Preamble
Recognizing that the World Health
Organization... is the directing and coordinating authority
on international health work.
This is inconsistent with a
recent statement by the WHO DG that the WHO has no interest
or intent to direct country health responses. To reiterate it
here suggests that the DG is not representing the true position
regarding the Agreement.
"Directing authority" is however in line with
the proposed IHR Amendments (and the WHO's Constitution), under
which countries will "undertake" ahead of time to follow the
DG's recommendations (which thereby become instructions).
As the HR amendments make clear, this is
intended to apply even to a perceived threat rather than actual
harm.
Recalling the constitution of the World
Health Organization... highest attainable standard of health
is one of the fundamental rights of every human being
without distinction of race, religion, political belief,
economic or social condition.
This statement recalls fundamental
understandings of public health, and is of importance here as it
raises the question of why the WHO did not strongly condemn
prolonged school closures, workplace closures, and other
impoverishing policies during the Covid-19 response.
In 2019, WHO
made clear that these dangers should prevent actions we now
call 'lockdowns' from being imposed.
Deeply concerned by the gross inequities
at national and international levels that hindered timely
and equitable access to medical and other Covid-19
pandemic-related products, and the serious shortcomings in
pandemic preparedness.
In terms of health equity (as distinct from
commodity of 'vaccine' equity), inequity in the Covid-19
response was not in failing to provide a vaccine against former
variants to immune, young people in low-income countries who
were at far higher risk from endemic diseases, but in the
disproportionate harm to them of uniformly-imposed NPIs that
reduced current and future income and basic healthcare, as was
noted by the WHO in 2019 Pandemic Influenza
recommendations.
The failure of the text to recognize this
suggests that lessons from Covid-19 have not informed this draft
Agreement.
The WHO has not yet demonstrated how pandemic
'preparedness,' in the terms they use below, would have reduced
impact, given that there is
poor correlation between strictness or speed of response and
eventual outcomes.
Reiterating the need to work towards...
an equitable approach to mitigate the risk that pandemics
exacerbate existing inequities in access to health services,
As above - in the past century, the issue of
inequity has been most pronounced in pandemic response, rather
than the impact of the virus itself (excluding the physiological
variation in risk).
Most recorded deaths from acute pandemics,
since the Spanish flu, were during Covid-19, in which the virus
hit mainly sick elderly, but response impacted working-age
adults and children heavily and will continue to have effect,
due to increased poverty and debt; reduced education and child
marriage, in future generations.
These have disproportionately affected
lower-income people, and particularly
women.
The lack of recognition of this in this
document, though they are recognized by the World Bank and UN
agencies elsewhere, must raise real questions on whether this
Agreement has been thoroughly thought through, and the process
of development been sufficiently inclusive and objective.
Chapter I. Introduction
Article 1. Use of terms
(i) "pathogen with pandemic potential"
means any pathogen that has been identified to infect a
human and that is: novel (not yet characterized) or known
(including a variant of a known pathogen), potentially
highly transmissible and/or highly virulent with the
potential to cause a public health emergency of
international concern.
This provides a very wide scope to alter
provisions.
Any pathogen that can infect humans and is
potentially highly transmissible or virulent, though yet
uncharacterized means virtually any coronavirus, influenza
virus, or a plethora of other relatively common pathogen groups.
The IHR Amendments intend that the DG alone
can make this call, over the advice of others, as occurred with
monkeypox in 2022.
(j) "persons in vulnerable situations"
means individuals, groups or communities with a
disproportionate increased risk of infection, severity,
disease or mortality.
This is a good definition - in Covid-19
context, would mean the sick elderly, and so is relevant to
targeting a response.
"Universal
health coverage" means that all people have access to the
full range of quality health services they need, when and
where they need them, without financial hardship.
While the general UHC concept is good, it is
time a sensible (rather than patently silly) definition was
adopted. Society cannot afford the full range of possible
interventions and remedies for all, and clearly there is a scale
of cost vs benefit that prioritizes certain ones over others.
Sensible definitions make action more likely, and inaction
harder to justify.
One could argue that none should have the
full range until all have good basic care, but clearly the earth
will not support 'the full range' for 8 billion people.
Article 2. Objective
This Agreement is specifically for pandemics
(a poorly defined term but essentially a pathogen that spreads
rapidly across national borders). In contrast, the IHR
amendments accompanying it are broader in scope - for any public
health emergencies of international concern.
Article 3. Principles
2. the sovereign right of States to
adopt, legislate and implement legislation
The amendments to the IHR require States to
undertake to follow WHO instructions ahead of time, before such
instruction and context are known.
These two documents must be understood, as
noted later in the Agreement draft, as complementary.
3. equity as the goal and outcome of
pandemic prevention, preparedness and response, ensuring the
absence of unfair, avoidable or remediable differences among
groups of people.
This definition of equity here needs
clarification. In the pandemic context, the WHO emphasized
commodity (vaccine) equity during the Covid-19 response.
Elimination of differences implied equal
access to Covid-19 vaccines in countries with large aging, obese
highly vulnerable populations (e.g. the USA or Italy), and those
with young populations at minimal risk and with far more
pressing health priorities (e.g. Niger or Uganda).
Alternatively, but equally damaging, equal
access to different age groups within a country when the
risk-benefit ratio is clearly greatly different. This promotes
worse health outcomes by diverting resources from where they are
most useful, as it ignores heterogeneity of risk.
Again, an adult approach is required in
international agreements, rather than feel-good sentences, if
they are going to have a positive impact.
5. ... a more equitable and better
prepared world to prevent, respond to and recover from
pandemics
As with '3' above, this raises a fundamental
problem: What if health equity demands that some populations
divert resources to childhood nutrition and endemic diseases
rather than the latest pandemic, as these are likely of far
higher burden to many younger but lower-income populations?
This would not be equity in the definition
implied here, but would clearly lead to better and more equal
health outcomes.
The WHO must decide whether it is about
uniform action, or minimizing poor health, as these are clearly
very different. They are the difference between the WHO's
commodity equity, and true health equity.
Chapter II. The world together
equitably: achieving equity in, for and through pandemic
prevention, preparedness and response
Equity in health should imply a reasonably
equal chance of overcoming or avoiding preventable sickness.
The vast majority of sickness and death is
due to either non-communicable diseases often related to
lifestyle, such as obesity and type 2 diabetes mellitus,
undernutrition in childhood, and endemic infectious diseases
such as tuberculosis, malaria, and HIV/AIDS.
Achieving health equity would primarily mean
addressing these.
In this chapter of the draft Pandemic
Agreement, equity is used to imply equal access to specific
health commodities, particularly vaccines, for intermittent
health emergencies, although these exert a small fraction of the
burden of other diseases.
It is, specifically, commodity-equity, and
not geared to equalizing overall health burden but to enabling
centrally-coordinated homogenous responses to unusual events.
Article 4. Pandemic prevention and
surveillance
2. The
Parties shall undertake to cooperate:
(b) in
support of... initiatives aimed at preventing pandemics, in
particular those that improve surveillance, early warning
and risk assessment; ... .and identify settings and
activities presenting a risk of emergence and re-emergence
of pathogens with pandemic potential.
(c-h)
[Paragraphs on water and sanitation, infection control,
strengthening of biosafety, surveillance and prevention of
vector-born diseases, and addressing antimicrobial
resistance.]
The WHO
intends the Agreement to
have force under
international law. Therefore, countries are undertaking to
put themselves under force of international law in regards to
complying with the agreement's stipulations.
The provisions under this long article mostly
cover general health stuff that countries try to do anyway. The
difference will be that countries will be assessed on progress.
Assessment can be fine if in context, less fine if it consists
of entitled 'experts' from wealthy countries with little local
knowledge or context.
Perhaps such compliance is best left to
national authorities, who are more in use with local needs and
priorities.
The justification for the international
bureaucracy being built to support this, while fun for those
involved, is unclear and will divert resources from actual
health work.
6. The Conference of the Parties may
adopt, as necessary, guidelines, recommendations and
standards, including in relation to pandemic prevention
capacities, to support the implementation of this Article.
Here and later, the COP is invoked as a
vehicle to decide on what will actually be done. The rules are
explained later (Articles 21-23). While allowing more time is
sensible, it begs the question of why it is not better to wait
and discuss what is needed in the current INB process, before
committing to a legally-binding agreement.
This current article says nothing not already
covered by the IHR2005 or other ongoing programs.
Article 5. One Health approach to
pandemic prevention, preparedness and response
Nothing specific or new in this article. It
seems redundant (it is advocating a holistic approach mentioned
elsewhere) and so presumably is just to get the term 'One
Health' into the agreement. (One could ask, why bother?)
Some mainstream definitions of One Health
(e.g. Lancet) consider that
it means non-human species are on a par with humans in terms of
rights and importance.
If this is meant here, clearly most Member
States would disagree. So we may assume that it is just words to
keep someone happy (a little childish in an international
document, but the term 'One Health' has been trending, like
'equity,' as if the concept of holistic approaches to public
health were new).
Article 6. Preparedness, health
system resilience and recovery
2. Each
Party commits... [to] :
(a)
routine and essential health services during pandemics with
a focus on primary health care, routine immunization and
mental health care, and with particular attention to persons
in vulnerable situations
(b)
developing, strengthening and maintaining health
infrastructure
(c)
developing post-pandemic health system recovery strategies
(d)
developing, strengthening and maintaining: health
information systems
This is good, and (a) seems to require
avoidance of lockdowns (which inevitably cause the harms
listed). Unfortunately
other WHO
documents lead one to assume this is not the intent...
It does appear therefore that this is simply
another list of fairly non-specific feel-good measures that have
no useful place in a new legally-binding agreement, and which
most countries are already undertaking.
(e)
promoting the use of social and behavioural sciences, risk
communication and community engagement for pandemic
prevention, preparedness and response.
This requires clarification, as the use of
behavioral science during the Covid-19 response involved
deliberate inducement of fear to promote behaviors that people
would not otherwise follow (e.g.
Spi-B). It is essential here that the document clarifies how
behavioral science should be used ethically in healthcare.
Otherwise, this is also a quite meaningless
provision.
Article 7. Health and care workforce
This long Article discusses health workforce,
training, retention, non-discrimination, stigma, bias, adequate
remuneration, and other standard provisions for workplaces.
It is unclear why it is included in a legally
binding pandemic agreement, except for:
4. [The
Parties]... shall invest in establishing, sustaining,
coordinating and mobilizing a skilled and trained
multidisciplinary global public health emergency
workforce... Parties having established emergency health
teams should inform WHO thereof and make best efforts to
respond to requests for deployment...
Emergency health teams established (within
capacity etc.) - are something countries already do, when they
have capacity.
There is no reason to have this as a
legally-binding instrument, and clearly no urgency to do so.
Article 8. Preparedness monitoring
and functional reviews
1. The
Parties shall, building on existing and relevant tools,
develop and implement an inclusive, transparent, effective
and efficient pandemic prevention, preparedness and response
monitoring and evaluation system.
2. Each
Party shall assess, every five years, with technical support
from the WHO Secretariat upon request, the functioning and
readiness of, and gaps in, its pandemic prevention,
preparedness and response capacity, based on the relevant
tools and guidelines developed by WHO in partnership with
relevant organizations at international, regional and
sub-regional levels.
Note that this is being required of countries
that are already struggling to implement monitoring systems for
major endemic diseases, including tuberculosis, malaria, HIV,
and nutritional deficiencies.
They will be legally bound to divert
resources to pandemic prevention. While there is some overlap,
it will inevitably divert resources from currently underfunded
programs for diseases of far higher local burdens, and so (not
theoretically, but inevitably) raise mortality.
Poor countries are being required to put
resources into problems deemed significant by richer countries.
Article 9. Research and development
Various general provisions about undertaking
background research that countries are generally doing anyway,
but with an 'emerging disease' slant.
Again, the INB fails to justify why this
diversion of resources from researching greater disease burdens
should occur in all countries (why not just those with excess
resources?).
Article 10. Sustainable and
geographically diversified production
Mostly non-binding but suggested cooperation
on making pandemic-related products available, including support
for manufacturing in "inter-pandemic times" (a fascinating
rendering of 'normal'), when they would only be viable through
subsidies.
Much of this is probably unimplementable, as
it would not be practical to maintain facilities in most or all
countries on stand-by for rare events, at cost of resources
otherwise useful for other priorities.
The desire to increase production in
'developing' countries will face major barriers and costs in
terms of maintaining quality of production, particularly as many
products will have limited use outside of rare outbreak
situations.
Article 11. Transfer of technology
and know-how
This article, always problematic for large
pharmaceutical corporations sponsoring much WHO outbreak
activities, is now watered down to weak requirements to
'consider,' promote,' provide, within capabilities' etc.
Article 12. Access and benefit
sharing
This Article is intended to establish the WHO
Pathogen Access and Benefit-Sharing System (PABS System). PABS
is intended to "ensure rapid, systematic and timely access to
biological materials of pathogens with pandemic potential and
the genetic sequence data."
This system is of potential high relevance
and needs to be interpreted in the context that SARS-CoV-2, the
pathogen causing the recent Covid-19 outbreak, was highly likely
to have escaped from a laboratory.
PABS is intended to expand the laboratory
storage, transport, and handling of such viruses, under the
oversight of the WHO, an organization outside of national
jurisdiction with no significant direct experience in handling
biological materials.
3. When a
Party has access to a pathogen [it shall]:
(a) share
with WHO any pathogen sequence information as soon as it is
available to the Party;
(b) as
soon as biological materials are available to the Party,
provide the materials to one or more laboratories and/or
biorepositories participating in WHO-coordinated laboratory
networks (CLNs),
Subsequent clauses state that benefits will
be shared, and seek to prevent recipient laboratories from
patenting materials received from other countries.
This has been a major concern of low-and
middle-income countries previously, who perceive that
institutions in wealthy countries patent and benefit from
materials derived from less-wealthy populations. It remains to
be seen whether provisions here will be sufficient to address
this.
The article then becomes yet more concerning:
6. WHO
shall conclude legally binding standard PABS contracts with
manufacturers to provide the following, taking into account
the size, nature and capacities of the manufacturer:
(a) annual
monetary contributions to support the PABS System and
relevant capacities in countries; the determination of the
annual amount, use, and approach for monitoring and
accountability, shall be finalized by the Parties;
b)
real-time contributions of relevant diagnostics,
therapeutics or vaccines produced by the manufacturer, 10%
free of charge and 10% at not-for-profit prices during
public health emergencies of international concern or
pandemics, ...
It is clearly intended that the WHO becomes
directly involved in setting up legally binding manufacturing
contracts, despite the WHO being outside of national
jurisdictional oversight, within the territories of Member
States.
The PABS system, and therefore its staff and
dependent entities, are also to be supported in part by funds
from the manufacturers whom they are supposed to be managing.
The income of the organization will be
dependent on maintaining positive relationships with these
private entities in a similar way in which many national
regulatory agencies are dependent upon funds from pharmaceutical
companies whom their staff ostensibly regulate. In this case,
the regulator will be even further removed from public
oversight.
The clause on 10% (why 10?) products being
free of charge, and similar at cost, while ensuring lower-priced
commodities irrespective of actual need (the outbreak may be
confined to wealthy countries).
The same entity, the WHO, will determine
whether the triggering emergency exists, determine the response,
and manage the contracts to provide the commodities, without
direct jurisdictional oversight regarding the potential for
corruption or conflict of interest.
It is a remarkable system to suggest,
irrespective of political or regulatory environment.
8. The
Parties shall cooperate... public financing of research and
development, prepurchase agreements, or regulatory
procedures, to encourage and facilitate as many
manufacturers as possible to enter into standard PABS
contracts as early as possible.
The article envisions that public funding
will be used to build the process, ensuring essentially no-risk
private profit.
10. To
support operationalization of the PABS System, WHO shall...
make such contracts public, while respecting commercial
confidentiality.
The public may know whom contracts are made
with, but not all details of the contracts.
There will therefore be no independent
oversight of the clauses agreed between the WHO, a body outside
of national jurisdiction and dependent of commercial companies
for funding some of its work and salaries, and these same
companies, on 'needs' that the WHO itself will have sole
authority, under the proposed amendments to the IHR, to
determine.
The Article further states that the WHO shall
use its own product regulatory system (prequalification) and
Emergency Use Listing Procedure to open and stimulate markets
for the manufacturers of these products.
It is doubtful that any national government
could make such an overall agreement, yet in May 2024 they will
be voting to provide this to what is essentially a foreign, and
partly privately financed, entity.
Article 13. Supply chain and
logistics
The WHO will become convenor of a 'Global
Supply Chain and Logistics Network' for commercially-produced
products, to be supplied under WHO contracts when and where the
WHO determines, whilst also having the role of ensuring safety
of such products.
Having mutual support coordinated between
countries is good. Having this run by an organization that is
significantly funded directly by those gaining from the sale of
these same commodities seems reckless and counterintuitive. Few
countries would allow this (or at least plan for it).
For this to occur safely, the WHO would
logically have to forgo all private investment, and greatly
restrict national specified funding contributions. Otherwise,
the conflicts of interest involved would destroy confidence in
the system. There is no suggestion of such divestment from the
WHO, but rather, as in Article 12, private sector dependency,
directly tied to contracts, will increase.
Article 13bis: National procurement-
and distribution-related provisions
While suffering the same (perhaps
unavoidable) issues regarding commercial confidentiality, this
alternate Article 13 seems far more appropriate, keeping
commercial issues under national jurisdiction and avoiding the
obvious conflict of interests that underpin funding for WHO
activities and staffing.
Article 14. Regulatory systems
strengthening
This entire Article reflects initiatives and
programs already in place. Nothing here appears likely to add to
current effort.
Article 15. Liability and
compensation management
1. Each
Party shall consider developing, as necessary and in
accordance with applicable law, national strategies for
managing liability in its territory related to pandemic
vaccines... no-fault compensation mechanisms...
2. The
Parties... shall develop recommendations for the
establishment and implementation of national, regional
and/or global no-fault compensation mechanisms and
strategies for managing liability during pandemic
emergencies, including with regard to individuals that are
in a humanitarian setting or vulnerable situations.
This is quite remarkable, but also reflects
some national legislation, in removing any fault or liability
specifically from vaccine manufacturers, for harms done in
pushing out vaccines to the public. During the Covid-19
response, genetic therapeutics being developed by BioNtech and
Moderna were
reclassified as vaccines, on the basis that an immune
response is stimulated after they have modified intracellular
biochemical pathways as a medicine normally does.
This enabled specific trials normally
required for carcinogenicity and teratogenicity to be bypassed,
despite raised
fetal abnormality rates in animal trials. It will enable the
CEPI
100-day vaccine program, supported with private funding to
support private mRNA vaccine manufacturers, to proceed without
any risk to the manufacturer should there be subsequent public
harm.
Together with an earlier provision on public
funding of research and manufacturing readiness, and the removal
of former wording requiring intellectual property sharing in
Article 11, this ensures vaccine manufacturers and their
investors make profit in effective absence of risk.
These entities are currently heavily
invested in support for WHO, and were strongly aligned with
the introduction of newly restrictive outbreak responses that
emphasized and sometimes mandated their products during the
Covid-19 outbreak.
Article 16. International
collaboration and cooperation
A somewhat pointless article. It suggests
that countries cooperate with each other and the WHO to
implement the other agreements in the Agreement.
Article 17. Whole-of-government and
whole-of-society approaches
A list of essentially motherhood provisions
related to planning for a pandemic. However, countries will
legally be required to maintain a 'national coordination
multisectoral body' for PPPR. This will essentially be an added
burden on budgets, and inevitably divert further resources from
other priorities.
Perhaps just strengthening current infectious
disease and nutritional programs would be more impactful.
(Nowhere in this Agreement is nutrition discussed (essential for
resilience to pathogens) and minimal wording is included on
sanitation and clean water (other
major
reasons for reduction in infectious disease mortality over
past centuries).
However, the 'community ownership' wording is
interesting ("empower and enable community ownership of, and
contribution to, community readiness for and resilience [for
PPPR]"), as this directly contradicts much of the rest of the
Agreement, including the centralization of control under the
Conference of Parties, requirements for countries to allocate
resources to pandemic preparedness over other community
priorities, and the idea of inspecting and assessing adherence
to the centralized requirements of the Agreement.
Either much of the rest of the Agreement is
redundant, or this wording is purely for appearance and not to
be followed (and therefore should be removed).
Article 18. Communication and public
awareness
1. Each
Party shall promote timely access to credible and
evidence-based information ... with the aim of countering
and addressing misinformation or disinformation...
2. The
Parties shall, as appropriate, promote and/or conduct
research and inform policies on factors that hinder or
strengthen adherence to public health and social measures in
a pandemic, as well as trust in science and public health
institutions and agencies.
The key word is as appropriate, given that
many agencies, including the WHO, have overseen or aided
policies during the Covid-19 response that have greatly
increased poverty, child marriage, teenage pregnancy, and
education loss.
As the WHO has been shown to be significantly
misrepresenting pandemic risk in the process of advocating
for this Agreement and related instruments, its own
communications would also fall outside the provision here
related to evidence-based information, and fall within normal
understandings of misinformation. It could not therefore be an
arbiter of correctness of information here, so the Article is
not implementable.
Rewritten to recommend accurate
evidence-based information being promoted, it would make good
sense, but this is not an issue requiring a legally binding
international agreement.
Article 19. Implementation and
support
3. The WHO
Secretariat... organize the technical and financial
assistance necessary to address such gaps and needs in
implementing the commitments agreed upon under the Pandemic
Agreement and the International Health Regulations (2005).
As the WHO is dependent on donor support, its
ability to address gaps in funding within Member States is
clearly not something it can guarantee. The purpose of this
article is unclear, repeating in paragraphs 1 and 2 the earlier
intent for countries to generally support each other.
Article 20. Sustainable financing
1. The
Parties commit to working together... In this regard, each
Party, within the means and resources at its disposal,
shall:
(a)
prioritize and maintain or increase, as necessary,
domestic funding for pandemic prevention, preparedness
and response, without undermining other domestic public
health priorities including for: (i) strengthening and
sustaining capacities for the prevention, preparedness
and response to health emergencies and pandemics, in
particular the core capacities of the International
Health Regulations (2005);...
This is silly wording, as countries obviously
have to prioritize within budgets, so that moving funds to one
area means removing from another.
The essence of public health policy is
weighing and making such decisions; this reality seems to be
ignored here through wishful thinking. (a) is clearly redundant,
as the IHR (2005) already exists and countries have agreed to
support it.
3. A
Coordinating Financial Mechanism (the "Mechanism") is hereby
established to support the implementation of both the WHO
Pandemic Agreement and the International Health Regulations
(2005)
This will be in parallel to the Pandemic Fund
recently commenced by the World Bank - an issue not lost on INB
delegates and so likely to change here in the final version. It
will also be additive to the Global Fund to fight AIDS,
tuberculosis, and malaria, and other health financing
mechanisms, and so require another parallel international
bureaucracy, presumably based in Geneva.
It is intended to have its own capacity to
"conduct relevant analyses on needs and gaps, in addition to
tracking cooperation efforts," so it will not be a small
undertaking.
Chapter III. Institutional and final
provisions
Article 21. Conference of the
Parties
1. A
Conference of the Parties is hereby established.
2. The
Conference of the Parties shall keep under regular review,
every three years, the implementation of the WHO Pandemic
Agreement and take the decisions necessary to promote its
effective implementation.
This sets up the governing body to oversee
this Agreement (another body requiring a secretariat and
support). It is intended to meet within a year of the Agreement
coming into force, and then set its own rules on meeting
thereafter. It is likely that many provisions outlined in this
draft of the Agreement will be deferred to the COP for further
discussion.
Articles 22 - 37
These articles cover the functioning of the
Conference of Parties (COP) and various administrative issues.
Of note, 'block votes' will be allowed from
regional bodies (e.g. the EU).
The WHO will provide the secretariat.
Under Article 24 is noted:
3. Nothing
in the WHO Pandemic Agreement shall be interpreted as
providing the Secretariat of the World Health Organization,
including the WHO Director-General, any authority to direct,
order, alter or otherwise prescribe the domestic laws or
policies of any Party, or to mandate or otherwise impose any
requirements that Parties take specific actions, such as ban
or accept travellers, impose vaccination mandates or
therapeutic or diagnostic measures, or implement lockdowns.
These provisions are explicitly stated in the
proposed amendments to the IHR, to be considered alongside this
agreement.
Article 26 notes that the IHR is to be
interpreted as compatible, thereby confirming that the IHR
provisions including border closures and limits on freedom of
movement, mandated vaccination, and other lockdown measures are
not negated by this statement.
As Article 26 states:
"The
Parties recognize that the WHO Pandemic Agreement and the
International Health Regulations should be interpreted so as
to be compatible."
Some would consider this subterfuge - The
Director-General recently labeled as liars those who claimed the
Agreement included these powers, whilst failing to acknowledge
the accompanying IHR amendments. The WHO could do better in
avoiding misleading messaging, especially when this involves
denigration of the public.
Article 32 (Withdrawal) requires that, once
adopted, Parties cannot withdraw for a total of 3 years (giving
notice after a minimum of 2 years). Financial obligations
undertaken under the agreement continue beyond that time.
