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.