:
Thank you, Mr. Chairman and members of the committee. Good morning and thank you for the opportunity to be here today. I guess it's a historic meeting.
I am joined, as you referenced, Mr. Chair, by Janice Tranberg, who is our vice-president for western Canada out of Saskatoon, our innovation office at the University of Saskatchewan, and who also leads our plant biotechnology file.
As the president of CropLife Canada, the trade association representing developers, manufacturers, and distributors of plant science technologies, including plant biotechnology, I'm always happy to speak about our industry's place in Canada's future.
Both large- and small-scale developers of agriculture biotechnology as well as distributors of these products all play an important role in the Canadian agricultural sector. As governments seek to maintain or attract investments from these companies, it is important to understand what drives their decisions.
Ours is a highly scientific industry that contributes significantly to international research. Each new biotech trait takes about ten years and costs between $100 million and $150 million to bring to market.
With annual global research expenditures of over $5 billion, our industry accounts for one-third of the world's total agricultural research and development investment. This represents about 11% of total sales, and puts our industry in the same league as the pharmaceutical industry in terms of overall reinvestment in R and D, which I think speaks directly to our commitment to innovation.
As you explore the future of agricultural biotechnology in Canada, let me be unequivocally clear about what our industry will be looking at when it contemplates the very same thing. Our industry will be asking whether Canada has upheld its commitment to science-based regulations. Without a solid, science-based regulatory system, our industry will not be able to invest in this country to the same degree it has in the past, particularly when there are options to invest in countries where the criteria for success are clear and predictable. Where these plant biotechnologies are supported, there are benefits on three very important fronts: benefits to farmers, benefits to the environment, and benefits to consumers.
As you can imagine, biotech would have fallen flat if they did not deliver economic benefits to our customers, the Canadian farmer.
Various studies tell us that the net global economic benefit from plant biotech crops at the farmgate level was $10.1 billion U.S., to use 2007 as an example. The direct and indirect economic value of GM canola is $300 million Canadian a year. Biotech applications decreased the environmental impact—and costs—from herbicide and insecticide use by 17.2%, when looked at through the period 1996 to 2007.
It's no surprise then that Canadian farmers are voting with their seeders in favour of biotechnology. In fact, Canadian farmers choose genetically modified options for approximately 90% of the canola they plant, 85% of the corn, and 65% of the soybeans. Globally, this makes Canadian farmers the fifth highest adopters in the world of the technology in terms of acres planted.
Much of today's research is focused on developing ways to enhance, protect, or adapt to the changing environment. In the coming years, we expect to see new traits that offer tolerance, that can withstand drought and other stresses like cold and saline soils, new disease resistance, better nitrogen utilization, and a range of healthier foods.
The prospect of drought-tolerant crops is particularly exciting given the high demand agriculture places on water supplies, because the United Nations estimates that by 2030, one in five countries will experience water shortages. We need drought-resistant varieties before that time if we are going to weather the food security challenges that such a significant water shortage would cause.
One in six people in the world is already undernourished. What happens if one in five countries ceases to have the water required to grow food?
Drought-tolerant crops can initiate natural drought defence mechanisms earlier in the moisture deprivation stage, and as such, they stand to have a significant impact on Canadian farmers as well as farmers in developing parts of the world.
Corn and canola, with improved nitrogen utilization, are also on their way. Reducing the amounts of inputs required saves farmers both time and money. It's something they clearly appreciate.
By improving the ability of crops to use nitrogen, we reduce the amount of money farmers pay for fertilizer, the amount of fuel they burn applying it, and at the same time it increases their profitability. From our perspective—and I would dare say it's a perspective many farmers and consumers share—these innovations are worth pursuing.
The question then becomes what is Canada's vision for the future of agriculture, for ensuring Canadian farmers are competitive into the future? Are investments in innovation and agricultural biotechnology things this country wants to see happen and happen here? If so, what needs to be done to attract investment and ultimately the commercialization of these new technologies here in Canada?
As I said earlier, first and foremost it's science-based regulations. A predictable, evidence-based regulatory framework built on science is essential. As an industry, we accept that the technology is and should be highly regulated to ensure public safety and environmental protection. But we believe this should be done on the basis of sound science, not public opinion polls, not personal anecdotes but solid, evidence-based, peer-reviewed science.
Secondly, Canada needs to take a leadership role on global modernization of regulations. Foremost, this means Canada must develop and adopt a low-level presence policy for genetically modified crops and then advocate for other countries to do the same. The fact of the matter is that detection technology has become so incredibly sophisticated that one flax seed, for example, in a sea of ten thousand is detectable. As you've heard from other members coming before this committee on this study and others, zero tolerance is simply not practical, and trace levels of safe and approved GM crops should not be impeding the movement of commodities around the world.
Other regulatory and policy areas of importance that I do not have time to elaborate on this morning include a clear policy statement on plant-made industrial products, the Canada-EU trade agreement, asynchronous approvals, product discontinuation protocols, and regulatory efficiency timelines.
Also related to regulations and Canada's ability to attract innovation will be the appropriate funding, training, and human resource allocation to regulating agencies and departments as well as the country's continued alignment with like-minded industrial nations. Plant biotechnology innovations are gaining momentum, and the number of submissions will be escalating. Canada must be ready and prepare for an explosion of activity on this front.
Let me explain. Whereas in the past ten years there have been 33 biotech approvals sought worldwide, we anticipate there will be 125 approvals sought in the next five years alone. And close to half of these will come from Asia.
Ladies and gentlemen of the committee, this is the new competition. It's the Chinas of the world that are spending 1% of their GDP on research, and a big chunk of that is dedicated to agriculture biotechnology. If you think there's an issue today around low-level presence policy and the nimbleness to make sure our farmers have the tools, wait until some of this competition starts to come online.
Improved efficiency and performance of the regulatory system, both within and between regulating departments and agencies, is essential for coping with some of that, so that one department's lag does not create a drag on government's overall performance.
Canada can, in part, help decrease the pressure it comes under by increasing synchronization of approvals, using common approaches to risk assessment, and doing joint reviews to avoid trade issues related to asynchronous approvals for plants with novel traits and low-level presence. Also, it can recognize regulatory decisions of other countries, particularly in North America, while Canada conducts its own risk assessments. And it can pursue regulatory bilateral and multilateral agreements to increase predictability and efficiency.
Our industry is excited about the future of agriculture innovations. For decades our innovations have been helping to feed people here and around the world by providing farmers with tools that help them grow more food on less land. We attract some of the brightest minds in research and business. And one thing we all share is pride in the solutions we generate for challenges that exist today and challenges we expect will develop in the future.
Our provincial and federal governments need to talk about the regulatory approach in a way that will reinforce public confidence. Alignment across the country and a willingness to defend the rightfulness of science-based polices will be absolutely essential to attraction of investment and further innovations.
We believe biotechnology can play a pivotal and transformational role in that future for Canada and for the competitiveness of Canadian farmers. Mr. Chairman, members of the committee, we hope you will come to that same conclusion as you explore this topic further. We ask you to join with us in helping to grow Canada.
Thank you, Mr. Chairman.
Thank you, committee members, for inviting me here today on behalf of the Canadian Biotechnology Action Network to speak to you about the issue of genetic engineering.
It is important to evaluate what we have learned about genetic engineering from our 15 years of experience with this technology in food and agriculture in Canada.
I work in Ottawa as coordinator for the Canadian Biotechnology Action Network, or CBAN. CBAN is a coalition of 18 organizations across Canada that have various concerns and experiences with genetic engineering. This includes international development organizations such as Inter Pares and USC Canada. It includes farmer associations such as the Saskatchewan Organic Directorate, the Ecological Farmers' Association of Ontario, and Union paysanne. It also includes coalitions of grassroots groups like the Society for a G.E. Free B.C., and the Prince Edward Island Coalition for a GMO-Free Province.
What brings us together is a concern about the impacts of genetic engineering, be they economic, social, or environmental, and the lack of democracy in relation to decision-making over this technology.
The Biotechnology Action Network is three years old. In my role heading the small secretariat here in Ottawa, I conduct research and assist in communications, such as my testimony here today.
I have worked as a researcher and campaigner on these issues around genetic engineering for 15 years. For example, on Tuesday Gord Surgeoner mentioned a council that brought diverse stakeholders together. He was referring to the Canadian Biotechnology Advisory Committee. I participated in the work of this committee when I worked for the Sierra Club Canada. That committee no longer exists.
My understanding from attending the first hearing on Tuesday is that the committee study is open to or explicitly asking for recommendations. I seem to be hearing that there is an openness to examine many issues around the biotechnology industry. We hope this is the case, as we think there are very many critical issues, such as those raised by Bill C-474. I'll speak to some of our analysis of what needs to happen in Canada on this issue, what we think, and what we will be faced with in the new year.
I understand that the debate over Bill C-474 has been a part of triggering these hearings, and we think it's highly appropriate that farmer concern about the impacts of biotechnology instigate an investigation into genetic engineering.
To be clear, I'm talking about genetic engineering as defined by the CFIA, which is recumbent DNA technology. This is what we're referring to when we talk about biotechnology. This is what's at issue and where the controversy largely lies.
CBAN argues that there are fundamental problems with genetic engineering and fundamental problems with the Canadian government's approach to this technology, including our regulation.
I'll talk about some of our concerns by looking at three immediate issues we face in Canada: the possible introduction of genetically engineered alfalfa, GE pigs, and GE salmon.
In the short brief that CBAN submitted to the committee we introduced these three case studies, as well as the issue of genetically engineered wheat, which we think illustrate the need to assess the potential export market harm of applications of genetic engineering. They also illuminate other critical issues and possible negative impacts.
To begin with, CBAN would like to state our support for Bill C-474 and the recommendation that social and economic concerns be incorporated into the regulation of genetic engineering.
CBAN would also like to remind the committee that in 2001, as commissioned by the ministers of agriculture, environment, and health, the Royal Society of Canada's expert panel on the future of food biotechnology published 58 recommendations for regulatory reform. CBAN would like to see the government implement all 58 of those recommendations.
I'd like to concentrate my testimony by discussing briefly the three genetically engineered organisms we must immediately deal with. All three pose major economic and environmental threats, and are or will be highly socially disruptive. They will certainly be socially contested--the alfalfa, pigs, and salmon.
This is the immediate future of genetic engineering. Any of these three could be commercially introduced next year, or even this year. Each is approved via a process that neither the public nor independent scientists have access to. Each is subject to intense opposition for distinct reasons. These three GE organisms illuminate three key concerns we would like to raise, among many.
First, contamination is a reality and has numerous negative social, economic, and environmental impacts.
Second, GE research is under way in universities with either industry or public funds, but without a public mandate.
And finally, government decision-making processes are kept secret and locked away from public participation, and these processes rely solely on privately owned science. These highly secretive processes could allow the commercialization of the world's first genetically engineered food animal.
If we look at this first issue, contamination, which of course the committee has discussed in depth, we see that it has numerous social, economic, and environmental impacts, and that the fallacy of coexistence will collapse if GE alfalfa is introduced. By coexistence I mean the ability of organic or other non-GE crops or farming, non-GE farming, to exist side by side with GE crops. Alfalfa will contaminate. This is a certainty, given the characteristics of alfalfa as a perennial crop pollinated by bees. You've already heard this in the testimony from forage groups. Contamination happens, but farmers always knew this would happen. Contamination was predicted and is predictable, and yet there are no policies that we see or regulatory mechanisms in place to address this.
The issue of alfalfa shows how certain applications of genetic engineering can be a clear threat to some or many farmers, and yet these farmers have no way to communicate effectively to government. There is no avenue for farmer consultation on the impacts they foresee.
As the committee heard in June, conventional forage growers are clear that GE alfalfa would ruin their businesses. As the committee heard from the organic industry, GE alfalfa is a clear and immediate threat to the future of the entire food and farming system in North America.
To summarize, we think the issue of GE alfalfa clearly raises the need to incorporate social and economic considerations in decision-making.
Second, we would say that GE research is under way in universities, as I mentioned, either with industry or even public funds, and yet without a public mandate. And here we could look at the example of "Enviropig". Canada is about to become the origin of GE pork, the GE pig trademarked Enviropig.
Canada could be the first to approve the GE pig for human consumption. The University of Guelph submitted a request to Health Canada in April 2009, and we only know this because this is the one piece of information the university has shared with the public. Environment Canada has already approved the pigs for confined reproduction.
Enviropig was developed by Canadian researchers, with public funds, at the University of Guelph. It was developed with public funds, but without, we would argue, a public mandate. Just like the GE Triffid flax, a university is ready to commercialize a product that consumers and, arguably, farmers do not want. So we would ask where the public oversight is in that process.
The project Enviropig was conceived over ten years ago and was pursued with at least two explicit assumptions that we now see are false: first, that this product was an environmental solution and would be seen as an environmental solution; and second, that consumers would accept GE foods by the time the product was ready for market.
Canada needs to, on an urgent basis, evaluate the social acceptance and economic impact of Enviropig. Our current regulatory system does not allow the government to consider these questions. These are, in practical terms, irrelevant in regulation. Health Canada could approve the GE pig for human consumption in Canada tomorrow. The fact that this decision alone is likely to cause chaos in the domestic and international market for Canadian pork and pork products is irrelevant in our current regulation.
This brings us back to the question of export market harm, the problem identified by , the core problem of approving GE crops despite and regardless of their known, anticipated, or possible economic and social impacts. The possible commercialization of Enviropig also brings into sharp focus the fact that there is no mandatory labelling of GE foods in Canada. The reality is that consumers will avoid pork and pork products in order to avoid GE pork.
Finally, we would say that the government decision-making processes are kept secret and locked away from public participation. These processes rely solely on privately generated and privately owned science, and yet these decisions can potentially have very grave impacts.
I did want to mention the case of the genetically engineered salmon, because it does illustrate some very specific problems that cross into other genetically engineered organisms. Canada is about to become the origin of GE salmon eggs for the world.
Documents released by the U.S. Food and Drug Administration revealed that AquaBounty, a U.S. company, actually plans to produce all of its GE salmon eggs in Prince Edward Island, then ship them to Panama to grow out and process and then ship to the U.S. market.
I and others have called Health Canada to request information about this possible risk assessment, and Environment Canada actually refuses to even tell us if a risk assessment is under way. This is because Environment Canada is now charged with regulating GE animals, including the fish.
In conclusion, the government has invested in the biotechnology industry as an economic driver, as a valuable economic activity. Yet in our view, we see that genetic engineering is actually about to take down Canada's pork producers and organic grain farmers.
It's urgent, in our view, that the government be proactive in resolving these ongoing issues that we see are building into a crisis, a crisis that will cost farmers their crops and organic certification. It will cost hog producers their markets, both domestic and international.
It's a crisis that will take the form of a consumer crisis of confidence in the food system and in our democracy. In the case of GE salmon, it is a crisis that could involve species extinction, a global conservation crisis.
Unfortunately, in our view, these are not exaggerations. These are risk evaluations, and our government currently does not have the tools to ask or address these questions.
We recommend that the government place a moratorium on approval of all new genetically engineered organisms until there has been a wide democratic debate and also a fundamental change in our approach to this technology.
Thank you.
:
Thank you for your observation and question.
On the issue that you rightly raise about the tragedy in the world of a billion people suffering from undernourishment and hunger, I think most people, when they look at that and how the world is going to help deal with that question, which has been a long and ongoing one--the millennium development goals spoke to trying to reduce that by half by 2015, I think it was--we're not doing as well there as probably we would like. But I think it's fair to say that a lot of the world's countries and governments and their regulators recognize that we're probably going to need all the tools that we can have, responsibly used, to help address that problem and water and all the rest of it.
I think you see that happening across the world now with the rapid uptake in a lot of the developing economies. We now have something in the order of 25 countries where GMO crops are growing about 330 million acres on the ground, including 90% of those crops now in developing economies.
On Europe, I should say right at the outset before I go to this part of the question, and on technology dependence--I should pick that up as well.... It's all about choice. It's about choice for the consumer and choice for the farmer. A lot of people think that because I work for the plant science industry I'm somehow against organic. I'm not. If farmers choose to grow organic and if consumers choose to buy organic, that is their right, and that should be their choice, as long as it's all done on a factual basis in terms of what the benefits and the risks are.
As to whether somehow these technologies that we're developing are making farmers technology dependent, I would suggest that this is a gross underestimation of the intelligence of the average farmer. They are very shrewd people and they wouldn't be choosing these technologies, like they are in Canada, if they didn't bring benefits economically.
Farmers are really good stewards of the land. That's their whole being, if you like, because if they don't look after the land and the environment, the land and the air, they won't be there subsequently. To suggest that this is somehow tech...that farmers aren't smart enough to see around that I think is a gross underestimation of them.
In terms of Europe and tolerance levels, once again--
I just want to pick up on the health, safety, and environmental observation in reference to some earlier discussion—I think maybe Mr. Valeriote raised it—about where there's common ground. We have some opposing views, but I think there's a lot of common ground around here and around your table.
First and foremost, we all want to make sure that technologies, whether they're pharmaceutical drugs or GMO crops, are used properly, responsibly, and they do not put at risk the health of the public or the environment. I think there's a pile of common ground there.
I think additionally there's a pile of common ground that if this stuff is going to be sold to farmers that it needs to work, that it's efficacious, and it's not some kind of snake oil, if you like. It has to work.
With the corn, the soybeans, the canola, the uptake by farmers has been phenomenal. It was probably considered revolutionary technology in the late twenties, when corn hybrid technology came to the marketplace. It had a huge adoption rate, and this has probably even exceeded that.
And there are some new traits we talked about that are coming in those sectors. I mean, I'm from western Canada and I still farm out there. Notwithstanding that we had a huge flood out there this year that wiped out ten million acres, I farm in the bottom of the middle of the Palliser Triangle. Most years, I'll tell you, I would love to have drought-tolerant crops; we're usually so dry the trees are chasing the dogs. Drought is usually our problem there, so that technology in Canada and elsewhere in the world can bring a huge benefit.
When you talk about common ground, once again, if climate change is coming at us—and farmers deal with climate every day, it's called weather—then to some degree, not totally, this technology is very much part of the answer for how we're going to deal with climate change on a go-forward basis.
For those of you who were at our conference a couple of weeks ago, you would have heard Dr. Skole, from the University of Michigan. He said our understanding of climate change is that if you're a wheat farmer in western Canada there are two tools you're going to need: farm practices and genomics. Those were the two tools that he pointed out are pivotal.
One final comment in terms of the common ground and safety and the environment and the rest of it. Lucy referenced the work she had done at CBAC, through one of the member organizations there. They spent two years studying biotech food. This is one of the conclusions of that CBAC committee report:
We conclude that no scientific evidence exists to suggest that GM plants and foods currently in the market pose any greater health or environmental risk than other foods.
In fact, they went on to say that arguably they “have undergone greater regulatory scrutiny than their conventional counterparts”.
I just wanted to pick up that point.
In terms of other products, Janice, did you want to...?
Thank you. I'm sorry that it's a little late, but I read the briefs and there is a lot of information here. And as Frank says, there are two solitudes. Our concern is how you bridge the gap. From our perspective, who do you believe? I'll put it that simply.
Prince Edward Island salmon was mentioned, Lucy, and I just want to refer you to what the FDA in the U.S. said on that product.
I will submit to you that non-GM canola is something we are extremely worried about in P.E.I. If GM canola got introduced in our area, we would completely lose the Japanese market, and the Japanese market is huge to us in terms of non-GMO canola and a lot of other non-GM and organic crops. The Japanese market is a premium market and important to us. And the reality is that we would lose that market just like that when they do their investigation, if there were a GM crop that could contaminate canola.
But on the Prince Edward Island salmon issue, the FDA has concluded in its analysis in the United States, AquAdvantage Salmon, on September 20.... I'll just quote what they say in this report. They conclude that food from the triploid ABT salmon “is as safe as food from conventional salmon” and that “there is a reasonable certainty of no harm from consumption of food” from this animal. They do say there should be another study performed on the allergenicity of the diploid fish and submit it for evaluation. They also talk about the adequate containment measures that appear in place in both P.E.I. and in Panama.
That's just to put that on the record that there are two sides to that story too.
Based on the hearings we held on Bill , the two areas I am currently worried about are that things are moving too rapidly without perhaps the right peer review, transparency, or protective measures in place on wheat and on alfalfa.
If alfalfa were to become contaminated, you are right, we would have a real problem in terms of many of our organic markets. It's the base crop for organic production, and there don't seem to be many areas that study not only the food and health safety but the environment, the economic impact, and the impact on biodiversity.
So this is my question to you all. There are pros and cons on the biotech industry—a lot of good and also some risk. How do we get to a system? What system has to be put in place? I agree with what Frank said earlier, that the Canadian Biotechnology Advisory Committee would be extremely important. But how do we get a system in place where there can be reasonable confidence on both sides that the measures necessary are actually being implemented so they can be believed by the average person out there and by some of the decision-makers in the political process as well?
Lorne.