Sub-working Group on RA&RM of Living Modified Mosquitoes

Thanks to the SWG for the opportunity to comment on this important document.  I have included my remarks on top of those provided earlier by Dr. Bergmans.

I have one overarching comment, which I raise under the section on "Other Issues," and that concerns the fact that the Protocol only takes into account risks to human health but not benefits.  It is my feeling that explanation of the potential of LMMs to benefit public health through reduction of disease transmission should be given more than one sentence (line 26) within the guidance.

I look forward to seeing other comments.
Stephanie

Dear Dr. Stephanie James,

Thank you very much for your suggestions.

The section on "Other Issues," was included in the document to call attention to the particularities of the LMMs, pottential benefits included. If the text is not satisfactory, could you please suggest changes to improve it, so the others can see and discuss the new additions? 

Thanks again.
Eliana

I have used the draft text supplied by my colleagues to introduce my comments. In addition to the emphasis that they placed on some topics, I would like to add the following. The parent document has a strong emphasis on the preservation of biodiversity. It is extremely important to recognize and acknowledge that mosquitoes are introduced and invasive species in the vast number of places in the world where they are vectors of human disease.  Thus, they are not components of primal, pristine or balanced ecosystems, but are better viewed as evidence of human disruption of such systems.  Furthermore, we have clear evidence from the impact of mosquitoes on the native bird populations of Hawai’i that the introduction of mosquitoes has actually reduced biodiversity, and indeed, has put many species of native avian fauna on the endangered list. Thus efforts to remove these mosquitoes also represent attempts to mitigate human damage to ecosystems.

As I indicated in my notes to the draft document, the effects of climate change on mosquito distribution may pale in comparison to what humans are doing currently by bringing water to places that previously could not support mosquito development. This also is exacerbated by the growth of mega-cities in tropical zones that shift disease transmission from rural to urban settings. These are areas that need serious additional research.

Beebe NW, Cooper RD, Mottram P, Sweeney AW 2009Australia's dengue risk driven by human adaptation to climate change. PLoS Negl Trop Dis.;3:e429.

Fink TM, Hau B, Baird BL, Palmer S, Kaplan S, Ramberg FB, Mead DG, Hagedorn H. 1998 Aedes aegypti in Tucson, Arizona. Emerg Infect Dis. 4:703-4

Gubler DJ. Dengue/dengue haemorrhagic fever: history and current status.
Novartis Found Symp. 2006;277:3-16; discussion 16-22, 71-3, 251-3.

Here is the paper by Fu et al recommended by Stephanie James.

I have updated Tony's version (incorporating comments from Stephanie and Hans). Hope this helps. Thank you, Eliana and Manoela, for extending the deadline.

Dear Eliana,
Thanks for the invitation to re-draft the section on "Other Issues," which I have done in the attached revised version.  I have also taken the opportunity to make a few other suggestions for changes based on the comments from Drs James, Vasan and Strickman.  Sorry that the document looks really messy now with all the track changes!

You will see that I am arguing the issues of social and economic trade-offs, as well as those ethical and cultural issues related to acceptance, are not really all that different from the situation for decision-making on other LMOs. I do believe that the health issues are different, however, and have tried to emphasize those in my suggested changes under "Other Issues."

I hope this is helpful, and look forward to seeing your compilation of all these comments.  Once again, thank you for the opportunity to contribute to this discussion.

Stephanie

If I accept all changes in the document, it is not messy and actually reads well. Thank you, Stephanie, for the revision. Cheers, Vasan