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NATIONAL BIOSAFETY POLICY OF TRINIDAD AND TOBAGO Updated June 2016

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Table of Contents Executive Summary ............................................................................................................. i 1 2 INTRODUCTION ...................................................................................................... 1 SETTING THE CONTEXT ....................................................................................... 3 2.1 2.2 2.3 2.4 2.5 Biotechnology, Innovation and Biosafety ............................................................ 3 International Perspectives .................................................................................... 3 International Trade and Implications for Biosafety ............................................. 5 Regional Perspectives .......................................................................................... 6 National Perspectives ........................................................................................... 7 Agriculture .................................................................................................... 7 Food and Health ............................................................................................ 7 Environment .................................................................................................. 8 Research Agenda .......................................................................................... 9 Public Perception and Opinions .................................................................... 9 2.5.1 2.5.2 2.5.3 2.5.4 2.5.5 2.6 2.7 3 Labelling............................................................................................................. 10 Regulatory Systems and Legislative Framework ............................................... 11 POLICY - SCOPE, OBJECTIVES AND GUIDING PRINCIPLES........................ 13 3.1 3.2 3.3 Scope of the Policy ............................................................................................. 13 Policy Objectives................................................................................................ 13 Guiding Principles .............................................................................................. 13 4 THE NATIONAL BIOSAFETY SYSTEM ............................................................. 16 4.1 Institutional Framework .......................................................................................... 17 4.1.1 4.1.2 4.1.3 4.2 The National Biosafety Co-ordinating Unit (NBCU) ................................. 17 Institutional Biosafety Committees (IBCs) ................................................. 18 Regulatory Agencies ................................................................................... 19 Administrative System ....................................................................................... 20 Applicants and the Application Process ..................................................... 21 Decision-Making Process and Procedures .................................................. 21 Procedures for Transboundary Movement of LMOs and LMOFFPs ......... 23 4.2.1 4.2.2 4.2.3

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4.2.4 4.2.5 4.2.6 4.2.7 4.2.8 4.2.9 4.2.10 Procedures for Conducting Research Involving LMOs .............................. 25 Procedures for Compliance Monitoring and Oversight .............................. 27 Administrative Costs of Decision-Making and Compliance Monitoring ... 27 Liability and Redress .................................................................................. 27 Contingencies .............................................................................................. 28 Management of Proprietary and Confidential Information ........................ 28 Public Awareness and Public Education..................................................... 29 4.2.11 Non-Compliance and Penalties ................................................................. 29 4.2.12 Appeal Process........................................................................................... 29 4.3 4.4 Legislative Framework ..................................................................................... 29 Plan for the promotion and facilitation of public awareness, education and information access ....................................................................................................... 30 4.5 5 National Biosafety Capacity- Building Plan ...................................................... 30 Appendix ................................................................................................................... 31 Figure of the regulatory and administration system proposed for Biosafety in Trinidad and Tobago ……………………………………………………………. 31 List of acronyms………………………………………………………………….. 32 Glossary of terms………………………………………………………………… 34

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Executive Summary Biosafety refers to the policies and procedures adopted to ensure that products of modern biotechnology do not negatively affect plant, animal or human health; genetic resources; or the environment. Biosafety became a consumer protection issue with the placing of commercial products of modern biotechnology such as genetically modified organisms (GMOs) or products derived from them, for example, soybean and corn, into the environment and the food chain in the mid 1990s. The National Biosafety Policy of Trinidad and Tobago (“the Policy”) was developed within the context of international agreements such as the Cartagena Protocol on Biosafety (CPB) under the Convention of Biological Diversity, (CBD), Codex Alimentarius Commission of the Food and Agriculture Organisation/World Health Organisation (FAO/WHO), the Sanitary and Phytosanitary (SPS), Technical Barriers to Trade (TBT), and Trade-Related Aspects of Intellectual Property Rights (TRIPS) agreements of the World Trade Organisation and the United Nations Convention on Human Rights (UNCHR). It is also in accord with the requirements for implementation of the CARICOM Single Market and Economy (CSME) as well as national policies on agriculture, human and animal health, food safety, and the environment. The Policy articulates a national approach to biosafety that integrates political, social, ethical, health, economic, and environmental policies and considerations into decisions regarding the safe and appropriate use of modern biotechnology and its products. It is balanced, transparent and participatory and promotes the precautionary approach to decision-making. Trinidad and Tobago has identified modern biotechnology as an important technology option to address issues such as food security, agricultural sector development, bioresource development, and environmental protection. The Policy‟s overall objectives are to guide the: (i) Development of an appropriate and transparent administrative, regulatory and legislative framework to govern the safe development and use of products of modern biotechnology, including Living Modified Organisms (LMOs) and LMOs intended for use in food, feed and processing (LMO-FFPs); Establishment and maintenance of appropriate mechanisms and strategies to assess and manage risk to ensure the protection of plant, animal or human health; genetic resources; or the environment; (ii) (iii) Development of an appropriate system for the labelling of products resulting from modern biotechnology in keeping with national consumer opinions and regional and international trade obligations; i

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(iv) Promotion and facilitation of public awareness, public education and access to relevant information related to the development and use of modern biotechnology as well as systems for participatory decision making; and (v) Development of a national biosafety capacity-building plan to effectively implement the Policy. The Policy is based on the following principles: i. Balanced approach to biosafety - The Policy advocates a balanced approach so that procedures for biosafety do not unduly restrict biotechnology development and trade, which are important for achieving sustainable developmental goals. Decision-making process based on cost-benefit analysis - Acknowledging the importance of biotechnology as a developmental tool, Trinidad and Tobago will use scientific risk analysis and socio-economic analysis for decision-making. Where scientific uncertainty exists the precautionary approach to decision making will be used. ‘Precautionary’ and ‘substantial equivalence’ approaches to scientific risk analysis - Recognising its commitments to the CPB, WTO (SPS and TBT Agreements) and Codex Alimentarius Commission, Trinidad and Tobago will use the precautionary approach for environmental safety assessments and substantial equivalence for food safety assessments, which are enshrined in the national environmental and health policies respectively. Case-by-case approach - Decision-making will be based on risk analysis of the individual biotechnological applications, rather than a general approach. Stage-by-stage approach - Decision-making will be based on risk analysis at the different stages of application of biotechnology (i.e. contained use, greenhouse, limited field release and commercial release). Flexibility in decision-making - Recognising that decisions are based on current, scientific information, the decision-making process will be flexible, to take into account advances in scientific knowledge. Decisions also have to be pragmatic to enable easy implementation. Participatory approach to decision-making - Recognising the wide-ranging implications of the Policy on various sectors, it provides for a mechanism to incorporate sectoral interests in the decision-making process. Transparency in decision-making - The decision-making process will provide opportunities for public participation and the results of such decisions will be made available in a timely and accessible manner. The Policy supports a public ii ii. iii. iv. v. vi. vii. viii.

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education and awareness campaign that seeks to inform the public of new developments on a timely basis. ix. Cognisance of intellectual property rights - The Policy will recognise the confidentiality of information contained in the applications. In addition, biosafety clearance granted by relevant authorities should not be construed as permission to import, stockpile, and market, as these rights may belong to industrial property owners. Pragmatic approach to labelling - Given our trading relationships, the Policy also outlines a pragmatic approach to food labelling, which is pro-choice, fair and at the same time intended to have minimal effect on food prices. Regional harmonisation - The Policy facilitates the regional harmonisation of biosafety standards and procedures, joint capacity-building efforts, public education efforts, labelling and risk analysis efforts to ensure smooth implementation of the CSME. Human rights-based approach - The Policy supports a human rights-based approach as enshrined in the „Rights-Based Approach‟ of the United Nations, recognising that human rights and development are not distinct. x. xi. xii. The Policy proposes a system, which consists of the following components: (i) An institutional framework, which includes: The National Biosafety Co-ordinating Unit (NBCU), which comprises the National Biosafety Secretariat (NBS) and Committee (NBC), is the legal authority for decisions relating to the safe transfer, handling and use of LMOs resulting from modern biotechnology, and products derived from them, that may have adverse effects on plant, animal or human health, genetic resources or the environment. Institutional Biosafety Committees (IBCs), which will be responsible for keeping an accurate and up-to-date record of biotechnology activities in institutions, ensuring that these activities comply with the guidelines provided by the NBCU, and submitting applications to the NBCU for confined or unconfined release of products of modern biotechnology including LMOs into the environment. Supporting regulatory agencies, including those responsible for environmental management; import and quarantine of living organisms; the import of food and drugs; customs and excise and the Tobago House of Assembly (THA). (ii)     An administrative system which includes procedures and guidelines for: Decision-making, including scientific risk analysis (risk assessment, management and communication), socio-economic evaluation and public participation; iii

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       Regulatory mechanisms such as permits, notifications and guidelines/oversight; Transboundary movement of LMOs and LMO-FFPs, contained LMO research at various biosafety levels, confined greenhouse or field research, deregulated status and export of LMOs; Compliance monitoring and oversight; Liability and redress, mitigation of risks, and managing intellectual property and confidential information; Public participation and transparency; Penalties; and Appeal processes. (iii) A legislative framework that will provide the legal authority to the relevant institutions and regulatory agencies, and harmonisation with existing legislation. (iv) A plan for the promotion and facilitation of public awareness, education and information access (v) A National Biosafety Capacity-Building Plan. The Government also recognises that in order to effectively implement the Policy, human resources and institutional capacity will have to be strengthened especially in the areas of risk analysis, public awareness, IT and communication technology, laboratory facilities for LMO testing, law enforcement and compliance monitoring. The Policy underscores the importance of the development of the national biosafety framework with appropriate legislation and regulations to enforce it, and stresses the need for capacity-building as an imperative for the effective implementation of regulations. iv

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1 INTRODUCTION Consumer protection is a core component of the national objective of the Government of the Republic of Trinidad and Tobago (“the Government”) to improve the quality of life for all citizens. Biosafety became a consumer protection issue with the placing of commercial products of modern biotechnology1 (e.g. genetically modified organisms (GMOs)2 or products derived from them) into the environment and into the food chain in the mid 1990s. Biosafety refers to the policies and procedures adopted to ensure that GMOs and products made from them do not negatively affect plant, animal or human health, genetic resources or the environment. Establishing credible and effective safeguards for GMOs is critical for maximising the benefits of biotechnology while minimising risks. Acknowledging biosafety as an important consumer protection issue, the Government established in August 2000 a Cabinet-Appointed Committee, chaired by the Ministry of Legal Affairs, to develop a National Policy and Regulations on Biosafety. Recognising the wide-ranging implications of such a policy on public health and safety, environmental management, international relations, trade, intellectual property rights and the innovation climate, the Committee was constituted with a wider representation involving various Government ministries, national and regional research and development institutions and civil society. The National Biosafety Policy of Trinidad and Tobago (“the Policy”) articulates a national approach to biosafety and integrates political, social, ethical, health, economic, and environmental policies and considerations of the Government into decisions regarding the safe and appropriate use of modern biotechnology and its products. The Policy was developed within the context of international agreements to which Trinidad and Tobago is a signatory, and is in harmony with the requirements for implementation of the CARICOM Single Market and Economy (CSME). The most important international protocol addressing biosafety issues is the Cartagena Protocol on Biosafety (CPB) to the Convention on Biological Diversity (CBD), to which Trinidad and Tobago acceded on October 5th 2000. The objective of CPB is to ensure an adequate level of protection in the field of safe transfer, handling and use of living modified organisms (LMOs)3 resulting from modern biotechnology, which may have adverse effects on the conservation and sustainable use of biological diversity or on human and 1 Modern biotechnology refers to the use of cell fusion technologies or recombinant DNA technology (genetic engineering) to alter the genetic makeup of living organisms. 2 Genetically modified organisms refer to organisms, whose genetic makeup has been altered by recombinant DNA or cell fusion technologies in way that does not occur naturally by mating or natural recombination. 3 Living modified organisms means any living organism that possesses a novel combination of genetic material obtained through the use of modern biotechnology and is capable of transferring or replicating genetic material. 1

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animal health. Other international commitments that may impinge on the policy and framework arise out of the Sanitary and Phytosanitary (SPS), Technical Barriers to Trade (TBT) and Trade-Related Aspects of Intellectual Property Rights (TRIPS) agreements of the World Trade Organisation (WTO), food safety standards and protocols developed by the Codex Alimentarius Commission of the Food and Agriculture Organization/World Health Organisation (FAO/WHO), and international plant and animal health protocols of the International Plant Protection Convention (IPPC) and World Organisation for Animal Health (OIE). In addition, the principles of the United Nations Convention on Human Rights (UNCHR) underlie the development of the Policy. Globally, biotechnology is regarded as the dominant general-purpose technology of the 21st century. Trinidad and Tobago, like many other developing countries, has identified modern biotechnology as an important technology option to address issues such as food security and the development of the agricultural sector, bioresource development, and environmental protection. The use of modern biotechnology is also seen as a means of achieving leadership in tropical medicine and diagnostics, specifically in HIV/AIDS research and therapeutics to assist in improving the health care available to the citizens of Trinidad and Tobago. Products of modern biotechnology however should be subject to rules to ensure that they are developed and used in a way that they do not pose an unacceptable risk to plant, animal or human health; genetic resources; or the environment. The Policy provides a balanced policy environment so that biotechnology development can be nurtured within an environment where the potential risks associated with the technology are appropriately managed. In light of the impact of such a policy on citizens, its development was informed by the widest possible public consultation across sectors, stakeholders and civil society. Towards this end, extensive stakeholder and public consultations, opinion surveys and public education campaigns to raise awareness of biotechnology and biosafety were conducted. The main purpose of this document therefore is to establish a biosafety policy for consumer protection while ensuring that biotechnology development and use are not unduly restricted. 2

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2 SETTING THE CONTEXT This section summarises the issues raised at various fora and discussions held at the committee level in arriving at the policy objectives and policy directions and provides the contextual basis for the Policy. 2.1 Biotechnology, Innovation and Biosafety The biotechnology revolution is influencing every sphere of human activity, including agriculture, human and animal health, biodiversity conservation, environmental remediation, industrial applications and forensics, and has significant implications for humankind. Widely regarded as a scale-neutral technology, it is of particular interest to Small Island Developing States (SIDS) in so far as it can provide innovative solutions to achieving development goals. The governing council of the Inter-American Institute for Co-operation on Agriculture (IICA), in its hemispheric plan for the next decade has identified biotechnological tools as critical to revitalising agriculture and in the sustainable exploitation of the region‟s bio-resources. In addition, biotechnology is contributing to health care through novel therapeutics and vaccines. Recognising the importance of this technology, CARICOM established a regional working group to develop a policy on biotechnology and biosafety. Trinidad and Tobago, like many other Caribbean nations, is also developing a biotechnology policy as part of the science and technology policy with the objective of encouraging innovation, research and development. Biosafety policies ensure that products of modern biotechnology, such as GMOs, do not pose an unacceptable risk to plant, animal or human health; genetic resources; or the environment. A biosafety policy also provides an enabling environment for biotechnology development by ensuring that the interface between technology and society is carefully managed. The Policy will ensure that the environment, along with plant, animal and human health, is managed at the highest safety standards without being unduly restrictive to biotechnology development and trade. Given the importance of achieving sustainable development goals, separate policies are required for biotechnology and biosafety. This two-pronged approach will ensure that perceived conflicts of interest, as they relate to biosafety, do not hamper biotechnology development and implementation or impinge on human rights. However, this approach requires that there is articulation between the two policies so that neither adversely affects the distinct goals of the other. 2.2 International Perspectives Internationally, GMOs and products derived from them have been the subject of great controversy. The proponents of the technology argue that genetic engineering can help feed the increasing world population with more nutritious food at a reduced cost. They also claim that it is critical to establishing a sustainable global agriculture system. 3

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Opponents on the other hand argue that the technology carries along with it numerous risks to the society. They maintain that the long-term impact of the technology on plant, animal or human health; genetic resources; or the environment is not well understood. Environmental concerns include the cross-pollination of the transferred gene („trans gene‟) from the GM crop to other related plants, referred to as „gene transfer‟, and the possible influence of the „trans gene‟ on non-target organisms. Human and animal health concerns include the possible toxicity or allergenicity of products of the „trans gene‟ and the transfer of antibiotic-resistant genes. The controversy is also influenced by issues, which are often outside the realm of simple costs and benefits of the technology. These include international trade obligations, socioeconomic concerns, intellectual property rights and patenting issues (genes and living organisms), accessibility of technologies by developing countries and marginalised 4 groups (rural farmers, women and indigenous persons), public trust in the regulatory agencies, moral and ethical issues, culture and heritage, and consumer rights. Scientific risk analysis is the generally accepted method for assessing the acceptability of GMOs, but there is disagreement with respect to the decision-making process. One view argues for the use of the precautionary approach whilst the other advocates substantial equivalence5. The proponents of the use of the precautionary approach argue that the technology is in its infancy and carries with it scientific uncertainties and justifies a cautious approach. The application of the precautionary principle allows countries to: i. Take preventative action in the face of scientific uncertainty; ii. Shift the burden of proof to the proponents of an activity; iii. Explore a wide range of alternatives to possibly harmful actions; and iv. Increase public participation in decision-making. The proponents of substantial equivalence argue that the use of the precautionary approach can lead to arbitrary decision-making, the creation of unjustifiable trade barriers, and the stifling of innovation. They regard the precautionary approach as an illdefined and nebulous concept, which is open to abuse and could serve as a front to further protectionist or competitiveness-driven trade agendas. Proper application of the precautionary approach requires an understanding of the magnitude, distribution and uncertainty of risks, the extent of exposure the trade-offs and lost benefits in foregoing the risk. The proponents of substantial equivalence therefore contend that it is a more pragmatic decision-making tool. Moreover, they point out that sound science as a basis of decision-making is enshrined in the WTO agreements such as SPS and TBT. 4 Marginalisation refers to the state of being considered unimportant, undesirable, unworthy, insignificant and different resulting in inequity, unfairness, deprivation and enforced lack of access to mainstream power. http://www.undp.org/rbec/nhdr/1996/georgia/glossary.htm (16/2/06) 5 The concept of substantial equivalence embodies the idea that existing organisms used as food or as a source of food can be used as a basis for comparison when assessing the safety of human consumption of a food or a food component that has been modified or is new. 4

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The Government is signatory to the CPB as well as the SPS and TBT agreements of the WTO and is a member of the Codex Alimentarius Commission. The precautionary approach is a basic tenet of the CPB whilst the Codex Alimentarius Commission of the FAO/WHO uses substantial equivalence in its food safety assessments. The precautionary approach is enshrined in the National Environmental Policy of Trinidad and Tobago whilst substantial equivalence is used as the basis for food safety assessments in Trinidad and Tobago. The Policy therefore adopts a dual approach to biosafety decision-making, in keeping with its international commitments. Trinidad and Tobago acknowledges the potential risks associated with the technology, but recognises that if these are properly managed, modern biotechnology can benefit society and can contribute to achieving national development goals (e.g. Vision 20/20). Like any other technology, the costs and benefits to the society depend on how the technology is used. A biosafety policy that evaluates biotechnology products on a caseby-case basis and takes into consideration both the risks and benefits would be able to harness the good of the technology, while avoiding the ills. Such an approach requires a flexible regulatory regime providing for notification and permits, and guidelines and oversight. The Policy will also allow the flexibility to alter decisions as new information becomes available. The Policy therefore advocates independent and rigorous scientific risk assessment as a basis for decision-making, but provides the flexibility to commission an independent socio-economic assessment, as required, to support the decision-making process and to safeguard the national interests of Trinidad and Tobago. 2.3 International Trade and Implications for Biosafety Internationally, it has been estimated that 70-100% of processed foods are derived from GMOs. Based on trade data for the period January to September 2005, North America (USA and Canada) supplied 31% of the imports into Trinidad and Tobago and attracted 61% of the total domestic export volume out of Trinidad and Tobago. The USA alone accounted for 29% of the imports into, and 60% of the domestic exports out of, Trinidad and Tobago, and can therefore be regarded as Trinidad and Tobago's main trading partner. In comparison, although the European Union supplied 13% of the total imports into Trinidad and Tobago, it only attracted 7% of the domestic exports. With specific reference to food imports and exports, the trade data for January to September 2005 indicated that the USA accounted for 45% and 6% respectively, compared to 11% and 22% in trade with EU. Based on data from the Central Statistical Office (CSO, 2006), more than 95% of corn, soybean, cotton and canola products are imported into Trinidad and Tobago from the key producers of GM crops such as USA, Canada and Australia. Therefore, it follows that GM foods already exist on the Trinidad and Tobago market. 5

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The Policy therefore ensures that trade between Trinidad and Tobago‟s major trading partners is not unduly affected. 2.4 Regional Perspectives The establishment of the CSME requires harmonisation of biosafety policies and legislation among CARICOM countries. To this end, CARICOM established a regional working group on GMOs, which has been mandated to develop a regional biotechnology and biosafety policy. Regional harmonisation of biosafety was first addressed in a regional biosafety capacity-building workshop organised by NIHERST in January 2004. Subsequently, a second meeting was organised by CARDI in April 2005 to move the agenda forward. More recently, the issue was further elaborated in a regional biotechnology and biosafety needs assessment workshop organised by IICA in November 2005. Deliberations at these workshops concluded that the following should be reflected in the regional policy document and implementation mechanism: i. The technical capacity to evaluate notifications is limited particularly in the smaller CARICOM territories and a mechanism should be developed to address this. A database of CARICOM expertise should be developed to ensure that the scattered human resources in the region can be used to maximum benefit in regulatory decision-making, particularly in cases where conflicts of interests arise. A joint database of approved GMO events in food for consumption can be developed. A regional biosafety information system should be established to provide information transfer between CARICOM member states to ensure that countries within CARICOM avoid duplication of efforts. Copies of notifications/applications for GMO release made to national authorities should be sent to the regional biosafety authorities so that countries can benefit from feedback from other CARICOM member countries. Common application requirements and administrative systems adopted by countries will allow experiences to be readily transferred to other CARICOM states. The region should establish common biosafety standards and guidelines so that trade between CARICOM member countries will not be affected. Joint capacity-building programmes and common testing facilities will reduce the cost of biosafety implementation and should be supported wherever possible. Regional public education campaigns and curriculum improvement efforts at primary, secondary and tertiary levels should be encouraged to reduce cost and bring greater harmonisation of efforts. 6 ii. iii. iv. v. vi. vii.

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viii. A common policy on labelling of foods modified by modern biotechnology should be developed towards supporting regional trade. A mechanism should be established for the national biosafety authorities to collaborate with the regional biosafety authority. The Policy should therefore reflect the aforementioned regional policy guidelines. ix. 2.5 National Perspectives 2.5.1 Agriculture The objectives of the Ministry with the responsibility for Agriculture are to increase and sustain agricultural productivity and competitiveness which includes the application of new technologies such as biotechnology for achieving these stated objectives. As such, in order to ensure that Trinidad and Tobago successfully exploits the biotechnology revolution, this Ministry will collaborate with appropriate agencies, and promote the development of the necessary institutional capacity and other resources for the effective implementation of the stated policy. In addition, there will be the development of mechanisms for the use, regulation and control of biotechnology and biotechnological products. The Ministry is empowered under the Plant Protection Act of 1975 (with amendments of 2001) and the Animal Diseases and Importation Act of 1954 (with amendments of 15/1955; 6/1963; 102/1977 and 45/1979) respectively, to regulate the importation of plants, plant products including seeds, and any other propagative materials, soil, animal and animal products. As a member of the International Plant Protection Convention (IPPC), guidelines for the introduction of LMOs as detailed in International Standard of Phytosanitary Measures No. 11 are used to guide the conduct of pest risk analyses. 2.5.2 Food and Health The introduction of foods produced through modern biotechnology potentially brings new issues for food safety such as changes to macro- and micronutrients, and introduction or altered levels of anti-nutrients, endogenous toxicants, allergens, and physiologically active substances. Safety assessments of food produced from GMOs should include their health and nutrition effects on the whole population as well as special groups (including immuno-compromised individuals, infants and the elderly); through direct and indirect exposure of humans to the food or to the GMO itself. The National Health Policy makes reference to the safe and wholesome food supply to the population of Trinidad and Tobago. Although legislation regarding public health and food safety is being reviewed and updated, there is no specific reference to foods produced through modern biotechnology. Accordingly, the existing National Health 7

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Policy has to be revised to reflect technological changes in modern food production without compromising food safety and wholesomeness. The Codex Alimentarius Commission of the FAO/WHO is a standing international commission on food safety standards, which is constantly evaluating emerging issues and contributing to the development of international standards and protocols for food safety and food labelling. The biosafety policy and legislation should therefore be flexible enough to incorporate the emerging and continually evolving world views on food safety. The Food and Drugs Division is empowered under the Food and Drugs Act 8 of 1960, Chapter 30:01 to regulate the importation, manufacture, storage, sale, distribution and destruction of food, drugs, cosmetics and medical devices in Trinidad and Tobago. The Act however does not specifically address the importation, use and placement in the market of LMOs intended for food, feed and processing (LMO-FFPs). 2.5.3 Environment The environmental concerns that relate to the intentional introduction of GMOs into the natural environment of Trinidad and Tobago are: i. ii. iii. iv. Unintended changes in the competitiveness or virulence of the target species; Possible adverse impacts of the transgenic products on non-target species; Potential of transgenes being transferred to wild relatives; and Possibility that an existing non-target gene may lose its effectiveness. The National Environmental Policy of Trinidad and Tobago provides in Section 3.2 that “GMOs shall not be imported or acquired, marketed or released into the environment of Trinidad and Tobago without authorisation from the relevant government authority”. This policy, however, does not provide sufficient guidance for the decision-making process. In this regard, a specific policy on biosafety is required. Such a policy should incorporate the precautionary approach a basic tenet of the National Environmental Policy, and include provisions for fulfilling the countr y‟s obligations under the CPB. Additionally, the policy governing the development and use of GMOs should not adversely affect the conservation and use of the country‟s biological resources in keeping with the National Biodiversity Strategy and Action Plan (NBSAP). The management and protection of the environment of Trinidad and Tobago is effected primarily through the Environmental Management Act of 2000, which established an Environmental Management Authority responsible for, inter alia: i. ii. iii. Developing and implementing policies and programmes for the effective management and wise use of the environment; Coordinating environmental management functions; Promoting education and public awareness programmes on the environment; 8

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