Comments on the draft ‘guidance on risk assessment of living modified organisms’ from the Convention on Biodiversity

Advisory reports | 11.03.2011 | CGM/110311-03

Recently a draft guidance document entitled “guidance on the risk assessment of living modified organisms (LMOs) was published. This draft guidance document was written by an Ad Hoc Technical Expert Group (AHTEG) on risk assessment and risk management under the ‘Cartagena Protocol’. The guidance document is being developed to be used as a reference for risk assessors when conducting or reviewing risk assessments and for use in risk assessment and risk management training programs (capacity-building activities).
The published guidance consists of two parts: a general ‘roadmap for risk assessment of LMOs’ and three more specific guidance documents on ‘LMOs with stacked genes or traits’, ‘living modified crops with tolerance to abiotic stress’ and ‘living modified mosquitoes’.

The guidance document describes the risk assessment process of LMOs in general terms and follows the generally accepted risk assessment methodology. The roadmap is meant to give guidance on the risk assessment process for all types of LMOs. In COGEMs view this aim is not met. The terminology that is used focuses too much on LM crops and not all aspects that are relevant in the risk assessment of other types of LMOs are included. Therefore the use of the roadmap for other LMOs, such as viruses and bacteria, is limited. COGEM suggests to develop more guidance documents for different types of living modified organisms (fish, insects, viruses, bacteria).
COGEM is of the opinion that the inclusion of clarifying examples would enhance the usefulness of the guidance. In addition, the guidance should indicate when information is necessary for the risk assessment and when this information is not needed.

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