Thank you, Mr. Chair.
I thank the committee for having me here to speak to you.
I am the president of Ontario Agri-Food Technologies. This is a consortium of our grower associations, our major farm associations of Ontario, universities, and private sector companies, from big multinationals to a lot of small Canadian, Ontario companies. I would say that my board is...half of which have to come from the farm associations, as they helped create the organization.
I'm going to be talking at a very high level to get some key points out.
First, in my opinion and our opinion, the Canadian regulatory system on biotechnology is not broken. We have arguably the best and most respected regulatory system in the world. There should not, therefore, be wholesale change, but we can, as with anything we do in society, continue to improve.
One thing I would like to emphasize is that the way we regulate biotechnology is not biotechnology, per se. In Canada we regulate the product, not how we got there. In other words, science can create herbicide tolerance through genetic engineering, mutagenesis, out-crossing. There are many ways that you can end up with a product that is novel and different. We actually regulate the product, not the process, which scientifically is the most valid methodology to do so.
In my opinion, the regulations have the ability to protect Canadians and global customers. I agree that we have to look at global customers, and in fact big companies--make sure they have to have a number of companies before they actually allow a product to be sold.
Plants with novel traits have been grown in Canada since 1995, so 15 years. To my knowledge, and again on a scientific basis, there are no validated cases of harm to either humans or the environment. I am, however, aware of lots of benefits--no till, reduced pesticides.
Again, the thing I would also emphasize is that when 80% of the farmers in the prairies use genetically engineered technology, 70% of our soybean producers and about 60% of our corn producers are buying these products. Anybody who knows agriculture knows that farmers are not dumb people, and they look at the value to them. I do agree that we have to figure out systems to protect others. So I emphasize that from multinationals to NGOs, we have the same objective: to create safe products that provide value to producers and, importantly, value to consumers.
Regarding safety, we must recognize that there are no absolute guarantees. I will be flying home tonight, and my risk factor went up because of the weather out there today. It needs to be balanced with allowing innovation to occur, innovation that benefits society and employs Canadians. So in my opinion, terms such as the “weight of scientific evidence” and “does not represent unacceptable risk to human health and the environment” are the lexicon of the regulations that should be used with “there are no absolutes”.
The other thing I have to emphasize is flexibility. Flexibility must be incorporated into the legislation and how it's managed. The probability of risk is very different depending on different products. For example, using this technology in Quebec, Medicago Inc. is developing new types of vaccines in greenhouse situations.
In Guelph, we have PlantForm that is developing new kinds of antibodies, where we grow them in plants. All of these are going to be maintained and produced in a greenhouse situation—containment. How we ensure that these do not get outside those greenhouses is the key, but that's part of the technology.
Similarly, right now in the Okanagan Valley we have Okanagan Specialty Fruits, which has developed a methodology for not having your apples brown--i.e., when you cut an apple and it turns brown, they prevent the browning.
In my opinion, that's not how things spread; it's a food safety issue. So the regulatory has to analyze the product and the risk associated with the use pattern.
Similarly, the next wave of this technology is drought resistance, frost resistance, salt tolerance. There I am concerned about weediness and how things move out, and whether or not these crops become more of a problem.
So we have to look at safety there, and we also have to look at environmental impact. A key message is that one size does not fit all when we analyze these products. You have to look at the use pattern along with the actual product.
We should share data. We are not the only country in the world that is analyzing and regulating these products, and I think we should share data, basic toxicology. There's a lot of standard information that should be shared between countries, and hopefully we don't have to continually reinvent the wheel.
We should have transparency. All toxicology and environmental data used by regulatory authorities to make decisions must be available to interested parties. I understand that there is certain proprietary information that may not be available, but I emphasize that for everybody to feel confident, the data should be available. A decision document describing the basis of the regulatory decision should be provided to any interested party that wants to see it.
The other key thing is to regulate novelty. In other words, the product is different. I guess the question that's not in the legislation is at what point something is no longer novel. If you look at soybeans in Ontario, 70% are, in this case, herbicide tolerant. We've been using them since about 1998 in very large numbers. In fact, the novel soybean is, by far, the most common soybean out there. Do we go 10, 15, 20, 30, or 100 years before we decide that it's no longer novel? That is a key question that I think is important.
Another one that's really interesting and that must be looked at is new uses. We are developing crops that do not have feed uses and do not have food uses, yet that is how we're regulating these technologies of change. There is camelina on the prairies and miscanthus for energy. We're looking at a number of products right now that we will not use for food or feed. They will be for industrial purposes. How do we regulate those crops, given current legislation?
There is another key thing that I think is important for Canadians and for the world. We always look at the risks, and I'm the first to stand up and say that all those risks must be looked at. But I think we should also look at benefits. Canola is a classic example. If I have a product that is trans-fat free--in our province of Ontario, obesity and type 2 diabetes are a $5-billion tax problem for our society in terms of health care costs--can we look at the benefits to Canadians as well as risks? I think that's important, particularly when we get into foods.
The other key thing is consistency. I've worked with industry for a long time. I've been a faculty member for 29 years. If investors are going to put money into these projects, many of them will last 13 or 14 or 15 years, with $10 million, $20 million, or $100 million invested to get a product to market. If our landscape is constantly changing its rules, and I don't know that landscape, it is difficult to get investors interested. I have to emphasize that if we want innovation and we want to continue to be excellent in this area, then consistency of rules, with flexibility for a particular program, is important to me.
We also want to learn from regulatory experience. We now have 15 years of experience with some of these crops. Can we have, for example, as we do in other regulatory areas, what we call minor uses? Some of the best, with the greatest environmental potential, are smaller-acreage crops. We cannot justify the cost because of the regulatory burden associated with them. In other areas, we say that's a minor use. We see what's happened in the large acreages. Can we, then, learn from that? We should incorporate some experience.
In agriculture, we are moving from input traits to what I call the environmental traits--the drought, the salt tolerant, and all that--and to the output traits for the consumers--healthy oils, fruit that doesn't turn brown, and so on.
In my opinion, our regulatory system has served us well. We must continue to ensure flexibility and transparency and to eliminate unnecessary costs if we are to continue to ensure the global competitiveness of our industry and the protection of our citizens.
Thank you.