Thank you very much for having me here today.
My name is Peter Andrée and I'm a professor in political science at Carleton University. I come at this from having studied the regulatory system in Canada for a number of years and having done research interviewing our regulators, and also looking at the international politics of GE regulation, regulation of genetically modified foods and crops.
First, I want to thank you for inviting me here today--that's the first thing I wanted to say. I think this is an important time for this debate, particularly because of the two issues that Terry just raised, the seeming approval of SmartStax corn in Canada without Health Canada's actually giving it regulatory oversight--and I'll come back to that in a second--and this case of the GE flax, which is not meant to be grown in Canada but has still managed to destroy overseas markets for Canadian farmers. Both of those issues point to weaknesses within our regulatory system, and if we don't figure out how to fill them soon, we're going to have more of these problems and we'll be putting Canadian farmers at risk again.
I should also clarify that while I am critical of the regulatory system for GMOs in Canada, I'm not against the technology per se. That's where I stand on these issues.
In September I was invited to speak at a symposium that the Royal Society of Canada organized together with l'Académie des sciences in France on the issue of GMOs. The symposium brought together scientists and people who study regulation and social issues from those two countries. I've passed out a presentation I did there, called “An Analysis of GMO Regulation in Canada: Eight Critical Issues”, in which I look at issues of the use of substantial equivalence in Canada, allergenicity testing, transparency, peer review--a number of areas that the Royal Society of Canada was invited by the Canadian government back almost ten years ago to do a thorough analysis of in terms of how effective the regulatory system is; whether there are any holes in that system, given the products that are going to be coming down the pipe; and what we need to improve that system.
In 2001 the Royal Society of Canada expert panel produced a substantial report, several hundred pages, in which they outlined 63 recommendations. One of the pieces of research I've done, I think it was five or six years ago now, was to look in detail at how the Canadian regulators responded to those 63 recommendations. My analysis would suggest there are still some critical holes that were identified in 2001 that remain to be filled. As I said, Canada really has to move on these if we're going to not put our farmers at economic risk in the way Terry was talking about.
I'm just going to touch on three of these eight issues, for the sake of moving us along. The first is this whole question of substantial equivalence. I won't get into all the technical details, but it essentially means that the regulators at Health Canada--and the Canadian Food Inspection Agency also uses this concept--compare the genetically modified food or plants to a non-modified counterpart and look for any areas where there are significant differences. If there are areas of significant difference, then it gets evaluated in more thorough testing.
This concept has been controversial, and in 2001 the Royal Society of Canada quite explicitly laid out to the regulators how the concept should be used. They said that if you're going to make a determination of substantial equivalence, you should look at the DNA structure, gene expression, proteomic analysis, which are the proteins that are created by those genes in the plant or food, and secondary metabolite profiling. They really spelled out that if you're going to understand these new crops in relation to the ones we've been using for a long time, these are the levels at which you have to understand the differences.
In the case of SmartStax corn, which Terry just pointed out, this is a corn variety that CFIA approved this summer. It has six traits that allow the plant to create Bttoxins, and then there are two herbicide resistance traits. The Canadian Food Inspection Agency, which looks at feed safety and environmental safety, did an analysis of this crop and approved it. Health Canada didn't look at it at all. The reason for that is because each of the eight traits, either singly or in pair, had been previously assessed. The assumption that they're going on is that the combination, the whole, is no different from the sum of the parts.
That's not the assumption the Europeans would make when they look at this, or most other regulatory systems in the world. In fact, even the U.S. Environmental Protection Agency just this past year had a whole scientific meeting where they looked at this question of stacked traits in crops. They said that there is the possibility of synergistic effects of these genes interacting. So we really need to look carefully at that before just assuming that the whole is more than the sum of its parts.
In Canada, the way the system is right now, Health Canada did not look at this product. I know there are people within Health Canada who would have liked to, but it's a hole in our regulatory system.
Related to that issue is the question of who is responsible for identifying potential problems. Our regulatory system actually requires that the applicant, the company bringing a product like SmartStax forward, identify if there are any changes that require further scrutiny.
There's a disconnect here as well because when The Globe and Mail wrote an article about this whole SmartStax getting through the Canadian regulatory system, the reporter approached Monsanto and asked, “Did you look carefully? Did you do the science to see if there are any differences between this eight-trait stacked product and the non-genetically-modified competitors?” Monsanto said that they didn't have to do that science because there's no need for additional safety assessments from Health Canada and the CFIA. So neither group is taking the time to do the science to figure out if there are any unexpected effects from the stacked product.
The second issue that I want to raise is the question of transparency in the regulatory system. I think it will interest some members of this committee that the Quebec government is the only provincial government that has an inter-ministerial committee that's kind of tracking the GMO regulatory approvals process at the federal level. I've been communicating with some members of that committee, and they are very frustrated. There have been inter-ministerial meetings between the Quebec government and the federal government to increase the transparency on two levels--both public access to some detail about how regulatory decisions are made, and allowing outside and independent scientists to verify the kinds of data upon which these decisions are made. That's a real concern for the Quebec government.
The last issue that I want to quickly touch on is this whole question of socio-economic considerations. It relates to the flax issue that Terry pointed out.
One of my pieces of research was on how the Canadian government dealt with the case of Roundup-ready wheat, or genetically engineered wheat, that was moving through the regulatory system in 2003-2004. It had been approved by Health Canada. It's not clear what the final response will be from the Canadian Food Inspection Agency.
I have to say that I felt they were doing a very good job and applying very tight scrutiny to this product. I think that's partly because they were getting some pressure from above. That's because if it had gone through, there would be no other mechanism to prevent this product from getting used by even just a few Canadian farmers. And if a small amount of that Roundup-ready wheat was in shipments going over to Europe, then all of the shipments would be turned back. That's a multi-billion-dollar industry. The federal government just didn't have a mechanism for saying that because in this case there's large economic harm that can happen with this product, we need a mechanism in place to prevent it from being used in Canada.
I interviewed a number of civil servants who, just like the minister at the time, were completely unprepared to deal with this because they didn't have the mechanism in place. I understand that you're all now looking at whether there's a mechanism for examining the economic harm, and I think that's really important.
Thank you.