Case study on soybean imports in Vietnam – Low Level Presence of Genetically Modified Crops

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Based on our presentation on behalf of IFPRI at the UN Food and Agriculture Organization (FAO) Technical Conference on the Low Levels of Genetically Modified Crops in International Food and Feed Trade held March 20-21, 2014 in Rome, Italy and based on responses from different stakeholders, we felt necessary to share not only the presentation but also our comments to the slides and additional information about the presentation.

Slide10

Let me examine a specific example done by Gruere in 2011 for the case of Vietnam. This is an example of a country with some interesting regulatory developments and options for further review. Gruere considered different tolerance levels, probability of rejection, cost of compliance and other sensible assumptions to measure the impact on economic welfare as defined previously in my talk.

Blue column represents a 0% tolerance level, maroon a 1% and green a 5%. Gruere in his paper considered other tolerance levels and assumptions in the model.In average, across different simulations and assumptions, a 0% tolerance level costs Vietnam 18 million US$, a 1% 4.1 million and 5% 0.5 million US$.

From the standpoint of a regulator/decision maker relevant questions could be:

  • Whether maintaining a 0% tolerance, costing $14 million more that a 1% level still realistic ?
  • Is the 0% level worth roughly 17+ million US$ more than the 5% level for the country?

Important to underscore that the product has been approved in one or more countries, and this may be an issue of confidence and/or information availability about the product in question and it is a trade issue.

Reference

Gruere, G. 2011. Asynchronous Approvals of GM Products and the Codex Annex: What Low Level Presence Policy for Vietnam?. International Food and Agricultural Trade Council Discussion Paper.

Limitations to studies on the impact of LLP – Low Level Presence of Genetically Modified Crops

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Based on our presentation on behalf of IFPRI at the UN Food and Agriculture Organization (FAO) Technical Conference on the Low Levels of Genetically Modified Crops in International Food and Feed Trade held March 20-21, 2014 in Rome, Italy and based on responses from different stakeholders, we felt necessary to share not only the presentation but also our comments to the slides and additional information about the presentation.

Slide9As I have started explaining earlier, studies conducted on the impact of LLP policies deal with a quite complex issue that requires extensive data for impacts. This task is complicated by data issues, in particular having reliable data on prices, trade volumes, shares and of testing costs is a limiting factor.

Research done in this area tends to use relatively -and at the same time deceptively- simple models and use multiple assumptions about data and model structure. This is born out of necessity as the need exists not only to identify the potential outcome, but also to define how relevant variables may influence the impact outcome. Extensive sensitivity analysis are routinely conducted to examine the potential variability in outcomes and how sensitive results are to assumptions.

LLPs and Key decision parameters and qualitative implications – Low Level Presence of Genetically Modified Crops

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Based on our presentation on behalf of IFPRI at the UN Food and Agriculture Organization (FAO) Technical Conference on the Low Levels of Genetically Modified Crops in International Food and Feed Trade held March 20-21, 2014 in Rome, Italy and based on responses from different stakeholders, we felt necessary to share not only the presentation but also our comments to the slides and additional information about the presentation.

Slide8

Our research and that conducted by others, has identified three issues of particular interest for the design of policy options. These include the tolerance level, approval delays and confidence on regulations particularly exporter regulations. As I have indicated previously, these are not the only issues that have an impact on economic welfare, these are the ones our research has identified as critical.

We can examine the likely qualitative impact of key decision parameters on economic welfare. For example, an increase in the tolerance level decreases costs whereas approval delays tend to increase costs of implementation.

In most cases, the best outcomes tend to occur with high confidence on regulations and with low delays. Yet, determining a tolerance level depends on the tradeoffs involved between costs of implementation and relative risks. Asking the questions in terms of tradeoff can help competent authorities pursue realistic and/or implementable policy options.

 

Relevant issues for choosing LLP policy options – Low Level Presence of Genetically Modified Crops

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Based on our presentation on behalf of IFPRI at the UN Food and Agriculture Organization (FAO) Technical Conference on the Low Levels of Genetically Modified Crops in International Food and Feed Trade held March 20-21, 2014 in Rome, Italy and based on responses from different stakeholders, we felt necessary to share not only the presentation but also our comments to the slides and additional information about the presentation.

 

Slide7

These three variables in turn can be determined in turn by different issues. For example the impact of price on economic welfare may be affected by the probability of rejection and the timing of approvals. In turn, risk may be affected by the trust in exporter regulations and the type of product. Cost of compliance can be affected by the tolerance level and the enforcement capacity.

Note that these issues may have different impacts of economic welfare in different countries.

LLP Policy Options – Low Level Presence of Genetically Modified Crops

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Based on our presentation on behalf of IFPRI at the UN Food and Agriculture Organization (FAO) Technical Conference on the Low Levels of Genetically Modified Crops in International Food and Feed Trade held March 20-21, 2014 in Rome, Italy and based on responses from different stakeholders, we felt necessary to share not only the presentation but also our comments to the slides and additional information about the presentation.

 

Slide6

To move forward one has to examine different policy options, their consequences and the variables that affect different policy outcomes. In our work while examining the impact of LLPs and other regulatory issues, we have focused our analysis measurements of the impact of polity options on economic welfare. Defined in most cases in terms of prices, quantities demanded/supplied/traded and the distribution of gains/losses amongst market players.

As we will see later, we have used a fairly standard economic focus, in part due to lack of data for key issues and have used relatively –yet deceptively – simple economic models. Notwithstanding these issues and limitations, this work has explored different methods and research validation approaches to ensure data robustness.

In the specific case of LLPs we have identified three distinct issues that can be relevant to identifying polity options. These are not the only issues that may be considered, these are the ones we have identified as more relevant.

These are the potential risk and price of the product and the cost of enforcing the regulation.

My presentation at Georegtown University on biotechnology and developing countries

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This is my presentation at Georgetown University today March 31, 2014 on B”Biotechnology and Developing Countries”.

Guest Post: The Union of Concerned Trolls

Really interesting blog entry in Random Rationality on the usefulness of GM biotechnologies…or better yet, the arguments some groups are making on the alleged trouble that these techniques may have…

Random Rationality

On March 27th, the MIT Technology Review—an otherwise great resource on science and technology—published a bizarre diatribe on GMOs: Are GMOs Worth the Trouble by Doug Gurian-Sherman. I encourage you to read it before coming to the meat of this post. I call it bizarre for the many non-sequiturs, misrepresentations, and statements so easily falsifiable that one wonders how it got past the editors; yet it did. As I was considering writing a response to it, Mary Mangan and I exchanged a few puzzled tweets, and I decided the response would be far better received from an actual scientist such as she is, instead of from a two-bit nitwit like myself.

She graciously agreed to my proposal for a reply to the article to be posted here. You’ll find her insightful rebuttal below.


The Union of Concerned Trolls

If you have spent any time around the series of tubes in the last decade, you will have…

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GM trade and LLPs and asynchronous approvals – Low Level Presence of Genetically Modified Crops

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Based on our presentation on behalf of IFPRI at the UN Food and Agriculture Organization (FAO) Technical Conference on the Low Levels of Genetically Modified Crops in International Food and Feed Trade held March 20-21, 2014 in Rome, Italy and based on responses from different stakeholders, we felt necessary to share not only the presentation but also our comments to the slides and additional information about the presentation.

 

 

Slide5

LLPs are becoming an important issue due to increases in market shares and the volume of trade of GM commodities. To this state of nature we can add an increasing pipeline of new GM crops and events – including for example stacked products- the lack of policies and even definitions which has lead in some cases to a slow down of import regulations development. Some countries, have implemented a 0% tolerance for imports of unapproved products, which may not be realistic.

I believe then that it is prudent to focus on implementation issues. The fact that the Codex Annex included a simplified procedure for dealing with LLPs, is a signal from multiple countries and stakeholders, of the need to move forward.

Sources of LLPs – Low Level Presence of Genetically Modified Crops

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Based on our presentation on behalf of IFPRI at the UN Food and Agriculture Organization (FAO) Technical Conference on the Low Levels of Genetically Modified Crops in International Food and Feed Trade held March 20-21, 2014 in Rome, Italy and based on responses from different stakeholders, we felt necessary to share not only the presentation but also our comments to the slides and additional information about the presentation.

 

 

Slide4

I will focus my conversation on one source of Low Level Presence (LLPs) and that is asynchronous approvals where at least one cultivating country authorizes a GM crop while other countries have not approved for importation. This source of LLPs has time and geographic dimensions.

I will not focus much on asymmetry. Asymmetric approvals are related to developers’ regulatory strategies and the regulatory/policy environment in the countries where a GM crop may be potentially released.

We need to clearly separate Low Level Presence (LLP) from Adventitious Presence (AP). AP occurs when traces of a low level of unintended material appear in seed, grain, or feed and food products, where the unintended material has not been approved anywhere for commercial release. Adventitious Presence is a failure of the biosafety management processes. It does not necessarily mean that it is an objective safety concern, the issue may be that the regulatory system does not have sufficient knowledge to make a determination about the safety of the product. Adventitious Presence need to be minimized or eliminated in all situations.

Certainly, these concepts are not rigid and may change over time.

FAO’s Working Definitions on LLPs and GM – Low Level Presence of Genetically Modified Crops

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Based on our presentation on behalf of IFPRI at the UN Food and Agriculture Organization (FAO) Technical Conference on the Low Levels of Genetically Modified Crops in International Food and Feed Trade held March 20-21, 2014 in Rome, Italy and based on responses from different stakeholders, we felt necessary to share not only the presentation but also our comments to the slides and additional information about the presentation.

 

Slide3

Here we introduce FAO’s working definitions as defined in a FAO draft report “Low levels of GM crops in food and feed: Regulatory issues” which will be published later. The report itself is based on a paper conducted by international consultants to FAO.