Cartagena Protocol on Biosafety - Correspondence with Secretariat of the Convention on Biological Diversity

Submission of the Government of Australia

Submission of views on the preliminary set of indicators for monitoring implementation of the Action Plan

(para 9, recommendation 3/5)

Australia provides the following comments on the preliminary set of indicators for monitoring implementation of the Action Plan, contained in Annex IV to this recommendation.

Performance indicators should be objective and be able to be measured.  The indicators should be restricted to measuring how the Protocol has achieved its environmental objectives as outlined in Article 1 of the Protocol.

1a)  Indicators of results

Australia questions the use of “Better biosafety policies in place”, preferring “Transparent, rigorous science based risk assessment and management procedures in place”.

Indicators of impact

Australia rejects the proposal that fewer incidences of illegal transboundary movements of living modified organisms (LMOs) is a suitable indicator of impact given the current absence of documented illegal transboundary movements of LMOs in international LMO trade.

Australia’s submission on compliance procedures and mechanisms proposes a facilitative, rather than judicial or adversarial approach, designed to assist those Parties which, in spite of best endeavours, are experiencing difficulty in meeting their obligations under the Protocol.

The proposal for an indicator of fewer or no cases of non-compliance prejudges the implementation of the Protocol and assumes that cases of non-compliance will arise.

1b) Indicators of impact

In keeping with comments in relation to 1a), Australia questions the references to motivating exporters to avoid illegal transactions as there is no evidence that there is currently any illegal LMO international trade.

Similarly, the reference to non-compliance presupposes non-compliance. 

1e) Indicators of impact

In keeping with comments in relation to 1a), Australia questions the references to illegal importation of LMOs as there is no evidence that there is currently any illegal LMO international trade.