SWG on Risk Assessment of LM Trees

Dear collegues
First of all I like to thank all who have commented and provided text proposals. That is very helpful.
In the enclosed draft I tried to combine and balance the different comments from experts (from Parties including the comments from non-Parties and Observers). I integrated text proposals from Didier Breyer, Georgina Catacora-Vargas, Les Pearson and Steven Strauss plus collegues. I tried to find a middle line between quite different concepts and proposals. Therefore I sometimes changed the wording compared to the initial wording suggested or I integrated text proposals  at other than the proposed places. 
A number of text proposals were more of a commenting nature with personal assessments  as for example the first insertion by Steven Strauss and collegues. My impression was that such proposals help to understand the direction of commenting but are not adequate for a guidance document or were not in line with the recommendations of the Biosafety Protocol.
The amendments are visualized by track changes – but only the new or added text not the deletions.
Now I like to ask you for your comments on this third draft until the 6th of January. I hope that gives enough time for reading and commenting even though most of us may have some days off at the end of the year. I then will finalize this draft based on your comments until the 15th of January for our next round of online activities.
Having said that I like to thank once again for your continuing support and constructive cooperation. I wish you peaceful and relaxing final days of 2011 and a good start into 2012.

Best regards
Beatrix

POSTED ON BEHALF OF JACK HEINEMANN 

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Dear fellow members of the SWG on GM tree RA

I also wish to congratulate the primary authors of the developing document for their hard work and dedication. I've taken the weekend to review the comments and drafts in light of the concerns that Kazuo places before us.

It is no surprise that in these large international exercises not everyone
will be pleased with everything in the document. Areas of disagreement can be argued and considered as per the process that is ongoing. I see no particular exception for this document nor do I see this document as developing outside of the normal parameters of the others already developed or still underway. 

1
I appreciate the process as has been conducted by the Secretariat and the Chair. In this process, those who went to the trouble to participate had a forum in which to express their views. If selected individuals that have opted out of the open process are now specifically sought for their views, we then suggest that their views are more important or authoritative than views held by those who have already contributed. That seems very difficult to justify. In any case, where does this reasonably stop? Not everything I
would have prioritised is in these documents; not everything that certain experts I know is prioritised in these documents; and some issues have been prioritised out of proportion to what I would argue is justified. However, I also consider that these are consensus documents; the science might be
equivocal in some areas and I am sufficiently uncertain to resign myself to the consensus view on these topics; these documents are guidance and not law, and therefore the purpose is to lift the capacity of those uncertain about what RA is appropriate for their countries by ensuring that they have the opportunity to consider risk pathways that may not apply everywhere but might apply where they are.

I am also reassured to note that there has been broader input from
individuals who, as far as I can tell, are the very type of experts being
called for (e.g., see explicitly Steven Strauss' submission #2849, which has 5 additional authors).

2
Having served on too many committees in my life I find the suggestion that Beatrix has been "dogmatic" in her process unkind and unfair. It is not justified in my view. She has been inclusive of the voices that Kazuo and others argue are absent (and are not). She is then criticised for allowing in a single view on fruit trees. Is the problem with what the latter had to say or with the process? Likewise, to suggest that the view was uniformed or irrelevant because he is a "molecular biologist" is in my view a dispersion on the person rather than the argument. Having said that, if there is a general argument to be made that the mix of scientific expertise in the
process should be expanded, then I would call for more explicit solicitation of forest, plant, animal and microbial ecologists, agroecologists and entomologists with active and ongoing research experience.

3
I very much appreciated Helmut's interjection on the parallel development of specialist guidance and testing and revision of the Roadmap. As I understood
from what he said: A. the process has been set by the Parties; B. these are living documents and can be amended or streamlined in the future if the minor issue of redundancy between them is perceived as a problem.

Best regards

Jack Heinemann

Thank you for providing us with the draft of December 12 and for all your hard work.  I am happy to say that I believe good progress is being made within this particular document.  Please find attached a few further suggestions and comments that should help us get over the “finish line” with this.
My overall comments for improvement are:  (1) we need to take care to include only concepts and references to phenomena that are unique to trees; and (2) the comparative approach should be accurately characterized.  Regarding #1, epigenetic effects and transformation induced mutations apply to any biological organism and genetic modification.  If they are special considerations for RA, they should be addressed in the Roadmap.  Regarding #2, the comparative approach was actually developed within OECD in light of the entire body of possible genetic modification.
Happy New Year to all!

Tom

Dear all,

Best wishes for the new year to all.

Thank you, Beatrix, for Draft 3 and the tremendous work you have done in the face of all the comments.

Please find attached a few remarks and suggestions. Unfortunately they are incomplete as I had very limited time to focus on the text, and the deadline has come.

Concerning Tom’s remarks in the section “Long life spans and genetic and phenotypic characterisation and stability” concerning the inclusion of genetic and epigenetic changes both in the rational and in points to consider, I regard it as very important to keep them, as they are of particular relevance for trees with their long life span and exposure to (and adaptation to coping with) often extreme abiotic stresses and conditions.

One area I have particular problems with is the last section “Risk management strategies”, which will require more work. (see comments attached).

Looking forward to a further debate at the upcoming face to face meeting.

With best wishes,
(from a very unseasonal Oxford, where not only snowdrops are flowering, but roses aswell, and now the irises are coming up ... still waiting for winter to arrive).

Ricarda