The Integration of Science and Policy in Regulatory Decision-Making: Observations on Scientific Expert Panels Deliberating GM Crops in Centers of Diversity

Karen E. Hokanson, Norman Ellstrand, Alan Raybould

Panels of experts with specialized knowledge and experience are often convened to identify and analyze information relevant for risk assessments of GM crops. A perspective on the use of such scientific expert panels is shared here based on panels convened to inform the regulatory strategy for three separate projects developing GM crops for cultivation in Africa: a nutritionally enhanced sorghum, an insect resistant cowpea, and a virus resistant cassava. The panels were convened specifically to consider the risks associated with gene flow from a genetically modified (GM) crop to naturally occurring 'wild' relatives of that crop. In these cases, the experts used problem formulation to identify effects that regulatory authorities may consider to be harmful ("harms") and formulate plausible scenarios that might lead to them, and the availability of information that could determine the likelihood of the steps in the pathway. These panels and the use of problem formulation worked well to gather the existing information and consider the likelihood of harm from gene flow in centers of diversity. However, one important observation from all of these cases is that it is outside the remit of such scientific expert panels to make decisions dependent on policy, such as which harms should be considered and what information should be considered essential in order for a regulatory authority to make a decision about the acceptable level of risk. These experiences of expert panels to inform GM crop risk assessment demonstrate the challenge of integrating science and policy for effective regulatory decision-making.