|
||
|
THIRD WORLD NETWORK BIOSAFETY INFORMATION SERVICE 4 May 2005
RE: SCIENTIFIC SUBMISSION ON CARTAGENA PROTOCOL ARTICLE 18 The New Zealand Institute of Gene Ecology (NZIGE) has put forward a submission to the New Zealand Ministry of Foreign Affairs and Trade ahead of the Second Meeting of the Parties to the Cartegena Protocol on Biosafety in Montreal on 30 May to 3 June 2005. At the Montreal meeting, Article 18 of the Protocol - Handling, transport, packaging and identification - will be hotly debated and negotiated. To this end the submission is timely as it focuses primarily on this provision and is a statement recommending the position the New Zealand government should take. The scientific points made in the submission have significant relevance for developing countries as well. It urges the government of New Zealand to reject the phrase "may contain LMOs" and replace it with "contains LMOs (living modified organisms)" for shipments that carry LMOs, thus shifting the burden of proof on the exporting country and relieving the importing country from the burdensome task of having to monitor and detect its imports. In order to avoid incidences such as that of the Bt 10 corn which was mistakenly exported as Bt11, a thorough documentation system that facilitates identifying and monitoring of shipments of LMOs.should be in place. NZIGE suggests that shipment of products containing LMOs should at the minimum contain the following information:
Documentation for LMOs containing multiple or "stacked" events must identify each of the events; any stacked derivative cannot be assumed to be equivalent to either parent organism and must be documented as a distinct LMO. On the issue of threshold, NZIGE proposed that if any thresholds are ultimately adopted, they should be based on safety thresholds (LMO loads below this threshold will not result in harm to human health or the environment) and a clear demonstration that national authorities can detect LMO loads at or above that threshold under normal sampling conditions. In addition, the burden should be on exporters to ensure consignments are free of unapproved or unidentified LMOs. This submission raises many important points which other countries should also consider as they enter into negotiations on this crucial topic in Montreal. The full text is reproduced below. With best wishes, New Zealand Institute of Gene Ecology For more information contact
Dr. Joanna Govern 22 April 2005 Submission to Ministry of Foreign Affairs and Trade concerning the second meeting of the Parties to the Cartagena Protocol on Biosafety The New Zealand Institute of Gene Ecology welcomes the opportunity to submit its views for consideration by the Ministry in its preparations for the second meeting of the Parties to the Cartagena Protocol. This submission focuses primarily on item 12 (Handling, transport, packaging and identification [Article 18]) of the Provisional Agenda (UNEP/CBD/BS/COP-MOP/2/1). The following section of the submission mirrors the structure provided in the Report of the Open-ended Technical Expert Group on Identification Requirements of Living Modified Organisms Intended for Food or Feed, Item 3. Part I: (a); (b). The documentation accompanying the living modified organisms; the information to be provided in the accompanying documentation It is not in New Zealand's interest to support those who seek to minimise the quantity and quality of information accompanying the goods they export to us. The fate of New Zealand's biodiversity as well as its reputation as an agricultural exporter depend upon the effectiveness of its biosecurity measures. The cost of New Zealand's biosecurity monitoring burden will be determined in part by the quantity and quality of information provided by those who export to us. In particular, the cost burden to New Zealand will be greatly increased by a failure to move from the imprecise umbrella phrase "may contain LMOs" to a requirement to indicate whether or not a shipment in fact "contains LMOs". The language "may contain" should be rejected by New Zealand. It abides neither by the spirit of the Protocol nor by Decision BS-I/6. It is not consistent with New Zealand's role as good global citizen to undermine an agreement it freely joined. The language "may contain" also undermines New Zealand's biosecurity by unrealistically overtaxing New Zealand's monitoring and detection capacity. It would force New Zealand to choose between jeopardising its biosecurity or monitoring an excessively large quantity of imports. Further, it is essential that sufficient information about the nature of the LMO or LMOs be provided in order that New Zealand or any other importing Party can verify that the imported LMOs are in fact those that it has agreed to import. Biosecurity requires that the documentation must be able to facilitate identifying, monitoring and containing a shipment of LMOs. This kind of documentation may be of minimal value when the LMO is of low risk and has been properly identified, but is critical in the case where the assessment changes or it has been mis-identified. For example, the impact of mis-identifying BT10 corn as BT11 (by Syngenta) in shipments to Europe could have been minimised by a thorough documentation trail that facilitated collection and containment of the seed once the mistake had been discovered. The minimum necessary information in our view is:
Here it is important to note that documentation for LMOs containing multiple or "stacked" events must identify each of the events; any stacked derivative cannot be assumed to be equivalent to either parent organism and must be documented as a distinct LMO. In the interest of protecting its biodiversity and its agricultural reputation, New Zealand should support information requirements that enhance its ability to implement traceability (identity preservation) within its own production chains. This is vital to protecting New Zealand's export markets and is consistent with current domestic practice in New Zealand. Rather than imposing excessive costs on New Zealand producers, it would require those who profit from the export of LMOs to shoulder a portion of the resulting monitoring and compliance costs that would otherwise fall upon the importing government, producers and retailers. Given the importance of these issues to New Zealand, New Zealand should ensure that documentation agreed under the Protocol will be regarded as the minimum necessary and will not prevent national authorities from requiring additional documentation when this is justified by consideration of the local environment. Part II: (d) Thresholds for adventitious or unintentional presence of LMOs that may be needed to trigger identification requirements Whether LMOs are present by design or by accident has no bearing on their ability to threaten human health or the environment. Adventitious presence can be a serious problem for New Zealand, as demonstrated by the 2002, 2003 and 2004 investigations into confirmed cases of GM corn/maize in New Zealand, and Japan's reaction to a shipment of bread-dough made with an enzyme from a GMO source. New Zealand should reserve the right to be more cautious when the type of LMO or its use creates special threats to our unique environment. It may be that the current policy of zero tolerance is appropriate for some or all LMOs. Thresholds are quantitative measures of LMO load in a consignment, but are not thresholds that establish safety to human health or the environment. If some thresholds are ultimately adopted, we advocate that they be based on:
We recommend that New Zealand pursue agreement on particular thresholds as minimum standards providing that Parties may choose stricter standards when justified by conditions particular to the health of citizens and preservation of the environment of the importing country. It would be a nonsense under the Protocol to set thresholds for unapproved LMOs. It is in New Zealand's interest to require that exporters ensure consignments are free of unapproved or unidentified LMOs. (e) Review of available LMO sampling and detection techniques, with a view to harmonization Harmonisation of detection techniques is premature given the inability of commonly used methods to detect LMOs with reliability. Priority should instead be given to the development of scientifically robust detection techniques and capacity-building for the implementation of such techniques. It is our understanding that the issues discussed above will be the major issues for decision-making at the second meeting of the Parties to the Protocol. We would welcome the opportunity to comment on the remaining substantive issues-in particular, risk assessment and risk management; socio-economic considerations; and public awareness and participation-on which we have considerable expertise. Yours sincerely, Dr. Joanna Goven
|
||
