Applications for the approval of Round-Up Ready Wheat have brought increased attention to regulations for the licensing of new GM plants in Canada. Some organizations have called for new legislation and/or regulations that would incorporate non-scientific factors, such as market acceptance, into the regulatory approval process for the licensing of new plant varieties that are products of genetic technology. Agriculture Canada is currently drafting a response to these calls for new legislation and/or regulations.

The Grain Growers of Canada (GGC) is extremely concerned with the direction proposed by those calling for changes to Canada's regulatory system. We have been very active in communicating this position to both legislators and regulators.
This issue extends well beyond Round-Up Ready Wheat, and even beyond wheat itself. Those calling for new regulations must recognize that the response they advocate for this particular variety of wheat could negatively impact farmers' ability to take advantage of future innovations in other varieties and commodities.

The request for new regulations to limit the ability of farmers to take advantage of genetic technologies appears to be based on the presumptions that there are no markets for plants derived from genetic technology and that the use of genetic technology is detrimental to farm income. However, the significant use of GM corn, soybeans and canola by farmers across Canada proves both that there are numerous markets for such products and that farmers accrue significant benefits by adopting them.

The approach used by the Government of Canada in approving plants and foods with ‘novel’ traits created by sophisticated genetic technologies has been endorsed internationally by groups such as the World Health Organization and the Organization for Economic Cooperation and Development. The Canadian regulatory approach recognizes that there are potential health and environmental concerns – which merit thorough evaluation – associated with the introduction of all ‘novel’ crops and other biological organisms used as food. Canada must defend its approach, not weaken our legislation and regulation by introducing nonscientific factors into our regulatory regime. Canada must continue to challenge countries that attempt to block trade for non-scientific reasons (e.g., canola moving into Europe, beef moving into Europe). Our ability to successfully make these challenges would be significantly reduced if Canada chose to pass its own non-science-based legislation.

Some countries are attempting to bring these non-scientific factors into other international forums, such as the World Trade Organization negotiations or the Cartagena Protocol on Biosafety. Our trading partners would be in a position to block Canadian exports of grains and oilseeds arbitrarily if these efforts are successful. Canada has resisted, and must continue to combat, attempts to move away from science-based sanitary and phytosanitary rules of trade. Again, passing our own non-scientific legislation or regulations would undermine these efforts. Not only would such regulations negatively impact farmers who are growing GM plants today, they may also set a precedent that could prevent the further introduction of GM products in Canada. Why would Canada make decisions that would restrict our farmers from taking advantage of future innovations in life sciences?

Countries that have chosen to base their regulatory regimes on something other than science are now beginning to see the cost of their error. For example, the European Union has found that non-scientific legislation and regulations drive away investment. European Research Commissioner Philippe Busquin, in a report issued March 5, 2003, found that over 60% of companies conducting GM research in Europe have canceled research projects because of the EU ban on the licensing of new GM products. Many believe that the EU will soon reverse its regulations in order to reverse this research brain drain. Hopefully this decision will result in the removal of the barriers to Canadian exports.

It must be acknowledged that concerns about negative market impacts, resulting from inadequate segregation and testing procedures for example, need to be addressed. The GGC has proposed a voluntary Advanced Stakeholder Review Committee (ASRC) to deal proactively with the marketing issues surrounding the commercial introduction of genetically modified wheat. A copy of this proposal can be viewed on the OCPA website under the title Addressing Concerns Surrounding New Products of Genetic Technologies - Grain Growers of Canada. The Committee would involve technology developers, seed growers, Canadian grain farmers, grain marketers and exporters, representatives from the grain handling and transportation sectors, the Canadian food processing industry, as well as consumers. ASRC would ensure an industry-driven process is in place to lead the introduction of biotech crops and ensure markets are ready with reliable identity preservation and segregation procedures in place.

This process would address the marketing concerns of farmers and grain exporters and provide governments and consumers with increased transparency and input into the development and commercialization of the products of genetic technology. This will help increase the acceptance of products that have been judged to be safe, both from a health as well as an environmental point of view.

Biotechnology will provide Canadian grains and oilseed farmers with a key tool to profit in an increasingly competitive trading environment. We must be ready to take advantage of these developments, while remaining cognizant of the needs of importers and the desires of consumers. We believe that the balanced proposal presented to the government by the Grain Growers of Canada will accomplish these goals.

Canada is a world leader in biotechnology research because our regulatory framework has been soundly grounded in science. We do not want to go down the path chosen by the EU, and drive investment, research, and innovation out of the country.

1