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Generic guidelines & procedures for the technical reviews of dossiers of new substances Leena Ylä-Mononen European Commission - DG Environment Unit C.4 Biotechnology and Pesticides UNECE CLRTAP Task Force on POPs 1-3 March 2004, The Hague. « Marching order » and timing.
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Generic guidelines & procedures for the technical reviews of dossiers of new substances Leena Ylä-Mononen European Commission - DG Environment Unit C.4 Biotechnology and Pesticides UNECE CLRTAP Task Force on POPs 1-3 March 2004, The Hague
« Marching order » and timing • A Party / several Parties together submit a proposal • EB decides: • Whether the risk profile is acceptable • Whether further consideration is warranted • If yes, to mandate the POP Task Force to conduct one or more technical reviews • Task Force on POPs conducts reviews and submits a report in writing to WGSR • EB completes the evaluation of the proposal
Requirements for the proposal • A Party / several Parties together submit a proposal (EB Decision 1998/2, para 1) • Content: • Risk profile (« comprehensive review of the scientific information … to provide suitable information for the assessment of risks associated with LRTAP» • Summary report (to include data on production, uses, emissions, socio-economic factors related to alternatives etc.)
Requirements for the proposal QUESTION 1: HOW THE PROPOSING PARTY CAN ENSURE THE SMOOTH HANDLING OF THE PROPOSAL? Timing? Content? Pre-work? Consultation in advance?
EB decision I EB decides: • Whether the risk profile is acceptable • Need to agree on minimum requirements • Whether further consideration is warranted • Need to agree on general lines in the cases of e.g. proposals on « dead chemicals » and incomplete data • If yes, to mandate the POP Task Force to conduct one or more technical reviews • Risk assessment; socio-economic assessment
EB Decision I Question 2: HOW COMPREHENSIVE THE RISK PROFILE HAS TO BE IN ORDER TO BE ACCEPTED BY THE EB ? What is the role of the Task Force? To give general recommendations? Request for submission of relevant information prior to the EB Meeting?
EB Decision I QUESTION 3: WHEN FURTHER ACTION WOULD NOT BE WARRANTED? What is the role of the Task Force? To give general recommendations?
TASK FORCE ON POPS Tasks: • Conducts one or several technical reviews on a proposal as mandated by the EB • Submits a report in writing to WGSR
TASK FORCE ON POPS • QUESTIONS…: • Is a Lead country approach appropriate? Could a Party who has proposed the substance act as a Lead? • Role of the Secretariat? • Comments by whome and when? Role of questionnaires? • Collection of additional information? • How to tackle borderline questions, cases with conflicting or missing data?
TASK FORCE ON POPS • … QUESTIONS: • Time lines for concluding a review? • Several parallel reviews – possibilities for prioritisation of the work? • When to invite experts? • Role of observers in the meetings? • Written procedures? • Possible conflict of interest situations? • How to handle confidential data?
EB Decision II • EB completes the evaluation of the proposal after having received the technical reviews from the WGSR together with a draft decision • Will there be a new commenting round, if necessary (e.g. if data is regarded insufficient for the ultimate decision making or there are conflicting views?)
Timing problems • EB meets only once a year • Documents to be submitted 90 days before the EB meeting • Task Force reports to WGSR – dead line 90 days before the meeting • Time for collecting comments on the proposal and the reviews scarce • Risk of delays in the procedure