Conclusions of the conference "The role of precaution in GMO policy"
This was the first conference deliberately dealing with the role and the application of the precautionary principle in GMO-policy. It has been initiated by the Federal Ministry of Agriculture, Forestry, Environment and Water Management and the Federal Ministry of Health and Women. Responsible for the organization was the Umweltbundesamt (Austrian Environment Protection Agency).
Helmut Gaugitsch as rapporteur of this conference has drawn up first conclusions and recommendations coming up from the conference and the main content is as follows (the original text was available on the conference-website): "The discussion showed that there is broad consensus around the recognition of the Precautionary Principle (PP) as one of the fundamental aspects that define the European approach to GMO legislation. The PP was described as a tool that allows countries to adopt the level of protection that was felt necessary, even in the absence of scientific certainty. Although the PP is enshrined in Rio Principle 15, in the EU in the various areas (such as the Commission Communication on the PP, Directive 2001/18, EU-Regulation 178/2002), as well as in the Cartagena Protocol etc. it remains questionable whether there is a common understanding of the PP and the way it can or should be implemented. What is the PP more than Common Sense of the application of "Better safe than sorry"?
Recommendation 1: Continue to discuss, exchange views on the concept of the PP in the GMO area (but in general as well) at the national, EU and international level (WTO, SPS; Codex Alimentarius among others). Ways from the PP to an applicable approach and/or action should be included in these discussions. This Conference is a good starting point for such a follow-up. There are different perceptions of the scientific considerations of the precautionary principle: How is it related to risk assessment? Is the PP only a risk management issue? How to deal with the different levels of uncertainty and/or ignorance (lack of knowledge/data, different interpretation of data, regional ecological characteristics, different interpretation of harm etc.)? Every risk analysis system which claims scientific and public credibility needs to be clear on these issues and has to face the opportunities but also the limits of current scientific knowledge. In that context also the EU system, including the institutions at member state but also at Community level, such as EFSA, have faced some criticism concerning their approach to GMO risk assessment. A basis for a credible system is an improved, harmonized and standardized, i.e. an accountable system of risk assessment and a common understanding of the PP within the risk assessment framework. It was also mentioned that the widest possible sources of scientific publications and data should be taken into account. On the other hand it is not clear when a satisfying level of certainty is reached by additional scientific results. The question is, when do we have enough data to take decisions? It became clear that risk assessment is an important prerequisite for decision making but not sufficient in itself because it is inadequate to adress the issue of uncertainty, by defintion cannot assess ignorance and also falls short of acknowledging benefits.
Recommendation 2: Start discussing the various concepts and definitions related to the PP nationally (e.g. within the Scientific Committees) but also EU wide (i.e. within EFSA and the GMO Panel) with the aim of a more common understanding. Elaborate mechanisms on how to explicitly include statements on the application of the PP in the area of GMO product notifications, such as referring to the level of uncertainty concerning the data basis in notifications.
Recommendation 3: Continue to improve, harmonize and standardize the risk assessment instruments, nationally and EU wide. This should include clear guidance on which kind of data should be included in notifications and the methodology to generate them. The systems should be based on the highest standards of scientific expertise, involving the necessary different scientific disciplines especially from the ecological side. Solid scientific data based on relevant and robust testing should be the standard rather than assumption-based reasoning. A balance between clear guidance and the necessary case-by-case flexibility should be kept. Different opinions on the PP were raised in the course of the Conference, partly in connection with trade restrictions or protectionism, partly as an instrument which is forward looking and can contribute to scientific innovation. Independence of the scientific community, diversity of scientific opinions can contribute a lot to make progress in GMO risk assessment, which in turn can lead to progress in other areas, such as agriculture in general, biodiversity research etc.
Recommendation 4: The PP should contribute to protection and not protectionism. Make use of the PP as possible instrument of scientific innovation, in order to gain further scientific knowledge in the GMO area, addressing questions of uncertainty and ignorance. National and EU wide research projects could take such approaches more into account than they probably did so far. The PP has implications in the area of natural sciences but also in social sciences. The broader context of decision – making was mentioned during the Conference, such as taking into account socio-economic implications, the choice of possible alternativ approaches as well as involving the public in decision making. Stakeholder involvement from all parties concerned (notifiers, farmers, environmental organizations, consumers, general public) may be a good tool to broaden the view and make sure that wider impacts are taken into account in political decision making. Clearer evaluation of different views and transparency how certain conclusions were reached may lead to a situation where a proper balance is achieved with respect to precautionary decision making which is at the same time proportional in its effect.
Recommendation 5: Enter into a dialogue with stakeholders at the national level, at the EU level and between these levels. National Scientific Committees and EFSA may have an important role to play here. Risk communication should be improved and a system for public participation needs to be set up and supported. Finally the necessary evolution of the European regulatory system was pointed out and reference was made to the number of policy debates going on. Nobody voiced explicitly the need for a general amendment of the existing EU legislative framework, but many interventions pointed to a need of finetuning and redefining the modalities of its application. An adapted system should provide the broad scientific basis for decision making and achieve a higher degree of transparency and thus fulfill the expectations of the general public." Additionally it has to be stated that also the issue of introducing an efficient liability regime for damage caused by GMOs and the question of insurability of such damages were addressed in this conference.
"The role of precaution in GMO policy", 18 - 19 April 2006