Thank you, Chair.
Thank you, committee members, for inviting me here today on behalf of the Canadian Biotechnology Action Network to speak to you about the issue of genetic engineering.
It is important to evaluate what we have learned about genetic engineering from our 15 years of experience with this technology in food and agriculture in Canada.
I work in Ottawa as coordinator for the Canadian Biotechnology Action Network, or CBAN. CBAN is a coalition of 18 organizations across Canada that have various concerns and experiences with genetic engineering. This includes international development organizations such as Inter Pares and USC Canada. It includes farmer associations such as the Saskatchewan Organic Directorate, the Ecological Farmers' Association of Ontario, and Union paysanne. It also includes coalitions of grassroots groups like the Society for a G.E. Free B.C., and the Prince Edward Island Coalition for a GMO-Free Province.
What brings us together is a concern about the impacts of genetic engineering, be they economic, social, or environmental, and the lack of democracy in relation to decision-making over this technology.
The Biotechnology Action Network is three years old. In my role heading the small secretariat here in Ottawa, I conduct research and assist in communications, such as my testimony here today.
I have worked as a researcher and campaigner on these issues around genetic engineering for 15 years. For example, on Tuesday Gord Surgeoner mentioned a council that brought diverse stakeholders together. He was referring to the Canadian Biotechnology Advisory Committee. I participated in the work of this committee when I worked for the Sierra Club Canada. That committee no longer exists.
My understanding from attending the first hearing on Tuesday is that the committee study is open to or explicitly asking for recommendations. I seem to be hearing that there is an openness to examine many issues around the biotechnology industry. We hope this is the case, as we think there are very many critical issues, such as those raised by Bill C-474. I'll speak to some of our analysis of what needs to happen in Canada on this issue, what we think, and what we will be faced with in the new year.
I understand that the debate over Bill C-474 has been a part of triggering these hearings, and we think it's highly appropriate that farmer concern about the impacts of biotechnology instigate an investigation into genetic engineering.
To be clear, I'm talking about genetic engineering as defined by the CFIA, which is recumbent DNA technology. This is what we're referring to when we talk about biotechnology. This is what's at issue and where the controversy largely lies.
CBAN argues that there are fundamental problems with genetic engineering and fundamental problems with the Canadian government's approach to this technology, including our regulation.
I'll talk about some of our concerns by looking at three immediate issues we face in Canada: the possible introduction of genetically engineered alfalfa, GE pigs, and GE salmon.
In the short brief that CBAN submitted to the committee we introduced these three case studies, as well as the issue of genetically engineered wheat, which we think illustrate the need to assess the potential export market harm of applications of genetic engineering. They also illuminate other critical issues and possible negative impacts.
To begin with, CBAN would like to state our support for Bill C-474 and the recommendation that social and economic concerns be incorporated into the regulation of genetic engineering.
CBAN would also like to remind the committee that in 2001, as commissioned by the ministers of agriculture, environment, and health, the Royal Society of Canada's expert panel on the future of food biotechnology published 58 recommendations for regulatory reform. CBAN would like to see the government implement all 58 of those recommendations.
I'd like to concentrate my testimony by discussing briefly the three genetically engineered organisms we must immediately deal with. All three pose major economic and environmental threats, and are or will be highly socially disruptive. They will certainly be socially contested--the alfalfa, pigs, and salmon.
This is the immediate future of genetic engineering. Any of these three could be commercially introduced next year, or even this year. Each is approved via a process that neither the public nor independent scientists have access to. Each is subject to intense opposition for distinct reasons. These three GE organisms illuminate three key concerns we would like to raise, among many.
First, contamination is a reality and has numerous negative social, economic, and environmental impacts.
Second, GE research is under way in universities with either industry or public funds, but without a public mandate.
And finally, government decision-making processes are kept secret and locked away from public participation, and these processes rely solely on privately owned science. These highly secretive processes could allow the commercialization of the world's first genetically engineered food animal.
If we look at this first issue, contamination, which of course the committee has discussed in depth, we see that it has numerous social, economic, and environmental impacts, and that the fallacy of coexistence will collapse if GE alfalfa is introduced. By coexistence I mean the ability of organic or other non-GE crops or farming, non-GE farming, to exist side by side with GE crops. Alfalfa will contaminate. This is a certainty, given the characteristics of alfalfa as a perennial crop pollinated by bees. You've already heard this in the testimony from forage groups. Contamination happens, but farmers always knew this would happen. Contamination was predicted and is predictable, and yet there are no policies that we see or regulatory mechanisms in place to address this.
The issue of alfalfa shows how certain applications of genetic engineering can be a clear threat to some or many farmers, and yet these farmers have no way to communicate effectively to government. There is no avenue for farmer consultation on the impacts they foresee.
As the committee heard in June, conventional forage growers are clear that GE alfalfa would ruin their businesses. As the committee heard from the organic industry, GE alfalfa is a clear and immediate threat to the future of the entire food and farming system in North America.
To summarize, we think the issue of GE alfalfa clearly raises the need to incorporate social and economic considerations in decision-making.
Second, we would say that GE research is under way in universities, as I mentioned, either with industry or even public funds, and yet without a public mandate. And here we could look at the example of "Enviropig". Canada is about to become the origin of GE pork, the GE pig trademarked Enviropig.
Canada could be the first to approve the GE pig for human consumption. The University of Guelph submitted a request to Health Canada in April 2009, and we only know this because this is the one piece of information the university has shared with the public. Environment Canada has already approved the pigs for confined reproduction.
Enviropig was developed by Canadian researchers, with public funds, at the University of Guelph. It was developed with public funds, but without, we would argue, a public mandate. Just like the GE Triffid flax, a university is ready to commercialize a product that consumers and, arguably, farmers do not want. So we would ask where the public oversight is in that process.
The project Enviropig was conceived over ten years ago and was pursued with at least two explicit assumptions that we now see are false: first, that this product was an environmental solution and would be seen as an environmental solution; and second, that consumers would accept GE foods by the time the product was ready for market.
Canada needs to, on an urgent basis, evaluate the social acceptance and economic impact of Enviropig. Our current regulatory system does not allow the government to consider these questions. These are, in practical terms, irrelevant in regulation. Health Canada could approve the GE pig for human consumption in Canada tomorrow. The fact that this decision alone is likely to cause chaos in the domestic and international market for Canadian pork and pork products is irrelevant in our current regulation.
This brings us back to the question of export market harm, the problem identified by Bill C-474, the core problem of approving GE crops despite and regardless of their known, anticipated, or possible economic and social impacts. The possible commercialization of Enviropig also brings into sharp focus the fact that there is no mandatory labelling of GE foods in Canada. The reality is that consumers will avoid pork and pork products in order to avoid GE pork.
Finally, we would say that the government decision-making processes are kept secret and locked away from public participation. These processes rely solely on privately generated and privately owned science, and yet these decisions can potentially have very grave impacts.
I did want to mention the case of the genetically engineered salmon, because it does illustrate some very specific problems that cross into other genetically engineered organisms. Canada is about to become the origin of GE salmon eggs for the world.
Documents released by the U.S. Food and Drug Administration revealed that AquaBounty, a U.S. company, actually plans to produce all of its GE salmon eggs in Prince Edward Island, then ship them to Panama to grow out and process and then ship to the U.S. market.
I and others have called Health Canada to request information about this possible risk assessment, and Environment Canada actually refuses to even tell us if a risk assessment is under way. This is because Environment Canada is now charged with regulating GE animals, including the fish.
In conclusion, the government has invested in the biotechnology industry as an economic driver, as a valuable economic activity. Yet in our view, we see that genetic engineering is actually about to take down Canada's pork producers and organic grain farmers.
It's urgent, in our view, that the government be proactive in resolving these ongoing issues that we see are building into a crisis, a crisis that will cost farmers their crops and organic certification. It will cost hog producers their markets, both domestic and international.
It's a crisis that will take the form of a consumer crisis of confidence in the food system and in our democracy. In the case of GE salmon, it is a crisis that could involve species extinction, a global conservation crisis.
Unfortunately, in our view, these are not exaggerations. These are risk evaluations, and our government currently does not have the tools to ask or address these questions.
We recommend that the government place a moratorium on approval of all new genetically engineered organisms until there has been a wide democratic debate and also a fundamental change in our approach to this technology.
Thank you.