Thanks, Corey.
Our messages today are that harmonized international systems are critical to our industry, and that cuts at PMRA have put that at risk. The act is workable in its current form with one potential caveat that I will elaborate on.
As Corey has described, the international regulatory landscape around food trade is becoming more challenging and complex. While there are many technical issues, the key for us is not what international regulators decide vis-à-vis certain technology, it's when.
We're in an era of increasing technological innovation, giving us the ability to test for substances right down to parts per trillion. In cases where an importing country has not completed its assessment, it is common for a zero or near zero default to be applied. This means that advanced technology could show that traces of a product are present but at levels that have never been shown to be of any concern from a health or environmental perspective. Still, cargoes can be rejected. Let me illustrate this point with a practical and real life trade example.
In 2011 the pulse industry experienced a high profile non-compliance on lentils going into the European Union, which has been known to have a sensitivity in this area. The issue was that farmers were using a crop protection product, glyphosate or Roundup, which is fully approved for use in Canada. Residues were well within Canadian and other established international food safety standards. However, the EU had never gone through the process of establishing an MRL for glyphosate on lentils, and consequently it applied a near zero default of 0.1 parts per million that resulted in the rejection of the shipment.
This also created the threat of a product recall off retail shelves, so this was a non-compliance that was treated as a food safety issue. All of this happened solely as a result of a lack of regulatory harmonization around the timing of approvals. I want to be clear to all committee members, who may not be aware of the detail and policy and processes around establishment of crop protection product tolerance levels, that Canada is among the toughest regulators in the world when it comes to establishing safety margins and the lentil shipments in question were easily compliant with Canadian standards.
I would again emphasize that the issue here is that regulatory gaps cause shipments of safe, nutritious lentils to be treated as a food safety breach and rejected randomly and unpredictably. Rather than seeing a strengthening of alignment at the international level, we see more national approaches to food safety with some countries moving away from Codex to establish their own national systems. Recent examples include China, South Korea, Hong Kong, and Taiwan, with a few of Canada's other key export markets signalling they may follow the same path. This is all making harmonization even harder.
We would suggest two positions for your committee to consider. The first is that PMRA's leadership to date on harmonization internationally must continue, and it must be fully resourced, including consideration that cost recovery fees be funnelled back into PMRA. Examples that Jan touched on of the progress that PMRA has made toward harmonization of science-based approaches include work within the NAFTA Technical Working Group on Pesticides and OECD global joint reviews.
The second is the need to find creative ways in the future to employ other competent authorities' risk assessments, in the interim, in cases where timing poses a problem and to ensure that at that point, if we go down the road or choose to go down the road of recognizing other risk assessments, that the PCP Act doesn't stand as a constraint at that time.
We favour a global approach to food safety standards. Clearly many countries including Canada will feel the need to establish separate national approaches, but we would also suggest that Canada and other countries must develop processes to allow for recognition of standards that have been established by equivalent competent authorities. This will only be acceptable to the public if there's acknowledgement that the science-based risk assessment of another competent authority, such as the World Health Organization, provides adequate protection to the health of Canadians.
If at some point in the future Canada requests that its trading partners follow this approach, we can expect to be asked how Canada would react to a similar request. Would Canada be willing to recognize a World Health Organization-driven risk assessment or tolerance as an interim tolerance in a case where an MRL had not been established by Canadian regulators?
The challenge is clear. Adoption of new technology is the key to sustainable intensification of food production. Canada is a trading nation and needs to export. Regulatory gaps are putting trade at risk increasingly, and Canada needs to continue, and even strengthen, its leadership role in this area.
Thank you, Mr. Chairman.