Thank you, Chair.
I'm speaking on behalf of the Canadian Biotechnology Action Network, which is a network of 18 organizations, and we have participated in the consultations on low-level presence where invited.
The adoption of the LLP policy would establish Canada as the first country in the world to accept imports contaminated with levels of GM foods that have not been approved by our own regulatory agencies.
I thought firstly I'd like to ask the question what LLP does achieve. Firstly the LLP policy does not achieve the stated trade goal. The proposed LLP policy will not accomplish the stated goal of minimizing disruption to Canadian exports. The LLP policy would govern imports to Canada.
The rationale for adopting this LLP policy rests on the hope that other countries will follow Canada's example and adopt similar LLP policies. We do not know, however, that this will be the result. Canada's acceptance of LLP does not necessarily bring us any closer to this goal.
Rather than improving the position of Canada's commodities in the international marketplace, LLP has a high potential to undermine Canada's international reputation regarding both food safety regulation and the integrity of our food system. This is because through LLP we are actively inviting contamination of our food system without domestic regulatory oversight.
Secondly, LLP will change domestic GM food safety regulation. LLP would change the way GM foods are regulated in Canada. The policy proposal asks Canadians to accept GM foods as safe even when Health Canada has not fully evaluated them and approved them as safe. LLP asks all Canadians to accept GM foods as safe even where Health Canada has not approved those GM foods as safe for human consumption. LLP also asks Canadians to trust the regulatory processes of other countries. LLP asks all Canadians to agree to the assumption that at a low dose, unapproved GM foods are safe.
What are the implications? In our analysis, LLP will sacrifice health and safety for elusive trade goals.
From a public health and safety perspective, there's no justification for allowing the import of foods contaminated with products that have not been fully evaluated by Health Canada. LLP will undermine consumer trust in Canada's food safety regulation.
The LLP policy introduces further uncertainty for Canadians in relation to what GM foods are in the food system. It creates further complexity for Canadians in understanding how GM foods are regulated and by whom. The LLP policy would further obscure the place of GM foods in the Canadian food system and would aggravate the current problem of the lack of GM food labelling. The policy asks all Canadians to accept the potential of unknown GM contamination in every food item on the shelf.
LLP will compromise Canada's science-based regulation of GM foods. The regulatory system for GM crops and foods in Canada has consistently been described as science based. Here, however, scientific oversight over GM foods is being removed in relation to the action level proposal and seriously reduced—in an as yet undefined way—in relation to the threshold level proposal. LLP is trade-based regulation that would irrevocably compromise Canada’s claim to science-based regulation of GM foods.
In the interest of time I thought I would perhaps condense a little bit of what I have presented on paper to look at the specific implications of the action level and the threshold level, which, with the existing approval system for GM foods in Health Canada, essentially create three tiers of regulation for GM foods, where of course the action level allows for a small amount of contamination.
The implications are really that the action level is not based on science. It's based on an assumption of safety relating to the science that has been assessed by another country. This is not science that rests inside Health Canada, and certainly there's no science behind a decision to choose one action level over another, 1% over another. The action level asks Canadian consumers to trust the regulatory systems of other countries.
In relation to the threshold level that allows for a higher level of contamination, higher than the action level, determined apparently by what's achievable in the industry, this would be allowed after a “Canadian LLP risk assessment”.
The proposal for a threshold level in our analysis further complicates the LLP proposal and further compromises Canada's claim to science-based regulation of GM foods. The proposal that a threshold level could be allowed after a “Canadian LLP risk assessment” begs the question, what is that risk assessment and how does it differ from the current Health Canada approval process for GM foods?
The proposal to establish threshold levels introduces a new second-tier approval process for GM foods based on an as yet undefined process and criteria. The fact that this assessment process is not defined brings home the point that the LLP policy is not science based.
Threshold levels would severely undermine the ability of a great portion of the Canadian public to trust Canadian regulation for food safety and for GM food safety in particular. Evaluation of GM food safety is already a process that is largely hidden from the Canadian public, and the proposal for threshold levels via a Canadian LLP risk assessment would further complicate and obscure the regulation of GM foods on the shelves.
In summary, our analysis is that the policy does not secure the stated goal of easing trade of Canadian exports. Rather, it has serious implications for the future of Canadian food safety regulation and Canadian trust in such regulation. Acceptance of LLP would undermine Canada’s international reputation for food safety. It would seriously compromise Canada’s claim to science-based regulation of GM foods, both in international markets and domestically. It would further engender consumer distrust of GM food safety regulation and leave the government with little ground to build or maintain that trust. This policy is extremely vulnerable from a public health and safety perspective, and this vulnerability extends to the biotechnology industry itself, which seeks a positive public perception for its products based on an appeal for Canadians to trust in government regulation. I would suggest that there are a number of stakeholders and actors in the food system that similarly rely on this same appeal.
Thank you.