UNITED STATES COUNCIL
FOR INTERNATIONAL BUSINESS
UNITED
STATES COUNCIL FOR INTERNATIONAL BUSINESS
USCIB POSITION ON FOOD SAFETY AND
BIOTECHNOLOGY ISSUES FOR THE JULY 2000 GROUP OF EIGHT MEETING IN OKINAWA, JAPAN
USCIB DRAFT POSITION
PAPER ON OECD’S RESPONSE TO G8
Heads of State
at the
July
2000
As the Group of Eight (G-8) Summit approaches, will discuss it is clear that the discussions related to food safety issues,
including but not limited to those involving including biotechnology, and issues, as
well as biotechnologyother biotechnology
matters, among them the question of as a separate issue,
and food safety issues will revolve around the issue of whether whether to create a newand how an international body to deal with biotechnology
concerns.is needed to
address these different issues. A
subsidiary issue to thi At s,
which will be raised at the OECD
Ministerialthat will precede the
G-8 Summit, governments will discussis
the appropriaterole of
OECD in food
safety and biotechnology.this discussion. This paper sets forth the views of the The United
States Council for International Business (USCIB)would like to put forward tThis document whichwill
lay lays out the background of the discussion, highlights various
approaches to theon issuethese issues., and makes
recommendations for moving forward at the G8 Summit in Okinawa.
I. EXECUTIVE SUMMARY
The USCIB [undersigned organizations] reiterates
[s] its ss
[their] support of Codex Alimentarius as the preeminent
international food safety standards body, and encourage [s]ncourages the U.S. Government to maintain
Codex as the lead food safety organization.
The U.S. Government should ensure
appropriate funding and outreach on key policy issues within the Codex
Alimentarius.
The USCIB urges [undersigned]
The USCIB [The undersigned
organizations] urge
[s] believe[s]the
U.S. Ggovernmentovernment toshould
oppose the creation of a newnother international internationalbiotechnology bodyforum,on the grounds
that becauseexisting
institutions are adequate toforums already can address the emerging issues surrounding biotechnology issues. If pressed, As a last
resort, the U.S. Government could supporta discussion on
the modalities of and need for an international forum through initiating an ad hoc discussion
undertaken by thethe U.S. National Academy
of Sciences, (NAS)
and its counterparts around the world,as means to facilitate scientific
assessment and information sharing.
As for the future
role of the OECD in the area of biotechnology, , we recognize the considerable
benefit to the international community of theOECD’s longstanding work
in the areas history of regulatory harmonization and development of
common principles. has been of considerable benefit to
the international community. We believe,
however, that tThe OECD not
should not move forward in
the area of food safety,
per
se, butbut rather concentrate
on its
historic strengths:instead in the areas
where the OECD has historically been of most benefit: economic impact analyses, policy reviews, and development of analytics in the area of biotechnology and
environmental
protection. The USCIB
reiterates its support of Codex Alimentarius as the preeminent international
food safety standards body, and encourages the USG to maintain Codex as the lead
food safety organization. The USG
should ensure appropriate funding and outreach on key policy issues within the
Codex Alimentarius.
II. BACKGROUND
At the 1999 Group of Eight
(G-8)
Summit, President Chirac of France proposed that the
G8 should establishment of
a new body to monitor food safety at the international level. This proposal was
resisted by some delegations. What
did come out of this discussion wasAs a compromise, result, the G-8 communique requested
a request to,
“tThe
OECD Working Group on Harmonisation of Regulatory Oversight of Biotechnology
and the OECD Task Force for the Safety of Novel Foods and Feeds to undertake a
study of the implications of biotechnology and other aspects of food safety. We
invite OECD experts to discuss their findings with our personal
representatives. We ask the latter to report to us by the next Summit on
possible ways to improve our approach to these issues through international and
other institutions, taking into account the reflections underway in other fora.”
The OECD OECD sought to meet this
mandate by decided that it would be necessary to expand the its work in order to meet this
request by the addition of organizing a
public hearing hearing and holding session, a scientific conference on
the science of biotechnology and food safety, and by the creationg of an Ad Hoc Working Group on Food
Safety. TheIts
final work product willould
consist be of documents
on environmental implications, health implications, and international
and national approaches to food safety and biotechnology regulation, and a
report on the findings of the scientific conference.
Drafts of tThese materials wereese documents will
behave compiledbeen compiled and
transmitted to the sherpas of the G-8 leaders in May,
2000. The sherpas have
been charged with assessing the information and providing recommendations. to the leaders. Based on these current drafts, of the reports, it seems that
that
two broad issues willthe following broad issues will
be raised:
1) Is there a need to create an international body toforum to review
the science of biotechnology, and/or food safety? focus on the
safety of biotechnology?
1) What gaps exist in both our scientific
understanding of biotechnology safety, and the systems we have in place to
assess and ensure safety, and how can they be filled?
2)
What is the role of
the OECD in the future discussions work on
biotechnology and food safety?.
III. Creation of an International Forum
The OECD’s work in response to the
G8 request has concentrated on been to capturinge and
summarizinge current knowledge,. It has not but not analyzed or madke has been clear from the start of their work
that the objective was to capture current knowledge, not make recommendations
about science or policy. However, While the reports of each of the OECD groups have
been true to this position ,position, with few
recommendations if any, the summary prepared by the Chair (Sir John Kreb’s), Chairman of
the scientific conference that was hosted by the U.K. Government Government and held in
Edinburgh in March 2000, made a specific
recommendedation that :
,
“…I therefore recommend that an international forum be set up to
continue the process started in Edinburgh. The aim of such a forum would be to
provide governments with a state of the art assessment of scientific knowledge
about GM technology, and to set this assessment in the context of broader
concerns of society.
A model for such a global assessment is
the IPCC (Intergovernmental Panel on Climate Change). This Panel allows
governments to draw on worldwide expertise in climate science. It informs but
does not make policy and it acknowledges the minority scientific views as well
as the current majority view. It also updates its reports at intervals.”
It
is important to note that theThe concept of an IPCC-like forumbody
on
biotechnology was raised only in Sir John’s Krebs'
introductory and closing remarks at the conference, and was
most fully elaborated at a press briefing immediately following the conference
and inthe Chairman’s
Sir Krebs’final report. As there was no full Such a debate iscussion on this proposal did not take place during the conference itself, and thus
we believe it needs
substantially substantially more discussion is required on
of whether
and how such a body is necessary
and how it would function, especially in light of the plethora
of existing
bodies
available for ongoing information-sharing and discussion opportunities
(e.g., within existing
structures at OECD or ,
CODEX). Sir Krebs’ proposal
should not be interpreted as the possible creation of an OECD body, but more as
a proposed international forum without the trappings of an institution. The OECD as an institution is not perceived as
a globally representative forum, particularly from the perspective of
developing countries and their ability to participate in OECD activities.
on
biotechnology was raised only in Sir John Krebs' introductory and closing
remarks at the conference. It was most fully elaborated at a press briefing
immediately following the conference and in his final report. Such a discussion did not take place during
the conference, and thus we believe it needs substantially more discussion of
whether and how such a body would function, especially in light of the plethora
of ongoing information-sharing and discussion opportunities (e.g., within
existing structures at OECD, CODEX, etc…).
The
IPCC is but one model on which to base future discussions about biotechnology
safety, recognizing that a clear discussion regarding purpose, goals, and
composition (among other considerations) must take place in a transparent and
open manner. The IPCC was established
to provide focused science-based input to the debate over a single
environmental impact. The elements of a proposal for a similar body as seen
now, would use the same approach to provide input to a very broad array of
subjects with only one common element: the use of gene technology. Also, given
the time foreseen to actually negotiate the terms of reference of such a new body,
there is a strong argument that it would be more timely and effective to
intensify the activities of existing international bodies instead.
Despite Sir JohnKrebs’s significant
efforts to raise the profile of this option, It
is clear that a compelling argument has yet to be made devised that will justifythat justifies
creation
of a new structure.the needthe need for such an
undertaking. The OECD
report of the Ad Hoc Food Safety Group addresses eight areas of “continuing development.” Thate report clearly and specifically outlines
demonstrates
that each of these areas of ‘continuing
development’ arealready can beable
to be handled in addressed
within the context of pre-existing international bodies.forums.
For example, Thus, Codex
AlimentariusCodex isis already addressing
concerns over the lack of internationally appropriate level of protection,
regulation of modern biotech within the international food system, and to some
extent the concept of precaution in food safety mechanisms. Codex also is also working on addressing socio-economic concerns, as
are both thewell
as U.N. Food and Agriculture Office (FAO), and the World Health Organization
(WHO). WHO , iswhich is addressingdeals with foodborne illnesses and capacity
building in the area of food safety.
Finally, the OECD is examining international seed trade measures and
certification standards, and has the potential experience and
ability to address the myriad of
economic impacts of the various policy proposals. in the many forums. In short, Thus,
from an international regulatory perspective, virtually all of the requiredsignificant workwork is already being carried
out or
can be
accomplished in established by preexisting there
is little work that cannot already be accomplished by preexisting forums and bodies.
Notwithstanding this conclusion, While
Although the USCIB does
nottherefore believes that such a
forum is wholly unn
necessary, we believe that
therethere could be may be significant pressure on at the G-8 governments meeting to go forward
with a proposal to create a new institution.n unnecessary
additional forum. In this case, the U.S. should
consider supporting Should
discussions move forward, it would be useful to an alternative
use a third model, which would
meet of discussion, meeting the following criteria
(among others):
·
A pre-existing
forum that is focused on the scientific issues related to
biotechnology, including human health, environment and safety, etc.
·
An experts forum that is
decoupled from national and/or regional governments
·
A forum that is
designed to augment, not supplant or supplement, existing multilateral
discussions.
It should be
possible to find a way Existing
bodies (such as the U.S. National Academies of Science) are designed to facilitate ad hoc scientific discussions and conclusions, without the need to create a new institutions. For
example, a process involving
theinvolving the U.S. National
Academies of Science (NAS) and other one of the NAS-like bodies around the worldies
could bringpull together representatives
fromother
academies on specific issues, . This allowsingqualified scientists to
discuss in a scientific forum the full range of biotechnology science issues. Anotherbenefit of this
approach is that the infrastructure already exists.
Such a Although this may be
an interesting option, this proposal
should be regarded as is a
‘last resort’ option. It should not
take the place of a position, which is
supported by the work undertaken by the OECD, that the existing mechanisms are adequate
to can and should address the issues of biotechnology.
In closingsum:
,
the USCIB would suggest that:
·
There is no
no
demonstrated need to create an additional organization(s); rather, efforts
should be made to increase the effectiveness of existing mechanisms based upon
specific and achievable goals.
·
An additional
study is not a substitute for timely decision making.
·
If, however, the
discussions on the creation of a forum move forward, significantly, the U.S.G
should focus the discussion upon the criteria of such a forum, with the
fallback position of using the NAS to facilitate scientific discussion. Should
the IPCC model gain support
IVII. IV. Increased discussion on the issues that lay
at the intersection between food safety and environmental protectionThe Role of the
OECD in Future Biotechnology Work
The OECD’s report clearly highlights that Codex
Alimentarius has done an adequate job of addressing global food safety
standards. It also recognizes the
current programs that are in place among many governments, and the work that
has been done in the past by OECD.
However, given the role of Codex, should further work need to be
undertaken on food safety, especially in specific areas (e.g., microbial contamination), Codex would be the
most appropriate forum for such discussions.
It was also clear in theis evident from
the OECD report, (as well as from in discussion papers presented in
advance of the Codex General Principles meeting),,that there is some confusion
internationally as to the role of environmental protection vis-à-vis food
safety. While Although some
view these as two integrated functions, others see them as separate activities
that inform each other. This wasdifference was
particularly evidenthighlighted in the discussion papers for
of Other Legitimate Factors at the Codex Committee on General Principles
(CCGP) meeting in April, and . Iit was also
apparent raised specifically in
the document
submitted to the G-8 from the Working Group for Harmonization of
Regulatory Oversight in Biotechnology document
submitted to the G8. For
products of biotechnology, theThe OECD historically has historically addressed
the issues of environmental protection concerning the products of biotechnology as they are dealt with in
the , as well as reaching into the linkages
between environmental protection and food safety.
Further, the Ad Hoc Group’s international
regulatory systems report noted the need for economic impact analyses of the many policyvarious policy recommendations now emanating fromwhich are being offered in various bodies. fora. The OECD has a role to play in this
regard.specifically in this sort of economic analysis. For
example:
The USCIB suggests the following approaches to fill
these gaps:
·
It
may be of use to expand the OECD’s role on such issues from only biotechnology
food products, to a more general discussion of the key issues that meet in the
intersection of food safety and environmental protection.
·
TIt may alsomight be of use to
expand the OECD’s role in could economicundertake
economic assessment of possible policy options and recently agreed-to
documents
in such areas as the following:, i., e.g.e.
economic impact of mandatory labeling, relative to its value for informing the
public,; economic impact of Biosafety Protocol
implementation;,
economic impact of food safety programs; , opportunity
costs of not using biotechnology in agriculture, etc.
·
The OECD
should expand its current workcurrentthat
includes some
analytical work and policy work in the areaof environmental
risk assessment.
·
The OECD
should increase its coordination with Codex Alimentarius, especially in the
area of substantial equivalence..
·
The OECD
biotechnology activities should become be reorganized
and bettermore coordinated.
