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.