Environment Committee on Nov. 25th, 2022

[Dr. Charu Chandrasekera]

That would be a fair comment if you could put in some language there that requires the timely incorporation of these methods into regulatory risk assessment. Then I think it will be more of an incentive to really focus on reduction and replacement while working on other ways to make animal lives better.

[The Chair, Liberal, Francis Scarpaleggia]

Thank you.

Ms. Pauzé, you have the floor.

[Monique Pauzé, Bloc, Repentigny, QC]

Thank you, Mr. Chair.

I would like to thank all the witnesses for being with us this Friday afternoon.

Mr. Rehn, thank you for your presentation. I don't have much time, and I have a lot of questions for you.

You mentioned the importance of shifting the onus when it comes to GMOs. For example, we know that the salmon farmed by AquaBounty grows twice as quickly as wild salmon.

Can you explain why this characteristic is relevant when you talk about shifting the onus in order to prove that there are no toxicity issues linked to novel genetically modified animals?

[Thibault Rehn]

Thank you for the question.

Actually, when we're talking about “shifting the onus,” what we are trying to understand is the following: why make a genetically modified version of an organism when that organism already exists in the wild?

I've been working on this issue for nearly 15 years. Fifteen years ago, AquaBounty told us that its salmon matured twice as fast. Then, it was only one and a half times as fast. In the promotional video that came out when the company announced its production launch, no mention was made of the fact that its salmon grew more quickly. Now, there's no mention on the company site of its salmon maturing more quickly.

They made us believe that their salmon matured more quickly, perhaps to attract investors and to help advance the technology used. That is not the case currently, and the Norwegians, the biggest salmon farmers in the world, are able to raise non-genetically modified salmon as quickly as AquaBounty.

Why take the risk of genetically modifying a living species that can contaminate ecosystems when there's no advantage for the consumer or for animal production?

[Monique Pauzé, Bloc, Repentigny, QC]

You said “contaminate ecosystems.” That is the major issue.

Can you tell us what improvements are needed in Bill S‑5, which amends Part 6 of CEPA that deals with animate products of biotechnology?

How can we improve the bill?

[Thibault Rehn]

I mentioned three ways of doing this.

I believe it is essential that first nations be consulted in order to give their free and informed consent. That is really important, especially because we are talking about animal species which are highly symbolic.

I am also closely following issues related to pesticides and GMOs. Those issues are linked. I don't think that Environment Canada, Agriculture and Agri-Food Canada and Health Canada can state that their studies are science-based if the science is not accessible. We have seen this in numerous instances, such as with Monsanto and the tobacco companies. Unfortunately, industries, as a rule, generally seek to make profits, whereas you, as our legislators, are charged with protecting the health of our citizens and our ecosystems and bringing in rules that protect us from these industries that sometimes cut corners.

We need an assessment of ecosystem contamination by genetically modified organisms, for example. We need free and transparent access to all the studies; otherwise, we can't possibly say that the assessment made by Health Canada or the Canadian government is correct.

[Monique Pauzé, Bloc, Repentigny, QC]

Indeed. What's more, the senator representing the region in question has said that he didn't even know what was going on in the factory. We can see that there is no transparency.

Do you believe that the regulations should take into account the impact of genetic pollution on biodiversity?

You mentioned COP15. Should the regulations take into account the impact of genetic pollution on biodiversity because of the presence of these organisms in the environment?

I assume, because of what you have just told us, that you are going to say yes.

[Thibault Rehn]

Yes, it is essential that ecosystem contamination be taken into account.

When we see how Environment Canada authorized AquaBounty to launch production, when we read the report, we see that the persons responsible came to the conclusion that there was little chance that the genetically modified salmon would escape. However, if the genetically modified salmon did escape, there would be no going back. The genie would be out of the bottle. The ecosystems will have been contaminated.

When we know that the AquaBounty factory in Prince Edward Island is in an ecosystem that has wild salmon, which is not the case of the AquaBounty factory situated in Indiana, it becomes necessary to take all precautions.

Currently, we are dealing with one organism. However, in the future, with genome editing, as I said before, there will no doubt be many more organisms being put on the market. It is therefore imperative to do things right right now.

[Monique Pauzé, Bloc, Repentigny, QC]

Can you tell us how far behind Canada is in this process compared to other countries?

[Thibault Rehn]

What you need to know is that Canada was the first country in the world, and is currently one of only two countries, to approve the production and consumption of a genetically modified animal. The United States is the other one.

As to determining if Canada is behind or in front of the pack, that depends on your point of view. You should know that 30 years ago, they were telling us that genetically modified organisms would feed the world and that we would have less hunger. I'm talking about agriculture in general here. However, here we are 30 years later, and we see that all genetically modified seed used in Canada has been modified to tolerate one or many herbicides, which has led to an increase in the use of herbicides. We have to stop thinking that...

[The Chair, Liberal, Francis Scarpaleggia]

Thank you.

Unfortunately, I have to stop you there.

Ms. Collins.

[Laurel Collins, NDP, Victoria, BC]

Thank you so much, Mr. Chair.

My first question is for Ms. Fast. You have raised the concern about lead hot spots. Lead hot spots have been a concern particularly in Manitoba. I was reading about the levels in children in certain communities and certain areas.

How do community members feel that this bill does or does not help address this issue?

[Heather Fast]

Thank you for the question.

The main point of our engagement on this bill is to seek more protections for the vulnerable communities that are living near hot spots. I think some of the recommendations we've seen, both in our own submission and what I've spoken about today and from other organizations—such as to recognize the right to a healthy environment—and some of the other supports that have been discussed could help address some of these issues in a general way.

One thing community members are concerned about with Bill S-5 is the removal of the existing provisions, which could result in dedicated regulations or other responses to directly address problems in these hot spot areas. This removal doesn't make a lot of sense to our community members because they would prefer that provisions like these be left in and potentially expanded, as suggested by other organizations like CELA.

At this point, they're seeking anything and everything that could potentially help. That is a big concern. Anything that can help direct specific funding and other programming or other supports would be very happily received by community members in these areas.

[Laurel Collins, NDP, Victoria, BC]

Thanks so much.

Public funding provisions to reduce the financial barriers that often limit community engagement in court processes seem to be very important, as are independent testing procedures.

Can you talk a bit about why that link to this protection of environmental rights is so important?

[Heather Fast]

Our community members were very excited about the notion of recognizing the right to a healthy environment, because they see this as a tool that's going to help them in the future to protect themselves and hopefully engage in some court processes and other things.

What has stopped them from doing this so far, besides limited opportunity in Manitoba, is the fact that it's incredibly expensive to engage in these types of processes.

That is one of the main things they've asked us to ask you for, any type of provisions—and we've made some recommendations in our written submission, which I don't think have made it to the full committee yet—that would create additional opportunities for financial supports, like participant funding. There was even some discussion by our community members about creating court challenges programs and things like that. Those could help community members to actually use the rights that will, hopefully, be recognized through Bill S-5.

[Laurel Collins, NDP, Victoria, BC]

Thanks so much.

I also have a question for Dr. Chandrasekera.

Can you talk a bit more about the comparison you made with what's being done in the EU and the U.S. on eliminating animal testing and how Canada is lagging behind?

[Dr. Charu Chandrasekera]

Most of these countries have legislation already in place and national strategic road maps geared toward eliminating vertebrate animal testing in the United States. They amended TSCA, the Toxic Substances Control Act the same way that we're trying to amend CEPA here.

The Environmental Protection Agency was told that within two years of that act's passing, it had to come up with a strategic road map to phase out and reduce and replace the use of vertebrate animals in chemical safety testing. They did that. I was there as a Canadian expert to provide feedback on that.

Then the U.S. Food and Drug Administration is going to be going through a transformation with the FDA Modernization Act, under which manufacturers and sponsors will be able to use alternative methods to test the safety and effectiveness of drugs.

There are three national strategic road maps in the United States. One was written by 16 federal agencies that use animals for scientific purposes; there is also the EPA road map and an FDA road map on top of the recent legislation.

[Laurel Collins, NDP, Victoria, BC]

Thank you so much.

You know, I find it very compelling. I didn't realize before—and this is part of my ignorance—that alternatives can be more effective when it comes to animal testing—before seeing some of the research of the Canadian Centre for Alternatives to Animal Methods.

Can you describe a bit more about the benefits those alternatives provide?

[Dr. Charu Chandrasekera]

The key benefits are that they are cheaper, faster and more predictive of human biology, and that's the most important thing. In most of these legacy animal methods, these are animals that have many differences at various levels, and they cannot accurately predict how we humans would respond to chemicals and drugs and other things that we are exposed to. With these new methods, we are able to capture human biology at different levels. We're using these integrated methods that can capture what happens to our genes, what happens at the cellular level, what happens at the organ level, and incorporate all of these using very sophisticated computational programs.

We're also using these methods to think about the questions differently. Some of these animal methods that were developed in the fifties and sixties were never really validated to see if they were predictive of human biology. They were just adopted in many cases, and now we're seeing that they cannot address some of our questions.

One example is developmental neurotoxicities. This is looking at the toxicity in the developing brain. The gold standard mouse model is not a gold standard at all.

[The Chair, Liberal, Francis Scarpaleggia]

We're going to have to stop there and go to our second round. I'm sorry. It's very interesting, but we have to go to our second round.

Mr. Benzen, you have four minutes.

[Bob Benzen, Conservative, Calgary Heritage, AB]

Thank you, Mr. Chair.

Thank you to all of the witnesses here today.

Mr. Masterson, you have a long history with the responsible care initiative. Maybe you could give us a little bit of background on what that is and tell us how your members of that initiative live up to the standards that have been set by the responsible care initiative. Also, you could tell us just how the initiative can work to help us have a healthier environment and how it's implemented through Bill S-5.

[Bob Masterson]

Our industry is extremely proud of responsible care. This was founded in Canada in 1985. It's now practised in 73 countries worldwide and by 95% of the top 150 chemical companies worldwide. It is “the” global ESG standard for the chemistry sector.

It's also a condition of membership for our association. We're a club of leaders, so when we come to the table, you're not getting the perspective of the entire chemistry industry. You're getting the perspective of the leaders who are committed to continual improvement and betterment of the environment and of society.

At its heart, the initiative covers more than 170 different requirements that go well beyond any regulation in Canada. It does oblige the members to take proactive efforts to protect the environment, as well as worker, community, customer and consumer health.

More broadly, though—and that's why we've been so involved with this process, both with the regulators and with other stakeholders—it's intended to ensure that the industry has awareness of, and is responsive to, society's changing expectations for the industry. You can see that no more so than in the last four years. This is an initiative that back in 1985 was largely focused on what happened inside our plant gate. That's not enough for society today.

In the last four years, what you've seen is that we have integrated commitments to indigenous reconciliation and engagement into responsible care, and just this past month, our board of directors also included commitments to diversity, equity and inclusion.

This is really important because one of the things at the heart of responsible care is that all these elements are auditable once every three years, and the reports are made publicly available. It's not just an empty commitment that, yes, I'm going to address indigenous engagement and reconciliation, and that, yes, I'm going to address diversity, equity and inclusion. I'm going to do it. I'm going to have a formal process to do it. I'm going to work with my critics and stakeholders to do it. I'm going to be audited, and the results are going to be publicly reported.

We think it's a world-class initiative, and in fact, it is a world-class initiative. We appreciate the opportunity to let parliamentarians know more about it.

Thank you.

[Bob Benzen, Conservative, Calgary Heritage, AB]

Thank you. That was a great answer.

Now, considering that in schedule 1 they're going to be creating two parts and requiring certain substances to have a higher risk management, do you think it is appropriate that there is a pollution prevention plan for every substance listed in schedule 1?

[Danielle Morrison]

A pollution prevention plan, or a P2 plan, is a form of risk management. Really, at the heart of decisions made about risk management is that risk management has to be tied to the risk assessed. Experts currently have a variety of risk-management tools at their disposal, depending on the degree of risk that is posed by that substance. This ranges from, on one side, pollution prevention to, on another side, prohibition.

There are also regulations under CEPA and other acts for the use of the best-placed act that can be used for risk management.

We think that any mandatory pollution prevention requirement would take away this discretion, and this link between risk assessed and risk managed would codify the process and would not adequately reflect the science and the risk-based nature of the act.

[Bob Masterson]

I could share one example, perhaps. Ontario did introduce a Toxics Reduction Act. It did require plans for anybody producing and using substances on a long list. It became a paperwork exercise. Here you are, maybe you're manufacturing sulfuric acid, which is an important component that goes into and out of the mining industry. Maybe you're manufacturing chlorine in Quebec. Suddenly you have to come up with a plan to do what? Is it to reduce the production of chlorine? It's not very effective.