Thank you very much for the invitation to present. Thank you for taking a look at this issue. We appreciate the opportunity to be before you.
I work with the Canadian Biotechnology Action Network, also referred to as CBAN, which monitors, researches, and raises various concerns and critiques to encourage and engage democratic discussion over the introduction and use of this technology in food and farming. We provide information to Canadians. For example, in the absence of mandatory labelling, we provide a list of genetically modified foods that are on the market.
CBAN brings together 17 organizations on the shared platform of Tides Canada. We are composed of environmental groups, farmer associations, international development groups, and regional coalitions of grassroots community groups. Together CBAN membership raises diverse types of concerns over the use of genetic engineering and brings together a wide and rich range of perspectives and expertise.
How close GM animals, products, and technologies are to the market is actually difficult to determine. The pipeline of GM animals is difficult to monitor because the research is most often owned by private companies, and the majority of research in the lab actually never leads to working products.
We heard last week from regulators that they discussed the product pipeline with companies, but this is not information that the Canadian public is privy to. In Canada, however, we already have two concrete examples of GM animals we can use to discuss the issue and the policy challenges that are raised, in particular the GM salmon.
Canada approved the world's first GM food animal. As you know, that is the GM salmon, which could make its way to market in the next two to three years. The company's initial plan, or stated business plan, was to produce the GM salmon eggs in Prince Edward Island, ship the eggs to Panama, and grow out and process the fish in Panama for the U.S. and Canadian markets; however, the company actually has approval to grow both the eggs and the salmon in Prince Edward Island. The ministers, in their decision to allow commercial production, had approved commercial production anywhere in Canada of eggs and salmon as long as it was in a contained facility on land. There's an ongoing court case, and in December 2015 that production was restricted to P.E.I.
In Canada we have the additional concrete example of the GM pig from the University of Guelph, called the Enviropig. The pig was approved by Environment Canada—because, of course, CFIA has been approving the environmental release of crop plants, but it's Environment Canada that approves GM animals for release. However, the review by Health Canada was halted after the project was removed after pork producers withdrew their support.
I did want to bring your attention to the six reports that CBAN has produced. I think these were sent to you in file format. A lot of the comments I'll provide today are based in our most recent research, looking at the impacts of GM crops and foods after 20 years in Canada.
In the interest of time—although much has passed already—we've structured our comments on five specific policy recommendations and a further final, broader proposal.
First, there needs to be an assessment of economic impact before any GM product is approved for release. The release of some GM products poses economic risks. These risks are not assessed by any department before a new GM product is released. Economic risk-benefit analysis is not part of Canadian regulation. This also means that farmers are not consulted before GM products are approved. In the case of GM fish, fishers, the aquaculture industry, and aboriginal peoples and local communities were not consulted. There is no assessment of risks, but there is equally no assessment of benefits before or after commercialization.
We need only look at the $29-million cost of GM contamination to Canada's flax industry to see a little of what could be at stake. This problem of the costs to some farmers is not new. It was articulated by farmers over the possible commercialization of GM wheat in 2004 and it continues to be heard in the objections to GM alfalfa by Alberta forage groups and 15 farm groups together earlier this year.
The economic risk manifests itself in at least two ways. One, the introduction of a GM product, especially in the absence of mandatory labelling of GM foods, can undermine the market for an entire commodity. This was the concern of apple producers: that the approval of the GM apple would undermine consumer confidence and damage the entire market. Two, if a new product is released and contamination occurs, the result can be market closure.
Second, there is a need to strengthen environmental risk assessment, including a need to assess the long-term system-wide risks of each GM product and the use this technology as a whole. Unfortunately, the risk of contamination is not necessarily diminished with GM animals. There have already been two contamination incidents with GM pigs in Canada, on two separate occasions, at two different institutions, with two different experimental pigs—pigs that were not approved for human consumption. In both cases, GM pig carcasses were rendered for animal feed instead of being incinerated as biohazard. Both contamination incidents were caused by human error. These two incidents highlight the problem of contamination even with large organisms, not just small flax seeds or pollen from flowering alfalfa plants. If we can't contain GM pigs, how can we successfully contain GM salmon or salmon eggs—or alfalfa, flax, or wheat, for that matter?
Third, Canada needs systems for tracking and tracing all GM organisms. Statistics Canada does not track all GM products on the market. Regulatory agencies do not track which products are commercialized and being grown. The government only knows what GM traits have been approved, not where they are or how much are on the market. This means that the government does not have the tools it needs to assess risks and benefits in the long term, or even answer your questions about the market status of the GM apple, for example.
The committee has already heard about the challenges of tagging from the Cattlemen's Association. The seafood industry already struggles to track seafood. It is too common that seafood in the food market is actually mislabelled.
Fourth, Canadians need transparency in regulation. CBAN examined this issue very closely in our GM inquiry. Transparency is missing in almost every step of regulation. In a few cases, there is partial transparency. For example, GM animals are not covered by the voluntary agreement between CropLife and the CFIA that allows the CFIA to post notices of products under review if companies agree. This is called the Biotechnology Notices of Submission Project. This means that at any given time, Canadians do not know what GM animals, if any, are under government review.
Finally, Canadian consumers need mandatory labelling of all GM foods in the grocery store. Lack of transparency is most obviously manifest in the lack of labelling. The issue of GM animals makes labelling an even more urgent issue for Canadians. The issue of GM animals also highlights the range of concerns that could bring a consumer to want GM food labelling, to want to choose. For example, some Canadians have specific ethical concerns.
Twenty years of polling in Canada consistently showed that 80% of Canadians want mandatory labelling of all GM foods. The most recent is 88%. Mandatory labelling needs to be in place before the GM fish hits the market.
In conclusion, the specific proposals that I've outlined are all needed to get regulation and policy close to what it needs to be to address the challenges of GM animals. We could also refer back to the Royal Society of Canada's expert panel report of 2001, which had 53 recommendations for regulatory change. We have articulated these specific proposals because the first GM food animal has already been approved and could be on the market really soon.
But there is a more fundamental need. We need to step back and ask if genetically engineering animals is ethical. Is it acceptable to Canadians? Is it necessary? It is Canadians who need to answer these questions. It is Canadians who need to be asked. There needs to be a moratorium on the introduction of GM animals until Canadians have a chance to be heard and until changes are made to increase the government's ability to regulate GM organisms and food, including tracking and traceability and transparency, including mandatory GM food labelling.
Canada has two decades of experience with GM crops and foods, but they have not yet been evaluated. We need to step back so that we can also evaluate the impacts of GM crops. We need to do this, and then learn and apply any lessons from the release of GM crops and foods before we consider allowing GM animals into our environment and food system.
Thank you.