Agriculture Committee on March 5th, 2013

[The Chair, Conservative, Merv Tweed]

Thank you, and good morning, everyone. Welcome to the Standing Committee on Agriculture and Agri-Food, meeting 70.

Our orders of the day are pursuant to Standing Order 108(2), a study of the agricultural and agrifood products supply chain, grains and oilseeds.

Joining us today from the Canadian Seed Trade Association is Patty Townsend, chief executive officer, and via video conference from Sherbrooke, Les amiEs de la Terre de l'Estrie, André Nault, president, and Laurier Busque, administrator. Bienvenue.

As always, we'll open with some presentations, and then we'll move to the committee for questions. I'll ask Ms. Townsend to please start, and then we'll move to our guests through video conference.

[Patty Townsend, Chief Executive Officer, Canadian Seed Trade Association]

Thank you very much for inviting us.

First, I apologize very much if I lose my voice. My directors kindly shared their cold with me when they were in Ottawa a few weeks ago, and they refused to take it back.

On behalf of the Canadian Seed Trade Association, I'd like to thank the committee for the invitation to meet with you to talk about low-level presence in seed. This is one of the highest-priority issues for our members at this time.

Just as a little background on the Canadian Seed Trade Association, we represent 130 member countries that are involved in all aspects of seed, from research and development and plant breeding, to production, processing, marketing, and trade. Our members work in 50 different crop kinds. We supply the domestic market, and we export on average to about 70 different countries around the world.

Our membership is very diverse. It includes small, single-producer retailers and large multinational companies. We represent marketers of vegetable and herb packet seeds, and we also have the large grain handling companies in the west. We also represent organic seed producers and suppliers and the world's biotechnology developers. As you can see, we have a very diverse membership. But our diverse membership comes together in support of CSTA's mission, which is to foster seed innovation and trade.

Agriculture Canada estimates that nine out of every ten bites of food taken around the world start with the planting of a seed. Seed is the foundation of the world's food supply, and it's an important contributor to its supply of fibre, fuel, and industrial products. Seed is also the driver of the innovation that the world's farmers are going to need to feed, fuel, and clothe a world population that's forecast to reach over nine billion within the next 40 years.

Almost every week there is another announcement of a significant achievement in plant breeding and research and development by the world's private and public plant breeders and researchers. Advances are being made in drought and heat tolerance, insect and disease resistance, efficiency of water and resource use, and in the quality and health benefits of plant products. These advances are being made through traditional plant breeding, with the use of recombinant DNA technology and through new and emerging breeding techniques. All of them are focused on greater productivity, a smaller environmental footprint, and improved quality.

In 2012, 17.3 million farmers in 38 countries planted 420 million acres of genetically enhanced crops. Canada was the first country to commercially produce GE crops, and we're now the fourth-largest producer of these crops, with almost 29 million acres planted to GE canola, corn, soybeans, and sugar beets.

Given that scale of production, the fact that production is for the most part done in large, open biological systems, and given the scale and nature of transportation and trade, it's well understood that low levels of GE material in non-GE shipments—a low-level presence—is likely.

While many countries have embraced the science and approved GE events, many have not yet and others are unlikely to ever fully approve the technology. Zero tolerance in these countries does and has resulted in the rejection of shipments, and the impact on trade is substantial.

Canada has taken a leadership role to develop a science-based, predictable, and trade-facilitating domestic low-level presence policy that we hope will serve as a model for countries around the world; however, that policy does not apply to seed.

Canada is a significant producer and exporter of seed. In 2012 seed was grown on 1.2 million acres across Canada, and as I said already, much of that seed is exported, some to countries and regions that maintain a zero tolerance for GE material.

Unlike with grain, seed production, handling, processing, and trading systems are subject to very strict regulations to ensure purity, quality, and trueness to type, but seed is produced in the same regions and often in the same fields as grains and oilseeds, including those that contain GE events. For example, 75% of Canada's certified seed acres are in the prairie provinces of Alberta, Saskatchewan, and Manitoba. As well, 98.9% of the canola that's grown, is grown in those provinces, and 98% of the canola that's grown is genetically engineered.

So despite the very stringent control practices in the seed industry, there is a possibility that there could be a very low-level presence of GE material in seed lots, and that does impact trade. It's impacting trade most significantly for our forage seed exporters, whose second-largest export market is the European Union. Exports of forage seed to the EU countries were valued at about $31 million in 2012.

Since most EU countries—not all, but most—have a zero tolerance for GE in seed for planting, our members are now facing existing contracts that are being modified, and new contracts are requiring legal declarations that the seed is 100% GE free. Some of our members have lost sales as a result of that because they cannot make that guarantee, and others have had shipments rejected. One shipment of timothy seed was actually rejected for the presence of .00009% GE, which is very, very, very small dust.

Given the large commercial production of GE crops around the world, the potential for trade disruptions and loss of markets is growing. The best solution for all of this would be for all trading countries to implement science-based timely approval systems for GE products. The next best solution would be for trading countries to recognize and accept the science-based approvals of other countries. While we're working toward that with our industry and government partners, in the more immediate term, and if those two objectives cannot be reached, we need an international low-level presence policy.

In the seed industry, we define low-level presence as the unintended presence at very low levels of genetically engineered seed that has been approved in at least one other country but not in the country of import.

As I said, Canada has taken a strong leadership role to develop a low-level presence policy domestically that can be used as a model around the world for grain, but it does not include seed. It is a very high priority for our members, given all of the impacts that we've already been facing and continue to face on trade.

We're working with our government to start the process to design a Canadian LLP policy for seed, and we hope it can, like our grain policy, serve as a model for other countries. We're also working closely with the international seed industry and with the industry and regulators in the Americas on the issue.

Our goal in the short term is to have seed trading in the Americas where over 90% of the GM production is. We'd like to have seed trading in the Americas under a common LLP policy. We support an LLP policy for seed that acknowledges that it's not practical or achievable to require a zero presence; that it's science-based, practical, and transparent; that it's proactive and predictable; that takes into account the safety and risk assessments of other countries; and that it takes into account the rigorous requirements to maintain seed purity and trueness to type, and the international standards that govern that and that govern seed trade.

Thank you very much. I'd be pleased to answer any questions.

[The Chair, Conservative, Merv Tweed]

Thank you very much.

We'll now go to our witnesses through video conference. I'm not sure which one wants to present, but I'll just ask you to commence, please.

[André Nault, President, Les amiEs de la Terre de l'Estrie]

Thank you very much.

My name is André Nault, President of AmiEs de la Terre de l'Estrie.

[Laurier Busque, Administrator, Les amiEs de la Terre de l'Estrie]

My name is Laurier Busque, Chair of the Zero-Waste Committee.

[André Nault]

Thank you for inviting us to participate, especially from Sherbrooke. You saved us nine hours of travel. Thank you kindly.

Before we begin,we'd like to tell you that our position has to do with what is going on right now. Our past is the key to our future, and that future is worrisome.

AmiEs de la Terre, or Estrie friends of the earth, is an environmental organization. Both of us are volunteers. We have no financial ties with any company. Now, I will go to our introduction at the bottom of the page.

Today’s greatest challenge related to food is a lack of knowledge of where that food comes from. The low-level presence, or LLP, of unauthorized genetically modified crops in grain shipments imported into Canada adds to this challenge. Agricultural practices are so different from country to country that the origin of foods is becoming essential knowledge if products are to be socially accepted. In Canada, the mere fact that the studies submitted by genetic modification companies are kept secret places a burden on a fair agri-food chain.

[Laurier Busque]

We would now like to discuss two sources that we believe are at the origin of the problem of the environmental drift of genetically modified organisms, or GMOs.

The first is the unrestrained development of genetic modification technology. Figure 1 contains a diagram illustrating this aspect.

Over the years, four stages of GM plant development have been observed. Stage 1 is the introduction of a transgene into a plant. That transgene can allow the plant to produce an insecticide or to tolerate an herbicide. That practice was authorized in Canada in 1996. Stage 2 came about the following year: the introduction of two transgenes into a plant, either to produce the Bt insecticide or to tolerate an herbicide. Stage 3 is the introduction of three transgenes into a plant, two insecticides and one herbicide, or vice versa, two herbicides and one insecticide.

In 2011, all of that culminated in the authorization of SmartStax by Health Canada and the Canadian Food Inspection Agency. SmartStax is a plant containing eight transgenes, with six producing insecticides and two tolerating herbicides. We believe the unrestrained development of GMOs is cause for concern.

The other source of the environmental drift is inadequate risk assessment. We have a table that summarizes everything. It shows two approaches to the risk assessment of GMOs. The first column shows the precautionary principle, which is used mainly in Europe, and the second column shows substantial equivalence, which is used mostly in Canada and North America.

We feel that risk assessment in Canada is clearly inadequate. There is a major difference between Europe and North America in terms of the assessment of GMO-related risks. In Europe, assessment systems based on the precautionary principle attach much greater importance to environmental impacts, whereas in North America, risk management emphasizes the commercial interests of the industry.

A bit further on in the document, we've included a quote from the Quebec government's science and technology ethics commission. As early as 2003, the commission was warning of the potential risks of GMOs to the environment. It said the following:

In terms of the environment, however, harm to biodiversity, the contamination of other crops or wild flora, the development of resistance to pathogens, and toxicity to wildlife are potential risks that cannot be ignored, particularly because we must be aware that if they come to pass, they could result in irreversible evolution for nature or transformations that will be difficult to remedy if required.

That comes from a document the commission released in 2003.

So 10 years ago, we were already being warned of the potential dangers. And today, there are studies that show those dangers are no longer potential but very real.

[André Nault]

In 1996, Canada authorized transgenic canola, and seven years later, in 2003, no accreditation for organic canola was granted in Canada. How did a seed that had only been an LLP become invasive in only seven years?

The case of organic flaxseed is even more striking. Transgenic flaxseed was approved in 1998 and withdrawn in 2001. In 2009, Germany reported the presence of GM flaxseed in processed products in 34 countries.

The first explanation for the origin of this problem is the open field trial at the University of Saskatchewan in 1995; from then until 2001, a total of 40 seed producers produced some 200,000 bushels of flaxseed for sale to farmers.

We feel that, in Canada, risk assessment is clearly inadequate for the production and use of agri-food GMOs. The Canadian Food Inspection Agency’s response to the complaint we submitted in February 2012 illustrates this inadequacy.

A recent study looked at the presence of pesticides in rivers in Quebec. The herbicides used in conventional agriculture are applied by spraying when the seedlings emerge from the soil. In contrast, the herbicides used on GM plants are applied later in the season and have broader impacts on the natural environment. With respect to Roundup, or glyphosate, the study had the following to say:

The detection frequency and measured concentrations for glyphosate continue to increase. This herbicide, which is used on GM corn and soybean crops, was detected, on average, in 86% of the samples collected from the four agricultural rivers under study. The dominant crops in the watersheds of those rivers are corn and soybean

Figure 3 illustrates that.

One of the claims often made by GMO advocates is that herbicide use is reduced when transgenic plants are grown. The results of Giroux and Pelletier’s study show that the opposite is true.

In light of the consequences of contamination by transgenic flaxseed, AmiEs de la Terre de l’Estrie asks that Agriculture and Agri-Food Canada establish zero tolerance for the low-level presence of unauthorized GM crops in grain shipments imported into Canada.

Thank you very much.

[The Chair, Conservative, Merv Tweed]

Thank you.

Ms. Brosseau, you may go ahead.

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

Thank you, Mr. Chair.

I want to thank all the witnesses for their presentations and their viewpoints.

I have a question for AmiEs de la Terre.

Your organization is non-profit. How many members do you have?

[André Nault]

Somewhere between 800 and 900 members.

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

That's a lot.

The government recently held consultations on the presence of GM crops in imports. Were you consulted?

[André Nault]

We provided a short statement that read: “If they can be detected, why not label them?” That was our submission.

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

Okay, but in terms of the government consultation, were organizations like yours consulted?

[André Nault]

We were consulted and our only comment was this: “If they can be detected, why not label them?”

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

I fully agree with you.

As far as labelling goes, can you tell us how the organic industry will be affected by the government's proposal?

[André Nault]

It will have a huge impact on the organic industry.

Take flaxseed as an example. If you import grain with a GMO content of just 0.1%, contamination will span the entire country. We looked at canola, and it took 6 years for it to become contaminated. In the case of flaxseed, which had been in production for just 3 years, 34 countries were contaminated. Coexistence is impossible if the unrestrained development of GMOs is allowed to continue; they can survive all over the world.

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

You are calling on the government to establish a zero-tolerance policy.

[André Nault]

Permanently.

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

How can the government achieve and maintain zero tolerance? Some witnesses have proposed or agree with a threshold of 0.1% or 0.2%. They've even talked about other countries with higher limits on genetically modified products that are imported.

How can Canada maintain zero tolerance?

[André Nault]

There is no labelling. How will we know for sure that the content is 0.1% or 0.2% without any labelling? Europe has a GMO labelling system. Europe decreased its GMO concentration in imported seed grains from 50% to nearly 0%. European countries have maintained a zero tolerance as far as GMOs are concerned, and they ensure products are labelled.

That's somewhat the same for us. If imported grain contains GMOs, without labelling, what is there to say that an evaluation was done and that the threshold does not exceed 0.1%? Do you see what I'm saying?

In contrast, the tolerance should appear on a label. If we had a labelling system, consumers could see that the level was 0.1% and think that's good. But we don't.

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

Someone could argue that organic products are certified and bear a label stating they don't contain GMOs. That's not enough in your view. You want labels on everything.

[Laurier Busque]

I could answer that, if I may.

When it comes to organic production, not only do farmers bear the burden of proof, but they also bear the burden of cost. They must ensure that their product is GMO-free, and they have to bear that cost. They have to take precautions and even financial risks to establish buffer zones to protect their crops.

That is another consideration. If we want organic farming to develop, we have to help those farmers do everything they can to prevent GMO contamination.

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

Patty, I just have a quick question for you. I'm sorry, I did come in a little late.

If you could reference the proposed policy with the action level of 0.1%, 0.2%, what percentage, science-based, are you asking for acceptance into Canada?

[Patty Townsend]

First of all, the policy that proposes that action level does not apply to seed; it's only for food and feed. In the seed industry, we are not yet at the point of determining what the action level and the thresholds would be for seed. What we are saying is that we need to make sure that whatever policy gets developed for the grain industry is not at a level that we can't carry as the foundation of the grain industry and the seed industry. So if it's set so incredibly low and they expect the seed industry that's produced in the same open biological systems to carry it, that would be difficult. Conversely, we wouldn't want to set a threshold in seed that's at a point where it would make the grain threshold way too high for international acceptance. So we need to work on that.

We have been saying all along that seed is different from grain, for a number of reasons. One is that we intentionally introduce our product into the environment, and the other is that the seed industry already practises very strict regulatory controls to keep our product separate and to keep it pure and true to its variety and its identity. So we believe that needs to be taken into consideration. We've been trading seed around the world under those standards for years, for decades, and it does allow very small proportions of other seeds. In a lot of clover you're allowed one canola seed, for example, in certain classifications, and we know that the one canola seed, if it's coming from Canada, is likely GM or GE.

So we're talking about taking those into account, and as much as possible mirroring those standards that are already in place to govern seed. But we have not actually defined the threshold levels yet.