Agriculture Committee on March 5th, 2013

[Patty Townsend]

We have to more than double our production within the next 40 years. We have to do it on essentially the same land base. There's not a lot of land left that we can bring into agricultural production. There's competition for that land from urban development. We have to do it while being challenged by climate change. Pests are now being found in areas where they were never found before because of changes in temperatures and climate. We have to do it with a decreasing share of the world's water, because the competition for water is increasing. We have to do it while our ability to use resources for fertilizer is being affected. It's been said that the world's sources of potassium and some other fertilizers are past their peak production now.

Given those challenges, and given the fact that we need to double our production in 40 years, I don't think we can do it without new technology. It's not just what has been classically defined as genetically enhanced or genetically modified or recombinant DNA technology. There are all kinds of new breeding techniques that are now being explored to ensure that we can leave a smaller environmental footprint, produce more food, and make it healthier and safer.

[The Chair, Conservative, Merv Tweed]

Thank you.

Due to time constraints, I'll have to thank our guests for being here today. Merci.

They were great presentations, and it was a very stimulating conversation, so I thank you for your time.

We're going to take a short recess while our new guests settle in. The committee is suspended for two minutes.

[The Chair, Conservative, Merv Tweed]

Welcome back to the second hour.

Joining us today from the Canada Organic Trade Association is Mr. Matthew Holmes, executive director. Joining us by video conference from Guelph, Ontario, as an individual, is Mr. Rene Van Acker, professor in the department of plant agriculture at the University of Guelph.

Welcome, both of you.

We will start with Mr. Holmes and then move to Mr. Van Acker. We're looking for a presentation of roughly nine to ten minutes. Then we'll move to questions.

Mr. Holmes.

[Matthew Holmes, Executive Director, Canada Organic Trade Association]

Thank you, Mr. Chair and honourable members.

It's my pleasure to again be before you representing Canada's organic sector and speaking on proposed policies on low-level presence of GM crops in feed and food.

First, I would like to brief you on where the organic sector stands today.

The latest global figures, released just two weeks ago, show that the world organic market is now valued at $63 billion per year in consumer sales. Canada is now the fourth-largest market in the world for organic, valued conservatively at $2.6 billion to $3 billion per year, and is among the top 10 countries by consumer spending on organic food.

Production is also increasing. If we look at the 2011 Census of Agriculture, we see that total farm numbers in Canada have declined since 2001 by 17%, while the total number of certified organic farms has increased by 66.5%. Organic farms support family farms and provide them with market opportunities at home and abroad. Organic offers a compelling agricultural success story that shows no signs of slowing. Organic can help revitalize our rural economies, feed our cities, and provide lucrative opportunities at export.

The committee has heard already from a number of experts on the proposed LLP policy. Like many such issues, it is rife with complexity, with minutiae, and, as I'm sure it feels at times, with angels dancing on the head of a pin, so my approach here will be to take a step back and apply what logic I can to the proposal.

The stated objective of the policy is to facilitate trade: to remove technical irritants that could result in hypothetical products being barred from entry at our own borders at some time in the future. Incredible amounts of time and money have already been spent to create and consult on a solution for a problem we have yet to encounter, at least at import.

Of course, we've encountered LLP issues with our own exports, but it's questionable that the countries currently blocking GMOs in this way will change their tune just because we've lowered our standards. In fact, Germany is already on record as stating that it will oppose any EU move to allow LLP for food, so perhaps more importantly from my perspective, from my sector's perspective, the proposed LLP policy brings with it the danger it would have for the organic sector, the exact opposite effect of the one it is intended to have.

An LLP will introduce new, unknown, and untested GMOs into Canada. It will increase the exposure of organic farms and manufacturers to contamination from GMOs, which are prohibited under our production system. Also, it will create an environment of heightened scrutiny and suspicion of Canadian exports, which will invariably result in increased costs for producer and trader and inhibit the progress we've made in market access.

I would be remiss if I did not also point out that the genesis, or the seed, if you will, of this proposal is based on concerns around continued market access.

For many years, the organic sector has asked for market access and economic impact considerations to be used in the approval of GMOs. We have lost many products and markets we used to have due to the introduction of these innovations. We have been told repeatedly that such demands do not hum along with the mantra of a science-based approach to approving plants with novel traits.Yet we now find ourselves debating a proposal that, at its heart, stems from concerns that markets we sell to do not necessarily want some of the products we are growing.

That was my preamble, Mr. Chair. I'm cognizant of the time you have granted me, so for the rest of my remarks I wish to focus on insights and recommendations for an LLP policy.

It's my opinion that an LLP policy might be realized in a way that ensures this government's commitment to accountability and transparency is upheld. The LLP policy proposes to accept that any GMO product that has been approved in a way that is consistent with the codex guidelines should be permissible if present below a certain limit.

Codex currently has 185 member countries, including many that make the nightly news, such as Zimbabwe, Mali, Iran, and China. I don't think any of us are in the practice of buying baby formula from China these days, and this of course has nothing to do with China's regulatory rigour; however, there is a certain trust deficit that emerges somewhere between what's on the books and what's on the plates. It is reasonable, I think, to predict that Canadians will have some concern that Health Canada is no longer reviewing and approving crops with novel traits, as proposed in this policy.

This would be the first instance of what I would call the “accountability gap” that's in the current policy and that I think could be addressed. We are tacitly approving things from a foreign jurisdiction that may or may not meet our standards in practice, regardless of how codex guidelines have been implemented. In the short term, we are washing our hands of due process and regulatory responsibility, but perhaps also, in the future, we could be undermining our right to use domestic requirements to vet such products.

The proposed LLP policy also includes crop-specific threshold levels, a higher tolerance than the basic action level, which is determined by what is deemed practical or possible by an industry advisory body. So first we allow China to approve which GMOs are allowed into Canada, and then we ask the industry that brought them here what they think is an acceptable level of contamination. The accountability gap just widened considerably, from our perspective. Meanwhile, with Canada as the first self-declared LLP safe zone, any rejected shipment in the world will be redirected here for safe dumping.

There are, however, ways to mitigate this accountability gap, even with an LLP policy. You have heard that an LLP is necessary, even unavoidable. You have been told that we must establish a threshold because the damage is already done. But one need only look at Canada's only other LLP precedents in agrifood to understand that this can be managed in a different way.

Health Canada and CFIA already require the food sector to maintain trace maximum thresholds far below the 0.1% proposed here by an order of magnitude. A number of allergens and regulated foods—gluten, THC levels in hemp seeds—are required to be under 0.001%, or 10 ppm. The industry responds to this requirement. They can. The industry tests and the industry can maintain this through proper controls and best management practices in place. But these types of protocols are not included in this policy.

In order to meet its own commitments on accountability, transparency, and communication, I would argue that the government ought to bridge the accountability gap in this proposal. The organic sector in Canada faces a disproportionate share of the burden from GMO contamination and LLP: in testing, in loss of product designation, and in loss of markets. If an LLP of 0.1% is to be introduced in Canada, as a minimum the organic sector requires and calls for the following:

1. Full and routine public testing of imports for GMOs;

2. Publication and communication of the incidence, the crop, the importer, and the country of origin of the crop, and whether that has come within the action or threshold limits;

3. Regular and specific reporting of this information to the organic sector so that our producers, handlers, and manufacturers may pursue best management practices and targeted testing in an effort to protect our products from further contamination;

And finally, with respect, I would recommend that we look to the lead of the United States and Secretary Vilsack in striking the AC21 committee to investigate the means with which to manage risk and compensate farmers whose crops and products are contaminated by unintentional GM events.

Thank you for your time and attention.

[The Chair, Conservative, Merv Tweed]

Thank you.

Professor Van Acker, welcome.

[Dr. Rene Van Acker, Professor, Department of Plant Agriculture, University of Guelph, As an Individual]

Thank you very much. I appreciate the opportunity to present to the committee today.

As a little bit of background on myself, I'm associate dean and professor here at the Ontario Agricultural College, and I was previously a professor at the University of Manitoba. I've worked on coexistence of GM and non-GM and movement of traits from crop to crop for over a decade, here and in various other places around the world. I've also been involved in conferences for over a decade looking at coexistence of GM and non-GM.

I want to make some comments about the mechanics of trait movement based on research and experience to date. In North America there is more than a decade of experience with commercial production of GM crops. This has provided two key lessons. One is that when GM crops are grown outside at commercial scale, the movement of GM traits beyond their intended destinations can be expected, and the risk of escape increases with the scale of production. Second, full retraction of escaped GM traits is very difficult and may be impossible if escape is into a broader agricultural supply chain.

These points support the need for caution, serious consideration, and systematic efforts where there is a hope, expectation, or requirement of coexistence between GM and non-GM crops, and commercial segregation, especially for situations where a GM trait is regulated or other situations where there is a zero threshold for adventitious presence. Recent scientific publications have noted that since the first GM crops were commercialized in the mid-1990s, reports of GM material appearing where it's not intended, expected, or wanted have steadily increased, reflecting both the massive increase in production acres of GM crops and the number of GM crops commercialized, and perhaps in some cases, an underestimation of the challenge of containing GM traits.

GM trait movement is especially complex within large agricultural supply chains that involve many actors and living elements across an active landscape. Traits may persist and move among living populations of plants, including feral and volunteer populations, and among latent populations in seed that may exist in a myriad of places within the production and supply chain and that may persist in the environment.

The potential for the movement of GM material depends in part on the nature of the crop species and the biology and ecology of those species in relation to the agronomy and farming practices. A primarily self-pollinating crop like wheat, for example, may represent the least challenging scenario, whereas highly out-crossing and persistent species like alfalfa or canola may be the most challenging. Placement along this continuum depends very much, again, on the biology and ecology of these crops in the context of their farming systems and the nature of the supply chains they move in.

In the context of low-level presence requirements, an additional and important consideration is the threshold level, of course. What is generally acknowledged in this regard is that when a given GM crop is commercially grown at substantive scale within a region, maintaining absolute freedom from GM for that crop species in that region becomes very challenging, and in some cases impossible.

In Canada we have the most experience with GM canola. It has been grown in western Canada since 1995, and currently well over 90% of the canola grown in western Canada is GM. By 1998, only four years after the start of cultivation, GM traits were already stacking within volunteer canola plants, and by 2007 the stacking of GM traits in escaped and possibly feral roadside populations of canola had also been documented. This was evidence of the effectiveness of GM trait movement within metapopulations in the landscape and through agricultural supply chains. Recently there was evidence of GM canola having moved through broad areas within the U.S., primarily along the Canada-U.S. border and along grain transportation routes. In addition, GM canola has been found commonly in shipping ports in both exporting and receiving countries, such as Japan.

The movement of GM traits within canola is a function of biology and ecology, the way in which canola is farmed, the farming system, and how canola is handled within supply chains, including the production of seed. There has been so much GM trait movement in canola in western Canada that farmers in this region have come to expect the appearance of unintended GM traits in their canola in all cases. The eventual adventitious presence of unintended GM traits in certified canola seed lots shows the extent to which all GM traits were pervasive in all canola in western Canada.

Some of the canola seed lots had unintended GM traits present at very high levels, approaching 5%. Given current knowledge of pollen-mediated gene flow, it's unlikely that this caused that high a level of presence in a single generation. We would expect, at most, 0.1%. Given the strict seed production and isolation protocols, if seed lots had above 0.25%, it was likely the result of inadvertent mechanical mixing of certified seed during harvest or handling.

In Denmark, an analysis of the possibility of achieving coexistence of GM and non-GM canola concluded that it would be difficult and perhaps impossible.

The two vectors of GM material movement are pollen and seed. Gene flow tends to occur over shorter distances, generally, but pollen can be carried over long distances by wind or pollinators. The distance for effective pollen-mediated gene flow depends on many factors, including the species, its out-crossing nature, the size and weight of pollen, the size of the pollen source, and weather. There is relatively good modelling of pollen-mediated gene flow for a variety of crops. However, those establishing protocols to prevent GM material from escaping have generally relied on traditional isolation distances for given crops taken from certified seed production standards, which may not be suited to the confinement task depending on the required threshold. If the threshold is very low—0.1% or lower, for example—seed production standards are not likely adequate. Seed movement is another means of GM material moving, or admixture. Seeds may travel great distances when crops are transported by humans, either knowingly or unknowingly.

Relatively little research has been done on the nature of seed movement of GM material, movement that is often related to human involvement or, in some cases, human error. In terms of seed movement, certainly complete separation of operations is acknowledged as a prudent means of working towards successful coexistence and maintaining GM-free material. Starting with absolutely clean seed is critical. Stringent separation of GM-free seed production from any sort of GM crop farming or handling, along with frequent testing, are required in this regard.

The persistence of seeds of GM crops is also an important consideration for GM trait escape and movement. After a crop has been harvested, volunteer and feral GM populations can appear in subsequent years and act as a place for GM traits to come from or escape to. In this sense, for crop species that have large and robust volunteer and feral populations, like alfalfa, for example, and especially for crops that produce very persistent seed banks, like canola, for example, a metapopulation for a given GM trait may arise within a given region. The ability of GM material to entrench itself in a system can be seen in western Canada, where a high proportion of feral populations of canola are GM, and those populations are accumulating multiple GM traits. For flax, since the Triffid GM-flax escape in 2009, researchers have shown that there is now a low level of GM flax, about one in 100,000, in the Canadian flax system that will likely be impossible to eradicate.

The segregation of GM and non-GM crops occurs throughout the world in scenarios both where coexistence is regulated and where it is not. In the case of jurisdictions where coexistence is not ensured by law, default is for the onus of segregation to be on the farmer or business operator who wishes to remain GM-free.

In Canada, when a GM crop is deregulated it is assigned unconfined release status. This removes any requirements for containment or confinement of that GM crop or GM material coming from that crop. In this case, those who wish to remain GM-free are recommended to employ a range of means, a system, to prevent incursion of GM materials.

After more than a decade of GM crop cultivation and decades of study of GM crops, it is now generally acknowledged that when GM crops are grown outside at a commercial scale, the movement of GM traits beyond their intended destinations can be expected and the risk of escape increases with the scale of production. Full retraction of escaped GM traits is difficult and may be impossible if escape is into the broader agricultural supply chain.

Since GM crops were first commercialized, reports of GM material appearing where it is not intended, expected, or wanted have steadily increased. With respect to GM crops, the nature of the crop, including its out-crossing ability and its ability to persist in the environment help to determine how difficult it will be to contain GM traits in this crop or to retract them after escape. There is an abundance of evidence from around the world that GM traits escape and end up where they are not intended, expected, or wanted. They move in one of two ways: either by pollen-mediated gene flow or by seed. PMGF—pollen-mediated gene flow—has been substantively studied, and the results of these studies show that it's common and can occur at low levels at long distances. There has been much less study of seed-mediated GM trait movement, but experts acknowledge that it occurs and that human error often plays a role.

After escape, GM traits can persist for a long time in the environment, even without new seed additions. Preventing GM crops from appearing where they're not expected or wanted is regulated in some jurisdictions. In these cases, segregation rights are protected in law, and there are formal recourse compensation mechanisms and also requirements for communication and full transparency about where GM crops are being grown, so that neighbours growing or not growing GM crops can prepare and work to prevent adventitious presence.

In areas where there is no regulated coexistence and where deregulated GM crops have unconfined release, the onus is on GM farmers or businesses to protect non-GM farmers or businesses from GM material incursion. These farmers and business operators use a variety of means and a systems approach in order to prevent the incursion of GM material or to confine GM material. It's understood by experts that GM containment and preventing incursions of GM material is challenging and that no single means of segregation or containment is sufficient to effectively contain GM material, especially in cases where low levels of escape can cause harm.

Thank you.

[The Chair, Conservative, Merv Tweed]

Mr. Allen.

[Malcolm Allen, NDP, Welland, ON]

Thank you, Chair.

And thank you both. These were interesting presentations, from both of you actually—especially, Professor Van Acker, this issue about the science of the unintended consequence, if you will. When a material is introduced, it's expected to do something, but unfortunately it may move—and does, according to the studies you're quoting and some of the studies you have performed yourself. I noticed in your written brief that you have actually participated in many of the studies. As much as we may not want it to, the material does move, and with that movement there is a potential for it to be where we don't want it to be, I suppose. I don't want to call it a risk per se.

Based on the fact that it does move, are there things, in your view, that we can do to mitigate the fact that it's in places we don't want it? You cited canola as being in the roadside, for instance. Most farmers aren't harvesting the roadside; it's simply there. Are there things that in your view we can look at to try to mitigate that movement, this particular unintended consequence?

[Dr. Rene Van Acker]

Backing up from that a little bit, I guess the first question is whether there is a requirement for us to prevent that movement or not. Currently, when we de-regulate and commercialize a GM crop in Canada, for example, there is no requirement to prevent movement, so I guess we'd have to start with a requirement. The discussion has been more about those who want to prevent incursion than about those who want to prevent movement in the first place.

One good place to start is clean seed. We can see, for example in the case of Triffid flax, that the flax industry went right to the seed first and worked with the seed suppliers and the University of Saskatchewan to ensure clean breeder seed, and then worked with farmers to strongly encourage a movement to the use of new, clean, certified seed. That's one important thing, I would say.

[Malcolm Allen, NDP, Welland, ON]

Thank you very much for that. I agree.

In your paper, which came to us earlier, you talked about the Danes saying “here it is by regulation”, whereas we are almost in a commercial place in which it's farmer to farmer, neighbour to neighbour, if you will.

Let me go to Mr. Holmes. You laid out some pieces, saying that if LLP were to be, here is what you thought, from your organization's perspective, needed to be done. Let me say what I've heard more than once at this committee from groups.

I'm not trying to be flippant about this, but it reminds me of one of the stories we used to tell our kids about “not too soft and not too hard”. We've heard that while it can't be too high and shouldn't be too low in this present case, it's science-based.

It seems to me, if I recollect the science of things, that usually you get a number. You may get a variation, but science doesn't give you “not too low” and “not too high”. That's not actually science; that's the “I would like” something or other—“I don't want my porridge to be too hot and I don't want my porridge to be too cold, I want it to be just right”—which is really about how to market rather than how to do anything else.

I'm going to ask you this specific question. Regardless of what one thinks about GM, if one just accepts the science that it's actually safe—we'll take that as the piece to say both parties agree that it's safe—but if one party says “I don't want it”, how do you enter into a commercial agreement? I don't care whether they don't want it because of a trade barrier or have just decided that their population doesn't want it. What are we doing to ourselves with a group whom we may want to trade with—in this case the EU, which is 500 million people, though we have to see the agreement on the table—when they have decided they don't want it? They are not saying it's unsafe; they just say they don't want it.

It's like Heinz's and Campbell's soup. Which one do you want? “I don't want that one; I want this one.” Am I not the customer? Do I not have a right to say as a customer what I want? Isn't that a legitimate piece that's not being asked at the moment? At least in my view it is.

I'll let you comment on that big piece there.

[Matthew Holmes]

That's a beautiful question.

Goldilocks was an imposter and a trespasser, so I won't go there.

[Voices]

Oh, oh!

[Matthew Holmes]

But the situation with the EU is clear, and it is the one the organic sector has been facing for some time. Wherever you happen to be on the philosophical or practical side of this question, the customer is right and you need to provide customers with what they want. In the organic sector we've seen time and again, wherever there is some adventitious presence or LLP of some kind, the product is gone: you have lost that market, you have lost your organic designation, and you're lucky if you can sell it as feed.

This is certainly compounded for the organic sector. It is something that all of agriculture faces. And with regard to the question you asked on the science of the number, the answer comes back to my comments that we've moved from a science-based approach, which has been the call for many years now, to a market access approach. There are many reasons to look at market access considerations when discussing GM, but I have yet to find, from the officials drafting this policy, whom I have consulted, to the industry that is speaking in favour of it, the scientific basis for any of the thresholds presented here.

[The Chair, Conservative, Merv Tweed]

Thank you.

Mr. Richards.

[Blake Richards, Conservative, Wild Rose, AB]

Thanks, Mr. Chair.

Thank you both for being here, or virtually here.

I will start with you, Mr. Van Acker. I want to ask a couple of questions that touch on some things you said in your opening remarks.

One thing you talked about was canola and its prevalence in western Canada. It has obviously been a huge success story. Many producers in western Canada looked at canola as an option when they were looking at ways to avoid the restrictions put on their marketing of their wheat and barley because of the Canadian Wheat Board. Obviously, we as a government have opened that market up, and yet we find that many producers are still looking at canola because it has become a great success story.

What you said in your opening remarks was that well over 90% of the canola grown in western Canada is genetically modified. I would think that GM seeds would cost more, both in the research phase and in production as well, and yet clearly farmers have overwhelmingly chosen to grow GM products.

I wonder whether you could tell us what you think the reasons for that are.

[Dr. Rene Van Acker]

Certainly, the adoption of GM canola was very rapid in western Canada. In fact, there's published work to show, through farmer surveys, that farmers chose GM canola because of operational benefits. Translated, that means they found GM canola easier to farm, and it provided better weed control than non-GM canola, in particular Roundup Ready canola, but even LibertyLink canola.

So farmers—and it's been documented—have acknowledged that it was an agronomic advantage to them to have GM canola in their farming systems, so much so that canola went from being a crop that you grew in your cleanest fields to being a crop that you could grow to help to clean up fields with respect to weeds. There's been a tremendous change. Yes, it's been a great success.

[Blake Richards, Conservative, Wild Rose, AB]

You also indicated that it's generally accepted now that completely preventing GM traits from, as you put it, escaping is impossible. You also indicated that the risk of escape increases with the scale of production. Obviously, with over 90% of the canola in western Canada being genetically modified, the scale of production is quite high. We know there's an increasing number of different varieties being grown. You, of course, indicated a few examples of those varieties in your response to my previous question.

I'm wondering if you could give us your opinion on whether, given those factors, we can actually realistically expect to be able to meet something like a zero-tolerance policy. Perhaps you can elaborate on why you would believe that's the case.

[Dr. Rene Van Acker]

Certainly, for the case of canola in western Canada, it would be exceedingly difficult to guarantee GM-free canola grown in that region. I would almost say that at a commercial scale it might be impossible to do that, because there's so much of it throughout the system.

For other situations, other crops, where that's not the case yet, that can perhaps still be a possibility. But within a given region, as you increase the scale of a certain GM crop being grown, it becomes more and more difficult to maintain segregation and to meet really low thresholds, especially if it's an out-crossing species where pollen movement can be relatively long distance. Maintaining an absolute zero becomes increasingly difficult. For canola in western Canada currently, I wouldn't attempt it. I think it would be very hard to do.

[The Chair, Conservative, Merv Tweed]

Thank you.

Mr. Valeriote.

[Frank Valeriote, Liberal, Guelph, ON]

Thank you, Matthew and Rene, for coming before the committee. I very much appreciated your presentations. They were, frankly, remarkable.

Rene, you spoke of the Danish model and the regulations they have. They clearly identified quickly what their preferences were and what they were prepared to do.

Again, I'm going to make it clear: I eat GM; I understand the argument about GM. But I also very much appreciate and will defend the right to coexistence, so that organics can grow, and grow safely, for lack of a better word, without contamination, to feed the market they prefer to feed.

It seems, though, in Canada that you talk about our taking a default position, basically placing it on the non-GM farmer to make sure their crops remain GM-free, which has made it rather onerous for them.

Is it too late to go back to the Denmark model? Is it too late to introduce regulations? With certain crops you said there may be a zero-tolerance level that could be achieved, whereas with canola there can't be. That has to be acknowledged. Is it too late, or is the toothpaste out of the tube, as I asked one of the previous witnesses? Is it too late to go back?

[Dr. Rene Van Acker]

That's a good question. I think the answer depends on the threshold and the crop. If the threshold is, let's say, zero and the crop is canola, I would suggest it's probably too late. That may also be the case for flax, though, given recent studies out of the University of Saskatchewan. If the threshold is something above zero, it may not be too late.

The other question is, what is the threshold in relation to? Is it in relation to regulated GM events or deregulated GM events? Here there is a difference between LLP proposals and other thresholds. The EU's policy on 0.9% as a threshold for the presence of GM material in non-GM crops or food is really related to events that they have deregulated themselves. Then they will allow a 0.9% presence, and that drives the labelling as well. It starts to become a little more complicated.

I'm sorry, I can't answer it straightforwardly like that, but those considerations all come into it. However, it's not too late, depending on the threshold levels and the purpose.

[Frank Valeriote, Liberal, Guelph, ON]

All right. Is it practical for people from the organics and other industries to get together and sit down and talk about these thresholds and to talk about regulations, the way they have in Denmark, or is it just impractical to do that? That's one question.

The second question, before I get cut off, is this. I heard four conditions that Matthew had recited if we're to adopt an LLP policy. They seem reasonable to me. It's about transparency, reporting, and disclosure. I'm wondering if you heard them and if you could comment on them.

[Dr. Rene Van Acker]

On the first question, of course, the Danish model is a decision by the nation state and not a subset thereof. Yes, the organic sector could get together and discuss this, but I'm sure their issues would be what are their protections and their recourse mechanisms and where are those set; are those set in law, or do they have to just do them ad hoc? That would probably be a question.

The other thing is that the organic sector operates under a zero threshold, and I don't know what movement there is around that, or whether there is movement around that. So that would be another question.

[The Chair, Conservative, Merv Tweed]

Mr. Hoback.

[Randy Hoback, Conservative, Prince Albert, SK]

Thank you, Mr. Chair, and thank you, gentlemen, for being here this afternoon.

I must say, I agree with Mr. Valeriote. I know we've had private conversations about how there must be a way to allow the organics and the non-organics to function properly together in a way that they both survive, and not only that but thrive.

When you define LLP, what we're talking about is not allowing product that's unsafe to eat to be the foreign content. Let me make that clear. It has to be product that is still considered safe to eat. Therefore, if it's 0.1% or 0.2%, or whatever number you should so choose, even that foreign content is still considered safe to eat in Canada.

When I look at the long-term viability of the organic sector and the pressures that are going to be on our agriculture sector over the next 20 years, I look at the organics wondering why they're not embracing this and looking for this as a way to allow them to survive as they move forward, because there will always be pressure on them now to have zero content, which is not something they can possibly sustain going 10, 15, or 20 years out.

As Mr. Van Acker talked about, as you see more commercialization of different GMOs or different products in other crops, it becomes tougher and tougher to keep them segregated. I just find that really amazing.

One of the things we have to face in the agriculture committee, in Canada, and around the world is a growing population, and Ms. Townsend, in the previous committee meeting, talked about this.

I look at the organic sector. Mr. Van Acker, you're from Guelph, so maybe I'll take advantage of your expertise in Guelph. Have you seen any research in Guelph, or anywhere else in the world, where we've doubled or tripled the output per acre in organics?