Letter to Minister Bibeau re CFIA regulatory guidance for gene edited seed
On January 17, 2022 the National Farmers Union sent the following letter to Agriculture and Agri-Food Minister Marie-Claude Bibeau:
Dear Minister Bibeau
RE: CFIA regulatory guidance regarding seed developed through gene editing technology
In September 2021, the Canadian Food Inspection Agency (CFIA) concluded a public consultation process on its proposed regulatory guidance in order to change how it interprets and applies Part V of the Seed Act Regulations in regard to products developed using new genetic technologies, often referred to as “gene editing”. The National Farmers Union submitted detailed comments on the proposed guidance, which are available here – https://www.nfu.ca/policy/nfu-submission-to-cfia-on-gene-editing-regulatory-guidance/ . In December, we attended a meeting hosted by the CFIA where staff indicated the Agency intended to proceed with implementing their proposal with a few minor changes, none of which addressed our concerns.
Our submission raises very serious questions of governance, science, and the duty of the CFIA as public regulator to serve the public interest. We noted that in the process of developing the proposed guidance, the CFIA relied heavily on representatives of CropLife Canada, whose members stand to gain undue control of seed, and financially benefit from deregulation of gene edited products at the expense of farmers and the public good. This conflict of interest is at the heart of our concerns. The CFIA’s approach suggests it equates regulated parties with stakeholders. Regulated parties seek to avoid constraints on their business, while the public has a long-term stake in environmental safety and transparency.
If allowed to proceed, the proposed regulatory guidance will result in most genetically engineered seed varieties produced using gene editing technology being exempt from Part V of the Seed Act Regulations, and thus allowed to be introduced into our environment, farms and food supply with no independent safety assessment and without any obligation to inform the government or farmers that the seed was gene-edited. We believe this is not only irresponsible, but also that it goes beyond the authority of the CFIA, as the guidance is not consistent with the intent of the regulation.
We are now writing to you as Minister responsible for the CFIA, to alert you to this matter and urge you to intervene to uphold the principles of transparency and independent scientific evidence by putting a stop to the CFIA’s proposed regulatory guidance in order to protect the public interest and regain public trust in the federal government’s role as regulator.
Katie Ward, NFU President