Thank you very much, Mr. Chairman.
For those of you not aware, the Canada Grains Council is the peak organization of grain industry interests, representing producers, crop input companies, grain companies, and grain processors.
Formed in 1969 to coordinate efforts to increase the sale and use of Canadian grain in domestic and world markets, the council has become the leading recognized forum of the entire grain industry in Canada and around the world. We are a pan-Canadian association, with 30 members, with interests across the various crop sectors encompassing cereal grains, oilseeds, pulses, and specialty crops value-chain participants.
The Canada Grains Council's mission is to lead, facilitate, and support policy development and implementation on issues and opportunities that affect all of these commodities and to enable cross-commodity collaboration. Our members include the Canola Council of Canada, Pulse Canada, Cereals Canada, the Flax Council of Canada, the Barley Council of Canada, and Grain Farmers of Ontario, among many others.
The Canada Grains Council members have identified two strategic policy pillars in our work, including trade-enabling market access and enhancing our approach to measuring and communicating on the industry's record on sustainability through the recent creation of the Canadian round table for sustainable crops.
I'm here today to speak to you about some concerns we've raised under our first policy pillar on trade-enabling market access issues in the context of interprovincial trade barriers.
In January of this year, the Canada Grains Council sent a letter to the Prime Minister, premiers, and federal ministers of agriculture and health outlining our concerns with non-science-based regulatory interventions by some provinces on crop sector agricultural products. I believe a copy of this letter has already been circulated to members of this committee for your reference.
In short, we're asking premiers to commit to work towards the adoption of a federal-provincial agreement on recognition of federal regulatory approvals related to the crop sector.
The productivity and international competitiveness of this multi-billion dollar sector is highly dependent upon timely and uninterrupted access to agriculture and food inputs and technologies that have received regulatory approval and are commercially available in other grain-producing and exporting countries.
Examples of these inputs and technologies include seed of crop varieties exhibiting agronomic and end-use performance traits that have been developed and registered for commercial production; licensed crop protection products that include seed treatments, herbicide, fungicide, and insecticide to provide the highest possible quality harvests while ensuring food feed and environmental safety; and food additives and processing aids used in the primary and further processing of commodities such as cereal grains, oilseeds, and pulse crops.
These inputs in technologies undergo pre-market evaluation and licensing registration by Canada's federal departments and agencies, including the Pest Management Regulatory Agency, Health Canada's food directorate, the Canadian Food Inspection Agency, and the Canadian Grain Commission, and are scientifically demonstrated to be safe for intended use in terms of food safety and environmental impact.
One of the foundations of Canadian agriculture and a key competitive advantage for Canadian farmers is our world-renowned science-based regulatory system. Many nations are envious of our system, which provides both rigorous science to protect the health of Canadians and the environment, and a predictable, timely system that gives farmers and industry the tools they need.
The foundations of this system, however, break down when provincial governments, who do not have the research capacity of the federal agencies previously noted, start imposing regulations that contradict and override federal regulatory decisions. This creates unpredictability in Canada on what jurisdictions should regulate on which issues, potentially leading to both a patchwork of regulatory approaches across provinces, unnecessary and costly duplication between the federal and provincial governments, and regulatory approaches by some provinces that appear to be grounded in perception rather than science.
A clear example of this is currently under way in Ontario where the Ontario government is imposing an arbitrary perception-driven restriction on neonicotinoid seed treatments for corn and soy seeds, in contrast to the cautious science-based approach taken by both PMRA at the federal level in Canada and the Environmental Protection Agency in the United States.
This will have far-reaching and very negative effects on farmers, forcing them either to go back to using older outdated pesticides or to source their seeds from outside Canada. It also sends a terrible signal to international investors that, notwithstanding Canada's science-based regulatory system, significant risks are involved when investing in Canada due to provincial intrusion into federal regulatory jurisdiction. Moreover, it distorts trade across provincial lines, hampers innovation, and hurts our farmers. In our view it's bad public policy, and it could be prevented with an agreement between the federal and provincial ministers to respect federal regulatory jurisdiction.
A similar distortion has been taking place for some time now in the context of provincial and local bans on urban use of pesticides. Notwithstanding the fact that PMRA performs rigorous evaluations and re-evaluations on all pesticides, we see politically driven pesticide bans at the provincial and local levels in Canada that hurt investment, distort trade, and send a clear signal to international investors that Canada is not in fact completely science-based in its regulatory decisions. Again, this stems from a lack of federal-provincial co-operation on regulations, more specifically a failure by some provinces to respect federal jurisdiction and expertise in the regulation of food, feed, and the environmental safety of agricultural products.
Farmers and industry are rightly concerned that these intrusions from provincial and local governments will become more frequent and even more disruptive, and the recent action of certain provinces is proving these fears to be accurate.
In conclusion, the Canada Grains Council believes that the federal government has a leadership role to play in removing this potential to have trade-distorting and duplicative regulation brought in at the provincial level. Federal regulatory agencies have the obligation to regulate and enforce Canada's national food, feed, and environmental safety measures, and we believe it should include ensuring that provincial governments do not casually sweep aside the science and risk-based determinations on agricultural products that are the foundation of market assess to these tools across Canada.
Thank you very much for your attention.