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VII. Regulatory Issues

18. In this session participants continued their discussions on monitoring and the pros and cons of incorporating a short-term monitoring strategy, with a minimum set of criteria, in GM crop regulatory systems. They also discussed pre-release/regulatory issues vs. post-release monitoring. Several experts strongly felt the need to build ecological concepts into regulatory processes. They emphasised that such an initiative would help in gathering the much needed field data from the registrants including all stakeholders and industry partners. They felt that even short-term data from large scale GM crop fields when collected from various geographic locations would be very useful in understanding the scale and effect of GM crops on the environment. It was important that all monitoring data was publicly available for further research and assessments. Post-planting monitoring needed partnerships and incentives which had to be built in, for farmers and stakeholders. The concepts of shared responsibility for monitoring by registrants or using independent crop consultants, as practiced in the USA were mentioned.

19. Some experts pointed out the difficulty of including ecological and long-term evaluation in a regulatory system, which by nature has defined targets and deliveries. They were of the view that an over-emphasis on setting up a monitoring system could make the release of GM crops even more stringent and thereby, defeat the purpose. While GM crops could be monitored for expected effects, one may have to monitor non-GM varieties, general farm practices and the specific agro-ecosystem for the unexpected effects; which would be a very difficult task. It is possible that registrants had some post-release responsibility, but a comprehensive ecosystem monitoring responsibility would be unfeasible. Therefore, a more practical approach had to be explored. The associated legal and related financial issues also merit more attention. The experts felt that although monitoring would be useful, all the issues surrounding it needed further clarification. The experts suggested that FAO consider holding a Consultation solely on monitoring to take the ideas forward.


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