Activities of the Open-Ended Online Forum (2014-2016)
Return to the list of threads...
|
Forum closed. No more comments will be accepted on this forum. |
Mid way fisrt week online discussions!
[#7587]
Dear participants of the online forum on risk assement and risk management:
First of all I would like to thank those participants who have posted their views up to know as well as all who are preparing their posts in the forum! (participating becomes crucial because the ideas, views, comments and suggestions will be taken up by the AHTEG in its further work planned to take place during this 2016 before COPMOP 8).
Lets not forget that this is a brainstorming session and the intention is to discuss how the different topics could be incorporated into the Roadmap. These could be incorporated maybe by adding a couple of sentences and/or text boxes in relevant places of the Roadmap to underline any special consideration or particularity in the risk assessment of these types of LMOs. That is to say, we are in no way intending to develop a full-fledged guidance.
I thank you all again once more for taking some time to give extra thoughts on these very important issues at hand.
Un abrazo a todos! Fran
posted on 2016-02-03 22:30 UTC by Ms. Francisca Acevedo, Mexico
|
Dear colleagues,
I join the others in thanking Francesca for being again available to moderate this discussion. I appreciate that Francesca and the Secretariat have arranged that the discussion on the 4 topics be conducted in separate threads.
I also thank Francesca for keeping this thread for general observations open, because I believe there are indeed some general questions that deserve discussion in this forum.
While I note Francesca’s plea not to discuss whether a certain item is relevant as a topic to be further considered, I actually believe that we should have a discussion on whether the suggested topics should be added.
Several colleagues before me have in my view correctly stated that some of the topics listed are more appropriately addressed in other fora than in guidance for ERA for GMO. More specifically, I support the comments of Martin Lema, Boet Glandorf and Maria Kammenou about the logic to assess the use – and possible overuse - of herbicides under the existing systems for herbicides, and not also under the CPB. As Boet said, there is no rationale to assess the safety of the same herbicide under two different regimes. Likewise, I support the comments by Martin Lema and Simona Baima, about the logic to assess food safety issues such as nutritional value under the existing Codex Alimentarius system, and not also under the CPB. The same applies mutatis mutandis for LMOs that are pharmaceuticals.
More in general I believe that the discussions and decisions of MOP7 advise us to first aim at improving the guidance on the basis of the test results and to discuss the revised guidance in MOP8, before new topics are considered.
This is particularly important given that the AHTEG seems to propose fundamental changes in the objective of the roadmap and the guidance in the text that has been added to the guidance starting on line 162: “The Roadmap introduces basic concepts of risk assessment rather than providing detailed guidance for individual case-specific risk assessments….”
I find this disconcerting on several levels. First, the notion that the roadmap would introduce new basic concepts is disconcerting, because the general principles are laid down in Annex III of the CBP, and it is not the role of the AHTEG or a roadmap to introduce new concepts. Introducing new basic concepts is the prerogative of the MOP. Second, the idea that this guidance is not intended to be used for individual cases, diverts from the very reason why it was – so many MOPs ago - felt necessary to develop practical guidance to help assessors apply the general principles and methodology of Annex III in actual cases.
I will follow up to the specific points in next posts Regards to all!
Piet
posted on 2016-02-09 23:17 UTC by Mr. Piet van der Meer, Ghent University, Belgium
|
Hello all, Thank you very much Francisca for all your efforts and work!!! In relation with the safety assessment of herbicides as applied to LMOs, I absolutely agree with Martin Lema, Boet Glandorf, Maria Kammenou, and the good summary sent by Piet van der Meer. In fact, in most of our countries, general agricultural regulatory frameworks will assess herbicide safety under international criteria and norms, therefore there is no justification to duplicate efforts. This is also valid for food safety issues. I really think that our major responsibility is to promote the harmonization and convergence of the different regulations and to encourage and facilitate compliance of the regulations, not to complicate them. Best regards, Elizabeth
posted on 2016-02-10 01:25 UTC by Professor Elizabeth Hodson, Colombia
|
Dear all,
I join others in thanking Francisca for her enthusiasm and hard work in moderating this forum.
I support Elizabeth Hodson and others in not duplicating efforts that are already addressed by agricultural frameworks and adding more complexity to an already complex guidance. My experience in biosafety discussions in my region (Honduras, Mexico) confirm that discussion often mix biosafety concerns regarding the potential risk of recombinant DNA technology and the use of LMOs, with issues related to inappropriate agricultural practices that may result in problems of insect and herbicide resistance and safety, to name a few. Weed and insect management in crops are issues that concern all agricultural systems including conventional, organic, subsistence and GM agriculture.
Best regards to all,
Maria
posted on 2016-02-10 04:50 UTC by Dr. Maria Mercedes Roca, CIBIOGEM, Mexico
|
Dear all, Firstly, thank the moderators and the CBD Secretariat for this forum. I also thank the opportunity to participate in this forum. My name is Adriana G. Moreira from the International Plant Protection Convention (IPPC) Secretariat ( https://www.ippc.int/en). Probably you all know, the IPPC, with its Secretariat hosted by the Food and Agriculture Organization of the United Nations, sets International Standards for Phytosanitary Measures (ISPMs), many of which are applicable to actions taken by Parties to the biodiversity-related conventions to prevent the introduction and spread of pests of plants through various pathways such as international trade. ISPMs can be applied to address the issues related to invasive alien species in terrestrial and aquatic environments, or living modified organisms (LMOs) that may present a phytosanitary risk. The IPPC is the only standard setting organization for plant health recognized by the members of the World Trade Organization under the Agreement on the Application of Sanitary and Phytosanitary Measures (the SPS Agreement). All this introduction was to highlight that the IPPC has the ISPM 11 on “Pest Risk Analysis for Quarantine Purposes” ( https://www.ippc.int/en/publications/639/). ISPM 11 provides details for the conduct of pest risk analysis (PRA) to determine if pests are quarantine pests. It describes the integrated processes to be used for risk assessment as well as the selection of risk management options. It includes guidance on evaluating potential phytosanitary risks to plants and plant products posed by LMOs. In addition, there are two annexes of this ISPM exclusively to deal with LMOs and in one of them (Annex 3 of ISPM 11) is relevant for living modified organisms only where there is potential for phytosanitary risks from the LMO associated with some characteristic or property related to the genetic modification. The IPPC also has an adopted recommendation on LMOs, Biosecurity and Alien Invasive Species (CPM Recommendation ICPM-3/2001, available at https://www.ippc.int/en/core-activities/governance/cpm-recommendations/recommendations-concerning-lmos-biosecurity-and-alien-invasive-species/). IPPC risk analysis and management systems are appropriate for assessing and managing, if necessary, the direct or indirect risks of pests to cultivated and wild flora and plant products that may be presented by LMOs/products of modern biotechnology. IPPC systems and procedures are relevant to, and adequate for, managing the risks posed by LMOs/products of modern biotechnology as they relate to the protection of plant health. There is a mention in line 293 on “international standards” however no reference to which international standards. The IPPC Secretariat wishes to express that this document should include reference to the IPPC, especially for ISPM 11. Pest Risk Analysis for Quarantine Purposes. The IPPC also has ISPM 5. Glossary of phytosanitary terms ( https://www.ippc.int/en/publications/622/) in which some terms could be included in this guideline (e.g. pest, pathway, pest risk (for quarantine pests), pest risk analysis (agreed interpretation), LMO (in which it refers back to the definition in ISPM 11)). As mentioned before by Professor Elizabeth Hodson “our major responsibility is to promote the harmonization”. Apologies for not providing specifics to the four topics in the guidance instruction of this forum, but a general comment within the remits of the IPPC. Best regards to all, Adriana Gonçalves Moreira P.S.: ISPM 11 attached to this post.
posted on 2016-02-10 16:05 UTC by Ms Adriana Moreira, Food and Agriculture Organization of the United Nations (FAO/UN)
|
Dear all,
I add my support to those who believe that any guidance on herbicide safety should be excluded from the guidance document. The reasons for this are presented very nicely by others.
Thanks, Tom
posted on 2016-02-10 17:57 UTC by Mr. Thomas Nickson, Consultant
|
Dear all: Again I thank you for the enthusiasm shown related to sharing your views, expertise and opinions with respect to the four topics put in front of you. I greatly appreciate the time and effort! I encourage those who still have not written in the forum to take some time and do so, what you may share certainly will make a difference. What lies ahead of us is trying to come to terms on having an improved guidance, together with having made an effort of taking into account the topics for which additional guidance has been already asked for. Un abrazo, Fran
posted on 2016-02-12 02:40 UTC by Ms. Francisca Acevedo, Mexico
|
Dear All, I wish to thank Francisca for her hard work in moderating this forum. With my post I join my support to Elizabeth Hodson and others in not duplicating efforts assessing herbicide safety under the AHTEG Guidance. Moreover I believe the assessing of herbicide safety would lead to more confusing and less user-friendly document. Valeria Giovannelli, PhD ISPRA - Istituto Superiore per la Protezione e la Ricerca Ambientale Dipartimento Difesa della Natura - settore OGM ( http://www.isprambiente.gov.it/it)
posted on 2016-02-12 09:38 UTC by Ms. Valeria Giovannelli, Italy
|
This is my first post during this Online Forum, so I would like to echo the thoughts of others in thanking Francisca for chairing the discussion, The Secretariat for providing this opportunity and all of the participants who have so far intervened for their interesting and enlightening contributions. The task of developing guidance for risk assessment is hard. It is conceptually difficult and administratively challenging as well. I am sympathetic to those who are trying to manage this largely thankless task. But I have to agree with Piet (#7596), and I think it would be irresponsible not to consider whether these topics, or any others, belong in the Roadmap when the core document is still not completed in a satisfactory way. The topic for this round of the Online Forums references Decision BS VII/12, and I think it makes sense to look at that decision. Since a link is not readily available within the forum, you can find this decision here: https://bch.cbd.int/protocol/decisions/?decisionID=13359Without belaboring the point, we are asked to undertake 2 activities. The first, is to consider the results of testing and feedback on the Roadmap in order to incorporate these changes. The Online Forum is specifically asked to review the response of the AHTEG to these suggestions, which we have not yet had the opportunity to do. The second task is to "attempt" to take into account suggestions for other topics during revisions to the Roadmap. I once again agree with Piet. We are attempting these tasks out of order and I don't think this will serve the objective identified in BS VII/12 of producing "An improved version of the Guidance on Risk Assessment of Living Modified Organisms" Asking participants to comment only on how these topics can be best incorporated into the Roadmap, and to refrain from commenting on whether or not it is useful to incorporate them into the Roadmap is pre-supposing that these topics are useful to include. To be clear, in my view there are many topics which may be interesting, worthwhile or even critical for national authorities to make case by case decisions about LMOs that simply don't belong in the Roadmap. The supposition that the AHTEG, with assistance from this Forum and incorporating comments from Parties, other governments and relevant organizations can produce a guidance document that provides easy to understand elaboration of Annex III while addressing, in specific detail, all the myriad types of LMOs, their uses and various receiving environments is simply unrealistic.
posted on 2016-02-12 12:06 UTC by Mr. Andrew Roberts, Agriculture & Food Systems Institute
|
As it is my first intervention in this Forum, I would like to thank the Secretariat and Francisca in special, for the opportunity to contribute to this discussion. I was organizing ideas in order to accomplish with the topics indicated at the beginning of this Forum (refer to Manoela´ email, Jan 25th 2016, and Francisca´s intervention [#7574]) and, at the same time, trying to review previous interventions in order not to be repetitive. In the middle of such a challenging activity I noticed Andrew´s post [#7619] with a nice and clear intervention pointing items which I completely agree since they reflect my difficulty in presenting suggestions to a document that is not yet agreed or complete. So, as my first intervention in this Forum I would like to echo many others like [#7619], [#7580] #7581, [ #7582], [#7585, [#7586], [#7589] [#7593], [#7596], [#7597], [#7598], [#7603], [#7609], [#7610] and others that also supported these interventions. I also would like to mention that, as presented by Werner Schenkel [#7600] and Adriana Moreira [#7601] we are trying to put in place a complete and “easy-to-use” Roadmap and at the same time we are missing or overlapping some other decisions/ guidance that are already agreed and in place elsewhere.
posted on 2016-02-12 13:14 UTC by Dr. Deise Maria Fontana Capalbo, Brazil
|
Dear all,
First thank you for the moderator and for all the valuable contributions.
I would like to make a general comment under this thread before some specific comments under other topics.
I totally agree with Piet comment about the discussions and decisions of MOP7 [#7596] and the necessity of guidance improvement before new topics are considered.
I would also like to remind the Decision: In paragraphs 5-7 of decision BS-VII/12, the COP-MOP invited Parties to submit (a) information on the needs and priorities for further guidance on specific topics of risk assessment of living modified organisms, and (b) existing guidance on specific topics of risk assessment of living modified organisms, requested the Executive Secretary to compile the information received, and agreed to consider the need for further guidance at the eighth meeting.
So it´s clear that the definition of specific topics is made by Parties. If we look the topics selected and prioritized by the AHTEG in the current discussion it´s also clear that they were not selected based on the Parties needed. Only RNAi, center of origin and human health are described in one document presented by Parties (Overview of the status of operational objectives 1.3, 1,4 and 2.2 of CPB strategic plan, 2014) and maybe can be considered as choosen by Parties (although there is no information about the number of Parties or the justification for those topics). The other topics were not selected by Parties:
- LMOs that produce pharmaceutical products: first identified / cited in the on line forum Nov 10 - Nov 28/2008
- dsRNA; nutritionally altered plants: first identified / cited in the on line forum Feb 18 – March 1/2013
- unmanagened ecosystems: first identified /cited in the AHTEG meeting April 19 -23/2010
- synergistic impacts of different herbicides: first identified / cited in the on line forum Feb 24 – March 10/2014
I understand that the compromisse reached in the COPMOP-7 was a fine-balanced compromise between Parties and I also believe that is very important to keep the discussion under the agreed terms.
Thank you.
Best regards, Luciana Ministry of Agriculture / Brasil
posted on 2016-02-12 19:19 UTC by Ms. Luciana Ambrozevicius, Brazil
|
A number of voices are challenging the legitimacy of conducting both tasks assigned to the AHTEG by the last MOP as we are doing it. I don't wish to debate the reasons, but I also do not want to leave the impression to those who may read these threads in the future or who are not part of the discussion now that this view is universal.
I personally see no significant problems with the process being followed and I believe it to be in accordance with the MOP mandate.
Thank you again Fran for your hard work and the welcoming spirit you bring to the proceedings.
Best wishes Jack
posted on 2016-02-12 20:10 UTC by Mr. Jack Heinemann, University of Canterbury
|
Dear all,
I thank Fran again for her commitment and enthusiasm to undertake this complex task. I support the statement by Deise Fontana from Brazil (#7624), Andrew Roberts (#7619,7620); Maria (#7625), Piet (#7596) and many others, in feeling some concern about the growing complexity of the guidance, as more boxes and additional information is requested and submitted. Access to relevant bibliography is key, but it must be presented and available in a manner that does not overwhelm the user.
It would be useful to define the target audience. Is it for novice regulators from countries (mainly less developed countries) that lack experience in risk assessment; is it for all regulators of all countries; is it for developers of the technology like new biotech firms starting everywhere; or is it a “one size fits all”? It is very useful when preparing training material, to understand the composition of the audience. My understanding is that the audience for this guidance are inexperienced regulators from less developed countries. Is this correct? More industrialized countries already have their biosafety systems in place and may never need to use this guidance. I would gently like to remind the group that maybe contrary to what the records may suggest, not all developing countries, in all regions, felt the guidance was “useful and practical” when tested. Many felt, at least in my region, that it was too complex to allow novice regulators to make decision about adopting or blocking a new technology. When in doubt, it is easier and safer for regulators to block, as few will criticize them.
We may now be contributing further to the complexity of the guidance, by adding more boxes and references that show opposing trends that reach no consensus on may topics. Reading opposing views on any technical topic is confusing if you are not an expert.
I recognize Fran and other moderators, that these opposing views are not making your job any easier and for this I am sorry. Maybe you can enlighten us on how to proceed.
Best regards,
Maria
posted on 2016-02-12 22:49 UTC by Dr. Maria Mercedes Roca, CIBIOGEM, Mexico
|
Again, I thank all of you who have already shared your views and opinion on these four topics. And I would like to once again invite those who have not expressed their thoughts with us to do so now. The online forum community is key to contributing to the best outcome of the improved guidance on risk assessment and management. Kind regards to all y un abrazo! Fran
posted on 2016-02-13 18:21 UTC by Ms. Francisca Acevedo, Mexico
|
As this my first posting, I would like to thank the Secretariat and Francesca for giving me the opportunity to participate in this discussion.
In support of others before me I would like to highlight the following:
Under the UNFAO, there are fora that address the harmonisation of standards on maximum pesticide residue levels, safety, environmental impact, amongst other things; at national level the safety of herbicides is regulated under a different legislative framework from the biosafety issues. In my view this would encourage the development of a parallel assessment process - to what end?
Food safety and the nutritional assessment of foods is also adequately covered by the Codex Alimentarius and should not be in the ambit of an environmental risk assessment framework; the same applies to pharmaceutical products.
posted on 2016-02-13 19:41 UTC by Ms. Kelebohile Lekoape, Bayer CropScience
|
Dear all: The forum is about to close, it will at 1am UTC which corresponds to Sunday night in most countries. If you still want to add some ideas….please do now! I will be posting a summary soon. Many many thanks to all of you! Un abrazo, Fran
posted on 2016-02-14 19:44 UTC by Ms. Francisca Acevedo, Mexico
|
Dear colleagues, First, let me thank Francisca for moderating the discussions. I have read the previous interventions with great interest, even though I have not had a chance to add my thoughts until now. In her post [#7587] Francisca asked us "to discuss how the different topics could be incorporated into the Roadmap." I think it is important for us to recognize that it is the prerogative of the Parties to choose whether to adopt the Roadmap and which topics, if any, should be added to it. To date, there has been insufficient attention to finishing a truly useful Roadmap document itself -- one that meets the standard of being truly useful to novice risk assessors and being based on the weight of experience we have in evaluating any potential environmental risks when organisms are introduced into the environment. Our experience with non-LMOs is just as useful as our experience with LMOs, yet the Roadmap does little to highlight this fact.
Let me suggest that what the Parties actually wanted from the AHTEG and online discussions is a description of criteria they could endorse, rather than specific "additional topics". Here are criteria that I hope the AHTEG will take up at their next meeting as they formulate their recommendations for the Parties at MOP8. Many reflect points already raised by others during this online discussion.
1. The "additional topic" is an emerging topic which does not appear to be well covered by the Roadmap document itself. We have already seen much discussion during this online forum of "potential topics" that should already be covered under the Roadmap document and therefore not warrant a separate section as an "additional topic".
2. For any "additional topic", there should already be a substantial body of environmental risk assessment experience that can be used to illustrate how the ERA was done (as well as the subsequent outcomes following the decision(s) related to the ERA). As with any good guidance, guidance in "additional topics" is most relevant when it comes from experienced experts with real-world responsibilities to provide their governments with ERAs to use in decision-making.
3. Consideration of any "additional topic" needs to be consistent with the scope of the Cartagena Protocol, i.e., potential adverse effects on biodiversity arising from transboundary movements of LMOs intended for environmental release. Any guidance should be consistent with the mandate and language of the Protocol, so that there is no confusion. As others have pointed out in their comments, the guidance is not to elaborate new concepts, but rather illustrate the concepts that are already in Annex III of the Protocol.
4. Any guidance in CPB "additional topics" should be in harmony with guidance and obligations under other forums. Consideration of the topic is not duplicative nor inconsistent with guidance or requirements under work being done under different forums. As others have pointed out numerous times during this online discussion, other institutions have already been well established mandates in areas such as food safety (Codex Alimentarius), safe use of pesticides (ICCP), risks arising from plant pathogens, pests, and weeds (IPPC). These are just a few examples to keep in mind when considering "additional topics". It is striking to note that while the AHTEG was drafting an "additional topic" on LM mosquitoes in 2014, the World Health Organization was finalizing its comprehensive "Guidance framework for testing of genetically modified mosquitoes" (available online).
Since Francisca has urged us to consider this first topic a “brainstorming” opportunity, let me turn my thoughts from the criteria for “additional topics” to some broader issues on the overall process to develop guidance serving as a Roadmap to use Annex III of the Protocol. In my experience over the past seven years, it seems to me that there serious limitations in the use of AHTEGs and online discussions. These include the non-transparent manner that the AHTEG incorporates or discards input from online discussions and AHTEG members, the disjointed nature of the online discussions, and the manner in which supporting and reference documents are accepted as citations in the final documents. Many of these practices preclude the ability to have the best expertise contribute meaningfully in drafting the Roadmap and any supporting "additional topics".
As we all recognize, developing useful guidance documents is hard work. I hope the AHTEG will seriously consider a recommendation to the MOP that is framed in criteria that the Parties can consider, rather than specific topics that were hastily chosen – a process that does not honor the quality needed for good, relevant guidance.
Best regards,
David Heron
posted on 2016-02-14 20:51 UTC by David Heron, United States of America
|
Dear participants,
I thank Lin (#7649) for highlighting how linked the issues of introduction of an LMO are in a center of origin to socio-economic considerations. This is definitely the case. However, it is unrealistic to expect inexperienced risk assessors to make sense of this additional information and arrive at coherent and timely decisions, by reading, understanding and internalizing a large volume of additional (and opposing) information that has been suggested we provide. This is a job for specialists who should advise risk assessors and risk managers. Since socio-economic considerations are so important, this is ultimately a political decision. I also appreciate Paul´s wise comment (#7662) that including bibliography of “academic treatises” showing opposing views and data, interpreted in different ways, can be very counterproductive for risk assessors.
I suggest some concrete proposals that may improve and simplify the guidance:
1. Don´t include boxes with additional information on a highly polarized issue such as “introducing an LMO in a center of origin”.
2. Select the most cited information available in the literature that show the spectrum of opinions and avoid including references in the text that only show one view of the issue.
3. Stress the value of using information of "history of safe use" and "transportable data" related to studies with "observed" rather than "expected" data, that are already available from countries that have gone through this process before. This could be especially valuable small countries in the Caribbean, Central America and Andean countries in South America.
Thanks everyone for your insightful comments and Francisca for your hard work. We look forward to reading your summary.
Maria
posted on 2016-02-14 20:52 UTC by Dr. Maria Mercedes Roca, CIBIOGEM, Mexico
|
Dear all,
As we are about to close this discussion, I fully support David Heron´s sentiment (#7668) that it is imperative that transparency and objectivity is fully implemented, and that all views or trends on specific topics are reflected in the summaries.
I speak for many in this group who feel discouraged and demoralized when they put time and great effort into AHTEG meetings and discussions and their views are not reflected in the summaries of the various activities.
To illustrate this point: great effort and money was devoted into organizing seminars and activities for preparing parties in Central America to test the guidance. Those Central American countries who participated did not find the guidance useful or practical in its current form, and many countries did not even participate, as they found the exercise daunting and excessively time consuming and complex. The summaries and conclusions however, stated that most developing countries found the guidance useful.
When these opposing views were shared in formal sessions at the last MOP, an article appeared in the scientific literature, accusing those parties that did not find the guidance useful, of somehow having a "commercial agenda" and siding with industry by "blocking" a perfectly good and useful guide that the AHTEG had developed for years and parties had found useful and practical. The article was unfair, deeply biased and offensive to the accused parties.
We are human and we all have agendas: agricultural - to mange pest and diseases with technology; environmental - to preserve the environment without intensive agriculture; ideological - big Ag Biotech industries are greedy and dangerous; commercial - GM products developed are safe and useful; political - GM maize contaminate local land races, excludes indigenous communities and should be banned, etc, etc.
We have to accept that this is the context of our "human AHTEG group" (humans cannot escape bias). Thus, we need to try our best to reach a middle ground - however difficult - where respect for all opinions, views and trends are reflected in the summaries. Then we take action. Continuing ahead with a certain bias as we have done, has not been helpful and has resulted in us going in ineffective circles.
Francisca, friend and colleague, I am truly appreciative and have the greatest respect for you for undertaking this complex task. Again, we look forward to reading your objective summary.
Maria
posted on 2016-02-14 21:59 UTC by Dr. Maria Mercedes Roca, CIBIOGEM, Mexico
|
Dear colleagues,
I join Maria Roca in supporting the suggestion made by David Heron that this process recommends to the MOP a clear set of transparent criteria as to when certain topics warrant additional guidance in the roadmap. The four criteria that David listed make good sense.
With regard to the fourth point, I would add the observation that the need for securing harmonisation and avoiding duplication with what is going on under other international fora and bodies is not only good practice, it follows directly from the CPB itself. See for example
Article 2.5: “The Parties are encouraged to take into account, as appropriate, available expertise, instruments and work undertaken in international forums with competence in the area of risks to human health.”
Article 5: “this Protocol shall not apply to the transboundary movement of living modified organisms which are pharmaceuticals for humans that are addressed by other relevant international agreements or organisations.”
Article 18.1: “……taking into consideration relevant international rules and standards”
Article 29.4.c: [The MOP shall] …….”Seek and utilize, where appropriate, the services and cooperation of, and information provided by, competent international organizations and intergovernmental and non-governmental bodies”.
It is therefore very important that this process keeps itself abreast of what is happening under the Codex, WHO, FAO, IPPC, etc
Wishing all a good night !
Piet
posted on 2016-02-14 23:47 UTC by Mr. Piet van der Meer, Ghent University, Belgium
|
Dear colleagues,
Thank the Secretariat and Francesca for this opportunity. I would like to echo the comments from other participants that the guidance should be simple and general one. While many concerns have been pointed out through this online-forum, I could not find any different/additional points to be integrated in the guidance with respect to the proposed four topics.
Regarding “Nutritionally altered living modified plants” “LMOs engineered to produce dsRNA or dsRNA”, I think the essential point is how to decrease uncertainty about unintended change of metabolism, phenotypes and NTOs. And regarding “LMOs introduced in centers of origin and genetic diversity”, it seems that the most key procedure is what protection goal and risk scenario are set. In this manner, I think all aspects have already been covered in the current proposed guidance.
I also echo the comments that the assessments for synergistic impacts of herbicides and human health should be performed by experts of each area.
Best regards, Ayako
posted on 2016-02-15 00:43 UTC by Ayako Yoshio
|
|