Development of the Roadmap for Risk Assessment

According to the draft roadmap, its purpose is: “…to enhance the utility of Annex III of the Protocol and assist risk assessors in conducting risk assessment, as well as reviewing existing risk assessments, of living modified organisms (LMOs) in accordance with Annex III of the Protocol”.
It is important to remember that, in order to achieve its main purpose, the roadmap should make the Risk Assessment (RA) in Annex III effective and straightforward. The inclusion of new aspects other than the existing related general principles and methodology to RA in annex III is a deviation from its main purpose. RA can be considered as the scientific determination of the probability of a specific unwanted damaging effect occurring, which is certainly one of the important aspects that contribute to decision making on the adoption of LMOs. In order to have the Risk Assessment and each aspect of decision-making considered in a valuable and efficient way, it is better to split them, as possible, in different activities. So that each aspect of decision-making can be assessed in its appropriate context by and with the competent expertise and pertinent attention. This draft roadmap included aspects that are considered of importance for decision making, because they can for instance change the acceptability of LMOs, but they are not per se part of the Risk Assessment. it would be better concentrate on the purpose of risk assessment, instead of covering all important aspects for decision-making.  The following items in the draft roadmap do not belong to the Risk Assessment as in Annex III:
- “Coexistence” (Coexistence is usually referred for mixtures between  cultivated varieties and is consequently more a economical issue, related to farmers and consumers choice not to ecological safety. One should keep apart the possible adverse effects caused by out crossing to wild relatives which are part from the RA in annex and its supporting roadmap and “coexistence” of cultivated species which are of economical relevance and not for environmental RA.)
- “Mechanisms to be implemented produce a dialogue involving stakeholders, in particular for communication between risk assessors and risk managers and to promote public awareness” (this is more related to acceptability which will depend on the aims of policies, abilities to manage and communicate risk, etc. It´s not a risk assessment step)
- “….existing policies, strategies…”
These, when relevant, should be addressed appropriately in the right context of the decision taking, but not as part of a risk assessment roadmap. While my suggestion would be to eliminate the above aspects from the roadmap on risk assessment, I´d give more attention and focus on trying to guide risk assessors to ask relevant questions (i.e. to identify important risks e.g. risks of ecological relevance, efficiently formulate risk hypothesis, estimate the level of risk, etc). Moreover the roadmap should help risk assessment to be consistent, scientific and of high quality. This is already a challenge, in some ways brought in the draft roadmap. In “General considerations/Chapeau” for instance the draft mentions points that are important to help risk assessors in making a quality work. Among the points for quality (including consistency, etc) one is the application of standards (discussion item 3) and the lack of harmonized, science based standards… the development of these is challenging but certainly very useful.