That's a great question. At the risk of offending my elect director, who employs me, I'll tell you a story.
Earlier this year in California at a global harmonization workshop, which a bunch of grower groups attended, one of the representatives of one of the horticulture crop groups from California said, “Do you know what? Four years ago our growers didn't even know what an MRL was.” I would say that four or five years ago, many growers in western Canada didn't know what an MRL was either.
This is a relatively new thing to discover, that there are these tolerances in place globally that are not harmonized. If we have a four and someone else has a five, or there's an eight there and a 10 here, we can deal with all that. The real concern for us is when somebody has a zero in place. In fact, we did some analysis after that lentil incident, because we didn't know, as the national association, where else we had potentially zero tolerances being applied. In some cases it's very difficult to determine. Countries don't have any defined default policy. We don't have a tolerance in place. What will we apply if we find a detectable residue? Will it be that the sky's the limit? Will it be a zero? Will it be the tolerance that is from another taxonomically similar crop or some chemical limit of detection?
There are reasons it's not always possible to know what you need to comply with on, let's say, 30 or 40 registered products on four or five crops going into 150-plus countries. How would we propose to deal with this? This is an emerging problem that's being increasingly recognized by multiple grower groups.
We have some suggestions. One actually brings us back to the request we made to make sure the PMRA is fully resourced in its efforts to bring resolution to this, and that is participation by more countries in global joint reviews, which bring regulators from around the world together to review the same data packages and come up with more harmonized tolerances. It doesn't require any regulator to give up its sovereignty; it's just looking at it together.
We now have better systems in place. We put out grower advisories every year to say, “Look, you really don't have the freedom to operate you might think.” Just because a product has been fully reviewed and is legal for use in Canada, we need to be careful about international tolerances that may not be in place. We're in our third year of putting out an advisory to growers every summer, and we have five markets by six different desiccants or harvest management products on four crops. In about 20% of these cases, we have inadequate international tolerances.
We think part of the solution in the future is some form of recognition of other jurisdictions' tolerances, only as interims, on a voluntary basis. Let me give you an example of a couple of countries that do something like this. Panama, for example, uses Codex MRLs generated by risk assessments from the World Health Organization. But if Codex doesn't have an MRL in place, they will say that they will use the U.S. MRL. If there's both no Codex and no U.S. MRL, then they'll use the European Union's MRL. This is the sort of country where we would never face a zero tolerance because of that. Someone will have gone through that assessment process.
I think it's safe to say that the problem will get more challenging before it gets better. We need to use all the solutions that are going to be available to us.