the Cartagena Protocol on Biosafety (http://www.cbd.int/biosafety/protocol.shtml) and the phytosanitary standards of the International Plant Protection Convention (IPPC 2001). The ERA paradigm described by the US Environmental Protection Agency (EPA) (USEPA 1992, 1998) has been used by the authors as a conceptual and procedural basis for a common framework and terminology that can be applied to ERAs for GM plants.
An inadequate PF may compromise the entire ERA and add to the level of uncertainty in subsequent decision-making. Frequent outcomes of this type of failure are continuing requests for more data, disproportionate risk mitigation measures and miscommunication of risk findings; this results in increased concerns about the environmental impact (Johnson et al. 2007; Raybould 2006) and leads to delayed decision-making. Some authors contend that such delays may lead to increased negative environmental impacts because of the consequent delays in the introduction of environmentally beneficial products (Raybould 2006, 2007). Additionally, an ERA with a poorly developed PF may have inadequately specified or inappropriate expressions of the environmental value to be protected (benefits including processes by which the environment produces resources), or insufficient clarity regarding the purpose and use of the data being collected. This report presents a framework for constructing PFs that can be applied to ERAs for GM plants.