Ask an Expert: International Plant Protection Convention

The Republic of Cameroon is initiating a project on the Development and Implementation of a National Monitoring and Control System (Framework) for Living Modified Organisms (LMOs) and Invasive Alien Species. What are your views on a coordinated regulatory approach premised on shared knowledge and use of expertise on risk analysis across sectors involving different but mutually supportive regulatory pathways for LMOs and IAS as potential novel organisms.  This initiative is supported by GEF and implemented by UNEP.  I will also want to explore potential collaborative partnership with IPPC and its collabortors bilaterally through further email exchange

I appreciate you raising the point of “a coordinated regulatory approach premised on shared knowledge and use of expertise on risk analysis across sectors”.  The application and principles of sound risk analysis are broadly applicable between sectors and across many different types of fields. In short, risk analysis examines probability or likelihood of an adverse event, and the magnitude of the consequences. It then looks at ways the risk (adverse event x probability x consequences) can be managed or reduced. Regardless of the sector involved, risk analysis depends on gathering scientific and other evidence, analyzing that evidence and making judgments about the likelihood and magnitude of any negative (or positive impacts) that may occur.

In the IPPC, the adverse events we are primarily concerned with are “pests” that have the potential to harm plants or plant health, whether the plants are cultivated or wild. In order to assess those risks, we conduct a “pest risk analysis” or PRA.  The PRA methods developed and used under the IPPC, and that are described in international standards for phytosanitary measures (ISPMs) are aimed at describing, assessing and managing risks associated with pests that are injurious to plants or plant health. Therefore, in IPPC terms, an invasive alien species, if it is a plant pest, would be subject to PRA and potentially subject to phytosanitary measures to prevent its introduction and spread.

Not all LMOs will have the potential to affect plant life or health---for these LMOs, a PRA would not be necessary. However, LMOs that have the potential to harm plant life or health may be subject to the same methods of PRA that any other pest is subject to.  In other words, the IPPC does not make a distinction between invasive species and pests (if the invasive species is a plant pest). Similarly, there are no special procedures for assessing phytosanitary risks for LMOs.  The same principles describe above (gathering scientific and other evidence, etc.) apply to PRA for LMOs, just as those principles apply to analyzing risks associated with any other pest.

Therefore, coordinating regulatory approaches using shared knowledge and expertise across and between sectors for conducting risk analysis is not only feasible, it is sensible. Developing and using common methods for conducting risk analysis, whether for plant pests, “invasive alien species”, LMOs, animal diseases or human diseases is—from a risk analyst’s viewpoint—makes sense.  The methods are the same and the expertise in risk analysis may be the same; only the scientific information, and the subject matter expertise will be different between sectors.