Agriculture Committee on Feb. 26th, 2013

[Brian Storseth, Conservative, Westlock—St. Paul, AB]

Not for GM, but for agricultural products like canola, wheat, and so on, how much do they export outside the European Union?

[Dr. Stuart Smyth]

You can probably speak better to that than I can, Jim.

[Jim Everson]

Yes, I think from the Europeans' point of view, the key issue is the import side of things, because they're very reliant on imported products from around the world. They're importing a great amount of soybean meal and so on from South America into the European market. They've actually taken some steps, from a regulatory point of view, to allow tolerance levels for feed—only for feed—recognizing that they won't be able to get access to protein for their animal feed industry unless they have some tolerance levels built in for GM products for feed. So they've shown some ability to move in that direction to look after their self-interest.

[Brian Storseth, Conservative, Westlock—St. Paul, AB]

You beat me to my next question already.

And that's the point. In this discussion, we can't compare ourselves necessarily to the European Union, because they are the importers of this. It's my understanding from my producers that it's all but impossible to guarantee zero as a presence when you're trying to export these kinds of crops.

[Jim Everson]

Part of the reason LLP is important is that internationally there is a lack of coordination of overall risk assessments and approvals. Typically, if a new canola product is available from one of the seed development companies, it will apply to all our major markets at the same time, and the product will be rigorously safety assessed by that regulator in that market and either approved or not approved, but most often approved.

That will happen in Canada and it will happen in the United States. It will be a little bit more delayed in some of the other countries, and then there are countries where there are significant delays. Dr. Smyth has talked about the European Union, where there are some pretty significant delays.

If that weren't the case, if those approval processes, going through the full risk assessment without cutting any of the standards, happened in a timely fashion in countries within 18 months to two years—that's how long it takes to do one of these full risk assessments—and if those countries assessed those products and approved them at the same time, there wouldn't be a requirement for LLP, because you would have had full approval in these markets.

It's the absence of full approval and the fact that you could have a challenge when you have asynchronous approvals—

[Brian Storseth, Conservative, Westlock—St. Paul, AB]

I have one last quick question.

Mr. Everson, of the producers you represent, how many of them would be strictly organic producers?

[Jim Everson]

Very few—

[Brian Storseth, Conservative, Westlock—St. Paul, AB]

—percentage-wise?

[Jim Everson]

I wouldn't even hazard a guess. I said in my presentation that 97.5% of the canola grown in Canada is a product of biotechnology now, so producers have elected—they have decided that this is a product that really works to their advantage and they've really adopted it in Canada.

Thank you.

[The Chair, Conservative, Merv Tweed]

Thank you.

With that I'll thank our guests for being here today.

We're going to take a brief recess to let our next guests settle in.

For the attention of the members, at the end of the meeting today there will be a motion to deal with the estimates process and when the minister is available, so I'm asking for five minutes at the end of the meeting for that.

Thank you again. We'll take a short recess and invite our new guests to come to the table.

[The Chair, Conservative, Merv Tweed]

Okay, are we good to go?

Thank you, and welcome back everyone. I'll ask everybody to take their seats, please.

Joining us for the next hour from CropLife Canada, we have Stephen Yarrow, vice-president, plant biotechnology, and Dennis Prouse, vice-president, government affairs.

Joining us from the Food and Consumer Products of Canada we have Susan Abel, vice-president, safety and compliance.

Welcome. As you know, the drill is you present, then we ask questions.

Stephen, I'll open with you, and then I'll go to Susan.

[Dr. Stephen Yarrow, Vice President, Plant Biotechnology, CropLife Canada]

Thank you very much. Good afternoon, everybody.

On behalf of CropLife Canada, the trade association representing the manufacturers, developers, and distributors of plant science technologies, including plant biotechnology, I am pleased to appear before you to speak about low-level presence of GM crops in the grain trade, and the need for science-based and pragmatic policies to address this issue.

I will start by providing some context on the significant role modern plant breeding and biotechnology play in keeping Canadian farmers globally competitive. Increased production due to plant science technologies, including products of plant biotechnology, generates $7.9 billion worth of additional economic activity annually for Canadian farmers of field, vegetable, and fruit crops. About 65% of Canada's $10 billion of food surplus can be directly attributed to increased yields that result from the use of crop protection products and plant biotechnology.

In 2012, 97.5%—which you heard about earlier—of canola planted in Canada was improved by plant biotechnology. Similarly, more than 80% of corn and 60% of soybean crops grown in Canada were developed through biotechnology as well. Today Canada has the fourth highest number of hectares, or acres, in the world planted with crops improved through biotechnology.

Plant biotechnology has definitely had a significant positive impact on agriculture in Canada through the precise introduction of desirable characteristics into crop plants within quicker timeframes. Canadian farmers, like many across the globe, are increasingly choosing to make plant biotechnology products a part of their business plan due to the benefits of these improved crop varieties. I am speaking of increased resistance to insect pests and improved tolerances to herbicides. The latter allows farmers to more effectively control weeds without tilling the land, which in turn markedly improves soil and water conservation and productivity.

Beneficial as these traits have been, even more exciting are innovations coming soon that will further assist farmers with drought, heat, salt tolerant crops, etc. In the coming years one can also expect to see new seeds with traits that offer increased yields through cold tolerance, broader disease resistance, and better nitrogen utilization, as well as crops with increased vitamin levels and reduced allergens. We can expect to see an expansion of these innovations too into forage, specialty crops, fruits, and vegetable crops.

What is particularly important to appreciate is the increasing pace of modern plant breeding advances such as site-directed mutagenesis and RNA interference techniques, techniques that tap into existing genes in a plant. To put these new techniques into context, some of the plant science innovations that underpin the current 97.5% of Canadian canola that I mentioned earlier are based on developments from the 1980s, when what we commonly refer to as genetic modification was born, along with the associated expression GM in the 1990s.

However, in reality this industry has been moving on in the intervening years towards deploying the latest modern plant breeding techniques to improve crops for farmers for the next 5 to 15 years. I am mentioning this since it's important to appreciate that agricultural innovation is a moving target that leads to increasingly variable levels of understanding between the Canadian public, policy-makers, and those who earn a living in agriculture. It's not all about GM.

Before getting into the low-level presence discussion, I believe it is important to appreciate how the current GM crops are evaluated and regulated, along with the crops produced by other modern plant breeding technologies presently and in the future.

The Canadian government has got this right. Developed in the mid-1990s, our regulatory systems for products of plant science technologies are based on regulating products and not on the processes used to introduce genetic change and improve crop plants. Canadian regulatory oversight applies to novel herbicide tolerance in a crop, for example, equally regardless of whether that trait is introduced by traditional breeding, mutagenesis techniques, GM techniques, or the next wave of modern plant breeding technologies that I mentioned earlier. In this example, it is the herbicide tolerance that is of regulatory interest, not how it got there, when evaluating the safety of that crop for human food, for livestock animal feed, or for the environment.

Canada can be proud to have the most science-based regulatory system in the world. Unfortunately, however, other countries have adopted process-based regulatory systems focusing on GM processes only.

Of pertinence to today's discussions on low-level presence, global acceptance and approvals of GM-derived crops have varied across the world, ranging from rapid adoption in countries such as Canada, the U.S., and Brazil to low adoption and even GM bans in some European, Asian, and African countries.

These differences lead to misaligned decisions regarding product approvals between key trading countries. This in turn can cause havoc when products that are not yet approved in importing countries are discovered in agricultural export shipments from countries in which they are approved.

This phenomenon is particularly significant for grain shipments, since grain is generally sourced from many different farms and locations as part of the modern bulk handling grain systems. Even the most sophisticated handling infrastructure cannot prevent different sources of crops from becoming, as they say in the trade, "commingled."

In an ideal world, all the existing GM crop varieties would be approved for commercialization in each of the key market countries, and therefore, this commingling would be of no consequence. However, that is not today's reality.

For example, in 2009 a shipment of soybeans from Canada was put into quarantine before it could enter the European Union, because of the detection of dust particles of GM corn. The corn in question, which made it into the shipment of soybeans somewhere in the transportation process, is fully approved for consumption in Canada but not in the EU.

In another case, which you heard about earlier, shipments of flaxseed travelling from Canada to the EU were halted because trace amounts of a GM form of the crop, previously approved in Canada and the U.S. but never commercialized, were found in those shipments.

These examples illustrate what we mean by low-level presence or LLP.

These types of LLP incidents are expected to increase as the number of GM varieties increases around the world, from 33 new products in 2008 to an estimated 125 by 2015. Countries such as China and India are close to commercializing their own plant biotechnology crops, which, although intended for domestic use, could slip into shipments destined for international trade and enter Canada as low-level presence.

Members of the agricultural value chain, including the plant science technology companies that are members of CropLife Canada, believe that these and potential future incidents must be managed through effective low-level presence policies. Neither Canada nor our major trading market countries have such low-level presence policies today, other than the policy of zero tolerance. Adopting a more proactive regulatory approach to managing low-level presence in Canada could avoid unnecessary costs through shipment stoppages, recalls, etc., and help to improve consumer confidence in our food supply and regulatory system.

Fortunately, the Government of Canada is proactively and aggressively attempting to address this issue. Recently, a proposed government policy was shared with stakeholders for input, a policy to address low-level presence of GM crops in grain, food, and feed imports into Canada. This policy focuses on low-level presence situations in which the GM crop in question has been approved for food use in at least one country, and for which Canada has accepted that the safety assessment conducted by that country is consistent with internationally recognized safety assessment guidelines.

The plant science industry applauds this initiative and supports in principle the proposed policy concepts within it, such as the so-called “action level” whereby, if GM material is present in grain shipments below, say, 0.2%, no regulatory action will be required, and also the idea of crop-specific threshold levels whereby, if GM material is found present in shipments below such levels, the importation can be completed following a low-level presence type of risk assessment by Canadian officials.

The industry believes that this bold Canadian low-level presence policy proposal will set the stage for productive international discussions through which other governments could be inspired to consider similar pragmatic policies for low-level presence in agricultural product imports. If these are adopted by Canada's key grain markets, then the Canadian grain value chain, from the plant science industry to the grain handlers, can continue their business with greater confidence and predictability.

That said, CropLife Canada, on behalf of its member companies, emphasizes that while developing pragmatic low-level presence policies internationally for today's GM products is important for agricultural innovation and broader food security initiatives, it is also imperative that the Government of Canada advocate internationally for science-based regulatory systems that address the safety of all products of modern plant breeding.

As mentioned before, new innovations that must be examined for their utility and safety to humans, livestock animals, and the environment are on the horizon. While low-level presence of GM crops will remain a regulatory challenge for the foreseeable future and the grains industry needs an effective low-level presence solution, low-level presence of crops derived from other technologies will also need to be addressed in the not-too-distant future.

This broader approach is consistent with the previously mentioned Canadian regulatory policy to address products rather than the processes used to develop products. Meanwhile, while the world continues to grapple with GM crops, the industry urges the Government of Canada to advocate for harmonized and aligned risk evaluations and decisions across the globe, particularly with governments of our key market countries, that will minimize the current problematic lack of synchrony in regulatory product evaluations and authorizations.

Finally, let’s not forget that so far, all products of plant biotechnology that have been commercialized over the past 15 to 17 years have been assessed and found to be safe for humans, animals, and the environment. These products are the most safety evaluated products ever produced by humans. Canada can be proud of being at the forefront of this type of plant science innovation and its regulatory framework. These products have significantly benefited Canadian farmers and consumers, in addition to assisting Canadian agriculture to produce major volumes of products, such as exported grain, for countries that depend on them for their food security.

Thank you again for allowing me to address this important subject with you today.

[The Chair, Conservative, Merv Tweed]

Thank you.

Ms. Abel, welcome.

[Susan Abel, Vice President, Safety and Compliance, Food and Consumer Products of Canada]

Thank you very much, and good afternoon.

Food and Consumer Products of Canada welcomes this opportunity to contribute to the Standing Committee on Agriculture and Agri-Food’s consideration of the proposed policy to manage the low-level presence of genetically modified organisms. Since the initial announcement of the proposal by Agriculture and Agri-Food Canada in 2011, FCPC has been actively involved with the consultative process.

For those of you who are not familiar with us, FCPC is the voice of Canada’s leading food, beverage, and consumer products companies that manage and distribute the products that sustain Canadians and enhance their quality of life. Founded in 1959, FCPC is a trusted source of information about our industry. Our member companies make most of the products found on grocery store shelves that you enjoy daily. If you look on the back of the information handout, you'll see the logos of our member companies, and, as you can see, we certainly do represent the majority of foods and consumer products that you'll find in stores.

Our 6,000 processing facilities across the country purchase and use over 40% of what Canadian farmers produce. In Ontario and Quebec our members purchase closer to 70% of what farmers in those provinces grow.

The commercialization of GMO crops in Canada now stretches back to 1994, nearly 20 years. In addition to those early varieties of herbicide-resistant corn, many more commodities have since been and continue to be developed, such as those designed to reduce pesticide use or to allow crops to be grown in drought-prone areas, including things like tomatoes, potatoes, soy, canola, and cotton. Farmers across Canada successfully grow a broad range of crops based on this technology.

With the adoption of this technology in other countries, there now exists a very real possibility that a genetically modified organism could be approved in another country prior to its approval in Canada, and that traces of that commodity could theoretically reach Canada through the use of large-scale carriers, such as cargo ships or bulk shipping containers. Our members are very pleased that Agriculture and Agri-Food Canada has adopted a proactive approach to managing these possible scenarios. FCPC firmly supports regulations based on sound science and policies that support a predictable business environment. We believe that with careful consideration, a low-level presence GMO policy can be developed based on these sound principles.

Under our current zero tolerance policy, shipments with low-level presence GMOs would have to be rejected. Given that these shipments are often very large, the Canadian processing facility that ordered the grain could potentially sit idle for many weeks waiting for replacement material to arrive. The potential disruption to Canadian companies is enormous: product lines would be halted and layoffs could occur. For grains that are converted to oils or flour, many downstream customers could find their facilities also sitting idle waiting for ingredients. The disruption could eventually affect retail sales and availability to the consumer as most manufacturers limit inventories for reasons of efficiency.

Our members support the proposed overarching framework in principle because the process has been clearly stated: if an unapproved GMO is found at a level below an action level, the material will be released; if the unapproved GMO is found above this action level, a risk assessment will be conducted. If the level found exceeds a defined threshold level by commodity, the material will be rejected.

That being said, our members do have some questions and comments that were shared with Agriculture and Agri-Food Canada during their consultation phase. Agriculture and Agri-Food Canada requested stakeholders to comment on either a 0.1% or a 0.2% level for this action level. In this discussion, it is important to remember that this policy is designed only to oversee genetically modified organisms that have already been declared suitable for human consumption by a competent authority. So we’re not talking about countries that have situations that are not necessarily comparable. As a result, we believe neither of the proposed action levels of 0.1% or 0.2% are appropriate because the test kits that we have available are not accurate enough or precise enough for results that are less than 0.1%.

That is to say if you get a test value result of 0% to 0.1%, you have to treat the answer as if it were 0%. Our concern is that a value of 0.1%, as an action level, will result in the need for frequent risk assessments. That means the policy does not meet the key objective of predictability for commerce. It takes time to conduct risk assessments, and the shipment will be held until the risk assessment has been completed. We have seen no service standards to regulate the time needed to conduct that risk assessment.

As an action level, 0.2% is still a very low number. The non-GMO project in the U.S. has set its definition of GMO-free as up to 0.9% presence. Also note that Switzerland accepts up to 0.5%. It is interesting to note that the level of GMO presence in identity-preserved corn grown in Canada and the U.S. can exceed the non-GMO project threshold of 0.9%.

With regard to the proposed use of thresholds, our members support the proposal to set levels according to commodity type. We can't really comment further because we have not seen much detail on how threshold levels are to be set.

For both action levels and threshold levels, our members would benefit from Agriculture and Agri-Food Canada providing insights into the data or scientific reviews used to determine these proposed levels. For this policy to be successful, acceptance from stakeholders, including consumers, is essential. The Government of Canada has a responsibility to ensure that this happens. It is critical to align our policies with those of our major trading partners. Our members would like to see engagement with trading partners prior to the implementation of the policy to ensure alignment. It is important to our members that the implementation of this policy does not create an inadvertent barrier to trade.

We firmly believe that none of our members' concerns are insurmountable, but the policy needs some refinement before implementation to ensure it meets its objectives, which are to support the predictable flow of materials globally while ensuring the continued safety of the Canadian food supply.

In summary, we wish to thank the standing committee for this opportunity to discuss Agriculture and Agri-Food Canada’s proposed policy on low-level GMOs. Our members support the leadership role Agriculture and Agri-Food Canada has taken on this emerging issue. We will happily continue our engagement with Agriculture and Agri-Food Canada to ensure the policy is meaningful and will effectively manage events should they arise. Equally important is for Agriculture and Agri-Food Canada to ensure this policy is accepted and in alignment with our major trading partners.

Thank you very much. I look forward to your questions.

[The Chair, Conservative, Merv Tweed]

Thank you.

Ms. Brosseau.

[Ruth Ellen Brosseau, NDP, Berthier—Maskinongé, QC]

Thank you very much, Chair.

Thank you to our witnesses.

This is a very important topic. It's very complex. I'm trying to understand it. When we think of the population expansion to 2050 we have to move forward in looking at trade, and it's not something that can be done in a day. It's ongoing and requires working together. It's a huge issue.

You talked about 0.1% and 0.2%. Looking at other countries like Switzerland with 0.5%, what level are you looking at for Canada to accept? You said you didn't have a number in mind, but would that be more toward 0.1% or the 0.5%? Where do you think Canada should align?

[Susan Abel]

We can't answer what the level is because we don't believe there has been enough science-based information to determine what that level should be.

The numbers we are referring to in the discussion today reflect the real-life situation of a fairly mature GMO situation in North America. We've been growing genetically modified crops here for 20 years, and we do have a little experience whereby we are seeing, for example, trace amounts of genetically modified showing up in what we call identity-preserved crops, because of course we do have consumers who are looking for choice and various streams of commodities are available.

We are seeing very low levels of commingling in those existing commodities, and they may be a good starting point for determining what that level should be.

The other thing that's really important to remember is that these particular grains would already have been through a risk assessment by a competent authority. We're not talking about something just showing up on our doorstep.

[Ruth Ellen Brosseau, NDP, Berthier—Maskinongé, QC]

Zero tolerance is not the way?

[Susan Abel]

Zero tolerance is not the way.

[Ruth Ellen Brosseau, NDP, Berthier—Maskinongé, QC]

I guess you would agree 100% that zero tolerance is not the way to go.

What kind of percentage are you looking at of acceptance? Is it 1% or 2%? I know it's all science based but it seems that it's debatable too.

[Dr. Stephen Yarrow]

It's important to put this proposed policy into perspective. I think you've grasped that two different thresholds are being proposed. There is this action level which is supposed to take into account dust and pieces of grain or maybe individual grains that are getting commingled. These are very low levels. To reiterate, this is about product coming into Canada that's already been approved by another country in a way that Canadian officials are comfortable with. It's to try to prevent huge shipments, these massive ships with tens of thousands of tonnes of grain coming in, being rejected just because of a dust particle and that kind of stuff. That's what that 0.1% or 0.2% action level is designed to cover.

There's another threshold which is the crop-specific threshold. I'm not speaking on behalf of the grain industry. I'm speaking on behalf of the trade developers. I understand that the grain industry is looking at numbers around 2%, 3%, or maybe 5%. It just depends on the crop. In those situations the government regulators will need to do a so-called low-level presence type risk assessment to ensure there's no risk to Canada if shipments were to come in with the levels I've just mentioned.

[Ruth Ellen Brosseau, NDP, Berthier—Maskinongé, QC]

It's been brought up before when you look at organic. I have some organic farmers in my riding. How would this benefit the organic industry? Would this benefit them? I'm looking at the paper you gave us with all the companies you represent. Are there any organic companies?

[Susan Abel]

Absolutely.

We do have member companies that do organic and we also have some member companies that have products that we call identity-preserved or for other terms, GMO-free.

[Ruth Ellen Brosseau, NDP, Berthier—Maskinongé, QC]

Have they voiced concerns about this? What's their point of view and what's their threshold if they have one?

[Susan Abel]

At this point because we really haven't seen enough science we haven't really been able to discuss what those thresholds would be. But we all agree that this is something that has to be managed. It's better to be proactive than to suddenly discover we have a serious problem on our hands. Where our members have a commonality is the importance of having a plan in place should this material arrive. Remember, we haven't actually had this happen in Canada yet. It's really good that we're thinking ahead to something that could possibly happen.