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Open-ended online discussions on the post-2020 Implementation Plan for the Cartagena Protocol on Biosafety

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General comments on the draft Implementation Plan

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Thread 1 - General comments [#9749]
Dear participants,

Welcome to the online discussions on the draft post-2020 Implementation Plan for the Cartagena Protocol on Biosafety.

As you know, the draft Implementation Plan has been developed by the Secretariat on the basis of views submitted and taking into consideration the guidance provided by the meeting of the Parties in its decision CP-9/7.

I would like to invite you to submit general comments on the draft Implementation Plan in this thread.

Information on the development of the draft Implementation Plan is provided in section II of the background document titled ‘Draft Implementation Plan’. This information shows among others that there are a number of areas where further discussion could be beneficial, for example on whether there is a need to include a vision and mission in the Implementation Plan and on the desirability of including milestones in the Implementation Plan. Input on these and other general issues can be provided in this thread.

The general discussion thread will remain open for the duration of the entire online discussions.

On 11 July, separate threads will be opened on specific parts of the draft Implementation Plan (i.e. the goals, objectives, outcomes and indicators). I would therefore urge you to make any comments on the specific parts once the respective threads have been opened.

Given that the online discussion is the first opportunity for Parties and other stakeholders to provide input to the draft Implementation Plan and keeping in mind that there will be several further occasions where the Implementation Plan will be considered (including a peer review process and the third meeting of the Subsidiary Body on Implementation), I would like you to focus on sharing your thoughts on the ideas in the draft Implementation Plan rather than on the specific wording of the text.

I look forward to a lively discussion and your active participation.

With best regards,
Galina Mozgova
(edited on 2019-07-11 12:50 UTC by Galina Mozgova)
posted on 2019-07-08 12:52 UTC by Dr. Galina Mozgova, Belarus
RE: Thread 1 - General comments [#9791]
Fellow Participants,

It is quite an honour and a privileged to be part of this important discussion in this honourable platform. I sincerely appreciate the efforts of the organizers of this forum. In contributing to the preparation for the post-2020 global biodiversity framework, as well as developing a specific Implementation Plan for the Cartagena Protocol on Biosafety for the period: 2021-2030, as a follow-up to the Strategic Plan for Biodiversity and the Strategic Plan for the Cartagena Protocol on Biosafety 2011-2020; I humbly submit my general comments on the Draft Implementation Plan in this thread.
For the protocol to be held as a significant step forward in reconciling the respective needs of trade and environment protection there is need to include vision and mission in the Implementation Plan. In accordance to the precautionary approach contained in Principle 15 of the Rio Declaration on Environment and Development, the objective of Cartagena Protocol on Biosafety is to contribute to ensuring an adequate level of protection in the field of the safe transfer, handling and use of Living Modified Organisms (LMOs), resulting from modern biotechnology that may have adverse effect on the conservation and sustainable use of biological diversity, taking also into account risks to human health and specifically focusing on transboundary movements. This should guide the vision and mission of the emergent Implementation Plan.
Giving the fact that there is sufficient flexibility to account for development during the period of implementation in the structure of the Implementation Plan, there is therefore, a strong desirability in including milestones in the plan. This is to ensure adequate periodic review of relevant issues, instruments and practices and ensure proper estimation of outcomes. It could also reflect lessons learned and inform recommendations in addressing operational gaps in the action plan and developing standards under the protocol. In my opinion, enhancing conceptual and practical operational measures for consideration of activities under the protocol could become dramatically negative, should this element be omitted in the content of this strategic Implementation Plan.
Best regards,

Edel-Quinn Ijeoma Agbaegbu
Every Woman Hope Centre, Nigeria
RE: Thread 1 - General comments [#9804]
Dear colleagues,

Firstly, thank you for the opportunity to provide comments on the draft post 2020 Implementation Plan for the Cartagena Protocol. In fact, I agree with rearranging the goals as proposed in comments by other countries in the implementation of protocols like the comment from Milanie (#9802) with the recognition and inclusion of indigenous peoples and local communities that play an important role in the conservation of biodiversity (Goal 1 and 4).

I have some remarks at respect with some goals listed in the draft Implementation Plan, specifically in Areas for Implementation. I totally agree with the comment from London (#9801) related with the objetives and indicators that are fine, but not sufficient to assess whether national biosafety frameworks are truly functional, is necessary clarity about goals, measures and biosafety methodologies available in each area. I think that the consideration of measures for these elements could be really useful.

Finally I want to consider that it is necessary the incorporation of  organisms produced through Synthetic Biology and organisms that contain engineered gene drives, even monitoring in organic products (Goal 6). In addition, it should be included aspects such as unintentional transboundary movements and emergency measures, and I consider  the identification and correct label in all of modified products necessary (Goal 3). Actually, considering the crops and also their derivatives, as well as adverse effects to the environment and native varieties (Goal 5).

Best regards
Mariana Ayala
Biosafety Subdirection, INECC, Mexico City.
posted on 2019-07-21 20:48 UTC by MsC Mariana Ayala, Mexico
RE: Thread 1 - General comments [#9811]
I welcome the opportunity to be able to provide inputs to the draft post 2020 Implementation plan of the Cartagena Protocol on Biosafety.
The post 2020 Implementation plan of the Cartagena Protocol  should be build on the experiences. challenges and accomplishments of Parties in implementing its provisions consistent with the Parties domestic needs and priorities. It should not loose sight of the Protocol’s real intent that is, ensuring adequate level of protection for the safe transfer, handling and use of LMOs resulting in transboundary movement that may have adverse effect on the conservation and sustainable use of biological diversity.
I support the inputs of Dr. Behzad Ghareyazie, Iran CPB NFP as indicated in 1,2,3 and 7 given the  experiences that the country had in dealing with applications on LMOs from contained use up to commercialization and importation for food, feed and processing. 
Further, based on my dealing with my colleagues in Asia, countries are at various levels of implementing biosafety regulation since some countries are only engaged in research and development work, some are already commercializing agricultural crops and are importing  commodities while some are importing commodities for direct use.  Given this situation, I believe that the post 2020  implementation plan should be flexible enough to address the challenges pose by LMOs and provide for building the capacities of the Parties in achieving the objectives while at the same time ensuring that funds are made available from the UNEP-GEF  Biodiverity Funds’ START allocation to implement the activities.  I also would like to support Ms. Galina on Article 5 - which are addressed by other relevant international agreements or organization,

Thank you very much and kind regards,

Julieta Fe L. Estacio
Head Secretariat, NCBP
(edited on 2019-07-22 05:39 UTC by Julieta Fe L. Estacio)
posted on 2019-07-22 05:37 UTC by Ms. Julieta Fe L. Estacio, Philippines
RE: Thread 1 - General comments [#9813]
Dear Colleagues,

Following my earlier General comments, I would like to respectfully submit my inputs on “B. Enabling Environment”, specifically item no. 2 “Parties mobilize resources to support the implementation of the Protocol”.

I believe that sufficient and predictable funding is crucial to effectively implement the provisions of the Protocol. While it is the obligation of Parties to provide from its national budget amounts necessary to implement the Protocol, most if not all get very little from their national coffers, specifically for countries where biosafety regulation is not legislated.  It is for this reason that funding from the national biodiversity STAR is necessary and should be regularly allocated  to ensure continuous funding for biosafety-related activities for the Parties to achieve this objective. For this purpose,  coordination should be established with the GEF - National Operational Focal Point, if not in place yet, or enhanced, as necessary.

There are instances where the FP for CPB is different from the FP for the CBD as in the case of my country, hence biosafety became the least of its priorities when it comes to GEF allocation. Based on my experience, there are some disconnect with this arrangement – different government Departments implementing the Protocols under the Conventions -, hence presentation to the NFP-GEF of the COPMOP decisions supporting  regional and sub-regional cooperation,  funding for biosafety projects  as well as decisions for GEF to consider biosafety projects proved very useful in increasing the level of understanding about the relationships between and among Convention and its Protocols, including the need for funding to implement the Protocol to fullfill country obligations.

Thank you very much and kind regards,

Julieta Fe L. Estacio
Head Secretariat, NCBP
(edited on 2019-07-22 07:04 UTC by Julieta Fe L. Estacio)
posted on 2019-07-22 07:03 UTC by Ms. Julieta Fe L. Estacio, Philippines
RE: Thread 1 - General comments [#9816]
Thank you for the opportunity to comment on the implementation plan.

I note that in the plan, the phrase "Parties..have access to…" is used often, especially with regard to guidance material. There has been much guidance material written over the years, much of it available on the BCH and online from several regulatory agencies and international organizations.  This guidance is robust enough to cover not only LMOs developed through established genetic engineering techniques but also new technologies.  Thus the indicator for percentage of Parties hat have access to this material is measured, it would be 100%.  Rather than access to the material, it is the implementation of that material that is critical to the post-2020 timeframe.  In this regard, capacity building (for which a post-2020 plan is still to be developed) is a key component of any future planning.  This includes capacity for implementing socioeconomic considerations.

In addition, the often-used term "Appropriate" is a nebulous term..  For example, in points 2.1 and 2.2.  It would be better to link the goals it to the wording in the column on Indicators: 

2.1 Parties apply risk assessment and risk management procedures on LMOs as required by the Protocol.

2.2 Parties have access to guidance materisl for carrying out risk assessment and risk management, that is consistent with the requirements of the Protocol

"Consistency with the requirements of the Protocol", or similar language, would be more precise.


Hector Quemada
Western Michigan University
posted on 2019-07-22 12:03 UTC by Mr. Hector Quemada, Retired