Thank you.
Good afternoon, Mr. Chairman and members of the committee. My name is Derek Jamieson, and I am representing P & H Milling Group, a division of Parrish & Heimbecker Limited, at the invitation of this committee.
Parrish & Heimbecker is a privately held, Canadian-owned company. Parrish & Heimbecker Milling Group was formed following the acquisition of Dover Industries Limited by Parrish & Heimbecker in February of this year.
The P & H Milling Group consists of the combined milling assets of Dover Flour, New-Life Mills Limited, Ellison Milling Company, and Parrheim Foods, operating seven flour mills in five provinces across Canada, as well as a pea processing facility in Saskatchewan.
I also serve as the chair of the Canadian National Millers Association technical committee, and I am accompanied today by Mr. Gordon Harrison, president of the CNMA.
I would like to thank the committee for the opportunity to present our views on recent events and background surrounding fusarium-infected wheat. Fusarium is a fungal disease that can occur in wheat and other grains and is more likely to develop if moist warm conditions occur during the flowering stage. The disease produces a mycotoxin on the kernels of wheat, commonly referred to as vomitoxin, or DON.
For many years, this disease was more prevalent in the wheat-growing areas of Ontario and other eastern provinces; however, it is becoming a greater concern in the wheat-growing areas of western Canada, where the majority of Canada's wheat is grown.
One of the impacts of fusarium is blighted or bleached kernels. This can affect the entire kernel or a portion of the kernel, and it is visible to the trained eye. The presence of fusarium-damaged kernels, or FDK, is a grading factor in Canada, and as such the top grades--1, 2, and 3 of Canadian Western Red Spring, for example--are permitted a quarter of a per cent, one per cent, and two per cent fusarium-damaged kernels respectively.
The significance of this is that the Canada Grain Act, through grading standards established by the Canadian Grain Commission, recognizes that fusarium not only exists in the main milling grades used by Canadian flour mills but is in fact permitted in the main milling grades used by Canadian flour mills.
I would like to emphasize that if there are FDK kernels present, there will be vomitoxin, or DON, present as well, and so by interpretation, the Canada Grain Act recognizes and accepts the presence of DON in wheat. I would also stress that while the presence of FDK indicates that DON will be present, there is no proven linear relationship. As an example, one per cent fusarium-damaged kernels does not predict a consistent level of DON.
Currently there are no regulations in Canada governing or restricting the level of DON in hard wheat, which is primarily used for bread and other yeast-leavened products. Canada first established guidelines for soft wheat in the 1980s, and the current guideline is for two parts per million in uncleaned soft wheat for non-staple foods and one part per million in uncleaned soft wheat for use in baby foods.
In light of the absence of hard wheat guidelines, the P & H Milling Group has adopted voluntary guidelines for hard wheat that mirror those in place for soft wheat. Approximately one year ago, as a consequence of discussions regarding Health Canada's proposed guidelines for ochratoxin A, we became aware that Health Canada was also embarking on a process to establish additional guidelines for vomitoxin in grain in Canada. This news was neither a surprise nor a concern to us. The flour milling industry is on record as asking Health Canada for hard wheat guidelines since 1994.
Furthermore, P & H Milling Group, along with several other mills in Canada, participated in a voluntary project in 2005 with Health Canada to assist it in supplying samples of grain, flour, and bran for a study of vomitoxin in Canadian grain and flour.
More recently, also through discussions around proposed guidelines for OTA, we learned of stepped-up compliance and enforcement activities by the Canadian Food Inspection Agency. This involves the monitoring of levels of OTA and DON at processing locations, including flour mills and further processors such as breakfast cereal manufacturers. Flour, bran, and other product samples are being shipped to CFIA labs in Burnaby for analysis, and results are being reported back to mills in approximately three to six weeks.
It is the CFIA's current compliance and enforcement activity that is giving rise to a great deal of uncertainty for millers and producers. This activity was begun without prior consultation with industry to advise us of the specific levels of OTA and DON that would be considered to be excessive.
This would have been an important step to take, considering the OTA guidelines are only at the proposal stage and that Health Canada's limited guidelines for DON that apply to soft wheat only are clearly indicated on the department's website as being under review.
The CFIA is an auditor of industry best practices, while industry is responsible to carry out these practices. We require regulations that are clear and guidelines that are meaningful and achievable in order to meet these responsibilities. Since there are no guidelines for either OTA or DON in either federal laws or regulations, the milling industry has been seeking clarification on CFIA's current enforcement policy.
In response to persistent inquiries from the Canadian National Millers Association and other industry sources, CFIA has provided conflicting advice to both industry and Agriculture and Agri-Food Canada. In some written and oral communication to millers and further processors, CFIA has advised that Health Canada intends to adopt the EU guidelines for DON and that the agency is therefore applying a maximum limit of 0.75 parts per million.
In other written and oral communication, CFIA has advised that since there are no established guidelines for OTA and DON, they are taking a zero tolerance approach, meaning that where laboratory analysis indicates the presence of either mycotoxin the results will be referred to the bureau of chemical safety, food directorate, Health Canada, for risk assessment.
We have no issue with these monitoring activities, and we support Health Canada's objective of proposing new guidelines for DON. We recognize and endorse these efforts to ensure the safety of Canada's food supply. However, we are alarmed and concerned about being subject to enforcement over guidelines that do not exist.
We are equally concerned that our industry, with other industry stakeholders, has taken several steps and opportunities to engage Health Canada and the CFIA to alleviate these concerns and to find interim solutions with very few tangible results so far. My colleague Mr. Harrison will address these concerns in more detail.
I suggest that given this atmosphere of uncertainty and a lack of any interim guidance from Health Canada or the CFIA, it is not surprising that some misunderstandings arose during the recent harvest in eastern Canada. These are the unwanted consequences of heightened concerns and a lack of collaborative efforts to bring solutions that benefit and protect every participant, from the grower to the consumer.
Thank you for this opportunity to present my views.