that outcrossing may occur, a separate risk assessment should be done for each potential new GMO that may arise through the outcrossing. I would propose that we include some wording along these lines at an appropriate place in the document.
In conclusion: - Outcrossing from a GM plant to sexually compatible relatives may lead to adverse environmental effects, that have to be taken into account in the environmental risk assessment that is done previous to any approval for deliberate release. - Outcrossing may lead to adverse effects other than environmental effects. In the EU this type of considerations is meant when we use the term ‘coexistence’, and is taken into consideration in the discussion on ‘coexistence’. - It is good to keep these two types of effects of outcrossing clearly separated: the adverse environmental effects and the ‘coexistence’ effects. - Therefore, I would like to reserve the term ‘coexistence’, as it is done now in the EU, to adverse effects other than those that are taken into consideration in the environmental risk assessment. - Adverse environmental effects due to outcrossing have to be taken into account in the environmental risk assessment. Therefore they should be mentioned in the Roadmap. We should however not use the term ‘coexistence’ for these issues. What we would have to do: - We should discuss how to take care of the adverse environmental effects of outcrossing in the Roadmap. - We mention the issue of ‘coexistence’ only under the heading ‘related issues’ in the document.
posted on 2009-07-02 13:13 UTC by Mr. Hans Bergmans, PRRI
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RE: co-existence or not
[#1281]
I think Hans has provided a useful compromise by suggesting that coexistence be moved to other considerations since this clearly falls outside of the scope of the roadmap . I feel the road map already has enough guidance on the consequencess of outcrossing and although language can always be improved, what is here seems descriptive enough.
posted on 2009-07-10 17:11 UTC by Mr. Phil Macdonald, Canada
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RE: co-existence or not
[#1296]
Replying to the discussion on co-existence, I would like to comment as follows. The risk of LMO on co-existence with non-LMO is basically related to crop yield and quality, and does not directly affect on biodiversity. Therefore we do not need to consider the risk assessment of LMO on co-existence as well as biodiversity. On the other hand, we cannot ignore the possibility of spread of LMO and/or transgenic genes (transgene), in case that the LMO have high potential of a) outcrossing and introgression and b) voluntary. Because the dropped such LMO seeds may expand their survival area secondarily, except for seed contamination to none-LMO.
Best regards
posted on 2009-07-10 23:53 UTC by Yasuhiro Yogo, Japan
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RE: co-existence or not
[#1300]
With all due respect to my colleagues, I cannot understand how people can argue that the co-existence question is not a potential impact which must be assessed because of its negative consequences (maybe there are even positive ones!)
One obvious potential impact of GE crops is gene flow--by pollen transfer, by horizontal gene flow mechanisms, etc. Research has shown that this is something like 20 times more likely for a change caused by GE than for a mutational change. (I don´t have the citation here--it was a Danish study, I believe--maybe 10 years ago). This is an impact, without possible argument. It is a "contamination" of the receiving crop (whether for good or ill). I do not see how such a change can be argued as not being an impact. Thus, it must be assessed.
"Co-existence" is a label given to policy responses to such contamination, but the term ALSO describes the physical situation itself. Can these 2 strains co-exist (ie, as separate identifiable entities, without "contamination"·)? Ie, is "co-existence " possible? How can we exclude this question from an assessment under the Protocol, since one of the primary motivations for negotiating the agreement was the need to curb such potential contamination.
If AHTEG does exclude consideration of this aspect of assessment, its results will be seriously devalued by relevant decision-makers.
Philip Bereano
posted on 2009-07-11 14:34 UTC by Dr. Philip L. Bereano, University of Washington
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RE: co-existence or not
[#1309]
Regulatory decision-making, which is a form of risk management, may be informed not only by the scientific risk assessment but also by other legitimate factors, to the extent permitted in regulations and consistent with international obligations. In this context, coexistence per se is not a consideration for environmental risk assessment, although management options permitting coexistence may be among those factors considered during the regulatory decision-making process. While it is often tempting to think of coexistence issues as only pertaining to environmental releases of LMOs, there are also examples for conventional crop types. For example, the identity-preserved production and genetic isolation of high-erucic acid rapeseed (non-LMO) from food canola is a risk management requirement put in place for food safety and coexistence reasons. Identity preserved production systems for certain crop varieties with enhanced quality attributes may be implemented to preserve these quality attributes within a value chain, while permitting coexistence with conventional production systems. In all of these examples, including those related to LMOs, the appropriate positioning of coexistence considerations is within the decision-making process and not as a component of the scientific risk assessment.
posted on 2009-07-12 13:10 UTC by Dr. Donald MacKenzie, Donald Danforth Plant Science Center
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RE: co-existence or not
[#1326]
POSTED ON BEHALF OF DR. LUTHER VAL GIDDINGS --------------------------------------------- The issue of gene flow is an interesting case study in just how far the public discussions of biotech in agriculture have become divorced from the context of current and historical agricultural practice, and unhinged from science. There is no basis in the scientific literature on the genetics of natural plants to support any suggestion that gene flow from biotech improved crops is either more frequent, or more likely to cause concern than the gene flow that is possible from conventional crops or ubiquitous in the plant kingdom. The few cases some have trotted out to support such claims do not stand up to scrutiny, and are contradicted by a massive body of scientific literature. Much of the discussion of gene flow in the context of risk assessment/management for biotech crops seems to presume, without any basis in science, that gene flow is per se hazardous. It is not. This abundantly falsified notion has no basis in fact, and moreover is rooted in a pre-darwinian, platonic paradigm that has been obsolete since 1859. It is interesting that discussion of gene flow is often cast, by some, as a negative consequence of biotech from which, for example, organic growers must be protected. It is ignored that, under the USDA organic standard, such gene flow, should it occur, would be irrelevant to organic status as long as the organic grower did not deliberately exploit it. It is left unanswered why, in the case of organic vs biotech but no other, the organic grower should have the right to export to a neighbor growing a legal, safe product the costs of producing a value added (organic) product for a niche market. If anyone can point to any other case where a grower has the right to impose the costs of production to meet arbitrary standards unilaterally set, on his or her neighbors without their consent and to their detriment, it would be a useful contribution to the discussion. Science indicates that all regulatory systems that focus on biotech crops due to the processes used in their production are not justified by science. A scientifically robust regulatory system would do what nature does -- evaluate specific products on the basis of their evident phenotype. Nature can distinguish by no other criterion, and science and abundant experience have not provided any basis to do otherwise. It is a further, interesting footnote to observe that there is no case yet established where biotech crops and foods approved and on the market today have been shown to be anything other than at least as safe as conventional and organic counterparts, and sometimes (as in the case of Bt insect-protected maize) safer. It is further true that claims of gene flow, per se (much less damage) have so far failed to withstand scrutiny. One is left to wonder why this topic is even included in this forum when there are inarguable, major sources of damage to biodiversity that are being less attended. The irony that biotech crops reduce the biodiversity impacts of agriculture (which is the single largest negative impactor on biodiversity) is palpable. As the Buddha is said to have stated, "Three things cannot long be hidden: the sun; the moon; and the truth." --------- Dr. Luther Val Giddings PrometheusAB, Inc. (PAB) LVG@PrometheusAB.com
posted on 2009-07-13 13:10 UTC by Ms. Manoela Miranda, UNEP/SCBD
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