Para todos que não tem acesso ao fórum on-line do AHTEG, aqui está a contribuição do Mark Benedict para a discussão sobre monitoramento pós-liberação comercial( apud AHTEG/ Convenção de Biodiversidade). O texto proposto pelo AHTEG foi redigido a várias mãos, sob a batuta do David Quist, do Genok, que se opõem (pesquisador e instituto) às plantas transgênicas faz tempo. A íntegra da proposta do AHTEG pode ser encontrada em https://bch.cbd.int/onlineconferences/discussiongroups_ra.shtml).
Na minha primeira leitura da proposta, no fim de agosto deste ano, observei que o texto todo é inconsistente, coalhado de falhas metodológicas e conceituais graves e redigido propositalmente para fazer do monitoramento um trambolho legal que torne a adoção de qualquer planta GM um desafio financeiro intransponível, sem contribuir minimamente à biossegurança. Deixo a todos a tarefa de ler a proposta e avaliar as críticas (leves, em minha opinião) do Mark.
General Surveillance [#2663]
After taking a somewhat brief look at the proposed “Post-release Monitoring and Long-term Effects of LMOs Released into the Environment” draft, I am astounded by its internal logical inconsistencies, expansive recommendations and operational impracticality. (There are numerous annoying typos that I will address at the end.)
The primary logical issue is that of General Surveillance. It tacitly posits an incorrect view of biological systems that assumes some level of temporal stasis, any perturbations of which are indicators of possible harm from LMO release. This presumably requires follow-up in order to determine whether a causal relationship exists between LMO release and change in the indicator. So in contrast to the assertion put forth in the draft that…
“Futher [sic], GS may begin as a hypothesis-free observation where detecting causation between the observed effects of the LMO may lead to testable hypotheses through further investigation.”
…there are clear tacit hypotheses. If these were explicitly developed in this draft and as part of the CSM plan, it would become much clearer what needs to be monitored and why, thus moving all of the GS into a science-based hypothesis driven CSM plan.
As long as the GS has no testable hypotheses, it cannot become what is asserted:
“…an important tool in decisionmaking [sic] with respect to the safeguarding of protection goals from any adverse effects of LMO release, particularly where the threats are considered serious or irreversible, but lack full scientific certainty of their occurance[sic].”
When hypotheses are abandoned, surveillance becomes a temporally and spatially indefinite un-scientific pursuit. While “long-term” is referred to repeatedly in the draft, in no place is any definition give to how long this is nor when it would no longer be required.
This expansive nature particularly impairs the usefulness of monitoring in the context of what the document is attempting to achieve. That is, it will be applied to…
“Parties without elaborated monitoring requirements within their domestic legislation, or little or no monitoring experience.”
The guidelines are being proposed as most helpful for Parties who have little experience or infrastructure, but then a monitoring approach is recommended that is open-ended and (supposedly) not hypothesis driven yet still claims to be science-based!
As a virtual footnote, the draft at least superficially acknowledges this limitation of the GS approach.
“Lastly, long-term effects monitoring may pose a number of practical challenges, e.g. in consistency or availability of test sites or subjects over long periods, and empirical limitations (e.g. establishing a causal relation with any change identified in the monitoring program).”
These are non-trivial issues which must not be dismissed with so few words and would merit a document at least as long as the one submitted! Even in the most developed countries, the likelihood of a GS leading to useful information is highly speculative. Developing countries will find this an insurmountable problem.
As a detail, I am puzzled by the statement that…
“…monitoring itself should not be considered a means for risk mitigation under decisionmaking [sic].”
Would not one’s ability to detect harm be essential to limit it and should be considered in risk mitigation?”
There also is little need to state the obvious:
“Unanticipated effects may be difficult to predict;”
Finally, this draft suffers from even basic editing for grammar and spelling. My apology if a writer who is not a native English speaker wrote it, but even a cursory examination with a spelling/grammar checker would have identified and easily remedied the obvious problems. It is hard to take the substance of a draft seriously when such a minor task as the latter has been neglected. I strongly suggest that in the future, drafts should be more closely vetted before distribution as style issues can compromise a fair consideration of the substance.
Mark Q. Benedict
Univ. Perugia, IT