Nithin Ramakrishnan, Third World Network
The study on DSI databases (CBD/SBI/7/INF/15) should not yet become the basis for policy decisions at COP17, without greater scrutiny, including through peer review.
Decision 16/2 decided to explore tools and models, such as databases, for making DSI publicly available and accessible in a transparent and accountable manner “to all Parties”, and requested the Secretariat to commission a study to support this process. This work is central to the implementation of the CBD’s multilateral mechanism for fair and equitable sharing of benefits arising from the use of DSI, including the Cali Fund.
Without greater transparency and accountability, the information necessary to verify the scope of use of the DSI and to support fair and equitable allocation of funds to provider countries and communities will continue to be lacking. This is because current DSI databases generally permit anonymous access and do not verify whether DSI has been lawfully made publicly available under applicable national legislation. “Accountability to all Parties” is fundamental to the implementation of decision 16/2. Yet the study largely overlooks this central objective.
Furthermore, provider countries, Indigenous Peoples and local communities remain unable to determine how DSI derived from their genetic resources is used.
The study identifies these important deficiencies in the current DSI database landscape, including the absence of information on compliance with national legislation, limited transparency regarding DSI use, and weak consideration of the rights of the providers of genetic resources, including Indigenous Peoples and local communities. But it does not demonstrate how its preferred solutions would remedy these deficiencies effectively.
The methodology itself warrants closer scrutiny. The study relies heavily on stakeholder interviews and surveys, while providing little explanation of how feasibility assessments were undertaken or what systematic analysis of evidence informed its conclusions. More problematically, the study treats academic researchers and private-sector entities as the sole users of the databases, and argues that any solution should have their buy-in. Comparatively little consi-deration is given to the legitimate interests of provider countries or communities, who also use the databases for providing access to DSI and who seek benefits from advancement in science and research. It neglects the basic requirement that DSI databases should not only serve those who access DSI, but also those who provide DSI and the genetic materials from which DSI is taken. As a result, the survey only sought views from academia and the private sector on whether a new DSI database is needed.
The study makes little effort to identify essential features of a DSI database that would make it fully ABS-compliant and supportive of Cali Fund operationalization. Instead it dismisses measures calling for an ABS-compliant DSI database as not feasible. It doesn’t produce a realistic estimate of resources required to maintain an ideal DSI database. Neither does it take into account present resources available for bio-informatic projects, and growing acceptance of database managers to facilitate implementation of ABS regimes, in collaboration with international organisations like the WHO.
There is also a lack of transparency around the study itself. It does not disclose the consultant’s identity or institutional affiliations, nor was it subject to independent peer review. Sources indicate that the study was prepared by a member of a scientific stakeholder network that has consistently equated anonymous access with open access, a position that is difficult to reconcile with the governance principles reflected in the UNESCO Recommendation on Open Science. While this may not establish a personal conflict of interest, it raises legitimate questions regarding whether these institutional biases have contributed to the methodological and conceptual shortcomings observed.