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Theme 3: Experiences and lessons learned
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How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2123]
The third guiding question for theme 3 is “How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?”
posted on 2011-04-03 20:04 UTC by Ms. Kathryn Garforth, Secretariat of the Convention on Biological Diversity
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2173]
Hello everybody Let me briefly introduce myself . My name is Armin Spoek (original spelling if you have an umlaut on your keyboard: Spök), I am a senior scientist at IFZ ( http://www.ifz.tugraz.at/index_en.php/user/view/18) working since 15 years on issues related to biotechnology (risk) governance. We have recently completed an exploratory study aiming at identifying some of the issues linked to socioeconomic assessment of GMOs. A particular focus was how socioeconomic assessment might be integrated into the decision making process. I will upload this study - just in case you are interested. In the course of our study we noticed that a large number of countries are deemed to consider socioeconomic impacts including Armenia, Bangladesh, Bhutan, Cambodia, China, Honduras, India, Lebanon, Mauritius, Nigeria, Philippines, South Korea, and the Syrian Arab Republic. Scope and nature of requirements seem to vary considerably as does the way they are being established: part of national legislation, draft legislation, policies or regulatory practice. Among EU/EEA Member States, only France and Norway are known to explicitly assess socioeconomic impacts; the Austrian national law on GMOs includes a provision on socioeconomics which has not yet been implemented though. Norway established a mandatory requirement to consider socioeconomic impacts back in 1993, focusing on ethical and social aspects as well as sustainability assessment. Requirements were subsequently detailed in regulations on impact assessment and opinions of the Norway Biotechnology Advisory Board (NBAB). Sustainability assessment includes all three pillars of sustainable development and explicitly recognizes the global scale. It thereby extends environmental risk assessment when considering effects on biodiversity in third countries. Social utility aspects include for instance demand, problem solving capacities, and alternative products. Ethical assessment considers for instance the moral views of the general population, impacts on traditional cultures and weaker groups, and the integrity of species. Socioeconomic information is being weighted against health and environmental risks and associated uncertainties and irreversibility. The unfavorable opinions of the NBAB frequently included lack of benefit to the society and a positive contribution to sustainable development, though, health and environmental risks seem to be still the most important reason. The lack of socioeconomic information in the dossiers is perceived by Norway to be a particular problem. It is neither possible to force applicants to provide such information nor to comment on such aspects in the EU authorization procedure because they are considered by EFSA to be out of scope. In France, the High Council on Biotechnology (HBC) was established following a recent change in GMO policy. One of the two HCB Committees (CEES) provides advice to the government on economic, ethical, and social aspects of GMOs including in the course of routine evaluations of Directive 2001/18/EC and Regulation 1829/2003 dossiers. Based on the limited experience gained so far, CEES perceives its main challenges to be the lack of relevant information in the dossiers and the lack of guidance for criteria, methods, data, and assessments. CEES practice apparently includes providing quite prescriptive advice instead of options to the formal decision makers based on a weighing-up of health and environmental risks on the one hand, and socioeconomic concerns and benefits on the other hand. This practice is potentially changing lines of accountability and needs a more careful analysis in the context of the EU governance framework established for the food chain. The Austrian GMO law includes a provision allowing decision makers to ban the marketing of products which are considered ‘socially unsustainable’ (‘sozial unverträglich’) - referring to social, economic, and ethical aspects. The meaning of this provision has never been clarified; it has been discussed to be potentially in conflict with EU legislation. In no case, explicit reference was made to this provision – which could therefore be considered as void. In case of an EU policy change, e.g. allowing for national assessments of socioeconomic impacts of GMOs, this provision could become an interesting reference. A more detailed legal analysis might be required to identify possible constraints. For more elaborate descriptions on these three countries, please, see the posted report. Within the EU/EEA context Norway and France seem to be the most interesting cases. We are considering to do some more research on these countries and would be interested to read about your thoughts and experiences. Looking forward to the discussion Armin Spoek
(edited on 2011-04-08 07:11 UTC by Armin Spoek, Austria)
posted on 2011-04-07 12:28 UTC by Armin Spoek, Austria
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2185]
My name is Gregory Jaffe and I am the Biotechnology Project Director at the Center for Science in the Public Interest, a non-profit consumer organization located in Washington, DC. I thought I would talk a little about the US experience with socio-economic considerations.
In the United States, the regulatory process includes a requirement that the agency comply with the National Environmental Policy Act (NEPA). NEPA is a procedural statute that requires the agency to conduct an environmental assessment of the action they are taking. This assessment can take the form of either an Environmental Assessment (EA) and a Finding of No Significant Impact (FONSI) or an Environmental Impact Study (EIS). The later is very involved and can take several years to complete.
In an EA or an EIS, the government does not limit itself to the potential environmental risks of their action. They also assess the benefits of the action as well as some of its economic impacts and impacts on humans. For example, the United States Department of Agriculture recently completed an EIS for herbicide tolerant alfalfa that looked not just at potential environmental risks but also benefits to farmers, the potential impact on organic and conventional alfalfa growers, the seed supply for different varieties of alfalfa and other issues.
Under NEPA, if there are impacts from the agency decision identified in the EIS, then the applicant can propose actions to mitigate those impacts. NEPA, however, is a procedural statute and the assessment done under it does not factor into the government agency’s decision to approve the action before it. Therefore, while USDA assessed the impact of GE alfalfa in an EIS, it made its decision on whether to approve GE alfalfa for commercial planting based on whether it was a “plant pest” according to their regulations and statute. Thus, there is a mechanism in the US for some analysis of some socio-economic considerations that could arise from the approval of a LMO.
posted on 2011-04-07 22:11 UTC by Gregory Jaffe, Center for Science in the Public Interest
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2189]
Dear All
Thanks, Greg, for raising the case of GM alfalfa. We also came across this interesting case and explored some of the issues in a recent paper which I had the pleasure to co-author (posted). Another potentially interesting case is the GM sugar beet which is apparently going through a similar process as the GM alfalfa.
This case suggests that the notion of environmental impact can be interpreted in broader sense far beyond biophysical risks. This is in itself an interesting observation as the US has for a very long time highlighted science-based regulation and criticized countries establishing regulatory requirements not based on scientific grounds. Even though, USDA, has dropped the case by moving towards full deregulation the content and the wording of the EIS suggests that the USDA’s scope of environmental impacts might become broader in the future and e.g. include coexistence issues.
For the US context this raises several questions and I would be very interested to hear your views.
First, what kind of impacts do you expect on the scope of EA/EIS for future/pending cases of deregulation, e.g. GM sugar beet, GM creeping bentgrass.
Second, I have somehow lost track to the APHIS reform activities described in their 2007 “Programmatic Environmental Impact Statement” - do you expect any impacts on the ongoing reform process of USDA biotechnology related regulation?
Third, though this seems to be a precedent - how did USDA proceed in gathering and assessing the additional information beyond science? How have they organized their decision making process internally?
Best Regards
Armin
posted on 2011-04-08 08:40 UTC by Armin Spoek, Austria
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2192]
It is common knowledge that most countries take into account socio-economic considerations into account when making decisions about the import of LMOs for food, feed and processing, and for general release into the environment. However, due to the non-availability of recognised methodologies and tools for socio-economic assessments of LMOs, such considerations are often done in a non-structured way. Often these considerations are not documented making it difficult for any lessons to be drawn from past experiences. Often no one will be comfortable to point out how decisions were arrived at. This brings in accusations of lack of transparency and consistence.
In my experiences as a technology regulator, I have seen that the absence of recognised tools makes regulators uncomfortable of interfacing with society to explain their decisions. Ideally there should be a separate process from risk assessment of generating data about socio-economic impacts of an LMO whose results should then feed into biosafety decision making in addition to the risk assessment report. Whether this should be done in parallel or in sequence with risk assessment will depend on regulatory provisions.
In our case, and as is generally the practice in many Southern African states socio-economic issues are handled in a non-structured way at the decision making stage. Efforts are now underway to provide for socio-economic impact assessments that are separate from but inputs to biosafety decision making. This of course is dependent on progress in the development of tools for socio-economic impact assessment.
posted on 2011-04-08 13:33 UTC by Abisai Mafa
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2195]
I want to respond to several questions raised by Armin.
First, he asks what kinds of impact should we expect in the scope of the EA/EIS for future LMOs in the US, such as sugar beets or creeping bentgrass. In my opinion, I think you will see more thorough EA/EIS documents that go beyond addressing the scientific environmental risk issues. Those documents will also address the impact of growing the LMO on other farmers, addressing issues such as access to conventional seed, likelihood of gene flow, any economic impacts from that gene flow, and so forth. Keep in mind, however, that although socio-economic issues may be analyzed in the EA/EIS document, that analysis still will not be a part of the decision to authorize the planting of the LMO. The approval decision will still be based primarily on a safety determination based on the scientific risk assessment and data, not on the socio-economic considerations.
Second, he asks about the status of the current APHIS reform effort started years ago, when APHIS conducted a Programmatic EIS and proposed revisions to their regulations. My understanding is that process is still being worked on by APHIS and revised regulations will be issued at some point. It is unclear what exactly the new regulations will look like but I think virtually all stakeholders believe the current regulations can be improved upon.
Third, he asks about the USDA process to gather the information for its EIS and how they organized their decision. While he asks a good question, unfortunately, I do not have the answer. I work for an NGO and don’t have good information about how USDA collected its data and conducted its analysis nor about the internal decisionmaking process.
Greg Jaffe Director, Biotechnology Project Center for Science in the Public Interest
posted on 2011-04-08 18:51 UTC by Gregory Jaffe, Center for Science in the Public Interest
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What experience has been gained to date with methods for assessingsocio-economic impacts?
[#2199]
*RE: What experience has been gained to date with methods for assessing socio-economic impacts?* < http://bch.cbd.int:80/protocol/cpb_art26/discussiongroups_se.shtml?forumid=17133&threadid=2122#2187> Thank you again for the opportunity to take part in the discussion. I completely agree with Mr Abisai Mafa and Ms Li Ching Lim, that "economic assessments per se are a part of and not a complete package of socio-economic impact assessment". I believe that before introducing a LMO in a country, most of the time the assessment is carried out in purely economic terms and not taking into account the full socioeconomic impacts and even less taking into account their environmental impacts. Probably the reason for doing this is because the information is coming from the industry and not generated in the countries. On the other hand there is lack of capacity from the regulators and lack of independent research on LMOs. In order to have a proper method of assessment there should be a way of getting independent assessment. Probably if we are able to answer the following questions, we might be able to move forward towards reaching a more independent socioeconomic assessment: Who provides the information in order to carry out the assessment on the LMO before being introduced? Where is the information coming from? Who pays for the assessments? What impacts are looked for when LMOs are assessed, economic or socioeconomic ones? María Isabel Cárcamo -- RAP-AL Uruguay Red de Acción en Plaguicidas y sus Alternativas para América Latina Ana Monterroso de Lavalleja 2112 Ap. 802 - CP 11200 Tel: 598 2401 2834 Fax: 598 2401 2834 e-mail: coord@rapaluruguay.orgCelular: 099 613193 http://www.rapaluruguay.org/
posted on 2011-04-08 20:45 UTC by Sra. María Cárcamo, Red de Acción en Plaguicidas y sus Alternativas para América Latina - Uruguay miembro de la Red para uan América Latina Libre de Transgénicos
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2230]
Determining the current status of the inclusion of socio-economic in biosafety and /or technology decision making processes is complicated by the fact that there are several legal and policy instruments where the country expresses its desire to include socio-economic considerations. These may include: o National biosafety framework drafts (such as those done under the UNEP-GEF country projects) o Laws, Bills, Acts o Biosafety, Biotechnology and/or Science and Technology Policies o Administrative regulations (Administrative Orders, Executive Orders) o Implementing regulations Here are some examples more fully described in the two papers listed below. As with any dated documented, the status and description may have changed since the papers were published or presented. Some descriptions may vary depending on the person who may be describing the process in country. • Canada and the United States had not considered socio-economics in their decision making, but this seems to be changing at least in the United States. In both countries socio-economic considerations have addressed in courts of law. • Ongoing discussion within the European Union on the inclusion of socio-economics. A proposal made by the Netherlands Commission on Genetic Modifications (COGEM) in 2009 described nine issues for potential assessment. Current debate seems to be whether requirement should for requiring ex ante or ex post assessments. • Norway has formally included socio-economic considerations in its legislation through the Gene Technology Act of 1993. The Norwegian Biotechnology Advisory Board has prepared a document “describing the implementation of the concepts in the Gene Technology Act” (Norwegian Biotechnology Advisory Board, 2009, Preface), which among others includes information for the assessment of benefits to the community. The assessment criteria are not strict, but should include problems being solved, availability of alternatives and possible problems as applied similarly to approval of antibiotics in Norway. • One of the few developing countries with a mandatory requirement for inclusion of socio-economic considerations in its decision making is Argentina. Narrow scope of impacts of approvals on Argentinian exports. • In Mexico, Chapter II Article 5.XIV of 2006 decree (CONACYT, 2007) defining the roles of the competent authority (Comite Intersecretarial de Bioseguridad de los Organismos Geneticamente Mejorados – CIBIOGEM), defines one of its roles to be, deciding on the socio-economic studies needed to analyze the impact of GMOs. • In Brazil Brazil‟s Biosafety Law No. 11.105 approved in 2005 considers two distinct bodies for the regulation of GMOs (GoB, 2005). A technical body which is the competent regulatory body, the national biosafety committee (CTNBio) and an independent body called National Biosafety Council (CNBS) that is formed by Ministers and designated experts. CTNBio approves new GMOs by performing an assessment on human health, animal health and environmental impacts, whereas the CNBS decides on the commercial deployment if any social or economic issue is raised during the evaluation process. • India’s current rules from 1998 do not formally require inclusion of socio-economics. Studies have been commissioned for some applications to date. How these studies influenced deciusion making is unclear. References Falck Zepeda, J. B. Socio-Economic Considerations, Article 26.1 of the Cartagena Protocol on Biosafety: What are the Issues and What is at Stake?” 2009. AgBioForum. 12(1):90-107. Falck Zepeda, J., J. Wesseler, S. Smyth. “The Current Status of the Debate on Socio-Economic Assessments and Biosafety Highlighting Different Positions and Policies in Canada and the US, the EU and Developing Countries”. Paper presented at the World Environmental and Resource Economics Congress in Montreal, Canada, July 2, 2010. Paper can be downloaded from http://www.webmeets.com/WCERE/2010/Prog/ (look under second day Parallel session 1).
posted on 2011-04-11 03:53 UTC by Dr. Jose Falck-Zepeda, International Food Policy Research Institute (IFPRI)
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2233]
Dear All From the postings of José and others it appears that there are quite some countries which formally integrated socioeconomic assessment in their decision making frameworks. I am particularly interested in countries which have have institutionalized a mandatory assessment of socioeconomic aspects conducted for each application for commercialization. It would be good to know more of these examples and to take a more in-dept look into some of them. For instance it would be interesting to know more about the institutional design, the scope of socioeconomic assessment, how the information on socioeconomics is being gathered and processed, how it relates to biosafety risk assessment, and how socioeconomic factors are eventually reflected in the final decisions. Norway and France have in fact institutionalized socioeconomic assessments for GMOs. Below, please find a brief description on France. In June 2008, France passed a new biotechnology bill (Law n°2008-595 from 25th June 2008) which resulted in a major change in GMO assessment and authorization. The newly established Haut Conseil des Biotechnologies (High Council of Biotechnology; HCB) replaced the Commission du Génie Génétique (CGG) and the Commission du Génie Biomoléculaire (CGB). In April 2009, the HBC was formally established. While the Agence française de sécurité sanitaire des aliments (AFSSA) is still in charge of assessing health risks relating the consumption of GMO products, the HBC was given a broader mandate. It is required to provide advice to the government on any question regarding biotechnology. This mandate includes the routine reviews of dossiers for both field trials and placing on the market of GMOs submitted under EU-Directive 2001/18/EC as well as of dossiers for GM food/feed products submitted under EU-Regulation 1829/2003. The HCB is linked to five ministries but portrays itself to be independent from political power. Government, elected officials and industrial boards, and NGOs can file inquiries to the HBC and the HBC can also launch proceedings by itself. Its two committees, the Scientific Committee and the Economic, Ethical and Social Committee (CEES), conduct different types of assessments. The Scientific Committee provides a scientific evaluation of the health and environmental risks, while the CEES is mandated to evaluate the economic, ethical and social aspects. The CEES consists of 27 members, three experts (lawyer, economist, and sociologist) and 24 stakeholders (elected officials, representatives from professional organizations, unions, as well as from consumer, environmental, and health protection organizations). The CEES becomes active after the Scientific Committee has issued its opinion. Its opinion is transferred to the government along with that of the Scientific Committee. Given the limited time of activity, little is known about the practice of CEES. The Chair of CEES, Christine Noiville describes the challenges to the Committee: - Convergence from the diversity of viewpoints present in the Committee - Absence of guidance on what to assess: in contrast to health and environmental risk assessment there is no guidance for providing data - Lack of data/access to data: there is no basis in the EU law to require notifiers to conduct their own socioeconomic assessments; HBC has apparently asked all EU CAs to ask notifiers to provide socio-economic data and a briefing document - What criteria, what methods, what data? The CEES is aiming to develop a checklist of questions which will complement the case by case approach. For instance, when reconsidering the French ban on maize MON810, the CEES identified a number of concerns: - Risks of an increase of the area treated with insecticides - High seed price is considered a problem if infestation frequency is low - Uncertainties on possible negative impacts on bees and livestock breeding - Possible economic impacts on certain branches of agricultural production The remit of the HBC and CEES is not entirely clear. As can be derived from its opinions, CEES does not only deliver assessments of socioeconomic aspects but does also interpret the results and conclusions of the Scientific Committee against this backdrop – providing a kind of synopsis of health and environmental risks, environmental benefits as well as socioeconomic impacts. For the hybrid maize MON89034xNK603 for instance, CEES acknowledged “few advantages” in case of maize monoculture and of higher infestation rates. Eventually the CEES found too many disadvantages for conventional and GM –free agriculture and – in light of the uncertainties associated with the scientific aspects – recommended not grow the crop. While the formal decision is still to be made by the administration, the activities of CEES can be perceived as intruding into the domain of risk management. It seems the HBC is weighting risks and benefits and provide monolithic prescriptive advice (lacking any alternative options). This practice illustrates a particular difficulty of socioeconomic advice: its relative position in the present EU risk governance framework favoring a separation of advice (science) and management (decision). For instance, even if socioeconomic assessment was considered not to belong to the realm of risk assessment, the mere assessment task would need to be distinguished from the weighing of impacts, options, and decision making in order not to change the lines of accountability. References Spök, A: Assessing Socio-Economic Impacts of GMOs. Issues to Consider for Policy Development. Final Report. Forschungsberichte der Sektion IV 2/2010, Vienna. http://bmg.gv.at/cms/home/attachments/5/0/0/CH1050/CMS1291038713992/assessing_socio-economic_impacts_of_gmos,_band_2_20101.pdf
posted on 2011-04-11 08:44 UTC by Armin Spoek, Austria
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2234]
Eight west african countries have a proposal for inclusion of socio-economic considerations in decision making like for example the West African economic Union Biosafety Act( n° 007/2007/CM/UEMOA ) taking into account studies needed on impact of GMOs. This was also included in the future GMOs risk assessment methodologies commun manual.
posted on 2011-04-11 09:07 UTC by Mr. Mahaman Gado Zaki, Niger
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2235]
In my country, Malaysia, socio-economic considerations may be taken into account at the decision taking stage.
Section 35 of the National Biosafety Act (2007) states:
"The Board or Minister shall not be prevented from taking a decision, as appropriate, under Part III or Part IV, where there is lack of scientific certainty due to insufficient relevant scientific information and knowledge regarding the extent of the potential adverse effects of living modified organisms or products of such organisms on human, plant and animal health, the environment and biological diversity and may also take into account socio-economic considerations". (Part III refers to the approval process for release and import, and Part IV to the notification process for export, contained use and import for contained use).
In the Biosafety (Approval and Notification) Regulations 2010 implementing the Act, Section 25 on socio-economic considerations states:
"The Board or the Minister, in taking into account socio-economic considerations pursuant to section 35 of the Act, may consider – (a) the changes in the existing social and economic patterns and means of livelihood of the communities that are likely to be affected by the introduction of the living modified organisms or products of such organisms; (b) the effects to the religion, social, cultural and ethical values of communities arising from the use or release of the living modified organisms or products of such organisms."
Lim Li Ching Third World Network
posted on 2011-04-11 09:49 UTC by Ms. Li Ching Lim, Third World Network
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2236]
Dear Armin,
What is tricky about determining what countries really want regarding socio-economics is reflected in where socio-economics are mentioned for implementation. Obviously,a draft national policy document does not have the same weight as a requirement within a law or bill/act passed by the legislature. Furthermore, once any reader starts examining legal documents, one quickly realizes that there is very little guidance in terms of the scope, how, when, etc.
This results is not surprising as most countries that I am aware of prefer to leave those legal instruments subject to Parliament/Legislature approval as general as possible so that changes can be made later on as the regulatory system matures and gains knowledge/experience. Most countries opt to develop the particularities of implementation to administrative documents such as implementation guidelines and/or standard operating procedures (SOPs) so that they can be changed over time.
There are several countries that have expressed their desire to include socio-economic considerations through different modalities. A presentation made by Dorothy K. Mulenga and Doreen Shumba-Mnyulwa from the RAEIN Africa network in 2010 in Pretoria shows this for the Southern Africa region. They also show that most countries have not provided guidance nor they are clear how they will implement such inclusion.
Very few have actually included socio-economics as a mandatory and even formal requirement and have gone through the experience of conducting regulatory approval processes that include socio-economics. Only ones that comes to mind are Argentina and Mexico. Have to inquire about Brazil if newer applications have triggered a socio-economic study. Others that have conducted socio-economic studies are not required in the law include India and China.
By the way, your last paragraph documents one of the major issues to resolve for decision making processes as the inclusion of socio-economics may lead in some countries to two-track assessment processes (environmental and food/feed risk AND the socio-economics) which may introduce quite a bit of questions on how to decide between competing approaches and/or integrate such results.
Furthermore, if a socio-economic study shows that results are dependent on the social-economic-cultural context, which is true for all emerging technologies not only LMOs, would the competent authority have the purview or even the authority to reject an application until the later (socio-economic) issues are resolved? I can think of other scenarios which will be problematic.
Reference:
Dorothy K. Mulenga and Doreen Shumba-Mnyulwa. 2010. OVERVIEW OF NATIONAL BIOSAFETY FRAMEWORKS (NBF) IN THE SADC REGION WITH EMPHASIS ON BIOSAFETY SOCIO-ECONOMIC PROVISIONS. Presentation made at the workshop organized by RAEIN AFrica and the University of Pretoria, February 15-17, 2010, Pretoria, South Africa.
posted on 2011-04-11 14:33 UTC by Dr. Jose Falck-Zepeda, International Food Policy Research Institute (IFPRI)
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2262]
Dear Fellow participants:
I find it hard to digest the pretty standard argument that “because manuscripts were not properly peer-reviewed or published in high impact-index, scientific journals” the author´s results and argumentation are doomed a priori. The same argument goes on “to disregard any technical and certainly any press release publication that deals with LMOs”. This is unfortunate since the latter two reach stakeholders that wouldn’t be reached through scientific journals.
As Professor Bereano argues, ex post long term risk analyses of LMO are required in order to properly judge the LMO impact on crop performance and on human health and the social, economical and environmental spheres. Benbrook is an author that has tackled the long term analysis and his results have had a significant impact on the scientific community as well as on the spheres of political decision, and of consumers. Part of his work has not been peer-reviewed in high-impact scientific journals. Nevertheless, I disagree with Jose Falk-Zepeda and Stuart Smyth’s dismissal of Charles M Benbrook’s work. Their asertion that "Benbrook's work has never been peer-reviewed is inaccurate. A search through Scopus shows that C. Benbrook is not unfamiliar with peer-reviewed scientific journals. He has published 17 articles since 2000 and one of those (Benbrook, 2001) titled “Do GM crops mean less pesticide use?” has 24 citations in 16 peer-reviewed journals that cover a broad spectrum of scientific disciplines. Benbrook´s technical series on ex post, long-term evaluations of Bt corn in the USA and roundup ready Soybeans in Argentine are certainly worth considering. So, Professor Bereano, I fully agree with your point.
With regard to this week’s question as it applies to Mexico, it can be said that the process of LMO introduction/release has gone through two stages: 1) Decisions for introduction of LMO were made within the Ministry of Agriculture before 2005. In this year, the Law of Biosafety of LMO (LBLMO) was promulgated. 2) Since then, decisions have been made through a formal process that takes into account socio-economic considerations, as well as biodiversity, human health, and the ecosystem.
Before year 2005 contained-space experiments on LMO were allowed, as well as some open field maize-LMO experiments. The latter field experiments required permission from the Ministry of Agriculture. However, after evidence of transgenic DNA contamination of native maize landraces in Oaxaca State was found and reported by an independent group of scientists in 2000, a de facto moratorium on maize-LMO cultivation under open field conditions was imposed by the same Ministry in 2001. The de facto moratorium on maize was lifted in 2005 soon after promulgation of the LBLMO. Open field experimentation on cotton-LMO was permitted in the first period, and allowed to pass from the experimental stage (few hectares) to the pilot studies stage (~200,000 hectares a year). No moratorium on cotton-LMO was ever imposed, nor has any long term ex post research on cotton-LMO been conducted in Mexico.
A system for decision making on introducing/releasing LMO technology was structured following the enactment of the LBLMO. The ministers of Agriculture, Ecology, Health, and Treasury and the DG of the National Council of Science and Technology (CONACYT) make up CIBIOGEM, the highest decision making body on LMO biosafety. Two other entities are also mandated by law: A Scientific Consulting Council (CCC) whose conclusions are obligatory to CIBIOGEM, and a Stakeholder Consulting Council whose conclusions are non binding to CIBIOGEM. Each of the ministries that form part of CIBIOGEM has internal techno-scientific committees. The LBLMO also mandates CIBIOGEM to stimulate the development of national, scientific and technical capabilities as well as on stimulating research on biosafety and biotechnology. Research on biosafety includes a) risk evaluation of LMO introduction/release on the environment, biodiversity, health, and socio-economic considerations, and b) evaluating and testing the information provided by the LMO industry. It is also mandated that maize native landraces should have a special program of protection from LMO contamination, since Mexico is the center of origin and of genetic diversity of maize, and because of its status of being the basic staple for Mexicans.
This system granted permission to the LMO industry to conduct open field experiments on maize-LMO in northern México in 2009. The Mexican scientific community as observer of this development expected that 1) The experimental stage would be conducted with transparency (observers allowed) and under a joint participation of both the National Institute of Agricultural Research scientists, and the LMO industry, 2) The experimental stage would last at least three years in order to judge LMO performance across years, and 3) Experiments should produce information not only on agronomic performance of maize-LMO, but also on characterization and follow-up of the initial experimental conditions. None of this happened. Instead, the industry lobbied CIBIOGEM intensively and succeeded in obtaining the permit to proceed to the pilot stage in year 2011, albeit on a one 0.24 hectare event in Tamaulipas state.
Participation of the Mexican scientific community has been limited largely to two topics: a) evaluating the extent and geographic distribution of transgenic DNA contamination of native maize, and b) mapping the precise locations of the centers of origin and of genetic diversity of maize and its wild relatives. Unfortunately, important as maize is in the national diet and as mandated by law, no national research of impact on human health has been pursued in Mexico under the auspices of CIBIOGEM. Rather, some very limited research on mice fed Bt-soybeans has been conducted independently in two public universities. LBLMO (Chapter VI, Art. 28) also mandates that critical information provided by the industry should be evaluated and tested under the auspices of CIBIOGEM. It seems that in Mexico, like in Uruguay as María Isabel Cárcamo reports, a great deal of the critical information required for LMO introduction/release is provided by the industry and as a rule has gone untested so far. Mexico has a reasonably strong scientific community that according to the LBLMO should be encouraged and funded to participate in all the so far unattended ex ante and ex post research opportunities on LMO introduction/release.
Finally, I would like to deal albeit in general terms, with a rather opaque side of the process of LMO introduction into Mexico. The “revolving door strategy” as described elsewhere may have biased the process of LMO introduction/release, as the interests of the industry may have been overrepresented. This revolving door strategy involves a) intensive lobbying in high government spheres, b) professionals working for the LMO industry applying for high-level positions in the public sector regulating system, to be later accepted back in the industry, b) well known scientists and other stakeholders that are enthusiastic about LMO technology are encouraged by the industry to apply to the several collegiate committees mandated by LBLMO. This strategy is complemented with strong marketing campaigns directed to critical actors (press, farmers, and politicians) that pays site-seeing tours abroad to high impact LMO-related sites.
It is my perception that this strategy has been an important factor of decisions leading towards introduction/release of LMO in Mexico. Conversely, other stakeholders of the civil society: non adopting farmers, consumers, non consumers vulnerable to damage, independent scientists, and NGO have not been able to match the industry strategy and stop its blitzkrieg so far. A continuation of this state of affairs could lead to the commercial release of maize-LMO in the center of origin and of genetic diversity of maize and wild relatives with whatever effects on stakeholder’s best interests. The same fate would await other crops domesticated in Mexico and wild relatives.
I believe as an observer, that what has been learned in Mexico from socio-economic studies and methodology and the process of LMO introduction/release itself is (1) a public agenda and funds should be allocated to independent Mexican scientists to study ex ante and ex post (long term) risk and socio-economic studies on LMO introduction/release, 2) Public funds should also be devoted to independent follow up evaluations of the decision making process.
REFERENCES Benbrook, C.M. 2001. Do GM crops mean less pesticide use? Pesticide Outlook 12(5):204-207
posted on 2011-04-14 19:01 UTC by Dr Antonio Turrent, Unión de Científicos Comprometidos con la Sociedad, A.C. (UCCS)
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2263]
ON BEHALF OF KOFFY DANTSEY De: Koffi DANTSEY < koffidantsey@yahoo.fr> Date: Mercredi 13 avril 2011, 20h43 First of all, I would like to thank CBD secretariat for allowing me to participe in the second round of discussion. [...] Socio economic assessment have been integrated into decision making proccess trough National Biosefaty Framework, laows, policies, implementing regulations . The mechanisms for taking socio economic considerations into account are the following : - the inclusion of socio-economic impacts in current risk assessment and risk management procedures; - The creation of specific socio-economic evaluation in decision makingfor LMOsimpacts associaed with this could be the establishment of a new body with the specific purpose of evaluating socio-economic impacts, or mandating an existing body with relevantexperts to undertake this task; - Adequate public consultation on socio-economic aspects that ensures effective acces toinformation and public participation prior to decision , including referenda. References : Falk-Zepeda , CBD'2008), Buck'2003) Fransen, Smale, Garforth,K'(2004) , Makenkie , Katarine,and Tapper, FAO(2006)
posted on 2011-04-14 19:19 UTC by Mr. Giovanni Ferraiolo, UNEP/SCBD/Biosafety
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2271]
Although I did not make the argument that Benbrook publications are not peer reviewed I do find the progression of his arguments a bit interesting. I have to confess that I have not kept up with list latest publications since I do not work in issues related to the U.S. anymore. In his earlier publications relating to Roundup Ready soybeans, Benbrook argued about the “yield drag”that RR soybeans had with respect to its conventional counterparts. Besides the obvious explanation that as RR soybeans had to comply with the biosafety regulatory process before release and thus there was delay compared to the flow of conventionally bred varieties (i.e. while RR soybeans waited for regulatory approval conventional breeding continued its delivery of varieties) this is an incomplete argument as there are more considerations than yield in farmer’s decisions. Even from a purely economic standpoint, an RR variety can yield less than conventional, but be preferred by farmers as it is profitable at the end of the cropping season. Benbrook then argued that there was a increase in the use of herbicides, especially Roundup which cost more than other pesticide and thus farmers were losing money. Again, an incomplete argument that did not match the reality of a significant increase in the adoption of RR varieties in the U.S. The later development implies that there may have been different measures of value beyond yield and cost. Later on Benbrook posed the argument that U.S. farmers where under a “technological mirage”. This is a curious argument when contrasted with the reality of multiple years of increasing adoption. When taking into consideration the level of sophistication of U.S. farmers, I can guarantee anybody that if a variety or technology does not deliver value in the medium term , U.S. farmers will move on to the next variety or other technology. If one consults other authors in the peer reviewed literature such as Jorge Fernandez-Cornejo. David Pschimmelfening and William McBride from USDA ERS, one finds their research on RR soybeans and posterior analysis compelling and quite complete as it is based on the ARMS (Agricultural Resources Management Survey) of more than 10,000 farmers in the U.S. and the use of state of the art econometric procedures. Their findings indicate that when estimating conventional economic gains from the adoption of RR soybeans these seemed to be small or insignificant and thus other measurements of value had to explain increased adoption. In fact, with careful measurements of labor patterns within U.S. farming households, they were able to trace and document that because of the management convenience brought by RR soybeans and the reductions in the amount of labor needed due to reductions in mechanical cultivations (remember a significant number of farms in the U.S. are still family operated enterprises) then the slack labor was able to obtain off-farm income and job security, especially in the educational sector. The lesson here is if one want to trace back these impacts one has to have careful adoption data collection and even more careful analysis to reach such conclusions. I would encourage people interested in the longer term farm sustainability of GE crops to consult the work done by the National Research Council -National Academy of Sciences of the U.S., This work summarizes a lot of what we know in the matter and goes beyond a single author’s conclusions. References Impact of Genetically Engineered Crops on Farm Sustainability in the United States Committee on the Impact of Biotechnology on Farm-Level Economics and Sustainability; National Research Council. ISBN: 0-309-14709-3, 270 pages, 6 x 9, (2010). This PDF is available from the National Academies Press at: http://www.nap.edu/catalog/12804.htmlFernandez-Cornejo, J., C. Hendricks, and A.K. Mishra. 2005. Technology adoption and off farm household income: The case of herbicide-tolerant soybeans. Journal of Agricultural & Applied Economics 37(3):549–563
posted on 2011-04-15 14:22 UTC by Dr. Jose Falck-Zepeda, International Food Policy Research Institute (IFPRI)
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2272]
On the value of peer review in science
Peer review has been for a long time (perhaps from its beginning) a staple of true science. Scientist willingness to disclose their research and analysis protocols, data, analysis procedures and conclusions to commentary and debate is a requisite and necessary step to the advancement of science.
Publication in a peer reviewed journal is a first step in the process of public disclosure, eventual public debate by peers and the general public, as well as opening the possibility for other scientists reproducing one’s results -or at least try to do so- and present evidence disputing results or even the whole research process done by a scientist.
Does publication in a peer reviewed journal is then a guarantee that the research presented is true? No, not even close, as published papers have indeed been withdrawn after publications due to failures of the peer review process who have not detected shoddy or even fraudulent research.
For the later reason, I am completely in favor of social and economic journals to require from all papers a mandatory submission of all data used in the paper, econometric/statistic procedures and computer routines used, and a full disclosure of funding and potential conflicts of interest, as is required by many of the medical sciences journals. This is to ensure quality and reproducibility.
Here I am talking about judging the quality and the relative strength of the evidence presented in any publication which turns out to be quite complex but something that one has to do and one which biosafety regulators/decision makers will be confronted when making regulatory decisions.
Scientists or other persons who publish a paper or opinion piece and then refuse to disclose what is behind their paper/opinion piece or submit their evidence for scrutiny; usually fall in the camps of those doing bad quality research, activists or quack/junk science practitioners.
Certainly, peer reviewed publications can be ranked based on many different indicators. Usually top ranked international journals are those with a more selective publication process, readership and impact. This does not mean that publishing a paper in a national or regional journal, then one has to dismiss such publication. Simply means that we have to examine the evidence a bit more carefully as the degree of scrutiny may have been a bit less stringent, but not necessarily so.
At IFPRI, we have made several press releases regarding different topics, but these have to be backed up by a peer reviewed publication according to our own internal communication policies. So the issue is not whether it is a press release.
We need also to recognize that there are different stages to the research process and in fact some papers are in the process of being presented in academic /professional conferences, reviewed and submitted for publication. This is why most serious scientists are extremely careful about launching publicly their research prematurely without having the proper peer review, as the later may indeed find issues with the research, analysis or conclusions.
posted on 2011-04-15 14:32 UTC by Dr. Jose Falck-Zepeda, International Food Policy Research Institute (IFPRI)
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2277]
Dear All, My name is Andreas Heissenberger and I work for the Environment Agency Austria in the area of GMO risk assessment and GMO policy/legislation. I want to give a little bit of an insight on how the issue of socio economic considerations is discussed at a European Union (EU) level. As you might know, in the EU the authorization process for GMOs is following a centralized procedure where the 27 Member States finally are voting to take a decision. It is important to know that all Member States are bound to the decision on the authorization of GMO once taken, even if they voted against it. In the past this fact caused some tensions in the EU and also lead to the discussion on how to take socio economic considerations into account, when making decisions on the cultivation or placing on the market of GMOs. In principle currently socio economic considerations are not taken into account in the assessment process, as this is not explicitly foreseen in the EU legislation dealing with the authorization. However, the legislation gives the possibility to take "other legitimate factors" into account, when deciding on the authorization of a GMO. So far there is no practical example on which factors could be taken into account, and what data needed to be provided in order to do so. There is a common understanding that, besides others, these "other legitimate factors" include possible socio economic effects. In December 2008 The Council of the EU published Council Conclusions, which - among other issues with regard to risk assessment and management of GMOs - invited the Member States to collect relevant information on socio economic implications and asked the European Commission to provide a report on these data. This report, after some delays, was published today: http://ec.europa.eu/food/food/biotechnology/reports_studies/index_en.htmFollowing the discussions which led to the Council Conclusions, some Member States including Austria, asked the European Commission to prepare a proposal to allow more freedom for the Member States with respect to decision making on GMO cultivation. In July 2010 the Commission tabled such a proposal which is currently under discussion. The discussions led to a list of possible grounds for justification, which a Member State may use in order to restrict cultivation of GMOs on its territory. The list contains mainly arguments which are related to socio economic implications, such as preservation of organic and conventional farming systems, keeping certain type of rural development in given areas to maintain current levels of occupation (such as specific policy for mountain regions) but also general policy issues like cultural policy or general environment policy objectives. However the discussions on these proposal are not yet finalized, and it remains open if the proposal will be adopted. In conclusion it can be said, that currently socio-economic considerations are not taken into account in the European Union, when a decision on the authorization of a GMO is taken. However discussions are currently ongoing and some Member States might decide to use arguments related to socio economic implications in order to restrict GMO cultivation on their territory. How this will be done and which data are needed to support these arguments is open, as there are no practical examples yet. Best regards Andreas
posted on 2011-04-15 16:03 UTC by Mr. Andreas Heissenberger, Austria
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2279]
One other thing that Benbrooke has failed to do is to disaggregate the increase in acreage from the increase in chemical use. It's elementary math that if the soy or corn acres increase due to the farmer benefits of GM soy and corn, then chemical use will increase. The crucial point that Benbrook conveniently ignores is the amount of active ingredient that is being applied, which as we found, has decrease substantially. In our case, the environmental impact from the production of GM canola has decreased by 53% even though the acreage of canola production has doubled in the past decade. More canola is being grown, more herbicide is being applied, but the environmental impact is half of what it was prior to GM canola. Sustained production of GM crops is the most environmentally beneficial means of producing crops.
posted on 2011-04-15 19:28 UTC by Dr. Stuart Smyth, Dr.
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2283]
How have socioeconomic assessments been integrated into the decision-making process and what lessons have been learned?
From my point of view socioeconomic considerations are not taken in account for decision making processes in Mexico as Turrent mentioned, the SEC are considered only in the law. I am afraid that in the last decision of release transgenic maize for a pilot plot, the authorities did not take into account socioeconomic considerations; they argued climate damage in order to bow under industry pressure.
In order to implement the Protocol’s 26th article, it is required a public policy formulation that balances between caution and innovation, and to consider the protection of biological diversity not only in strict economic benefits, but also the value that diversity provides environmental terms, employment, social development, the importance to indigenous and local communities, among other things. That is, to put forward the social returns, not economic.
posted on 2011-04-15 21:19 UTC by Dr. Michelle Chauvet, Universidad Autónoma Metropolitana
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2294]
From Ossama El-Tayeb, Cairo University, NFP, Biosafety - Egypt. The Egyptian National law (still in draft) integrates socio-economic considerations into the risk assesment approved procedures and hence in decision-making. RA must be conducted "in a transparent and scientifically sound manner" and should also "identify risks which are uncertain or unknown(eg, due to a lack of appropriate data)". RA must take place in the potential receiving environment, with 6 major topics including "human activities in that environment". In addition, the overseeing structure (the National Committee for Consideration of GMO Applications) is empowered to co-opt specialists in speicific areas of expertise to participate in discussion of specific applications and to hold public hearings on specific applications on its own initiative or upon request from the public, where socio-economic (including religious, spiritual, national security etc. elements) could be raised. Presentations during such hearings have to be evidence-based but no set criteria are required beforehand.
posted on 2011-04-16 18:59 UTC by Mr. Ossama El-Tayeb, Egypt
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2297]
Dear all, With regards to implementation of socioeconomic criteria in national legislation Norway is one country that has done this. In the Norwegian Gene Technology Act of 1993 the national decision making process regarding deliberate release of LMOs is comprised of 5 criteria that must be considered before an eventual approval: 1) health risk; 2) environmental risk; 3) benefit to society; 4) contribution to sustainable development; and 5) ethical considerations. The Norwegian Regulations relating to impact assessment (IA) pursuant to the GeneTechnology Act (latest revision from 2005) includes all the five criteria mentioned above. Appendix 4 in the IA regulations contain guidelines/elements relevant for the assessment of the three criteria benefit to society, sustainable development and ethical considerations. The list of elements listed in Appendix 4 is not exhaustive and not all elements may be relevant in all cases. With regards to the three Norwegian criteria we continue to develop methods and guidelines for applicants to follow. The criteria are complex and need to be considered and revised as new knowledge is acquired. Amongst others the Norwegian Directorate for Nature Management ( http://www.dirnat.no) has in 2010 co-operated with the Norwegian Biotechnology Advisory Board ( http://www.bion.no) in organizing an ad hoc group on the specific IA criteria sustainable development. The choice was made to focus on the particular case of insect resistant LMOs. The ad hoc group has discussed the three "components" of sustainable development - environmental, economic and societal considerations - and has considered how these should/could be assessed. The report from the group is scheduled for completion in 2011. One of the major challenges regarding the national follow up of the criteria benefit to society, sustainability and ethics is the lack of relevant information in the LMO applications/notifications that the authorities receive. Norwegian authorities will continue to focus on this. Best regards, Nina Vik
posted on 2011-04-17 09:00 UTC by Dr. Nina Vik, Norway
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2298]
On the number of countries with practical experience
Perhaps it would be instructive reviewing those countries with practical experience with the inclusion of socio-economic consideration in their decision making. I did a quick check on the Biosafety Clearinghouse, and there are 356 cases on the “Decision on LMOs for intentional introduction into the environment (Article 7-10)”.
We need to take this data as a departing point for any analysis as we have to take into considerations all the known limitations of the BCH in terms of reporting. In fact, I am at least aware of three more countries with risk assessments and posterior decisions on intentional release that are not reflected in the following list.
Obviously, there may be other regulatory triggers for the inclusion of socio-economics such as decisions for LMO-FFP or transit, but I am focusing on what I considered the most likely candidate for such inclusion. Since the Protocol does not contain the figure of “Confined Field Trial” recognized by many countries’ national laws and regulations, the count on deliberate release into the environment includes confined field trials, multi-locational trials and commercial release.
List of countries with decisions on deliberate release (Article 7.1( Country Number of decisions Argentina 2 Australia 5 Brazil 22 Canada 45 China 2 Colombia 14 Costa Rica 12 Cuba 9 E. U. 31 Germany 18 Indonesia 1 Japan 56 Malaysia 1 Mexico 12 Norway 1 Philippines 4 Romania 2 South Africa 3 Spain 27 U.S.A 89 Total 356
The big question here is how many of these countries and decision combinations have actually included socio-economic considerations into their decision making in real practice?
Per our understanding of the situation, further corroborated by the contribution by Lema and Burachik in this online discussion, we know that Argentina has done so and that it is a dynamic process…who else has actually included socio-economics?
I believe it would be quite illuminating reading the decisions and then doing a follow up with the regulators and decision makers in order to understand what was the role and how was socio-economic taken into consideration in those decisions. Finding out who has done so can enable this process.
(edited on 2011-04-17 11:49 UTC by Dr. Jose Falck-Zepeda, International Food Policy Research Institute (IFPRI))
posted on 2011-04-17 11:25 UTC by Dr. Jose Falck-Zepeda, International Food Policy Research Institute (IFPRI)
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2299]
the list of countries with experience should include those countries with formal requirements and those who have done so in an informal setting as the process was not included in current legislation.
posted on 2011-04-17 11:27 UTC by Dr. Jose Falck-Zepeda, International Food Policy Research Institute (IFPRI)
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2321]
On behalf of Carlos Almendares From: Carlos Almendares[SMTP: CALMENDARES81@YAHOO.COM] Sent: Friday, April 15, 2011 12:19:57 PM Previously there have been consultations to indigenous communities and has respected their decision of not allowing sale of seed crops or GMOs, in his region. Lessons learned?, after 9 years of planting modified corn, has not seen any different behavior in relation to the planting of conventional corn, so, I think that trying to add more assessment, impede the process involves national research of our universities that do not have sufficient economic resources for their project, and that, must be added the cost of risk assessments. Carlos Almendares
posted on 2011-04-18 13:54 UTC by Mr. Giovanni Ferraiolo, UNEP/SCBD/Biosafety
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2326]
Posted on behalf of Georgina Catacora-Vargas (moved here from another discussion thread):
Dear all, In Bolivia, the biosafety regulation was issued in 1997 before the development of the text of the Protocol and hence, its entry into force. Accordingly, the current biosafety regulation has several gaps and mostly focuses on agronomic and environmental impact assessment. However, this has not limited the inclusion of socioeconomic considerations in the process of decision-making related to LMO introductions. For instance: - In 2000, field trials on GM potato tolerant to nematodes were not approved due to its potential socio-ecological adverse effects given that Bolivia is part of the center of origin and genetic diversification of potato. An important driver of this decision was the concerns raised by social groups, mainly peasants and indigenous people. They submitted to the competent authorities their opposition to the introduction of GM potato due to its potential adverse effects on their main source of food and on the conservation of local varieties for agricultural and cultural purposes. - In 2005, field trials of GM maize tolerant to armyworm (Spodoptera frugiperda) and the herbicide ammonium glufosinate were not approved due to environmental and socioeconomic reasons. The decision process considered that Bolivia is an important center for genetic diversification of maize, there is a high probability of genetic contamination and local varieties of maize is a staple food with multiple local and cultural uses. Although in 2005 was banned the introduction of GM maize seeds, in 2009, native communities denounced to the competent authority the illegal introduction of GM maize seeds from neighboring countries. To Bolivia, the main lesson learned in these processes are: i) indigenous and local communities needs are central in decision-making related to the conservation and sustainable use of biological diversity particularly in countries, such as Bolivia, that are centers of origin and genetic diversification of important species; ii) the impact assessments related to the introduction of LMOs need to effectively include potential impacts on the sustainable livelihoods, with particular emphasis to indigenous and local communities; iii) particular attention should be given to illegal introductions and appropriate approaches to assess their impacts need to be developed since they pose particular monitoring challenges. Currently, in Bolivia socioeconomic considerations related to LMOs are approached under two pieces of legislation with high legal hierarchy. These are: 1. The New Political Constitution of the State (issued in 2009), which has specific clauses on the prohibition and legislation of GMOs. It also provides guidelines to make operative the social and economic rights of the Bolivian people, making particular emphasis on the rights of indigenous and peasant communities on: i) the conservation and use of natural resources, and ii) conservation and exercise of their social, spiritual and cultural dynamics. 2. The Law on the Rights of Mother Earth (issued in 2010), which is rooted in the recognition of the strong and intertwined Nature-Society relationship, setting clear rights to and duties on the protection of Nature, recognizing the importance on sustainable rural and indigenous livelihoods. Based on this, the Plurinational State of Bolivia approaches socioeconomic considerations of LMOs and other technologies in light of impacts to: i) food security; ii) food sovereignty and iii) wellbeing (as a more comprehensive approach towards sustainable development). Indigenous peoples and peasant communities are of particular importance to all decision-making processes. Currently, we are in the process of strengthening our national mechanisms for an effective inclusion of socioeconomic considerations into biosafety decision-making. Based on this, we find very useful the process carried out by other Parties where a comprehensive analysis on sustainable development, societal utility and ethical considerations are included in biosafety decision-making. Thanks ad kind regards to all, Georgina Catacora-V.
posted on 2011-04-18 19:09 UTC by Ms. Kathryn Garforth, Secretariat of the Convention on Biological Diversity
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2329]
Posted on behalf of Eric Sachs. Due to technical difficulties, the message is being posted after the discussion group has closed:
Dear all, I have read with interest the various points of view on the potential integration of socio-economic assessments in the decision-making process for LMOs, and in particular the lessons learned. As various persons have stated, there are challenges to implement robust methodologies, insufficient experience to implement ex-post analyses, a multitude of potential considerations and relevant approaches can vary from country to country depending on national priorities and goals. Consequently, there are several over-arching policy considerations that directly impact a country’s development and implementation of LMO biosafety assessment and decision-making, particularly in the context of authorizing cultivation of LMOs.
1) Food Security and Dependence on Food Imports Policymakers need to weigh the needs of the national population and determine what priority to place on food security and independence from reliance on imported food and feed. They also need to consider whether there is potential to increase food and feed production based on available technologies and infrastructure and whether to participate in global trade as a means to support the national economy. Strong economies and well-fed populations may approach these decisions differently from developing economies or economies in transition. Countries dependent on imports are subject to market forces and price fluctuations that can at times put enormous pressure on local communities. A key question for policymakers is what emphasis to place on access to technologies that can improve agricultural productivity.
2) Technology Choice in Mega-Diverse Countries or Centers of Origin A common argument in countries rich in genetic diversity is to avoid use of LMOs that allegedly may threaten biodiversity. It is important for policymakers to consider potential threats to biological diversity in LMO decision-making but such decisions should be based on real rather than perceived or hypothetical risks and in the context of national priorities. Mega-diverse countries owe this diversity to indigenous farmers, which have maintained genetic diversity through generations of selection for varietal attributes important to local communities. In most cases this also has resulted in low productivity compared to countries with agricultural practices and breeding based on productivity.
3) Preserving Genetic Diversity and Use of Modern Agricultural Methods and LMOs Preserving genetic diversity as an adaptive capacity resource is achievable while utilizing additional genetic improvements from biotechnology. Policymakers must consider how to preserve genetic diversity and at the same time improve productivity to meet national needs. Allegations that landraces and other sources of genetic diversity are threatened by LMOs must be examined in the context of the biosafety assessment. The introduction of LMOs is not inherently risky to genetic diversity. If there were risks then the environmental risk assessment would characterize these risks and decision-makers would take these risks into account during the decision-making process. Based on the experience to date, the addition of transgenes to the genetic pool of locally adapted crop varieties has not resulted in harm to genetic diversity. In practice, farmers continue to plant adapted varieties with the same genetic diversity that existed prior to the introduction of LMOs, except they may choose to plant newer varieties that include improved traits introduced through biotechnology. Policymakers should utilize the environmental risk assessment to evaluate the potential for risks to genetic diversity and avoid decisions that are based solely on perceived risks or alleged threats to traditional knowledge and contamination of indigenous varieties.
4) Taking Advantage of Traditional Knowledge and Technology Choice Choice is essential to provide access to current and future innovations in agriculture that have the potential to improve agricultural productivity and national food security. Farmer’s rights include access to new agricultural knowledge and technological advancements that can improve productivity, the local environment and community livelihood. As stated above, the use of LMOs is not inherently risky to genetic diversity; neither is use of LMOs a threat to traditional knowledge and indigenous communities. Local farmers and indigenous communities have played a central role in conserving and developing local genetic resources. As stated above, these genetic resources are the foundation for further improvements using biotechnology. The question is not whether to choose one or the other but to recognize the potential for utilizing existing genetic resources and biotechnology in combination.
5) National Priorities and Policies Regarding LMOs Some countries have integrated socio-economic considerations into the LMO biosafety assessment, while others may take into account socio-economic considerations separately. Whatever the approach policymakers choose, it is important to consider national priorities related to food security, dependence on imported food and feed, preservation of genetic diversity and choice of technologies for local farmers and communities to improve agricultural productivity. Policymakers ultimately determine the functionality of LMO biosafety laws and systems, either toward the safe use of LMOs or not, depending on national priorities and goals. These are major decisions and should be made based on facts and not on unsubstantiated allegations of risk. As a result, the inclusion of socio-economic considerations in decision-making should be weighed against national priorities and evaluated in the context of their utility for informing decision-making. Policymakers also should consider how delays in decision-making, based on efforts to consider socio-economic impacts that by their nature are challenging to apply, may impact achieving national priorities and goals.
Dr. Eric Sachs Global Industry Coalition
posted on 2011-04-19 21:34 UTC by Ms. Kathryn Garforth, Secretariat of the Convention on Biological Diversity
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2393]
I am sorry I am submitting this comment so late but I have been away from the office for several weeks. What I think the discussion so far points out is that there are many references to socio-economic assessments and analysis in many national biosafety regulatory systems but not all of those systems have yet to implement their policy for specific LMOs. There are some LMOs that have had socio-economic assessments in some countries and it would be extremely valuable to have a comparison of those experiences: Who did the assessment? What did it include? How was it incorporated into the decision process by the decisionmaker? Was the process transparent? How did the public participate, if at all? It seems to me that this information would be extremely valuable in understanding the role of socio-economic considerations in LMO decisions and also what issues different countries thought were important. In other words, an analysis of the “lessons learned” with suggestions for going forward would greatly benefit everyone who follows this issue. It might also lead to some generalizations that could be valuable for countries still deciding what to do in this area (or deciding how to implement existing policy positions in this area).
Gregory Jaffe Director, Biotechnology Project Center for Science in the Public Interest
posted on 2011-05-04 17:30 UTC by Gregory Jaffe, Center for Science in the Public Interest
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RE: How have socio-economic assessments been integrated into the decision-making process and what lessons have been learned?
[#2418]
I need to post a late comment on the posting by Eric Sachs (2011-04-19) because I think that two points need to be discussed in the right context - also with regard on the workshop in November.
The statement that their is no inherent risk with the introduction of LMOs is wide spread but actually in the context of biosafety regulation and risk assessment this is not the starting point of our discussions. The Cartagena Protocol is based on the assumption that the application of modern biotechnology/genetic engineering is more risky than traditional breeding methods and thus needs specific regulations. This is also the starting point for those 161 countries which are Parties to the CPB and develop their national regulation.
The posting seems to suggest that politicians can make use of the environmental risk assessment performed in the context of LMO applications to evaluate the biodiversity risks with regard to landraces. Although this would be useful, many if not most ERA would not include an assessment of the effects of LMOs on biodiversity aspects concerning landraces because such an assessment would be rather considered as being agricultural than environmental. At least in the EU context this specific lack in risk assessment - concerning conservation and sustainable use of agricultural biodiversity - is one trigger to call for broader, socio-economic assessments.
It might be useful when preparing further documents to elaborate on this interface between environmental and agricultural risk assessment.
posted on 2011-05-08 11:28 UTC by Dr. Hartmut Meyer, Deutsche Gesellschaft fuer Internationale Zusammenarbeit (GIZ) GmbH
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