Action: Health Canada Public Consultation on Gene-edited Plants
Take Action: Health Canada consultation on gene-edited plants
Deadline: May 24
(Note – if you missed the deadline, please feel free to send a message anyways. Health Canada will continue recieving input from the public for the next several weeks.)
Demand mandatory disclosure and safety assessments for all gene-edited plants! Use the Action Box below to send an email to Health Canada, or send your comments to Health Canada: hc.bmh-bdm.sc@canada.ca Feel free to edit the letter to personalize your message.
Health Canada Public Consultation As a farmer I support mandatory government safety assessments of all foods from gene-edited plants, and public notification of all gene-edited foods and plants before they are put on the market. I want to be able to make an informed choice about the seeds I purchase. I am concerned that if gene-edited products are put on the market without notification it will put some markets or prices at risk. For example, if important trading partners reject shipments that contain products they have not approved. I know that science is always learning more about genetics and new technologies are always being developed. Not everything is understood, and unexpected problems can be discovered. It is important for Health Canada to be able to assess new products to make sure they are safe. Independent government safety assessments are also needed for public trust. Thank you for listening.
Background
Health Canada is holding a public consultation on how it will interpret regulations for gene-edited plants. It is proposing new interpretation of the Food and Drug Regulations (the Novel Food Regulations) that concern the question “when is a food that was derived from a plant developed through breeding a “novel food”?” and for pre-market assessment of foods derived from genetically engineered plants referred to as “Retransformants”. The consultation closes on Monday, May 24, 2021.
Click here to read the NFU’s full brief
Canada’s approach to regulating biotechnology is triggered by the plant’s novelty (newness) and not the technology used to develop the plant. Health Canada’s proposal would make major changes the “regulatory guidance” that tells Health Canada how apply the actual regulation. The proposed interpretation would exclude most products of gene-editing from regulation, and would allow plant developers to sell unregulated gene-edited products without first informing Health Canada or the public.
Gene-editing is a powerful tool. These new genetic technologies allow plant developers to introduce traits that would not be possible using traditional breeding techniques. Health Canada recognizes that plants developed using gene-editing technology are different from previously existing plants and produced by means of genetic engineering, but the proposed change would deem many of them “non-novel”.
Who decides what is or is not novel? The proposed guidance would rely on plant developers to assess whether their new gene-edited variety is “novel”. If a new plant is considered “non-novel” there is no requirement to report its existence to Health Canada before putting it on the market. Health Canada proposes to set up a “Voluntary Transparency Initiative” (VTI) where companies may inform Health Canada when they plan to put a product they believe is non-novel onto the market. If Health Canada disagrees the product might have to undergo safety assessment. This would increase costs, so there is a strong incentive to put product son the market without reporting them to the VTI.
Proposed guidance lacks scientific evidence and transparency. The results of gene-editing are not knowable in advance. Scientific knowledge is constantly increasing through a constant process of investigating, testing and disproving hypotheses, publishing results and designing new experiments. A regulatory approach that says “we don’t need to know more” before any gene-edited products are put on the market is fundamentally unscientific. To also create a mechanism that allows these products to be marketed without identifying them as being developed through gene-editing is the opposite of transparency.
Canadian farmers should not be faced with unknown products of gene-editing that have not been assessed for safety by Health Canada. Farmers know that when unapproved crops are rejected by markets they are the ones who pay the costs.
Organic standards, prohibit gene-editing technology in certified organic production. The proposed guidance, by allowing non-transparent marketing of gene-edited varieties, creates a high risk that certified organic farmers will inadvertently use these prohibited varieties.
Retransformants. Health Canada also proposes new regulatory guidance to reduce regulatory requirements for plants with traits and/or DNA sequences that have previously been reviewed based on an assumption that it is possible for plant developers to make “identical” changes to the same variety using new technology, or to a different variety by using the same technology, and even to a different variety using new technology.
NFU recommendations:
All gene-edited products should be regulated as novel and therefore subject to government safety assessment and pre-market notification. This would ensure Health Canada maintains its ability to regulate foods derived from gene-edited plants in the public interest. It would ensure farmers have access to the information they need to make informed choices about the seed they purchase and crops they grow. Mandatory reporting prior to marketing would reduce the risk of market rejection due to the presence of gene-edited varieties not acceptable in sensitive markets, including the certified organic market. Mandatory pre-market notification would also provide Health Canada with information needed for traceability in the event it needed to carry out its responsibilities if a recall of food derived from gene-edited plants was necessary.
In light of the lack of robust scientific evidence and the newness of gene-editing technology, it would be prudent to continue requiring full data and review retransformants as new events. Once these products are on the market, it will be farmers and consumers that bear the risk if the proposed lighter regulatory treatments result in market rejection or food safety issues. We therefore recommend that all retransformants continue to be assessed as new plants with novel traits.
