After debating Bill C-474, An Act respecting the Seeds
Regulations (analysis of potential harm), the Standing Committee on
Agriculture and Agri-Food (the Committee) decided to examine the status of the
agriculture and agri-food biotechnology industry in Canada. The members hoped
to gather information on the various stakeholders in the sector, the
opportunities biotechnology creates for the Canadian agriculture and agri-food
industry, and problems stakeholders encounter in developing biotechnologies. The
Committee also hoped to determine what public policy is needed for the sector
to be productive, competitive and innovative and to benefit the Canadian
agriculture and agri-food sector.
The Committee held 10 public hearings between December 2010 and
March 2011 in Ottawa and Guelph, Ontario; and Saskatoon, Saskatchewan. It heard
researchers, corporations, agricultural organizations and groups representing
members of the public interested in the impact of the development of
biotechnologies. The Committee also visited public and private research
institutions across the country.
This document is a summary of the issues discussed by the witnesses
during the public hearings. Following a brief overview of the themes that were
addressed during the public hearings, the summary presents ideas that were put
before the Committee for each major theme.
The witnesses began by sharing their vision of what biotechnologies
are. Biotechnologies are more than transgenic crops and genetically modified
organisms (GMOs). Many other biotechnological processes are used to improve
plants and animals and also in agri-food and industrial processing. The
dialogue with the members of the Committee covered the evolution of
biotechnology, the benefits of biotechnologies in terms of agricultural
innovation and the importance to the future of agriculture and agri-food around
the world.
Much of the discussions focused on genetically modified crops
because they have monopolized public debate on biotechnologies in recent years.
The witnesses stated the advantages and disadvantages of GMOs for the
environment, health and the Canadian economy. They talked about the importance
of appropriate regulation and expressed their views on the direction regulations
should take in Canada. Among the other issues raised were the coexistence of
genetically modified crops and “conventional” or organic varieties and the need
to initiate or renew dialogue between supporters and opponents of this
technology.
Research and development issues were also discussed. The witnesses
described their vision of research funding. They also identified the impact of
regulations on research and development, in particular regulations on
intellectual property and the approval of new products.
Biotechnology is broadly defined as scientific applications that
involve the use of living organisms, or parts of living organisms, including
individual genes, to provide new methods of production and make new products.
It includes genetic engineering (GE), in which an organism’s genetic material
is intentionally altered in a way that does not occur naturally, such as by the
insertion of foreign genes, as well as a range of non-GE molecular techniques.
The witnesses differentiated conventional biotechnology (such as the
use of yeast for fermentation) from modern biotechnology. Modern biotechnology
comprises relatively recent methods that have made great strides in the past
decade; examples include genomics, biofortification and molecular marking. The
best-known modern technology is genetic engineering, which helps in the
production of genetically modified organisms or GMOs.
There are clearly two views of the evolution of modern
biotechnology. Some think that recent methods are an extension of older
methods, while others think that the advent of genetic engineering brought
about a more radical change:
- Some witnesses consider genetic engineering to be a fundamentally different process from other technologies because it can be used to introduce a foreign gene into an organism.
- Other witnesses believe that plant selection has always been based on the introduction of new characteristics, often with the help of methods that are far removed from nature like mutagenesis: they indicated that thousands of genes have been incorporated into crops from species with which they have no affinity in their natural state without the use of genetic engineering.
Although Canadian legislation uses a broad definition of
biotechnology, some witnesses limited their comments on biotechnology to
genetic engineering alone because in their opinion, biotechnology cannot be
considered homogeneous. The witnesses underscored the confusion that may exist
in the minds of the public between biotechnology and genetic engineering.
Because biotechnology is more than GMOs, the reservations about biotechnology
that were expressed pertained only about GMOs.
The witnesses described numerous methods used in modern
biotechnology, such as genomics, proteomics, molecular marking, tissue culture,
pyramidal gene arrangement, targeted induced local lesions in genomes
(TILLING), targeted mutagenesis, genetic engineering and bio-informatics. These
methods are applied at different stages of new product research and
development.
For example, genomics is the study of the totality of the
hereditary information of an organism, or the “genome,” which includes genes,
also non-coding regions of DNA or RNA that may serve other functions and have
effects on how genes are expressed. Tissue culture consists in growing
identical plants from the cells of a single plant and accelerates the
development of a new variety. Genetic engineering, meanwhile, consists in
introducing a foreign gene into an organism’s genome.
New products can be developed using one or more of these methods. The
witnesses talked about a number of products that are currently on the market or
at the research stage:
- new crop varieties that have such properties as tolerance of drought or other stressors (cold and salt), disease resistance or the ability to use the nitrogen in soil more efficiently;
- food and food supplements, such as products fortified with Omega-3 fatty acid;
- drugs and vaccines; many existing drugs (insulin, for example) are genetically engineered;
- animals modified to meet production requirements; examples include a pig genetically engineered to excrete less phosphorus (Enviropig) and a salmon engineered to grow faster.
Technological change has been at the core of growth in agricultural
productivity for 150 years. Innovation is needed in order to increase farm
productivity around the world and meet such challenges as a growing population,
the need for water and climate change. Innovation is also essential in keeping
the Canadian agriculture and agri-food industry competitive with countries that
invest heavily in research and development.
Biotechnology can be credited with a large proportion of the
innovations that have been made in Canadian agriculture. Many industries
attribute their current success to innovation in general and biotechnology in
particular: much of the development of soya, canola and pulses took place in Canada
with the advent of new varieties.
However, whether the increase in yield over the past 10 years can
be attributed to genetic engineering or other factors not developed by genetic
engineering that may come into play is open to debate. For example, the pulse
industry has developed many varieties using modern biotechnology, but not
genetic engineering.
For many, biotechnology has an important role to play in improving
agricultural productivity and creating new products. However, some think that
we should try to invest as much effort and resources in agronomic research and
organic farming methods.
Some believe that genetic engineering is not the answer to
increased agricultural productivity and is not even necessary, because the same
results can be obtained using other methods. Others, meanwhile, believe that
genetic engineering is one of many tools and that it has its benefits but is
not a miracle solution.
Much of the discussion during the hearings was devoted to GMOs and
genetic engineering. The biotechnology debate focused primarily on consumer
acceptance of GMOs and its repercussions down the road. There was conflicting
evidence on many issues; that evidence is reported here without any indication
of relative weight (many witnesses in favour of one argument, for example).
GMOs have been widely used by Canadian farmers since the mid-1990s.
For example, more than 80% of farmers on the Prairies use genetically modified
varieties.
Canada ranks fifth in the world in areas seeded with GMOs. The
other countries that have adopted this technology are the United States, China,
South Africa, Argentina and Brazil. Inversely, some countries, such as the
European Union countries and Japan, are still wary of these products.
GMOs have been in use since the mid-1990s, and there have been no
proven cases of damage to health or the environment. A study of more than 500
independent research groups carried out by the European Commission showed that
GMOs are as safe for health and the environment as other foods currently on the
market. The Canadian Biotechnology Advisory Committee has also concluded that
there are no scientific data indicating that genetically modified plants and foods
create more health and environmental problems.
The risks are hypothetical and difficult to prove. It is therefore
important to be vigilant and monitor human health and the environment after the
products hit the market.
Health:
- Genetic engineering is a new frontier with long-term consequences that are still unknown. Studies have shown possible health effects, which is an indication that more research is needed. This refers to a very small number of studies not published in refereed journals, raised by a small number of witnesses. Further, several subsequent witnesses dismissed these studies as having little scientific credibility, the finding of which were contrary to a much larger body of work.
- Regulatory bodies are aware of the new studies and are evaluating them. Standardized research protocols are needed so that the results of studies can be replicated and confirmed beyond the shadow of a doubt.
- In terms of health risks, the key is to study which gene was introduced and what it produces, because the concept that natural products are better is false (there are many toxic natural substances), and it is also not true that GMOs are safer than other foods.
- People talk about the risk associated with GMOs but know little about the risks associated with many other substances found in food.
Environment:
- The biggest risk stems from the fact that a gene can easily pass from one variety to another or from one species to another. Once a gene has passed into a wild population, it can further spread and would be difficult if not impossible to contain.
- Some indigenous varieties of corn in Mexico have been found to be contaminated, and that could be a problem for the preservation of biodiversity in that country.
- Genetically engineered salmon could compete with wild species.
- GMOs are not environmental disasters. Some varieties have made it possible to adopt more environmentally friendly methods, such as minimum till cropping systems, and the decrease of the use of pesticides. Studies have shown, however, that the amount of pesticide applied to some crops has increased.
Farmers would not choose GMOs if there were nothing to gain. From
an agronomic point of view, existing GMOs have been used to improve weed
control and increase the use of zero tillage systems. Studies have shown that
farmers have earned hundreds of millions of dollars from genetically modified
canola since the product was introduced. It has increased the net income of the
farmers who use it, primarily because the cost of some inputs (fuel, etc.) is
lower.
The introduction of GMOs is not without risk, however: weeds that
are resistant to some herbicides can emerge, for example, or private companies
may increase their control of the seed supply, especially if they have the best
stock of elite seeds. There could be an increase in dependency on inputs from
outside the farm (licensed technology, patented seeds, etc.) and a rise in monoculture.
For some, controlling the seed industry is no different than
controlling any other industry, such as banking, fertilizer and farm machinery.
Farmers always have the option of not buying genetically modified varieties.
Market reaction is another risk, since access to genetically
modified products on some international markets is a problem. Because some
markets are wary, contamination of unmodified varieties can lead to market closures
and heavy economic losses. The economy has already suffered as a result of the
appearance of genes where they were not expected to be (Starlink corn,
transgenic flax, etc.).
The dispersal of genes to organic farms is a major challenge for
organic farming and limits the range of choices: organic farmers say they can
no longer grow organic canola because they cannot guarantee that their product
has not been contaminated by genetically modified canola.
If genetically engineered pork were approved for human consumption,
consumers might shy away from pork products so they do not run the risk of
eating genetically engineered pork. That would hurt the entire industry.
Regulation is the foundation of the public’s trust in products. Two
visions of Canada’s regulatory system were presented. On the one side are those
who believe that biotechnology regulation in Canada is working and that we have
one of the best regulatory frameworks in the world. There are areas that could
be improved, but no drastic changes are needed. On the other, are those who think
that the regulatory system needs to be reviewed and that the government must
implement the recommendations made by the Royal Society of Canada in its 2001
report Elements of Precaution: Recommendations for the Regulation of Food
Biotechnology in Canada. The witnesses discussed the following issues:
Scientific principles underlying the evaluation of new products:
Some believe that the available scientific information shows that the current
regulatory system is working. Since it is impossible to prove that there is no
risk, the weight of scientific evidence has to be used, and measures have to be
taken to ensure that new products pose no unacceptable risk to humans or the
environment: when 1 study says one thing and 40 others say something else, we
have to look at the weight of the evidence. Others believe that precautions
have to be taken in regulating and approving new products; they oppose the
principle on which current regulations are based, namely that genetically
modified crops are by and large equivalent to conventional crops. They base
their argument on a report from the National Research Center in the United
States which says that we should reassess our study methods.
Need to evaluate products case by case: Canada regulates
products, not the way they were obtained (technology), because a crop resistant
to herbicides, for example, can be created using genetic engineering or conventional
methods. Most of the witnesses support this approach, although some would like
regulations that apply only to genetically engineered products. Everyone
agrees, however, that each product has to be evaluated on its own merit. The
point was also made that the current regulations give the same treatment to
GMOs that essentially pose no risk as they do to GMOs that pose significant
risks. Some are too regulated, and others are not regulated enough. Because
every GMO poses a different risk, a multi-level regulatory system like the
system currently used for drugs should be put in place. It was noted that there
are no specific regulations for genetically engineered animals.
Trust in the system: The witnesses talked about the need to
include as many stakeholders as possible in the regulatory process in order to
ensure that the opinions of those who are in the field are heard. It was stated
that people may get the impression that the regulatory system was designed to
benefit companies, mainly because the government’s decision-making processes
are kept secret and do not have any public input. On the other side of the
coin, some witnesses stated that the system is sometimes too slow and costly
for companies. It was pointed out that the government’s role is not to block
these products or to promote them. The government is a third party; its role is
to defend a regulatory system that protects the public’s health and the
environment.
Need for greater transparency: Some witnesses stressed the
need for transparency in regulatory decisions so that everyone has confidence
in the system. They stated that regulatory authorities examine all new
scientific data, but that information is not in the public domain. Neither the
public nor independent scientists have access to the scientific data the
government evaluates. For now, regulatory authorities are required by law to
keep confidential any information produced by a commercial venture. The
witnesses talked about the need to come up with ways of making scientific data
accessible. Peers could review scientific protocols and replicate experiments,
and that would improve the regulatory process.
Science and socio-economic factors: For some witnesses,
regulations must be based solely on scientific elements which show that a new
product poses no risk to health or the environment. Straying from that concept
would make the regulatory process too unpredictable and would drive investors
away. They suggest that non-scientific elements are often commercial obstacles
that do not mesh with World Trade Organization (WTO) rules. For others, the
introduction of genetically modified wheat showed that evaluating biotechnology
based on scientific criteria alone is not without problems. The case of
genetically modified alfalfa shows that some products can be an economic threat
for some farmers but that regulations are not designed to take that into
account. They make the point that evaluation of the socio-economic impact of
new genetically modified crops should be included in the Canadian regulations.
There are quantitative methods based on scientific data that can be used to
properly evaluate technology. Other countries, such as Argentina, take that
approach without impeding trade.
Labelling and monitoring: Some witnesses talked about the
need for a mechanism for monitoring the environmental and health effects of
products after they go on the market. A government initiative to set up a
project to monitor genetically modified foods was launched and then abandoned.
Some witnesses stated that mandatory labelling of genetically modified foods
could help track potential problems.
Studies show that genetically modified crops spread toward
conventional crops and it is impossible to guarantee that there is absolutely
no contamination. Some crops are better suited to segregation than others
because of their biological properties. For example, soy growers and exporters
have been able to put in place segregation systems that enable them to supply
their customers with different types of soy with specific properties. This
means they can supply Asian and European markets with GMO-free or certified
organic products. This could not be done with other crops, such as canola:
organic or non-genetically modified canola can be grown only in geographically
isolated areas, such as Prince Edward Island. Some fear that the methods used
by GMO growers will prevail and it will no longer be possible to guarantee
GMO-free crops. In their view, not enough thought has been given to systems for
segregating GMO and GMO-free crops.
Cohabitation of different types of farming: The witnesses
talked about the importance of finding ways for all types of farming (organic,
genetically engineered, etc.) to coexist. New technologies can be used to
improve segregation, and it was stated that regulatory agencies should
encourage molecular geneticists to come up with methods of preventing gene
transfer in nature. Regulatory authorities already require buffer zones in some
cases, but that method is not always effective. The United States is currently
considering imposing geographical restrictions and segregation distances for
some crops.
The industry has (or is hoping to) put in place protocols for
segregating crops. Generally, however, it is very costly to keep crops apart so
that they do not mix. For now, growers who do not use GMOs are the ones who
assume the cost and the task of implementing measures to guarantee effective
segregation. The organic farming sector says that biotechnology developers and
users should pay for and implement measures to guarantee successful coexistence
that respect both farming systems. Biotechnology companies and farmers who grow
GMOs should compensate organic farmers for the financial losses caused by the
sudden appearance of GMOs in plants and seeds.
Organic farming: Organic farmers accept pesticide residue on
their products but do not tolerate any GMO contamination. That is a standard
the organic farming industry has imposed on itself and can be found in
international organic standards. To prevent pesticide contamination, organic
producers create buffer zones. They also have to provide affidavits from their
neighbours in which they undertake to refrain from spraying in windy
conditions, etc. It is easier to take measures to
prevent contamination by pesticides than by GMOs. The organic farming industry
has not reached consensus on GMO contamination (zero tolerance or acceptance of
a certain level of contamination as is the case for pesticides). Stakeholders
do not believe that European consumers will accept a small percentage of GMOs
in their products.
Alfalfa: The organic industry is afraid that the
introduction of genetically modified alfalfa will eradicate certified organic
alfalfa. Some stakeholders have called for a moratorium on the approval of
genetically modified alfalfa. Genetically modified alfalfa has received regulatory
approval in respect of health and the environment. However, it cannot be sold
in Canada because the variety in question has not been approved. Some witnesses
stated that the company has indicated it will not seek approval in Canada as
long as farmers do not ask for it, there is no clear and acceptable policy on
coexistence, and there has been no full deregulation in the United States (the
United States has deregulated GM alfalfa since the end of the Committee study).
International trade: Internationally, there is zero
tolerance of the presence of unapproved genetic material. That is the current
policy in Canada, the United States, Australia, Japan, Korea and all European
Union countries. The policy can be attributed to the fact that if a variety has
not been approved, it is not yet considered safe. To avoid a situation where a
variety has been approved in one country but not in another, the industry has
made a commitment to try to obtain approval in all major countries in which a
product will be marketed. For example, a variety of canola cannot be marketed
in Canada unless it has been approved in the country’s primary export markets.
Others have stressed the importance of harmonizing approval processes so that
producers can sell their products in countries where consumers are less
amenable to biotechnology.
However, with the proliferation of varieties and properties, many
stakeholders think it is unlikely that a zero tolerance policy will last.
Efforts must therefore be made to find ways of adapting the tolerance rules to
international trade. It was proposed that Canada take on a leadership role in
the modernization of global regulations. The presence of small quantities of
genetically modified crops in a given country should not impede the movement of
products around the world. A policy aimed at managing the presence of traces or
low levels of genes in products that growers would like to see approved in
other countries would be good for international trade. Some witnesses stated
that there are already international rules on the movement of GMOs: the Cartagena
Protocol on Biosafety was established to manage the international
transportation of modified living organisms. Canada signed the protocol but has
never ratified it.
In the late-1990s, initiatives were taken to sit the various
stakeholders down in one room. A number of authorities studied the issues
related to biotechnology, in particular the Canadian Biotechnology Advisory
Committee under the jurisdiction of Industry Canada and the Canadian General
Standards Board’s Committee on Voluntary Labelling and Advertising of Foods
that are and are not Products of Genetic Engineering. The groups that opposed
the technology withdrew from these initiatives primarily because they were biased
and favoured the industry.
The debate over GMOs is certainly not over, and the witnesses
stated that they support dialogue among all the stakeholders because the public
needs to be fully informed and the interests of the stakeholders are better
defined and reconciled. The debate has to be broad enough to incorporate all
segments of society. The debate has often been brought down by sensationalistic
headlines (for or against) that have not served either cause. The type of media
coverage can have a significant impact on the quality of the debate (United
Kingdom, for example); the level of dialogue must be raised.
The witnesses noted the importance of investment by both the public
and the private sectors. The industry has invested a great deal in
biotechnology research, but only the big corporations can afford to invest
heavily. Small companies have trouble raising capital. As a result, innovations
are concentrated in a handful of companies and research is limited to a certain
number of crops (e.g., canola, corn, soy), to the detriment of small grain
crops and pulse. The private sector invests only in crops that are produced in
large quantities and crops on which there is no research and development suffer.
Some witnesses remarked that public-sector spending on agricultural
research has decreased in Canada, and that the decline has been accompanied by
lower growth in agricultural productivity since the 1990s. The positive impact
of public investment in research on agricultural productivity has been
demonstrated. The involvement of the public sector also ensures independent
research and investment in areas of the agricultural industry that are not as
appealing to the private sector because they are too small or there is no product
to market (for example, research on organic farming methods). The witnesses
stated that China and many other countries invest heavily in public
agricultural research.
The witnesses were adamant that agriculture remain a national
research priority. They said they were disappointed by a number of recent
decisions by grant-giving agencies. The National Science and Engineering
Research Council (NSERC) has dropped “Quality and Novel Bioproducts” from its
list of target areas for strategic grants, and the Networks of Centres of
Excellence has not renewed its funding for the Advanced Foods and Materials
Network (AFMNet).
Regarding the type of investment, the trend is toward short-term
funding (one to three years). The witnesses stated that there is also a need
for ongoing and permanent investment, particularly in basic research. They also
talked about investing in research infrastructures and in what is known as the
“death valley” of research, that area between a concept and an actual product;
many good ideas die because there is no mechanism for moving them forward.
Almost all of the witnesses said that it is important to foster
collaboration among the industry, producers, universities, governments and
consumers. The food industry is fragmented at the national level, and research,
too, is often dispersed. To help build partnerships, the government can, for
example, provide the research infrastructure and thus attract corporations.
According to the cluster theory, competitors will set up alongside each other.
The witnesses talked about many partnerships they have formed, for example,
pulse producers: the University of Saskatchewan, and the Saskatchewan
Department of Agriculture signed an agreement to develop new varieties. The
development of new products must begin with a discussion with clients.
Historically, research was done without giving any thought to clients or users.
To encourage investment in research and development, regulations
must be clear and foreseeable; otherwise there is a risk of researchers going
elsewhere. The issues raised were:
Cost: The witnesses mentioned the very high cost of getting
a new product approved. It costs hundreds of thousands of dollars over several
years to get a GMO on the market. That favours big corporations and reduces
competition. It is also not good for small companies.
Administration: The industry finds that approval generally
takes longer in Canada than in other countries. More and more crops are being
developed for industrial applications (bioplastic, etc.) or energy, and
regulations must be adapted to that shift. Regulations must also be flexible
enough to ensure that undue obstacles to innovation are not created.
Intellectual property: Intellectual property rules ensure
return on investment. In the field of biotechnology, Canada’s legislative
framework is equivalent to the frameworks established by our main partners.
However, some aspects of the regulatory framework applicable to intellectual
property create uncertainty that can undermine the investment climate.
Intellectual property is not always evenly protected, and the practices used in
research laboratories are not uniform.