Thank you very much for the invitation, Mr. Chair and honourable members.
I'm going to talk on behalf of these guys or gals who are busy producing food, and on behalf of the staff at Dairy Farmers of Canada. Our president, Mr. Wally Smith, sends you his regrets for not being able to attend and comment on the bill dealing with important issues affecting the income of agricultural producers and affecting the entire agrifood industry.
Dairy Farmers of Canada's position on Bill C-18 is well reflected through comments made by Mr. Ron Bonnett, president of the Canadian Federation of Agriculture, soon after the bill was presented to Parliament. Referring to plant breeders' rights, Mr. Bonnett indicated that the legislation strikes a good balance between plant breeders' investment in the development of new varieties and the farmers' ability to save, store, and condition seed for their own use.
Dairy farmers depend on continuous improvement in forage and grain varieties to increase their productivity. One important element of Bill C-18 for dairy producers is the Feeds Act. Bill C-18 would result in a major renewal of feed regulations. Dairy Farmers of Canada, along with the animal nutrition industry and other animal and fish commodity producers, is involved in a thorough consultation, which will likely result in a set of regulations accommodating a modern animal and feed industry while protecting food safety and the health of consumers. Dairy Farmers of Canada acknowledges the Canadian Food Inspection Agency for its foresight and leadership in the modernization of the feed regulations.
Regarding animal health regulations, the proposed changes are addressing existing gaps in the current regulations. Dairy farmers are looking for a positive outcome. The changes require careful monitoring and analysis to ensure that they do not negatively affect other aspects of animal health regulations.
The concept of incorporation by reference introduced in Bill C-18 is an element of particular interest to dairy farmers. The rationale is excellent as long as the affected parties are adequately consulted and their observations are taken into consideration. It is clear that incorporation by reference will lead to a reduction in the period of time required for modifying relevant regulations. However, this new approach needs to be monitored very carefully by all parties involved.
Another concept introduced by Bill C-18 is the notion of preventive control plans. Over the last few decades, agricultural producers and the food industry with government support have developed food safety programs grounded in a series of principles based on hazard analysis and critical control points generally called HACCP. The Canadian food industry system rests on this basis. The concept of preventive control plans deals with sensitivities new to producers and requires careful discussions. Producers are concerned that they will be required to implement preventive control plans and they need clarifications. For example, the on-farm food safety program for dairies is named Canadian Quality Milk. It is evolving as a component of an integrated program involving milk quality, food safety, animal welfare, animal health including biosecurity, along with different aspects of sustainability, including the three pillars of sustainability, namely economic, societal, and environmental.
Producers are concerned that changing the basis of the on-farm food safety program may affect our national program named proAction. There are equivalent programs for all other commodities.
In conclusion, the process and criteria need to be clearly communicated. Producers need to see written evidence demonstrating that our on-farm food safety programs will be sufficient to meet the requirement of the preventive control plans, and producers are asking for producer-specific information from CFIA on the issues raised above.
Thank you for your attention.