[Recorded by Electronic Apparatus]
Wednesday, June 5, 1996
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[Translation]
The Chairman: Pursuant to Standing Order 108(2), the topic today is biotechnology.
[English]
As you have noticed from previous meetings, here we are attempting to bridge a gap of knowledge between the political sector and the industrial sector. So far we have had some comprehensive meetings. Today we hope that we will progress in the same constructive direction that was initiated a couple of weeks ago.
The witnesses today are assembled in four groups. The first will be the Food Biotechnology Centre, represented by Dr. Surgeoner and Joyce Groote. They will be given ten minutes as arranged. We apologize for not being able to do more, but as you know a lot of good information emerges in the question-and-answer period.
The second group will be from
[Translation]
the Fédération nationale des associations de consommateurs du Québec, represented by Elisabeth Hunter and Richard Dagenais.
[English]
The third group is from the Consumers' Association of Canada, and is represented by Chris Mitchler and Marnie McCall.
Finally, there a combined presentation by Agriculture and Agri-Food Canada and Health Canada, with Dr. MacKenzie and Mr. Reasbeck, Dr. Paterson and Mr. Mayers.
We apologize for not having started as originally planned at 3:30 p.m., but it was due to an awards ceremony that is still taking place in the Centre Block, which explains the absence of some colleagues, who will join us very soon. We would like to start as quickly as we can.
We welcome you all in this room, either at the table or in the less expensive seats. We look forward to a couple of very interesting hours.
Dr. Surgeoner, would you like to start?
Dr. Gordon Surgeoner (Chair, Board of Directors, Food Biotechnology Centre): Thank you, Mr. Chairman. We very much appreciate being the opportunity to come and speak to you and the members of the committee today.
The first thing I'd like to explain is who I am. I think that's important in this whole process. I'm a professor in the Department of Environmental Biology at the University of Guelph. There are a number of roles that are pertinent to this committee that I have played in the past.
I am currently the director of plant research at the University of Guelph. I also chair the Environmental Farm Coalition, which is made up of some 7,000 farmers who have completed environmental farm plans. We thank the federal government and the Green Plan for giving us the capability to do that. We have a nice brochure that I'd like to thank you with and provide to the committee.
Finally, I am here as chairman of the board of directors of the Food Biotechnology Centre. Very importantly, too, I'm a father. I have three young children and have been happily married for23 years. I'm a Canadian and very proud to be so. I look to the future of this country.
The next point I'd like to make is about who the Food Biotechnology Centre is. Basically that centre is its members. The members are composed of universities, consumer associations - in fact, some of them are here today - the federal government, industry, including farm organizations, the provincial government, food processing and distribution corporations, and health and nutrition professionals, as well as individual citizens.
I think the key point about the centre is that it's not owned by one sector. I am a volunteer here today. I've driven up on my own accord. The objective of our group is to provide balanced information in a forum for interchange of information on food biotechnology.
Already the centre has hosted nine forums associated with food biotechnology. In fact, very relevant to today's meeting is a forum held in Montreal - it's in your package - on food biotechnology, consumer information, and ``do we need to label?''
The point of the centre is to have open dialogue and a fair exchange of ideas. In our opinion, there are three key ideas we need to bring across to the committee.
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First, what are the right questions we should be looking at in terms of labelling? Through our association - and the executive director Joyce Groote is here today - we have had these forums, and a number of key questions consistently come forward. The consumer wants to know if the food is safe, if the food is nutritious, if there is benefit to the consumer, and finally if there are major ethical concerns associated with that food. The key is the questions - are we asking the right questions?
The second key point is that labelling is only one of several mechanisms for providing information associated with food biotechnology. Other mechanisms are education, particularly at the school, university and the public level; point-of-sale information as the consumer purchases in the grocery store; Web sites, and we now have an Internet site through the Food Biotechnology Centre to provide information for those wishing it; and 1-800 or 1-888 numbers. There are many mechanisms by which information associated with food labelling, including food biotechnology, can be brought to the public.
I think the important question is this: what is the most meaningful way to provide that information, what is the meaningful information and what is the most effective way of providing that information?
A subset of this is that labelling is a very complex issue. I'm going to use Ontario, as I work with Ontario producers to a very large extent, and we'll use corn. In the province of Ontario in the next five years we are likely to eliminate through biotechnology all insecticide use in corn. We will have corn to control the European corn borer, corn varieties where we control the corn rootworm.
In so doing, we will have a complex issue to address. That corn can be turned into some2,000 products. Indeed, it is used as one of the feedstocks of our major livestock industry. How do we label food associated with that? We take corn, and let's say we use only corn rootworm. That material may be fed to hogs and then be part of our swine industry and part of our major international trade with the United States. Those could be changed into sausages, which could end up on pizza. Do we label that pizza as a product of biotechnology? These are some of the issues. We would be looking at literally thousands of products in the province of Ontario.
The third point is that our members strongly embrace the concept that the consumer has the right to information, within certain societal norms. I guess we do have the right to know whether our milk came from a blue-eyed cow. The question is, who has the responsibility for finding that information, and do we as a society have the responsibility for providing that information?
A subset of that is that everyone has a responsibility to provide information, again where appropriate. Consumers, government, educators - we all have a responsibility to provide information. It is becoming very apparent that government must be increasingly supportive in how we communicate information to consumers about biotechnology. I emphasize that this is just the start of many potential products. We have to provide meaningful information in an effective manner.
That's the challenge I would put to this committee. We all should work to provide consumers with information so that they can make informed decisions. I think the key questions, however, are the essential information that most consumers would like and how we can effectively provide meaningful information to them. That is the challenge this committee has before it. Thank you.
The Chairman: Thank you.
Who is next? Would you introduce yourself and your organization?
[Translation]
Ms Elisabeth Hunter (Liaison Officer, Fédération nationale des associations de consommateurs du Québec): We would like to start by thanking you for inviting us to take part in this meeting of the Standing Committee on the Environment and Sustainable Development.
Richard Dagenais, a researcher at the FNACQ, and myself, Elisabeth Hunter, liaison officer, will try to answer your questions about labelling foods from biotechnology.
We would like to take this opportunity as well to describe our organization.
The Fédération nationale des association de consommateurs du Québec, the FNACQ, was established to give a strong voice to consumer groups in Quebec, particularly those with low or modest incomes.
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The FNACQ was set up in 1978 and is composed of four groups: the Associations coopératives d'économie familiale from Granby, the Eastern townships, Quebec City and the South shore of Montreal.
The Federation gained a reputation particularly for its work on regulating milk prices and labelling food prices in connection with the introduction of the optical reader in supermarkets. It is also known for its work in the area of telecommunications. We have also been involved in biological agriculture issues and the review of the federal Pesticides Act.
The Federation and its member groups have also been doing research for five years on the development of biotechnological products, particularly in the agri-food area.
This year, because of a project support grant from the Bureau of Consumer Affairs at Industry Canada, the FNACQ had an opportunity to make some recommendations put forward by public interest groups on the federal government's biotechnology regulatory review, and on citizen information and participation in this field.
In order to do this, the FNACQ set up a Canadian network of consumer associations, and public and citizen interest groups that represent the interests of Canadian consumers. At the moment, this network includes some 30 public interest organizations representing over 250,000 Canadian citizens, as well as about 10 individual citizens with a specific interest in the issue. The list is attached in Appendix 1.
These members come from various areas - agriculture, environment, health and consumer affairs - and promote a type of economic development that respects citizens' rights and protects the environment at the same time.
Since the network was created in the fall of 1995, the FNACQ has had its member groups participate in public forums and consultations organized by the federal government, on the labelling of novel foods, for example.
In addition, about 60 representatives of consumer associations and public interest groups presented their positions at 10 regional discussion meetings organized by the FNACQ in cooperation with local member groups.
In this way, the Federation is trying to work with member groups in the network to develop a common vision regarding the regulation and labelling of products from biotechnology.
The main message that came out of our consultations was that the development of new biotechnologies is being carried out too quickly for us to assess responsibly the impact on human beings and the environment. The groups and individuals with whom we have met point out that the values and rights of citizens are not adequately represented in decisions about the regulation of new biotechnologies in Canada, because of a lack of information and resources.
The complete document describing the meetings and the project will be tabled today and will be available for consultation. The summary of "Guidelines for the Regulation of Biotechnologies" produced by the FNACQ as a reference document in this project can be found in Appendix 3 of our text.
I know you've already had an opportunity to hear about some of the new dangers that can be caused by the new biotechnologies and genetic engineering, in the presentations of the Canadian Environmental Network, for example. Consequently, we will devote the rest of our presentation to the issue of labelling food from biotechnology.
Mr. Richard Dagenais (researcher, Fédération nationale des associations de consommateurs du Québec): I will continue the presentation. We submitted a second document which sets out our comments to Agriculture and Agri-Food Canada about its guidelines on the labelling of novel foods from genetic engineering. So you can have a look at it, and I will summarize the main points of our position.
In December 1995, the federal government published, for consultation purposes, some guidelines on the labelling of novel foods from genetic engineering. I would like to remind you of the definition of a novel food: it is a food product that has not been on the market long enough for its safety to be fully proven.
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According to the proposal, the labelling of novel foods would not be required, except in some cases. Voluntary labelling would be permitted in a positive manner, for example for products from genetic engineering, or in a negative manner, for products not from genetic engineering, for example milk without bovine somatotropin.
The Department of Agriculture and Agri-Food maintains that its position is substantially the same as the consensus established at a forum held in Ottawa in 1994. However, we do not think this forum was a genuine public consultation, because NGOs and citizens accounted for a very small minority of the participants, namely 14.3%, including consumer representatives, with a figure of 7.1%.
Most heavily represented were federal departments with economic missions and businesses. Thus, it is not surprising that the alleged consensus is not in keeping with the will of the majority of Canadian consumers, who favour compulsory labelling. For example, the OPTIMA poll done for Industry Canada in 1994 showed that 83% of the people consulted said they would like to see labelling of novel foods from genetic engineering.
The FNACQ's position and that of 50 public interest groups and many individuals who are part of the Canadian Coalition for Compulsory and Specific Labelling of Novel Foods from Genetic Engineering is as follows:
- It is our fundamental right as citizens to be informed of the processes used in producing food
and to choose or reject products from genetic engineering for socio-economic, religious,
environmental, ethical, health and other reasons. We demand that the federal government
introduce compulsory and specific labelling of foods from genetic engineering.
Requiring labelling of the genetic engineering process only if new foods constitute a health risk or undergo significant alterations runs counter to the initial logic that advocates labelling on the basis of the product and the risk, and not on the basis of the process.
The FNACQ maintains that many factors may play a role in the choices made by consumers, and that they can therefore require information not only about the product itself, but also about the production, processing and conservation processes. They may have an impact on the environment, the well-being of animals, the socio-economic situation of various people here and abroad, moral or religious convictions, and potential long-term risks to health.
In this way, consumers can make a subjective evaluation of the risks, which is different from the evaluation of experts or specialists, and may therefore require that they be informed about new products so that they can manage the long-term risks themselves.
The main fear regarding foods from genetic engineering relates to allergies linked to the new proteins introduced into genetically modified plants and animals. However, there are other risks to health and to the environment. Despite the trend toward deregulation, we think new applications and new products from biotechnology must be better controlled.
We find the alternatives to compulsory labelling suggested by Agriculture and Agri-Food Canada to be inadequate. For example, it is mentioned that consumers could use organic products. We find this inadequate especially because these products are produced in very small quantities at the moment and are not subject to any Canada-wide regulation. We think this is due to a clear lack of will on the part of Agriculture and Agri-Food Canada, which promotes biotechnology and conventional agriculture rather than other new approaches such as organic farming.
The voluntary labelling of food with no publicly-controlled certification system: Decisions about labelling would be made on the basis of the commercial interest of firms, not the rights and interests of consumers. In addition, there would be no credible, reliable control procedures, and this would cause consumers to doubt claims made about food products.
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Using other information medias to enable consumers to recognize the processes used, the reasons changes are made and the characteristics of new products: Theoretically, the right to information can be met in different ways, through scientific programs, and articles and newspapers or brochures at places where the products are sold. However, these approaches do not have the same scope because they do not cover all consumers and do not play the same role as compulsory labelling. The approaches for informing consumers suggested by Agriculture and Agri-Food Canada may be complementary to labelling, but they are no substitutes for it.
Information of this type on processes provided by the media or in other ways that are separate from the products themselves cannot guarantee freedom of product choice. Only direct labelling on all products allows consumers to identify and distinguish between products and choose those that meet their own criteria. Thus, on the one hand, the purpose of the label is to inform consumers about the nature of the product, but the purpose is also to enable consumers to make a choice, and to do this, the product must be labelled. Otherwise, it is impossible to identify the product on the market.
Finally, Agriculture and Agri-Food Canada does not think that moral or religious concerns come under its jurisdiction. It thinks that religious or other groups, such as vegetarians, which have specific food requirements, must take their own steps to label products in order to comply with their moral or religious requirements. This completely ignores the European proposal of taking the moral or religious requirements of clearly identified groups in society into account in the compulsory labelling of foods from genetic engineering.
Far from satisfying the expectations of Canadian consumers, the guidelines presented by Agriculture and Agri-Food Canada are a narrow vision of reality. They attempt to bring a scientific but biased solution designed to promote biotechnology to a socio-political problem that involves choices, values and rights. The approach whereby labelling is not necessary if there is no danger or no significant change in the characteristics of a product tends to make this issue of rights subject to scientific, quantifiable criteria.
However, increasingly consumers are not choosing just products, but also, as dynamic market agents, they are choosing sustainable, fair approaches to economic and social organization by favouring a particular product or technique over another. It is therefore essential that citizens be informed about the processes used to produce products and foods so that they can choose or reject products from genetic engineering for social, economic, religious, environmental, ethical, health or other reasons. Only specific, compulsory labelling of food from genetic engineering could meet these criteria.
That completes my presentation.
The Chairman: Thank you, Mr. Dagenais and Ms Hunter.
[English]
Who would like to go next? I believe it's Chris Mitchler.
Ms Marnie McCall (Director, Research Policy, Consumers' Association of Canada): Good afternoon, ladies and gentlemen. My name is Marnie McCall. I am the director of policy research for the Consumers' Association of Canada.
We would like to thank you for the opportunity of being here this afternoon. I'd just like to introduce the association briefly before passing over to Mrs. Mitchler.
In addition to some materials I think you received yesterday, we've made available a quick sheet that describes a little bit of CAC's history, our current priorities, our sources of funding, and information such as that. Also, in a spirit of very great optimism, there's a membership application form. If it's of no use to you, please pass it along.
The Consumers' Association of Canada is a national association of volunteers dedicated to bringing the interests and concerns of consumers to the attention of government, industry and other interest groups.
CAC was founded in 1947. Issues concerning food have been a major motivating factor in our life for almost the last 50 years.
We have a network consisting of a national office; provincial and territorial associations throughout the country; regional offices in five other cities; a national newsletter, which reaches 250,000 Canadians through its inclusion in Consumer Reports five times a year; as well as a membership newsletter for our Canadian members. Through these means, we believe that CAC provides a vital part of the communication link between stakeholders and consumers on a wide variety of health, environment, finance, telecommunications and agrifood consumer issues.
I'd now like to pass over to Mrs. Chris Mitchler, the chair of Consumers' Association of Canada's national food committee for the past year. She's been an active CAC volunteer since 1988, and has dedicated an immense amount of time to the organization.
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Ms Chris Mitchler (Chair, National Food Committee, Consumers' Association of Canada): Thank you, Marnie.
In the area of biotechnology, it has been CAC policy and practice to advocate, protect and ensure the consumer's right to information, safety, quality and choice, and to be heard and to participate in decision-making as applications of biotechnology are developed in health care and food production.
It is CAC's belief that a comprehensive and integrated approach to the regulation of novel foods is essential to addressing such issues as labelling requirements, enforcement, legal redress, and product quality and value. Such an integrated framework must be able to accommodate existing biotechnologies and, to whatever extent possible, new and emerging applications of the future.
CAC believes that jurisdiction and regulatory authority for regulating products of biotechnology is best left to those departments that have been regulating both novel food products and traditional agrifood products. These departments have the personnel and expertise to cost-effectively evaluate the health, safety and efficacy of both traditionally derived and genetically derived food products without a waste of resources or duplication.
Therefore, CAC supports the principle of building on existing legislation and regulation, rather than reinventing the wheel with new legislative authority.
With respect to human and environmental health and safety, the Consumers' Association of Canada has full confidence in the existing regulatory framework. CAC believes that the risk assessment process Canada uses to determine health, safety and efficacy is one of the best in the world.
However, Canadian consumers want to know where and how non-health or safety issues, such as economic impacts, social concerns, consumer education and awareness issues like labelling, will be addressed. Will they be included as part of the existing formal regulatory framework, or is it expected that they will be addressed to the usual public policy development processes?
CAC believes that labelling and advertising regulations and guidelines must respect the consumer's right to know through relevant, accurate and understandable information. Most of us would likely agree that consumers have a right to information about a product in order to make informed buying decisions. Both industry and government have a clear responsibility to provide consumers with factual and accurate information needed to make such choices.
No one has denied that consumers have a right to know about a product when it relates to health and safety; however, when products are derived from a genetic engineering process, such as transferring genes across species or addressing non-health or safety concerns, the responsibility of government and industry to inform the consumer is much less clear.
CAC believes that labelling is a problematic and impractical way to meet a consumer's need to know. For example, in the case of the Flavr Savr tomato, the consumer clearly has a right to know that this tomato is safe. In addition, the consumer has the right to know the benefits that justify any difference in price at the grocery store. The consumer would also like to know whether he or she is buying a conventionally grown tomato or a genetically engineered one, just as some consumers might prefer a particular hybrid of one tomato over another.
The company that developed the Flavr Savr made a voluntary and conscious choice to respect the consumer's information needs and differentiated the product from conventional tomatoes through point-of-purchase stickers that described the tomato's origin and its benefits to the consumer.
However, the difficulty is not with the tomato itself, but how will the label on a packaged pizza address the consumer's need to know that the processed tomato sauce was made from genetically engineered tomatoes?
Some groups have indicated that ethical and social concerns, in addition to health, safety and environmental concerns, must also be mandatory on a label. It is our understanding that no other product is required by regulation to justify its existence on moral, ethical or other grounds. In addition, it is difficult to see how such information could be conveyed on a label.
To be effective, CAC believes that information must be clear, relevant and meaningful to the consumer. If the end product is exactly the same as its conventionally grown counterpart in terms of its composition and attributes, does the consumer need to know through a mandatory label how it was grown? Do consumers ask how other food products were produced, such as how beefsteak tomatoes are bred and grown? Provided the product is safe to humans, animals and the environment, and has tangible benefits to the consumer who buys it, will the consumer care how it was produced?
The Consumers' Association of Canada is concerned that the net effect of mandatory labelling of all products and processes derived from genetic engineering will be to render the labelling meaningless, since consumers could conceivably see a genetically engineered logo on almost every food product in the grocery store. Moreover, a small label or logo will not provide sufficient information to provide the consumer with an appropriate context. Some consumers will be confused as to whether the logo is intended to be a warning or an information label.
CAC believes there is a difference between consumers' right to know and their need to know. The difference is that the consumer has a right to know a product is safe, while the need to know implies the availability of adequate information about the product regarding its benefits for providing informed choices. Complete disclosure on a product label should consider the purpose of the disclosure and whether that disclosure will be relevant and meaningful for the consumer.
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Governments should also consider the purpose of labelling and who the target audience is intended to be.
This raises the question of why labelling is needed in the first place. There is a clue in the federal government's policy on the three main functions of labelling from the draft novel food labelling communiqué of July 25, 1995. This communiqué states the purpose of labelling as being to ensure adequate and accurate information to assist consumers in food choices relative to health, safety and economic concerns; to protect consumers and industry from fraudulent or deceptive labelling, packaging and advertising practices; and to promote fair competition and product marketability.
The primary user of food labels is clearly the consumer. Labels provide them with the tools to help them choose among food products and to protect them and industry from fraud and misleading claims. Clearly industry also has an interest in labelling to promote fair competition and marketability.
In its comments on Agriculture and Agri-Food Canada's proposed guidelines for labelling of novel foods derived through genetic engineering, CAC stated it would be folly to place all of one's communication eggs in the labelling basket. CAC believes labelling is but one tool and that there are other means of communicating to consumers about products derived from genetic engineering. Some of these include: providing a consistent and common core of information throughout a number of stakeholders; point of purchase information; and consumer education and awareness programs.
A comprehensive and integrated approach is particularly important given that four out of every ten Canadians, or 40%, have difficulty reading.
CAC has participated and continues to participate in an Agriculture and Agri-Food Canada steering committee to look at other mechanisms for informing consumers and respecting their need and right to know. This committee has been actively examining what is being done now, by whom, and with what resources, and possibilities of forming partnerships to effectively inform the consumer.
In considering whether to mandate labelling of all products derived from genetic engineering, CAC urges the federal government to observe these principles.
Consumer information should be relevant, accurate and necessary and provided to consumers in a practical, meaningful and understandable way.
Consumers should have a voice in the development of labelling guidelines, acknowledging that the main end user of the product label is the consumer. This requires that the label be kept as simple as possible. The label must also be relevant and accurate. In addition, labelling criteria must be consistent and enforceable.
Ultimately it is government's responsibility to develop simple, clear, accurate and enforceable labelling guidelines and criteria. It is industry's responsibility to comply with criteria once they are in place, but industry, government and consumer and health groups have a shared responsibility for developing the necessary communication mechanisms beyond labelling to inform the consumer about the safety, efficacy, benefits and value of a product and its technology, regardless of its origin or production process.
Thank you.
The Chairman: Thank you very much, Ms Mitchler and Ms McCall.
The committee will hear now from Dr. MacKenzie, Mr. Reasbeck, Dr. Paterson and Mr. Mayers.
Who would like to go first?
Dr. Anne MacKenzie (Director General, Food Inspection Directorate, Food Production and Inspection Branch, Agriculture and Agri-Food Canada): My name is Anne MacKenzie and I'll start.
First of all, thank you very much, Mr. Chairman and committee members, for the opportunity to appear before the committee this afternoon. I will be speaking on the labelling of novel foods produced through genetic engineering.
Agriculture and Agri-Food Canada and Health Canada carry a joint responsibility for federal food labelling policies in Canada under the Food and Drugs Act. Health Canada is responsible for setting food labelling policies with respect to health and safety matters. These policies apply to the labelling of all foods, including novel foods derived through genetic engineering. My colleague, Dr. George Paterson, will be providing further information on Health Canada's regulatory role in a few minutes.
Agriculture and Agri-Food Canada is responsible for the development of non-health and safety food labelling regulations and policies. More specifically, my department is responsible for the establishment and enforcement of Canadian policies under this legislation to: one, protect consumers from misrepresentation and fraud with respect to food labelling, packaging and advertising; and two, prescribe basic food labelling and advertising requirements that are applicable to all foods marketed in Canada; for example: the rules that respect common names, the listing of food ingredients, the components, any product claims, mandatory information and statements, etc.
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Again, these very basic requirements and responsibilities apply to all foods, including novel foods. The identification of novel foods derived from genetic engineering has certainly generated considerable interest, both internationally and in Canada. I will be speaking shortly about recent international developments in this area, but first I would like to outline for you the very focused approach we have been taking in Canada to address this very important matter.
In terms of consultations, since 1993 there have been three major Canadian multi-stakeholder consultations that have focused on the labelling and the identification of foods derived through genetic engineering. These were held in November 1993, November 1994, and December 1995. A copy of the communiqué that was released in December 1995 is contained in annexe 1 of the brief, and this provides a summary of the consultations.
The 1995 consultation was entitled ``Labelling of Novel Foods Derived Through Genetic Engineering'', and this was sent out to over 500 stakeholders. Responses from this consultation will be made public shortly. There also have been a number of independent consumer surveys mounted by groups such as the Fédération nationale des associations de consommateurs du Québec and the 1994 Optima Consultants consumer survey, which was conducted for Industry Canada.
Now I would like to clarify the points of agreement. Based on these consultations, including our considerations of the results of the independent surveys that have been conducted, we have seen a number of key points of general agreement emerging.
The first of these is that mandatory labelling is needed if there is a health or safety concern, such as from the introduction of an unsuspected allergen in the food - the example is peanut or Brazil nut protein - or where a significant nutrient or compositional change from your regular food has occurred. As such changes are health and safety matters, determinations and decisions respecting any required labelling will be made by Health Canada based on its novel food guidelines.
The second point of agreement is that labelling must be truthful and must not be misleading.
The third point of agreement is that in regard to non-health and non-safety concerns, it's clear that many consumers desire more information about these types of foods. Accordingly, we intend to explore ways in which such information might be provided through means other than direct product labelling.
I would like to consider for a moment the concept of blanket labelling. We acknowledge the work and the views of organizations such as FNACQ and the coalition, which have requested a mandatory blanket labelling for all foods, their ingredients, and their components derived from genetic engineering.
We agree that many consumers desire more information respecting these types of foods. However, we do believe this information could certainly be provided through means other than direct product labelling. You could have point-of-sale information or news releases, and this would permit the food label to remain as the key focus and information source for important health, safety, and compositional information, including allergenicity issues relating to genetically engineered novel foods.
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In addition to the significant practical difficulties it would present, we are concerned that blanket labelling, if it were implemented, could ultimately result in most foods in the marketplace carrying a label declaration. This would be a label declaration of some level of genetic engineering, either to the food itself or because it might contain an ingredient or a component derived from an engineered plant or an animal source, however small.
We must ask ourselves whether this situation would be useful and informative to consumers or would result in making it more difficult for consumers to identify those foods that might present a health or safety concern. We are now actively working with organizations such as the Consumers' Association of Canada to determine how consumers could be informed without blanket labelling.
An action plan has been developed by a steering committee consisting of the Consumers' Association of Canada, the Canadian Dietetic Association, grocery distributors and manufacturers and the three federal government departments involved in labelling.
I would like to say a just a word on some international considerations and specifically the Codex Alimentarius Commission. In our efforts to move toward a domestic policy on this issue, Canada must also address its international responsibilities as a member of the Codex Alimentarius Commission. Codex Alimentarius is the international standard-setting body for food. It administers the Joint FAO/World Health Organization food standards programs and has 153 member countries.
As the Codex standards have been recognized by the World Trade Organization as a basis for trade agreements, their acceptance by member countries is becoming increasingly important. The Codex Alimentarius Commission will be developing, through its food labelling committee, which I have the honour of chairing, guidelines for the labelling of foods derived from biotechnology.
I wanted to mention some of the positions other countries are taking. Suffice it to say, as an introduction, there is currently no international consensus on the labelling of novel foods derived from genetic engineering.
At the recent Codex committee meeting on food labelling held in Ottawa from May 14 to May 17, we heard a very wide range of views expressed by the countries in attendance. Many delegations called for mandatory and comprehensive labelling of all foods prepared with the aid of biotechnology in order to provide more information to consumers. Many other delegations stressed that labelling should address the specific concerns of safety - including potential allergenicity - nutrition and food composition on a case-by-case basis, all of which could be subject to scientific study and evaluation.
In such cases, the provision of consumer information other than that required for the purposes of safety, nutrition and food composition could be considered by means other than labelling. Alternately, several countries indicated that, as this was under review, taking an international position on the matter would be premature.
The United States supports labelling on a case-by-case basis only in instances of health, safety and compositional change and the use of Codex-adopted scientific principles as the basis for elaborating the international rules.
Case-by-case labelling based on scientific considerations has also been supported by Japan, South Africa and Slovakia.
In Norway, the Norwegian Parliament has debated the issue and has decided to mandatorily label all such foods as a means of providing information to consumers.
The European Community, which as you're aware now consists of 15 countries, has been unable to take a definitive position. A draft regulation concerning novel foods and novel food ingredients, including foods from biotechnology, is now being discussed between various European bodies. A decision may be taken by the Council of Ministers before the end of this calendar year.
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Looking at the next steps as a result of the deliberations at the Codex Alimentarius meeting, agreement has been reached that guidelines on the labelling of foods produced by modern biotechnology should be developed. Given questions raised about inclusion of cultural and ethnic preference in the labelling of such foods, the committee agreed to seek the advice of the executive committee of Codex Alimentarius on how the guidelines should be formulated in view of the Codex principles on the role of science in the Codex decision-making process.
This decision is expected by September 1996. Draft Codex guidelines on the labelling of these foods will be developed by the Codex secretariat for circulation to member countries for comment and subsequent discussion at the next Committee on Food Labelling. This meeting is to be held in Ottawa in April 1997.
Canada will be looking to the Codex Committee on Food Labelling discussions to provide further insight into international thinking and direction.
So in summary, ladies and gentleman, the present Canadian policy with respect to food ingredients or additives that are the products of biotechnology is to assess such products on a case-by-case basis to ensure protection of the health and safety of the public, and to require labelling, when required, to alert consumers to any special health and safety considerations. Health Canada will outline the operation of this process.
In regard to the non-health and non-safety identification aspects, the Canadian approach must consider both domestic factors and our international commitments. Considerable progress has been made to date, but Canadian policies have not yet been finalized. Accordingly, discussions on this issue will continue on a multi-stakeholder basis.
Thank you.
The Acting Chairman (Mr. Lincoln): Thank you, Dr. MacKenzie.
Dr. Paterson.
Dr. George Paterson (Director General, Food Directorate, Health Protection Branch, Department of Health): Thank you, Mr. Chairman.
Health Canada's responsibility has its legislative basis in their Food and Drugs Act and regulations. As my colleague Dr. MacKenzie indicated, this is a shared responsibility between both departments, Agriculture and Agri-Food Canada and Health Canada.
Health Canada's principal responsibility, though, has been mentioned and is with respect to the specific labelling requirements based on health or safety considerations. In other words, our primary role in reviewing such products is to ensure the health and safety of Canadians is protected.
In considering foods derived from biotechnology, it is important to note Health Canada has proposed an amendment to the Food and Drugs Act. This was published in part one of the Canada Gazette in August 1995. This amendment would require what we call pre-market notification for all novel food. By novel foods I mean foods developed through the application of genetic modification where new characteristics have been introduced or existing characteristics have been modified.
Pre-market notification will, we believe, permit the department to ensure a complete and comprehensive safety assessment can be conducted for all such products prior to their being offered for sale to consumers.
The safety assessment of biotechnology-derived foods follows principles that have been developed by an international committee of experts working through the Organization for Economic Cooperation and Development. This approach relies on a comparison of the novel food to a traditional counterpart having a history of safe use.
The assessment includes determination of the potential for the food to present a safety concern. As Dr. MacKenzie indicated, for instance, there could be allergenicity or other such concerns. This could be for certain population subgroups, or for certain religious or other groups.
The other thing we're looking at is changes in the composition or nutritional quality of the food. The safety assessment considers the developing and production of the food product, including a detailed review of the genetic modification process; complete characterization of the specific food product in comparison to its traditional counterpart, particularly as it relates to composition; detailed assessment of the dietary exposure to the product and the nutritional impact of the product, including a comparison of the nutritional quality of it to the traditional counterpart; and a toxicological evaluation of the potential for harmful effects of the product or its component. So it's a fairly comprehensive and broad review and assessment.
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In September 1994 the department issued guidelines outlining these information requirements for the safety assessment of novel foods. Since the publication of these guidelines, product developers have been voluntarily notifying Health Canada of their intent to market novel foods.
Where, on the basis of the safety assessment, safety concerns such as allergenicity or compositional and nutritional changes are identified, Health Canada has clearly indicated that it will require special labelling to alert consumers or susceptible groups in the population. This labelling would therefore present material information to be considered by consumers. I think this meets the point made by the representative from the Consumers' Association. This approach is consistent with Health Canada's treatment of any and all foods that might present a health or safety concern to consumers.
Where the Health Canada safety assessment demonstrates a novel food to be as safe and nutritious as similar foods already available in the Canadian marketplace, then the department would have no health or safety basis to require an additional labelling statement since the food is demonstrated to be equivalent to foods already on the market in Canada.
The Health Canada position regarding the labelling of foods developed using genetic modification to alert consumers to health or safety concerns has been discussed in several broad consultations since 1993. There appears to be unanimous agreement that special labelling is appropriate to inform consumers of health or safety concerns, and of changes in composition or nutritional quality of food products.
To date, Health Canada has conducted safety assessments for several genetically modified food products. Of those, the majority were demonstrated to be equivalent to and as safe and nutritious as their traditional counterparts. Therefore, they were treated the same in terms of labelling requirements. One product was intentionally modified in its composition. Health Canada demonstrated that this product was safe and nutritious, but required that a different common name be used to describe the product that would reflect the intentionally altered composition of the food. That was a product from canola oil.
As noted in Dr. MacKenzie's presentation, the stated United States position regarding labelling foods derived through genetic engineering is identical to the approach taken by Health Canada. In addition, few other countries have elaborated a position on labelling, but all of those have clearly noted that they agree labelling is appropriate to identify health or safety concerns or to indicate nutritional or compositional changes.
In conclusion, Health Canada remains committed to helping Canadians maintain and improve their health. The department therefore has taken appropriate steps to ensure that comprehensive safety assessments are conducted prior to permitting novel foods to be marketed in Canada. Where a novel food presents health or safety concerns to certain groups of Canadians, or where the composition or nutritional quality of the novel food is changed from that of its traditional counterpart, Health Canada interprets this to be material information that must be provided to consumers by appropriate labelling of the specific product.
Thank you, Mr. Chairman.
The Acting Chairman (Mr. Lincoln): Thank you very much, Dr. Paterson. I will now open the floor to questions.
[Translation]
I will now give the floor to Mr. Deshaies, from the Official Opposition.
Mr. Deshaies (Abitibi): That's a lot of material to absorb in 50 minutes, for those of us who are not too familiar with the subject. Nevertheless, I do have some questions I would like to ask. The first is to Mr. Surgeoner.
You said you represented a group of food producers and you mentioned an agricultural coalition. Is the coalition made up of farmers only, or does it include companies?
[English]
Dr. Surgeoner: I think you were referring to the fact that I was part of the Environmental Farm Coalition, which had no basis in any companies whatsoever.
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Ms Joyce Groote (Executive Director, Food Biotechnology Centre): Perhaps I can just talk a little bit about the Food Biotechnology Centre.
The Food Biotechnology Centre is comprised of a number of different parts of the community. It includes not only the industry - and certainly industry is one of its members - but also members from government, universities and health professionals.
With me is one of my co-chairs of the advisory committee, from the Consumers' Association of Canada. Agriculture Canada is also a co-chair on that advisory committee, so it's the whole breadth of the community.
[Translation]
Mr. Deshaies: So from your experience, you have known for several years how many new products there are each year, given that "new products" are those that have not yet been proven safe.
[English]
Ms Groote: We put together information on products that have gone through the regulatory process, both through Health Canada and through Agriculture Canada, and we provide lists to those interested. All it does is itemize the different products that have been commercialized and exactly what stage in the process those products are at - if it's gone through food safety approval, environmental approval or feed safety.
We don't actually talk about where those products are destined to go; we only talk about the products. So we would talk about seven canolas that had been approved, what the traits or characteristics would be, what companies are involved and again, what stage in the process.
[Translation]
Mr. Deshaies: So you don't know how many new products there are. Perhaps Ms MacKenzie could provide me with this information about the number of new products. Are we talking about 5, 20, 100 or 2000 new biotechnological products each year?
[English]
Ms Groote: Actually I do have a list in front of me here. A total of, I believe, twenty products have been approved now. I think you have those lists in your packages.
The Acting Chairman (Mr. Lincoln): Would you like to add to that, Dr. MacKenzie?
Dr. MacKenzie: No. I'm very satisfied with the response. As I think the committee members have heard, there certainly is a tracking system, if you will, on the stage at which these products are, heading towards an approval or a rejection, as the case might be. There is certainly a comprehensive record.
[Translation]
Mr. Deshaies: My question was about the number of new products. It is true that last year there were 20 new products?
[English]
Ms Groote: With this particular list we have, I can give you exact numbers, if you like. There have been a total of eight canolas, two tomatoes, one potato, one soybean, five corns, one flax and one cotton. That's as of April 30 of this year.
[Translation]
Mr. Deshaies: My question is not about a specific description of the products. I was thinking that if there were only 20 new products a year, it would be possible to label them. Mr. Surgeoner said that the problem was that a product could be found in pizza, for example. Does that mean that on the labelling of the pizzas, it would be necessary to indicate "enriched flour from a product..." and then name the product in question? That is what I want to know. When there will be 2000 new products, then the problem becomes much more serious.
My second question is to Mr. Dagenais. For the Quebec consumer associations, the issue is that the specific description of each of these 20 products match the actual contents. Is that correct?
Mr. Dagenais: First, the label should say whether the product is from genetic engineering, for example from a genetically changed plant or animal. So this would be a genetic indication on the label.
Mr. Deshaies: Mr. Paterson answered that some products already had this type of labelling. Do you not find this adequate?
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Mr. Dagenais: It is an essential piece of information. I also think people are entitled to additional information. They should have access to information sources, through a 1-800 number, for example. We want to target the biotechnological procedure that was used. We think the consumer should know whether a new technique or new product was used, for example a genetically modified or changed plant.
Mr. Deshaies: You spoke mainly about labelling. You say that it's good to have information, but that labelling provides the most direct information. How could a single label explain the entire process that was used? The label is not always big enough to hold all this information.
Mr. Dagenais: I agree with you. It is not necessary to describe the whole process. If the label states that the product is from genetic engineering, the consumer knows that a new technique was used and that the product is from a new plant. Consumers who want to know more can then turn to additional sources of information, because some consumers are more curious than others.
Mr. Deshaies: Ms Mitchler, from the Consumers' Association of Canada, said that consumers were entitled to know, but that there was a limit to the need to know. I don't know whether there are any links between your two associations. Who would set the limit on the need to know? Would it be Agriculture and Agri-Food Canada or Health Canada? Who should set the limit?
Mr. Dagenais: We think it should be a democratic process, involving as broad a consultation as possible. In addition, we must take into account the opinion of the majority of consumers.
Mr. Deshaies: You seem to say in your introduction that your opinion was not taken into account.
Mr. Dagenais: That's our impression. We were among the minority in the consultation process undertaken by Health Canada or Agriculture and Agri-Food Canada. There was a majority of specialists, businessmen and so on involved in that process.
Mr. Deshaies: Do you think consumers have enough information, Mr. Paterson? Do you think that at the moment there is no potential risk and that consumers do not need information?
[English]
Dr. Paterson: It's in terms of what information is essential. If there is a health and safety risk, then obviously, as a number one priority, Canadian consumers need to know that.
The dilemma we're facing as public policy-makers working within the system of governance we have is to decide what constitutes reasonable information to provide to the consumer in this area. As someone mentioned, genetically engineered corn could make its way into hundreds of products. How much information do you give out in terms of the down-the-line products that are produced from that genetically engineered corn?
Obviously as much information as can be shared by all stakeholders - industry, consumer groups and public health professionals - makes for better development of the most effective public policies. That's what we're trying to do in collaboration with our colleagues at Agriculture and Agri-Food Canada. We're seeking solutions. We're trying to consult. Maybe there are better ways of consulting. We're prepared to look at these other mechanisms and get as much input as we can to make the best decision.
[Translation]
The Acting Chairman (Mr. Lincoln): You have to come back later on, Mr. Deshaies.
Mr. Deshaies: Fine. I will be back on the next round.
[English]
The Acting Chairman (Mr. Lincoln): Mr. Steckle following by Mr. Knutson, and then if there are no more questions we'll go back to Mr. Deshaies.
Mr. Steckle (Huron - Bruce): I apologize for my lateness in arriving here, but I do sense there is a great deal of concern about the labelling and the kind of knowledge the public has of food products.
I'm just wondering whether this group here does differentiate between animal science and plant science in terms of genetically engineered products. Is there a greater hazard to human health in the consumption of plant products versus meat products? I'll have a further question afterward.
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The Acting Chairman (Mr. Lincoln): Who are you directing the questions to?
Mr. Steckle: I will leave it for each of the groups to decide who wants to answer that and who's best equipped. I missed some of the earlier speakers, so I'm not sure who is able to address that.
The Acting Chairman (Mr. Lincoln): I suggest that you ask Agriculture and Agri-Food Canada, and maybe the Consumers' Association could say something if they want to.
Mr. Steckle: I'm sure there are a number who want to speak to that.
Dr. Paterson: We'll go first. Dr. MacKenzie will defer to Health Canada. I'll ask my colleague Paul Mayers to speak to that.
Mr. Paul Mayers (Acting Chief, Evaluation Division, Bureau of Microbial Hazards, Department of Health): Thank you.
In terms of the issue of one presenting greater hazard than another, because we recognize that the application of biotechnology itself is just a technology doesn't bring with it any unique risks, then in fact there is not a difference in terms of hazard between animal biotechnology and plant biotechnology. The simple matter is that in terms of the development of the technology, plant modification has occurred first because of the technical aspects, and therefore we are seeing plant products approaching the market much earlier than we are seeing animal products. In terms of either one presenting a greater hazard, no, not at all.
Dr. Surgeoner: I would concur with that comment. I think it has to be looked upon on a case-by-case basis. There may be greater ethical concerns associated with animals, but not safety concerns.
[Translation]
Mr. Dagenais: I am not a specialist in biotechnology, but from what I read, different techniques are used for injecting new genes into plants and into animals. The effects are different as well, as is the degree of accuracy. In my view, since the cellular balance of animals is much more complex than the cellular balance of plants, and since the number of vital functions is different, genetic manipulation of animals is much riskier.
I would just like to mention the example of a professor from Laval University who injected a cancer gene into a mouse. He subsequently noticed that the mouse suffered from a variety of other diseases, including heart disease, and so on.
I think the effects can be very complex. We still do not have a complete understanding of the cellular mechanism of plants or animals, and the structure is even more complex in animals.
[English]
The Acting Chairman (Mr. Lincoln): Mr. Steckle.
Mr. Steckle: This whole process is about education and the public's acceptance of new products with the full knowledge that the product they're consuming or are about to consume is safe. I'm just wondering how we're going to accomplish that if in fact, as you have suggested, Chris, 40% of our people can't read. I know that isn't biotechnology, but maybe we need to start the technology in terms of the educational sciences.
Ms Mitchler: I think part of it is keeping the message very simple and also having it consistent, where you're hearing different groups saying much the same thing.
There are a number of questions that consumers are asking about biotechnology. Some of them are health and safety related, some of them are not. Some of them are related to ethical issues and questions or to socio-economics and that sort of thing.
I think health and safety questions and issues are best addressed through a label, but when you're dealing with religious or ethical concerns or that type of thing, I think you need a broader consumer education and consumer awareness program in place. You need stakeholders that are involved in the community to be getting a consistent, clear, and very simple message out to consumers.
Ms Groote: I'd like to add to that. That is exactly one of the things we're facing. How do you get out to such a broad group of people, whether in fact they can read or not? One of the things we've been looking at is giving displays at public events, for instance. Certainly it shows how important the media are going to be. If someone can't read, if they hear it on the radio or see it on TV, that's going to help them a lot. Certainly we have to make sure that people within the community, such as health professionals and consumers' groups, have that kind of information so that when people phone them they have it as well.
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So those are some of the tactics we're trying to take to make sure key people in the community have the information so that when others are looking for it they know who to go to.
[Translation]
The Acting Chairman (Mr. Lincoln): Would you care to respond, Mr. Dagenais?
Mr. Dagenais: Yes, briefly. In 1993-94, our organization surveyed representatives of organizations throughout Canada. We found that a small minority of people had a good understanding of biotechnology and its applications. The majority of our respondents had university education, but very few of them had a good understanding of this subject. People with basic training in genetics and biology were best able to understand.
In my view, all consumers should be given the basic popular information available on genetics and biology, before trying to explain certain applications to them.
[English]
The Acting Chairman (Mr. Lincoln): One last question, very brief.
Mr. Steckle: I'll just change the subject slightly, if I may. Since we're caught in an international community of trade - we're trading with the Americans, the Americans are trading with us - in your deliberations in terms of how you come to grips with labelling and this kind of thing, are you as cognizant as you ought to be in terms of the labelling procedures and how that might apply in terms of being used against us in non-tariff trade barriers and that type of thing? Since we are into this whole international global community, how much does that impact in terms of what we both can and should do in terms of our labelling?
Dr. MacKenzie: I want to mention that the trade agreement between Canada and the United States requires that countries seek an open border policy on trade and food, as under article 708. The NAFTA agreement, under article 906, urges Canada, the United States and Mexico to make standards that are going to be compatible to facilitate trade.
On the procedure being followed under the Codex Alimentarius Commission the first step will be to develop guidelines around the labelling of these particular products. Right now 152 countries are members of Codex Alimentarius, and it is expected that as we move through this process the countries that are members of Codex Alimentarius, the vast majority of whom are also signatories to the World Trade Organization and the GATT agreement, there will be an acceptance of these guidelines. Therefore, this should in fact preclude artificial trade barriers being established.
That's the way we see it unfolding.
The Acting Chairman (Mr. Lincoln): Mr. Knutson.
Mr. Knutson (Elgin - Norfolk): Thank you very much, Mr. Chairman.
People have used a number of words that can only become meaningful when applied to specific cases. We've used words like ``safety'' and ``relevant''. I just wanted to throw in a couple of hypotheticals, starting with Health Canada.
If I were to come out with a biotechnology-devised brand of scotch that posed the same health hazard to unborn children as our conventional scotch, would that, in your mind, trigger a label?
Dr. Paterson: I was here two weeks ago on alcohol warning labels. Is this a trap?
Mr. Knutson: It seems we're saying if products aren't safe we're going to label them, but we didn't do it two weeks ago.
Mr. Mayers: I think, though, if we take the approach in terms of the safety assessment of relying on establishing equivalents to a food already on the market, what we are saying is that we would treat the food similarly. We're not saying we would require something special in one case.
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Because we would treat the food similarly, we would then defer to any decisions made in the broader context of alcohol labelling, perhaps, but it would be impractical to require special warning labelling on the biotechnology version while permitting the conventional version to continue without that type of information.
Mr. Knutson: So if we have unsafe products in the marketplace, they set the threshold - what's in the marketplace right now.
Mr. Mayers: Yes. At the same time, it's not just a measure of products on the market being unsafe. Alcohol in and of itself is not automatically unsafe; it's the usage of the product.
Mr. Knutson: I appreciate that.
I am certainly not an expert on this, but I was once told that aspirin wouldn't pass today's standards, because it causes bleeding in the intestines. Is that true?
You're nodding, Dr. Paterson.
Dr. Paterson: Lots of products used conventionally now, and that have been in use for years, might well be found to not be acceptable, not be permitted for use, if they were looked at now in terms of the procedures and criteria we use.
Mr. Knutson: So following up on Mr. Mayers' statement, it's a pretty low threshold for safety if we're saying we're using products that have been around for years.
Dr. Paterson: Indeed it is, but of course you're addressing a much bigger issue.
Mr. Knutson: Which is...?
Dr. Paterson: Well, products that are in use, whether it's alcohol or tobacco or foods or drugs -
Mr. Knutson: Or aspirin.
Dr. Paterson: - that should be reassessed. Should the government devise new criteria to regulate these? I think that would be for -
Mr. Knutson: The wise committee.
Dr. Paterson: - a committee like this to make reference and suggestions.
Mr. Knutson: I want to ask the Consumers' Association a question about relevance. If I'm a dairy farmer and I'm worried about BST milk creating a general concern among consumers, i.e., they either stop drinking milk or drink less of it and I want to produce non-BST milk, is it relevant enough to go to the government and tell them they should label milk if it's produced with the help of BST cows simply because there are some people out in the marketplace who are nervous about it, and they're going to drink less milk? When you said relevance, was that relevant to something else? What did ``relevance'' mean?
Ms Mitchler: I guess what I was talking about in that context was that the information contained on a label has to be meaningful for the consumer. For example, if you're going to have on a product a logo or a symbol for genetic engineering, a logo or a symbol by itself is not going to provide a consumer with relevant, meaningful information. A symbol isn't going to tell them what the risk is, if any, and neither is it going to tell them what is the benefit of the product.
Mr. Knutson: Do you have an opinion on BST per se?
Ms Mitchler: Yes, we do. Our opinion on BST has been that a number of issues need to be looked at. Health and safety is the primary one, but there is also the issue of benefits. Will the consumer benefit from the use of BST? There is some question as to whether or not they will.
Mr. Knutson: Let's assume it's healthy, that Health Canada approves it and they release it into the marketplace. A farmer from Elgin County comes to me and tells me that people are nervous about this, even though it's approved by the government, that people are going to drink less milk, and that we have to accept it as part of contemporary life. They want it labelled.
From the Consumers' Association's point of view, is that a...? There's no health problem, according to Health Canada, but they want it there just so they know.
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Ms McCall: Without getting into the system of how milk gets from the farm to the table, which creates some difficult problems because of pooling and what not, assuming you have separate pools of milk, there's nothing stopping the producer who is not using rBST in a production, or the distributor of that milk product, from labelling it as BST-free.
Mr. Knutson: Right.
Ms McCall: At least I don't believe there are any regulations about that. That may be more effective particularly if you're dealing with local consumers who are used to dealing with a particular small dairy, although that's getting less common. The advertising going directly to the consumer you're aiming at may be more effective than something that says this milk contains BST in terms of reassuring customers and reducing the impact on the customer demand for milk.
Mr. Dagenais: We produce reports on rBST. We are of the opinion that there are some risks for human beings and for animals too. I think we were not of the same opinion as Health Canada. They said there is no human risk. We think there is some and that it's not being seriously studied.
You can have long-term risk if there has not been enough study. Some consumers have...[Inaudible - Editor] The question is: who will decide that there is an acceptable risk for human beings? If there is some possible long-term risk, who will decide if it is acceptable or not? The question of acceptable risk is a question of value. Citizens have to be in place in the process to decide what is an acceptable process.
The Acting Chairman (Mr. Lincoln): Mr. Finlay.
Mr. Finlay (Oxford): Thank you, Mr. Chairman.
I don't want to be the least bit flippant, but Gar is attacking a couple of products I'm certain you don't want to remove from the market.
One is good scotch. Taken in moderation, I'm quite sure it has harmed very few people. Someone said that it's the use that's unsafe. That's right. If you drink too much of it, you may kill yourself in a car crash.
With respect to aspirin, if it's coated, I think we're all right now, Gar.
The other thing is that we learn all the time. I suggest that we're never going to be able to go back to correct all those unknowing mistakes of the past. I agree with what Mr. Dagenais is saying about risk in the sense that we're never going to remove risk from life, and we're never going to be able to study every possible reaction of every product that we eat, breathe or consume.
We're discovering things all the time. We used to play with mercury on the desk. We're not allowed to do that in school any more. We have big corporations saying lead doesn't hurt us, when lead has been hurting us for a long time. It's a very tricky problem we're into. Of course, peanut butter, which a lot of us, at least of my age, grew up on, we now discover will kill some people. We didn't know that before.
I guess evolution has been going on a long time, Mr. Chairman. It's going to go right on, and we're going to have some people who are susceptible to things we never, ever thought about.
I think we are throwing around some words in biotechnology on which I need a little more explanation. We've heard about new products. Are they new products? We may be too philosophical or maybe too precise, but are they really new products or are they simply old products made a new way? Are they different products, not new products? I wonder about ``new'' and I wonder about ``different''.
Dr. Paterson: It's a good question. I think we'll give you a government answer, then we'll give you an academic's answer.
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An hon. member: We're used to that.
Mr. Mayers: I think your question is very pertinent. Clearly, if a product can be demonstrated to, both compositionally and in terms of use, be equivalent to an existing product, then it is not really new.
What is different about it is how it has been produced. That is really the key here. It's that recombinant DNA technology, or genetic engineering, as it's termed, is a further evolution in the practice of traditional breeding. It allows a more focused modification than simply mixing the thousands of genes that two plants may have when you breed them together. Instead, you introduce one or two specific genes.
But beyond that, it is not in fact different, and it is not in fact new. It is further in the evolutionary process of, in this case, crop development, or in the case of animal breeding, animal breeding. It's very important to realize that. That's why I think your question is in fact very pertinent.
Mr. Finlay: Thank you.
Dr. Surgeoner: I agree very strongly with your comment on risk. When you look at risk, you also have to look at benefits. That's a weighing process. I think that's very important. Aspirin has tremendous benefits, as we've discussed, as well. So you have to do that in the process.
In terms of ``new'', there are different types of biotechnology. There may be certain ones, for example, the insertion of a gene for Bt, a bacterium, with which we control corn rootworm.
Again, we could do these by other mechanisms to some degree, but it's a new technology that allows new opportunity. I would emphasize to you that we've created new products through natural processes, like a nectarine, which is a peach and a plum. There are all these different ways by which we can create the word ``new''. This is just one methodology by which we can do that.
Mr. Finlay: Thank you.
Ms Groote: If I could just add to that and say something that's, I guess, just a little bit close to my heart. We tend to use the terms ``biotechnology`` and ``genetic engineering'' interchangeably. I think that causes some confusion.
Biotechnology is a whole set of technologies, including things we've been doing for many years, whether that's fermentation or breeding or, more recently, tissue culture. Genetic engineering is one of those tools.
What has happened is that people are getting the two things confused. I understand where that confusion comes from.
Mr. Dagenais: I would say that we have to ask the question: is the process different and can it affect the environment, for example? The project could be the same, but the process could change and affect the environment and people in some other way.
For example, Bt techniques could affect the environment. If you change the plants, and plants are resistant to insects, for example, you could have environmental impacts.
Your food could be the same. The process could affect the environment, too.
The question is: is it necessary that consumers be informed of the process and the possible impacts on the environment, for example? As consumers, we say that it is valuable information because it's a global system. You don't look only at the food you consume but at the way the food is produced. If you affect the health of some people because you have environmental problems, that's an issue.
Here's the other thing. What's an important modification of food? For example, there has been a potato produced by traditional cross-breeding. In this case there was a problem. The potato produced chemical elements in more important amounts than usual because there was more rain. Then you had some cases of intoxication. The question is: what is an important modification of food? Some toxic elements could be present in small quantities and it could have an impact on some people who are more sensitive, for example. It's not an easy question to respond to.
Mr. Finlay: No, it's not an easy question to respond to, but we have to recognize that there are limits in all of this, which is what we're wrestling with in CEPA. I notice that the environment committee - this is a standing committee - doesn't have any, according to the presentations we've had. It's fisheries and oceans, agrifood and health. We are concerned about the overall environment, absolutely. I guess we have to go on learning, working, being vigilant and doing the best we can.
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The Chairman: We have ample time for a second round. Please allow a couple of questions from the chair.
Of the many representations we have heard on the subject of public information, there is one that urges this committee to follow four steps in the notification of the public and the participation of the public in decision-making regarding biotechnology.
The first urges notification in the Canada Gazette when applications for the approval of manufacture, use, import and export of new technology products are made, followed by a public comment period of not less than 90 days or something to that effect. The second is notification by the Canada Gazette or other ministers of the minister's decision to approve or prohibit, again the same series of steps. The third is notification in the Canada Gazette of ministerial intentions to vary or rescind conditions imposed on import, use, manufacture, sale, export, and even discharging to the environment of biotechnology products. The final one is notification in newspapers and general circulation in the vicinity of the test for proposals for field test of products of biotechnology.
These are four substantial steps that have been recommended to us. The reason for raising them now is to learn first of all what your thoughts are on these recommended steps, and secondly whether you think this kind of approach would go a considerable way toward compensating for the need to inform the public by way of labelling.
Who would like to tackle that? Please go ahead.
Ms Groote: My comments are based on public opinion surveys that have been conducted. From the surveys it's clear that we have no single consumer. We often talk about them as if they're a single group and they're not. They tend to fall into almost a continuum of five segments.
The first one is those who would embrace all biotechnology products because they offer alternatives or benefits that they perceive and want. On the other end of the spectrum are those who would reject all biotech products, regardless. There is a very large group of those who are indifferent, who just want to make sure their food is safe, nutritious and has some quality or some benefit to them. There are those who want actual information of a general nature, again on how nutritious and safe it is. Then there's a very small segment that seems to want information on genetic engineering.
That is what some of the public opinion surveys would suggest. Those are surveys that look at the public's general shopping habits, surveys that look at people's perception of science and technology, and surveys that look at people's perception and biotechnology very specifically.
The Chairman: Do I take it that the idea of gazetting and notifying in those four steps is acceptable to the others? Are there any other comments?
Dr. MacKenzie: The procedure you described is certainly an official procedure and obviously well designed. However, my concern would be that this procedure of notification probably doesn't reach consumers. One of the things we've been hearing today is that it will be very beneficial for the committee to consider and possibly make recommendations around how consumers can be better reached, both on the deliberations of the policy-makers and on the developments we see coming along.
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Although you very clearly laid out the official notification, I would say as a government official that this particular series of steps probably does not reach the consumer. Through our ongoing consultations we want to explore a way of ensuring that consumers are in fact aware of the policy development.
The Chairman: Thank you, Ms MacKenzie.
Yes, you may speak briefly.
Ms Hunter: I agree with Dr. MacKenzie. I wanted to add that even if consumers are made aware through newspapers and through information sources that reach them more directly than a gazette publication does, if the product isn't labelled then they're not going to be able to make a choice.
I think everyone agrees there needs to be many different types of information given to the consumer, but our position and our bottom line is that they've made a choice about whether they do or don't want to buy a product of genetic engineering. Unless the product is labelled they won't be able to choose.
The Chairman: Thank you. It's an infernally complex subject. A recent immigrant brought to my attention the fact that in Europe when you buy prescription medicine the label shows to the patient who buys it the content of the prescription. Here in Canada the information on the label is the name of the doctor, the name of the medicine and the number of times the medicine has to be taken. It stops there. The consumer of this prescription medicine is kept in the dark as to what the prescription contains.
Would you people from Health Canada like to comment on this?
Dr. Paterson: Thank you, Mr. Chairman. I have no comments other than to say that through personal knowledge I am aware this happens in Europe. In Canada I think what we have seen more recently is information sheets provided with the prescription. Of course, these could become detached and are not part of the bottle.
In terms of what our drugs directorate is doing to modify policies and in terms of what will be required, I can only say I will take your point under advisement. I don't exactly know if Canadian policy is moving towards this thinking.
The Chairman: Well, it would be helpful to know why we haven't developed over time this approach to medical prescriptions. Evidently there is almost a culture, which is quite in contrast to the approach in Europe. I think it would also help this committee to understand other things.
Mr. Deshaies, please.
[Translation]
Mr. Deshaies: I have two other brief questions, the first of which is to Dr. Paterson.Ms MacKenzie said that Agriculture and Agri-Food Canada had adopted an ad hoc policy on change, that is, it responds as needs arise. You told me that there had been so many changes recently that you had little time to assimilate all of them.
Is Health Canada comfortable with all these changes? In the case of bovine somatotropin, the hormone injected into cows to increase their milk production, is Health Canada satisfied that the chemical injected is not dangerous to people's health? Is this something we should be concerned about? In the long-term, might there not be some effects that we are not familiar with at the moment?
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I remember that in 1960, Health Canada authorized the use of thalidomide to treat nausea in pregnant women. The result was that some women who took these pills gave birth to children with disabilities. Should consumers not be able to say that the authorities are acting in good faith and that they studied to the best of their ability the qualities and defects of a product? There may be some danger, but there may be some benefits as well. Is your department not torn between modernity and fear of change?
[English]
Dr. Paterson: Yes, indeed. Are we ever truly happy with the information we have with which to make decisions? I think the answer would be no, because science is evolving and information is becoming available. As the gentleman said earlier, what we're looking at is always a risk assessment, an assessment of the risks to the health and safety of Canadians based on the knowledge and information we have available, what the product would be used for, etc. We're never really 100% comfortable because we always are aware that new information and more knowledge become available as science evolves.
With respect to BST, I hope everyone does know that BST has not yet been approved. It's being reviewed within Health Canada, but that process has not come to a conclusion yet. Again, we're faced with reviewing it on the basis of information we have available in terms of the science with respect to its effect on humans, on Canadians, but also we're reviewing it in terms of its safety and efficacy with respect to the animal it will be used on, i.e. the dairy cow. That review is still ongoing; no decision has been made.
As new information becomes available, that's looked at by Health Canada scientists. But as you've said, sir, you're always in a situation where information is changing, and with the pace of change, as we know in discussing biotechnology and genetic engineering, we're on an exponential curve. As a regulator, am I ever truly satisfied and happy with the information we have available? I'd have to be honest and say no, but we have to use what information we have available, and we try to get that from as many sources as we can: scientific literature, scientific experts, and indeed ordinary consumers.
Thank you.
[Translation]
Mr. Deshaies: My final question is for Dr. Mackenzie, who said that she was part of an international committee to codify international standards for food. Do you think an international agreement would set our standards here in Canada?
[English]
Dr. MacKenzie: I must say that's an excellent question. The goal of the various Codex Alimentarius committees is in fact to reach consensus. It's very rare that in the Codex Alimentarius committees a vote is taken to decide an issue. There is discussion, there is a lot of analysis, and ultimately a decision is made by consensus of the countries around the table, which I think is a good process. Once that decision is taken, countries can use or not use the standard.
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Now we are advancing to the point where if a country chooses not to accept the Codex Alimentarius standard, there has to be a justification or a reason why that standard is not appropriate for that country. If in fact a country takes that position, then that issue usually comes back to the committee to look at the standard. Why is it not being used? Is there something wrong with it? Then one can work, update, change, modify, modernize - whatever the situation may be - the standard.
The ultimate hope, if I could say that, is that when you have countries coming to consensus around a standard, it is a good standard, a standard worthy of acceptance by countries. That's why I mentioned that the Codex Committee on Food Labelling is the only Codex committee chaired and hosted by Canada. I was referring to the deliberations that go on at that committee, one of them being the potential development of guidelines for labelling foods produced through biotechnology.
[Translation]
The Chairman: We can continue on and have a third round, if you like.
[English]
Mr. Knutson.
Mr. Knutson: Dr. MacKenzie, the group from FNACQ suggested that your consultations were biased, that you've given too much weight to industry. I wondered if you wanted to respond directly to that criticism. And I'll ask FNACQ to respond to the response.
Dr. MacKenzie: I'm going to ask my colleague, Mr. Gerry Reasbeck, to respond to that.
Mr. Gerry Reasbeck (Director, Food Division, Food Inspection Directorate, Department of Agriculture and Agri-Food): We did refer to the fact that there were a number of multi-stakeholder consultations beginning in November 1993. At that particular time there was a workshop on regulating agricultural products of biotechnology. It was a multi-stakeholder consultation. It included representation from a cross-section of interest groups and there were approximately 250 participants. I briefly mention these, but I would refer you to a green-bordered document in your briefing, which is the first appendix. It gives a much more thorough explanation of the deliberations from a consultation perspective.
In November 1994 there was a technical workshop on the labelling of novel foods derived through genetic engineering. Again, it was a multi-stakeholder workshop. At that time specific attention was directed toward the labelling issues.
Going into this meeting there was a significant diversity of views, the kinds of extremes we are still seeing. There were proponents of absolute and complete marking or labelling of all foods, all components, all ingredients of foods, no matter how many products they might go into - a very significant demand and one that could probably never be delivered. On the other hand, we had certain individuals and groups saying that a minimalist approach is necessary, perhaps no labelling at all. In between we had groups saying that health and safety is important, that significant compositional changes such as nutritional changes that might be brought about by a genetic change, changing the fatty acid profile of a food from one that was normally monounsaturated fats to one higher in saturated fat or perhaps trans-fatty acids, which we know to have implications of raising serum cholesterol...
So we had a range. Interestingly enough, coming out of these consultations there seemed to be a move toward a consensus that not everything is possible. That certainly has been observed in a number of members' representations here today.
In December 1995 these consultations were brought together by way of a document called ``Draft Communiqué on the Labelling of Novel Foods Derived Through Genetic Engineering''. That's the document I referred to earlier, which you might want to look through. This document attempted to bring together the overall guideline proposals and it went out to 500 individuals across the country. In fact, that was the document we were referring to in Dr. MacKenzie's presentation. We will be sending out information on the results of that document.
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I think it might be useful for me at this time just to mention very briefly some of the results so that you might be aware of who responded to this. We had responses from consumers' associations that represented approximately 10,000 members. We had responses from trade associations and producer groups: 520,000 producers, 750 processors. We had dietitians and professional associations, with approximately 5,000 members, and a range of professional groups, academia and other interest groups, including interested individuals.
Very briefly, coming out of that consultation - and we will be making this information public in the very near future - approximately 74.4% of the group was against mandatory labelling of all foods. They basically felt this was not a feasible undertaking. It could not be practically delivered, and it would result in virtually every food in the marketplace carrying labelling of some kind. Ergo, our concern was about informing, or misinforming, the consumer, particularly ensuring that those who have special health or safety interests, such as food allergens, would be able to pick out those foods that might be of significant concern.
Finally, 22.3% were in favour of mandatory labelling, and 2.32% were neutral.
So we feel we have made a significant effort to consult. It is a work in progress. Dr. MacKenzie did indicate that we are continuing to work with groups such as the Consumers' Association of Canada and others, because we believe and recognize and acknowledge that consumers do want more information. They do want it. We intend to try to provide it to the extent we can.
Considering the space that's available on a label, considering that we have a bilingual country, where we're talking about full bilingual lists of ingredients and nutrition labelling on all the foods as required by Canadian law today, we think what limited space there is should be retained to ensure that the public is aware of health and safety concerns and compositional changes.
Thank you, Mr. Chair.
The Chairman: Thank you.
Ms Hunter: Perhaps I could just respond by reiterating what Richard said before. I don't have an analysis of the November 1993 workshop. Participation in the November 1994 workshop was about 38% from government and 37% from le monde des affaires - industry and business - and 14% from public interest groups.
I would add that I attended the preparatory meeting for the Codex meetings to develop the Canadian position. The representation was very similar to that breakdown. We hadn't received the results from the last consultation until just now. I assume we will be getting more complete information soon.
I think there is a problem of representation, not only in terms of who hears about these consultations and is interested in going but also who's able, in terms of resources, to get to the meetings. Clearly biotech companies that have an interest in saying something at the meeting have a lot more resources than environmental organizations.
I just wanted to make one other small comment, that the definition of ``consensus'' used by Agriculture Canada is quite different from what a lot of public interest groups use, in that consensus means majority. It's interesting to see how people use the word differently and to clarify, in that context, that this is what it means.
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The Chairman: Mr. Reasbeck.
Mr. Reasbeck: Mr. Chair, I would like to respond to a couple of points that were made. I chair the Canadian delegation for Canada to the Codex Committee on Food Labelling. It is my responsibility to effectively ensure there is adequate consultation on all of the positions Canada takes or puts forward. I would reaffirm that attendance at the consultation meetings prior to the finalization of the positions are open to anyone who may wish to attend. In fact, I had a much larger group this year than I normally have. I was very happy to have them. I can assure you, these sessions are open to all.
The objective, obviously, is to ensure that we're going to meet the needs of Canadians, that we are going to do what is necessary to ensure that the public is consulted - that all members of the public are consulted.
Private companies have a right to be there, as does anyone else who wishes to attend. It's very important that we reaffirm that this is certainly our intention. We are continuing to consult with groups. Certainly I would invite FNACQ to be part of any consultations we continue to have in terms of how we are going to reach closure on the identification of these types of foods.
Thank you, Mr. Chair.
The Chairman: Mr. Finlay, please.
Mr. Finlay: Thank you, Mr. Chairman.
Several witnesses have made reference to the case where a gene that codes for a protein from the Brazil nut was transferred to a transgenic soybean variety in the United States by Pioneer Hi-Bred International. The transgenic soybean variety was found to be strongly allergenic as a consequence of the introduced gene. I'm assuming that information is correct.
Was this transgenic soybean variety ever marketed in the United States or Canada? What was the intended purpose of creating this soybean variety? Was it intended to be used for food for humans or for livestock feed? Is there any evidence that any person was harmed through consuming this food produced using this transgenic variety? In the regulatory system in the United States and in Canada, is our system adequate to identify such allergenic crop varieties before they can reach the marketplace and pose a potential risk to consumers? Are there effective and efficient scientific tests available to identify such allergens in foods? Are they routinely used in Canada if they are available so that we have some assurance that new or novel foods are safe?
The Chairman: You'll have to organize a conference to answer those questions.
Mr. Mayers: I'll attempt to answer all the questions, but if I miss any, please do prompt me.
On the particular example of the soybean modified with the Brazil nut protein, first I'll address the intent. Soybeans are deficient in an amino acid called methionine, which is considered an important amino acid for animal feed. Brazil nuts happen to be very rich in methionine, particularly the storage protein from the seed. This was in fact the protein that was introduced into these plants. So the intent was to improve the nutritional quality of the product, particularly as an animal feed.
Because we do recognize that Brazil nuts are a product that certain population subgroups have a sensitivity to in terms of allergenicity, it was very important that the potential for that modification to cause allergy be assessed. That was done. That's how this was determined. The potential for allergenicity was in fact assessed. It was demonstrated that this protein was in fact one of the allergens from Brazil nut. At that point, further development of the particular product was halted. It does underline for us the utility of a comprehensive safety assessment in identifying concerns prior to marketing.
The product was never marketed. Consumers were not exposed to it. Even in the testing humans were not exposed; blood serum from humans was used instead.
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In terms of the application of these tests, the Health Canada guidelines we have elaborated for the safety assessment of these products does include a section on allergenicity. Allergenicity is a very important consideration in each safety assessment we conduct for these products because of concerns not only in the case where the introduced protein comes from a known allergenic source but also in the case where proteins that are new to the food supply are being added.
There is no one specific test to determine the potential for allergenicity. We can do that using methods as were used in this particular example, where the protein is sourced from a known allergen. You can then use serum from susceptible individuals. Where the potential for allergenicity is not known, we do know that allergens share certain characteristics, and based on those characteristics the potential for allergenicity of a protein can in fact be assessed.
In addition to that, we are fortunate that there are databases that include the actual protein sequence of many of the known allergens. So the sequence of an introduced protein can be compared against those sequences, and is routinely done, to determine the potential for allergenicity.
Those requirements are built into the guidelines Health Canada applies to the safety assessment of these products. The tests are in fact available to assess the potential for allergenicity. As well, the pre-market notification that Health Canada is pursuing will provide the opportunity to ensure that these criteria are assessed prior to marketing products for Canadians.
Thank you.
Mr. Finlay: Thank you very much.
The Chairman: Mr. Steckle.
Mr. Steckle: I hardly know how to ask my question after listening to my learned colleague; I much less understood the response. I simply come back to the notion of education and understandability. If we look at the kind of information that's on labelling, if it's as complex as the response or the question we certainly have a very illiterate society. I suggest that most of us have taken our chances on most things we consume.
How do we deal with frivolous claims by groups of people or by individuals who come before us from time to time with claims - for instance, on BST - that this or that may be dangerous to human health? How do we finally dismiss those kinds of claims? There are all kinds of claims being made against anything. We were taught to believe that salt was dangerous to our health. Now it's good for our health - and I'm so glad to hear that. I'm going to continue to use salt.
At the end of our discussions the other day I was ready to leave this world, because it's such a dangerous place in which to live. I'm being a little facetious, but how do we deal with it? Let's get this thing down to a plane where we understand one another and where we can use terms so that all of us, or myself, at least, can understand what we're talking about. There are claims being made from time to time that certain things are not good for our health, yet we're eating and consuming things every day that none of us would be able to attach all the implications to.
Mr. Mayers: I think it's a very interesting question. In terms of salt, I'd suggest moderation, even though you love it.
In the broad context of what you ask, I think it's really important that we recognize that consumers are interested in information, and consumers do need information to make informed choices. The mechanisms have to be found to do that. Agriculture and Agri-Food Canada have certainly indicated, both in the communiqué they have submitted and the presentation today, that they will continue to consult regarding what mechanisms might be appropriate to provide information. Certainly the Food Biotechnology Centre has indicated several of the tools they are using.
But communication is a very difficult area. We recognize that providing information, particularly when, as you mentioned, some of it can be very technical, can be very difficult, and it can completely miss the point.
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The Consumers' Association of Canada has mentioned that they would like to see simple, consistent, common messages. I very much agree, but we are dealing here with technology that can be very complex. Because, as you mentioned, some people do make claims regarding the technology it sometimes is very difficult in simple terms to allay those concerns.
I certainly don't have all the answers in terms of how we can do that, but I believe the approach Agriculture and Agri-Food Canada has outlined that they intend to take, in terms of consulting to identify some of the mechanisms with which we might provide information to consumers, will go a long way in assisting us to present consistent, common and simple messages.
Ms Groote: I'd just like to build a little bit on that. I mentioned that the public is not a consistent mass, and trying to get messages out to those different segments is also very difficult. You need to understand who they are. You need to understand that there are going to be those who simply don't care and don't want the information. Do you try to provide information to them or do you say, okay, they're not the group that really wants it, so let's focus on the people who do? There are 27 million Canadians out there; how do we deal with them all?
That is a challenge we're all starting to deal with now. I think it's something all of us really are starting to deal with, as recently as probably last September, when we realized these products were coming through.
Going back to the surveys, the public is really confused as well. They don't know what to believe and who to believe in a lot of cases, because there are always mixed messages. Scientists often disagree on various things. I think we're starting to see a public, if we can believe those surveys, that's looking for the information of those segments that do actually do that sort of thing. They're just wanting to make up their own mind now. They're starting to not look to people to tell them what to do, but to make their own decisions.
Ms McCall: Part of the problem here is that there are two levels of information. There is technical information, which is necessary to assess the health and safety issues, and there is what you might want to call ``general public'' information. They have very different contexts. Much of the work the Consumers' Association does is to try to make sure that things are placed in the context that makes the information relevant to the consumer. Food issues around food safety and quality have motivated the Consumers' Association since its beginnings. We have been involved at various times with various organizations.
We see a need to develop consumer education and awareness, including education through the school system, that all foods belong in a healthy diet. There's no such thing as good foods or bad foods; it's how you use them. A steady diet of potato chips and Coca-Cola is not going to be good for you, but the occasional soda pop or deep-fat-fried food won't kill you. My grandmother used to say that you had to eat a peck of dirt before you died, which I'm sure is not in Canada's food guide. It's a very sensible approach. Don't get so tied up in little details.
If we bring labelling into a context of a broad understanding of the role of all foods in a healthy diet, then it may be easier to figure out exactly what it is people want to know about specific foods.
Dr. MacKenzie: Just to follow up on the remarks that have been made, approximately two to three years ago the Food and Drug Administration of the United States proceeded with the Nutrition Labelling and Education Act, which in the U.S. required mandatory nutritional information to be displayed on labels. I'm sure many of you who have travelled to the United States and looked at food products have noticed that a lot of information seems to be on labels there that at present is not on labels in Canada. We've had many ``snowbirds'' in particular coming back from the United States and asking when we are going to get on a label the kind of information that seems to be available in the United States. There are discussions going on now, and I believe that in Canada we will probably be moving down a road where that kind of nutritional information will be available in Canada.
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Recent surveys in the United States have shown that since the introduction of the NLEA, the Nutritional Labelling and Education Act, there has been a 68% increase in consumers' attention to the information displayed on a label. I wanted to respond to the comments made by the Consumers' Association on the power of a label, and also on the importance of the information on that label in directing possible eating habits and trends that will have a long-term health impact.
The Chairman: It may well be that looking back 25 years from now, we will judge our behaviour in relation to this issue as reminiscent of and parallel to our reaction when the steam engine was introduced. I don't know. But the fact is there is uncertainty and lack of clarity out there, and also a certain element of fear.
It would be helpful to have your comments on two brief questions. One follows up on Mr. Finlay's question on transgenic crops. Could you tell us if they are tested for nutritional quality and safety before being approved for use in food, how the testing is conducted for the nutritional quality or safety, and whether it is conducted routinely? Are new crop varieties produced by traditional breeding methods also subjected to tests for nutritional quality and safety? Could you give us a brief outline on that?
Dr. Paterson: Thank you, Mr. Chairman. Mr. Mayers will deal with that.
Mr. Mayers: Nutritional quality, of course, is a very important component of the safety assessment.
Our approach to the safety assessment, as noted in Dr. Paterson's presentation, is based on principles elaborated by the Organization for Economic Co-operation and Development. These principles utilize a concept of substantial equivalence of the novel food to a food with a history of safe use. In conducting that assessment, characterization and compositional comparison are used in the determination of equivalence. Nutritional quality is an important part of that: one, in terms of the composition of the significant nutrients as well as the toxicants that may be present in a product; and two, that the nutritional quality, from the standpoint of those nutrients being available to the human metabolic system for use, is in fact equivalent to the traditional food.
So nutritional quality is assessed in terms of the nutrient composition of a food in comparison to its traditional counterpart, as well as the biological availability of those nutrients in comparison to the traditional counterpart.
In terms of traditional foods, or foods that are not products of recombinant DNA technology, a long history has been used in the assessment of those products. Those products do not go through a pre-market safety assessment per se. They go through a system of agronomic comparison, a determination of the quality of those products, but not a formal safety assessment like we are applying here for novel foods, which would require pre-market notification that would permit us to conduct that formal safety assessment.
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The Chairman: Is it your conclusion, then, that the treatment of transgenic crops is more stringent than that of non-transgenic ones?
Mr. Mayers: Certainly for those products that would not qualify as novel foods. In Health Canada we do not make a distinction that genetically engineered products are the only novel foods. We recognize that not only genetically engineered products but all foods may present certain concerns we need to consider. So our focus is in fact novelty, the introduction of modification of existing characteristics in the product.
Having said that, there are many traditional means of plant breeding that do not introduce significant change. Those products would not qualify as novel foods and therefore would not go through the pre-market notification safety assessments. For those products the system would be less stringent in terms of formal safety assessment. But having said that, there remains in Canada - and perhaps our colleagues from Agriculture and Agri-Food can speak to it - a system of variety registration for certain crop plants, which does give consideration to the characteristics of the product.
The Chairman: Are there any other comments on that? If there are none, let me ask one final question on labelling.
I agree with those who say that labelling and consumer information are converging and not separate streams. There is an inevitable conclusion that there is consumer information on every label, even if it is printed in an almost invisible size, requiring a magnifying glass. Nevertheless the label performs a consumer information role.
When it comes to the consumer - and here I'm guided by the very helpful brief byDr. Surgeoner, on page 2, the fourth paragraph - the consumer is primarily interested in three points: whether the product is safe, what it does to me and whether I benefit from it. If this is an oversimplification, it nevertheless leads to the question of whether it is possible for biotechnology products to summarize in a label answers to these three basic questions for the guidance of the consumer.
Dr. Surgeoner: There are a number of issues here. I'll refer back to my corn. If we have Bt corn to control corn rootworm and it goes into literally hundreds of vegetable products - cornstarch, corn syrup, things like that - and then it's fed to animals and moves up the food chain into chickens, swine, things like that, at what point are we talking about biotechnology? It's a very important question we should be asking in terms of consumer information.
The Chairman: That's why you are here, to tell us.
Dr. Surgeoner: I guess the key point is that if there are significant concerns about safety, about the ethics of a product and/or about nutritional change, that's the point at which we should start to do it, in my opinion. I think that's what is being said here today.
The Chairman: Who is to determine that threshold?
Dr. Surgeoner: I assume it's the government, in consultation with the consumers and the citizens of this country.
The Chairman: Is that the case now?
Dr. Surgeoner: Me again? In my opinion, yes.
The Chairman: Dr. Paterson.
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Dr. Paterson: Thank you, Mr. Chairman.
I would agree that we operate in a democracy through a parliamentary process. We are servants of whatever ministry we're in. In our case it's Health, but my colleagues are from Agriculture and Agri-Food Canada. We don't make policy; policy is made by the minister. We recommend and suggest, and that's the way democracy works in getting the information.
We get that from different sources. We get it from international scientific literature. We get it from industry. We get it from public health representatives, the public health sector, and we get it from the consumers.
Could we do a better job? No doubt we could in some areas. We're always striving to do that within the limitations of the timeliness of decisions and budgets, but I think we're all working to the same end: to benefit Canada, whether that's the health and safety of individual Canadians, or the competitiveness of a sector. So yes, I agree.
Ms Hunter: I think a lot of the studies that have been done on consumers' vision of biotechnology show that although certainly health and safety concerns are paramount, there are also a lot of other reasons why people want to have information, such as environmental and socio-economic reasons. What are they going to do to the family farm if bovine growth hormone is regulated in Canada? There are ethical and religious concerns.
I think there's a concern that there's a certain narrowness in the regulatory process, which does use scientific criteria to look at health and safety concerns. That may be not to the satisfaction of everyone, but it does look at those questions.
But there are a lot of other concerns that people have that are not... If we only take into account the health and safety concerns, then we'll say there's no need to label perhaps. I just think people have a lot more reasons for wanting to know how their food was produced.
Dr. Surgeoner: As an agriculturist at the University of Guelph and head of the plant science program, what I would have to emphasize is that if we want information, there are costs to providing that information. I'll again use corn as the example. Are we going to create separate audit systems from start to finish on our corn, and who is going to bear the costs of them?
Again, I think the questions are fundamental questions, but if we do that system, there would be a tremendous infrastructure necessary to monitor and audit the entire agricultural process in the province of Ontario.
Mr. Reasbeck: I'd just like to make a point or two in agreement with those just made. We really have to consider the extent to which a genetically engineered or modified item can move through the food chain. If we are talking about corn, we can talk about 2,500 different types of products in the marketplace whereby corn would have to be labelled if we went to the extent that might be recommended by some.
The point that was made earlier here is really quite an important one. At what stage do we start and at what stage do we stop a labelling requirement? Do we begin when it has just been developed and talk only about the modified food itself, or do we attempt to take it as far as possible?
Quite frankly, Mr. Chair, we doubt that there are enough resources or capability in today's system to establish such a monitoring, tracking or audit process to deliver that type of demand. We just don't think it is possible. Basically, that's why we do think it is important for consumers to have information, but the key is: what needs to go on the label? What really must go on the label?
Right now, I can tell you that, as Dr. MacKenzie mentioned, Canada is giving serious consideration to strengthening its nutritional labelling system. Our trading partner in the United States has gone to considerable lengths to become a world leader in informing their public about the nutritional attributes of foods.
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We do know that this information is influencing the American public. No other country in the world has mandated nutritional labelling, yet the United States has chosen to do this. In fact, it can be shown that consumers' buying habits are changing.
I think at the heart of all this is that we're at a communications crossroads. Communications has come out on a number of presentations already. It's communication to the public and education of the public to provide what they would like to know about these new foods, but within the limits and capabilities of the system to do that and to ensure that the information is truthful, accurate, efficacious and beneficial.
So the observation by the CAC was a good one. It's that is there is a joint responsibility on the part of all players in the system to ensure that information is conveyed to the people who need to know it and to decide at what point it can be delivered effectively and at what point it's absolutely necessary that they have it.
The Chairman: Thank you, Mr. Reasbeck.
Before we decide on the content of the educational message, are we satisfied that whatever methodology we apply, it is applied and guided by a principle that we err on the side of caution? Also, there's the principle that, however limited the scope, as Ms Hunter was telling us in a critical way - namely, limited to health and safety - we do apply methodology whereby we err on the side of caution and place the onus on the proponent rather than on the those who are examining the approach, the new technology, in proving that a particular product is healthy and safe.
Mr. Reasbeck: Thank you, Mr. Chair. I won't speak on behalf of Health Canada, but as a citizen I have put my faith in the expertise we have in Health Canada.
I think what we do see in considering the concerns that many consumers have today about new technology is the feeling that they have to be their own inspectors. They have to protect themselves. I think if we move in that direction in which we have every person for themselves and we put aside the expertise and the knowledge that we have within the government or in our scientific community to provide the direction that we should have, then I think we are moving into a very disorganized and chaotic type of environment.
For me as a private citizen, I am trusting myself, my family and my children to be in the hands of those who have the knowledge necessary to make the evaluations we have to have.
The Chairman: Dr. Paterson, is Mr. Reasbeck's faith well placed?
Dr. Paterson: I think so. We believe that health and safety are paramount.
The Chairman: Who carries the onus of proof, the proponent or you?
Dr. Paterson: I think that at the moment there is certainly more onus on Health Canada to take the responsibility. My own view is that this has to shift and become more shared.
The Chairman: Would you propose to shift the onus to the proponent? Is that what you're saying?
Dr. Paterson: I think what we've heard this afternoon, to the extent that industry is represented by my fellow participants, is that industry does acknowledge an onus and a responsibility. I think that's the way it should be. More and more in the future, it has to be a joint responsibility.
The Chairman: But at the present time, the onus is on you.
Dr. Paterson: Primarily, yes, through legislation and the Food and Drugs Act.
My colleague would like to intervene.
Dr. MacKenzie: I certainly wanted to note that the industry has a tremendous responsibility for the products they produce. They have a responsibility to comply with the laws of the land. I think that we, as officials with the responsibility for setting regulations, have a responsibility to make sure those regulations are set in such a manner that the industry can in fact then follow those regulations and meet their responsibilities.
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I just wanted to add a note on that. When we're talking about the regulations, as for the examination of foods that are the products of biotechnology, we don't have more stringent standards for novel foods; we look at safety for all foods. As new products come along, that simply means that one has to have new knowledge, but one doesn't become more or less stringent. You look at the situation and, as knowledge advances, you then apply your scientific principles. I just wanted to make that point.
The Chairman: Dr. MacKenzie, where does the onus of proof rest at the present time?
Dr. MacKenzie: Sir, could I just ask if you could clarify the ``onus of proof'' a bit for me?
The Chairman: It's whether the onus of proof rests on the applicant for a new product or on the department that examines the new product in terms of its safety.
Dr. MacKenzie: The onus of proof clearly rests with the applicant submitting the product. Then an assessment is done to the very best ability. Taking all risk assessment principles into consideration, an assessment is done by Health Canada.
I don't want to stray too far into my colleague's turf here, but I believe that you are getting into potential questions around liability, for example.
The Chairman: No, I'm not. I just need to have a clarification since there is a different answer from one department to the other. It would be helpful if you were to give us a clarification as to where the onus of proof is.
Dr. Paterson: Mr. Chairman, I would agree with my colleague Dr. MacKenzie, now that you've rephrased it and explained it: the onus of proof is with the applicant.
The Chairman: It's with the applicant. That's fine.
Dr. Paterson: As for the legislative framework within which the country operates, obviously the laws are made, and regulations promulgated under them puts an onus on the applicant.
The Chairman: Then the learning curve grows exponentially at every meeting we have, at least speaking for myself.
I want to thank you on behalf of my colleagues for this very interesting and stimulating afternoon. We apologize for having kept you until almost midnight, but we won't do it again. If we need you, we'll call you. Many thanks again, and have a good evening.
The meeting is adjourned.