Plants > Variety Registration > Review  

Review of the Canadian Seed
Variety Registration System

Appendices

Appendix A: Survey Questions
Appendix B: Excerpts of Written Comments

Appendix A: Survey Questions

1. Should There Be A Variety Registration System In Canada?

2. Should all crops of commercial importance be registered?

3. Are changes needed to the current system? Please provide details.

4. Should registration be based solely on merit (as is the case now)?

5. Should the approach to variety registration and regulation be solely science-based and consider "merit" only from a scientific viewpoint ?

6. Should social, political or trade factors also be considered within the context of merit in variety registration?

7a. Should merit be based on the principle of "better than" rather than "equal to" in important traits and characteristics?

7b. If you believe that the principle of "better than" should be used, please define better than as:

8. In general, should merit include:

9. Should merit include emphasis on the acceptance of a variety for end-use in ?

10. Variety registrations may be restricted in geographic scope (regional registration) or in duration (interim registration).

11. Do the current Recommending Committees provide an objective means to evaluate credible scientific data?

12. What data should be accepted for registration purposes by recommending committees?

13. Should all valid scientific data, regardless of the source, be considered by Recommending Committees?

14. Do you believe Recommending Committees have the capacity to objectively determine the validity of data? If not, is there an alternative mechanism ?

15. Does there continue to be a need for objective inspection/validation of variety registration trials regardless of where they are grown, or by whom?

16. Which crops currently subject to variety registration on the basis of merit should continue to be registered on the basis of merit ?

17. Please indicate additional crops now exempt from registration which should be returned to a registration system based on merit, e.g. turf grasses, industrial hemp, ginseng, hybrid corn, high protein soybeans, fibre flax.

18.Many countries utilize a catalog system of registration whereby variety information is provided and the variety is included in a registry or catalog. Do you believe that a catalog system, (to be used for international recognition, seed certification), which provides a record of variety data, but does not consider merit,

19. Variety registration trials are viewed by some as a source of unbiased data. Would registration without merit (cataloguing) inhibit the provision or collection of regional/provincial performance information ?

20. Should all plants with Novel Traits (PNTs) be subject to some form of registration (including those crops presently exempted)?

21. Should some form of variety registration (with or without merit) be used as a mechanism for the recall and disposal of PNTs not in compliance with regulations including those crops presently exempt from the registration requirement e.g. tomato, hybrid corn ?

22. The existing scope of harm is now applied to domestic situations. Considering ongoing problems with the acceptance of PNTs in some international markets, should the definition of harm be expanded to include harm to export markets? If yes, which or how many export markets?

23.If the definition of harm were expanded, would this make Canada vulnerable to non-tariff trade barrier problems in the crops of interest to you if domestic approvals for sale were withheld pending international approvals? If so, which crops ?

24.Should a proponent of a PNT variety have the responsibility to ensure that the sale of their proprietary PNT or PNT products does not interfere with the potential for acceptance and sale of the generic commodity or products derived therefrom in domestic and/or international markets?

25 If the definition of harm was expanded, would some of the new or proposed variety registration mechanisms (e.g. contract registration, cataloguing) be appropriate ?

Appendix B: Summary of Written Comments

WS001A - Flax Council of Canada

• Letter, Dec 23,1998
• Commentary restricted to flax

Resolution of Council:

1. The Flax Council of Canada recommends that loss of foreign markets should be considered by the Canadian Food Inspection Agency as criteria for withholding full varietal registration of flax.
2. The Flax Council of Canada recommends that any seed variety registration system be tailored to individual crop requirements.

WS001B - Flax Council of Canada

• Letter Jan 29,1999. Comments for flax only.
• The council believes that crop types play a larger role in defining and establishing procedures.

Resolved that:

1. There be a flax recommending committee which would make science based recommendations.
2. There be a second committee made up of the flax industry, which is in contact with the flax markets (exporters and crushers.)
3. The approval of any flax variety would require the concurrent recommendation of both committees.
4. Both committees to be chaired by the Flax Council.
5. The Flax Council is not in agreement with any attempt to develop a system that would be generic to all crop types.

WS002 - Ontario Cereal Crops Committee

• Unanimous consensus that the existing system is working well.
• The OCCC accepts the need for the smallest acceptable amount of performance information and agronomic data from Ontario to evaluate the merit of new cultivars of cereals. The OCCC has developed a system that facilitates the acquisition of data without undue delays. Recommended that CFIA consider the implementation of this system Nationally.
• Merit to include yield, quality and disease.
• Consider international markets.
• No consensus on the possible utility of a cataloging system.

WS003 - Bonis & Company

• System does nothing to protect producers from obsolete and unadapted varieties.
• Entire system could be replaced by a strong provincial recommending system.
• A cataloging system that provides knowledge of varieties to be produced by pedigree system and eligible for certification may be suitable.
• The public sector tends to underrate the importance of market reputation in private sector cultivar development.
• Changes are needed to the current system: simplification, cost reduction, establish uniformity.
• Reduce the number of crops subject to registration, e.g. bromegrass, wheatgrass, ryegrass, lupin, buckwheat, beans, etc.
• Potato could be handled by a cataloging system.
• There is no reason to continuously increase the complexity of variety evaluation for registration.
• The question of merit and who is to determine is not easily answered - see CSTA brief.
• Varietal registration on the basis of specific geographical areas is nonsense.
• Interim registrations make it difficult for companies to justify effort of seed multiplication.
• Utilization of private data has been tremendously beneficial.
• Varieties grown in Canada but not necessarily registered in Canada must be recognized for production of pedigreed seed. WE must not have a system where varieties have to be registered before they can be included on an OECD list.
• Plants with novel traits must have restricted access to the market place, however we can not be unduly influenced by foreign countries. Issue of harm becomes a political and trade issue beyond the realm of variety registration. Question of who defines harm.
• Contract production serves to restrict possible contamination of generic markets.

WS004 - Canola Council of Canada

• The CC supports the Canadian variety registration system.
• The council supports regulations that allow the contract production of specialty varieties.
• Loss of international markets should constitute harm - RESOLUTION recently passed to this effect.
• For the canola industry maintenance of quality traits are critical to the well-being of the industry.
• There is a need for some type of management system to provide assurance to the international marketplace.
• There was no council consensus concerning all aspects of variety registration development and management.
• Strict guidelines can not be developed that will meet the needs of all crops.
• A Canadian variety registration system that allows for a recognized and enforceable management system for introduction of novel traits should not be seen , nor understood, as implying a segregation between GMOs and non-GMOs.- only segregation of non-approved GMOs.
• Procedural elements, the requirement for key international market acceptance, the definition of what are key international markets, the importance of agronomic characteristics, the importance of quality characteristics, should be the decision of the crop sector and not CFIA.
• The make up of the WCC/RCC would need to be reviewed if industry to play a bigger role in self-regulation.

WS005 - Ontario Soybean Growers' Marketing Board

• Soybean growers want the variety registration system to be responsive to their changing needs.
• Soybean grower want early access to new varieties.
• Annual public variety performance testing is most important to soybean growers.
• Soybean industry is changing: more acreage, more specific uses, reduced cultivar life span, trade off between special traits and high yield.
• Testing system needs to evolve, OOPSCC has introduced a 1-year modified form of soybean variety testing system for 1999 - need for access to new varieties.
• OSGMB has concerns regarding the inflexibility of the federal registration system, with delays and fees.
• As the U.S. is likely the first country to promote any new soybean PNTs the need for the variety registration system to protect the industry from trade and market risks is less than other crops such as canola.
• Canada very good and recognized for ability to grow identity preserved soybean varieties.
• Annual variety performance testing very important.

WS006 - Pioneer Hi-Bred Ltd.

• Strongly opposed to revisiting variety registration requirement for corn.
• Many crops do not need any system; quality issues important.
• Supports CSTA position.

RE: Canola:

• Registration should be retained in a simplified form.
• Only quality traits to be included as criteria.
• Considerations related to PNTs should not be included in variety registration.
• Registration should be possible with only private data.
• Supports the position of phasing in changes.

RE: Alfalfa:

• A merit based registration system provides no value what so ever.
• Remove all forage crops from registration requirement.

RE: Soybeans:

• Merit based registration system is of no value, remove soybean from requirement.
• Can see no justification for need of minimum oil and protein standard.

RE: Soft White and Red Winter Wheat:

• Producers have been forced into growing a crop where only a small percentage could be used domestically because of variety registration constraints.
• Consider removing all Eastern cereals from a registration requirement.

RE: Sunflowers:

• Registration unnecessary, provincial recommending committees unable to provide adequate testing services, companies do not want to pay high testing and registration fees.
• Current registration system is hindering the introduction of new varieties that are already know to be vastly superior because of requirement for three years of Canadian data.

WS 007 GPCRC - V. Poysa

• Supports the concept of registration but process needs to be flexible to provide fast access to new varieties. Full registration with one year of data (combination of public and private.)
• Current recommending committees are best qualified to determine which traits are of importance to the industry (merit.) Merit to be assessed by a comprehensive committee.
• A catalog of all transgenic varieties sold in Canada , including those not subject to registration is needed.

WS008 - Manitoba Corn Growers Association Inc.

• Letter expressing concern that corn remain exempt from variety registration.

WS009 - CSGA

• Letter expressing general support for the registration of varieties, detailed info to follow.

WS 010 - Zeneca

• View that Canadian variety registration system is failing in its objective to provide growers with the best cultivars - market should decide what varieties are grown after deregulation.
• The present system does not attempt to provide the grower with information on which is the best variety to plant or produce data that allows the comparison with previously registered varieties.
• The system does not attempt to prohibit production of varieties that may cause harm to the industry.
• Disease resistance requirement inappropriate, farmer needs to decide if disease resistance is needed on his farm. Also checking for disease resistance that is not required.
• Market decides what quality parameters should be. It is the domain of the producer and marketer to decide what the market wants. The present system does not address the rapid segmentation of the market.
• It is only after being widely grown that true performance of a variety can be determined.
• For canola, the system is argued to be based on merit, however the evaluation is a complex formula representing a compromise between many conflicting interests.
• Trade related novel traits must be recognized as having potential harm to the industry. The present system is science based and is not equipped to decide whether a particular trait should be released if it has potential to harm the industry.
• If there must be a variety registration system it should be based on products that will not cause harm to the industry. Harm should consist of quality and novel trait trade issues. It is essential that the industry itself determine what may cause harm. Issue such as yield, disease, oil and protein content should be abandoned as part of the registration system.

WS 011 SeCan

• The variety registration system should serve the interests of Canadian agriculture overall and not just the seed industry.
• If the data used for variety evaluation is no longer available then, an alternative system must be developed to generate additional data. Stakeholders would be more easily persuaded to accept removal of yield and other performance criteria from registration criteria if there were assurance that the necessary data would be generated in some other way.
• Concerning plants with novel traits this issue should not be part of the variety registration system providing that there is another mechanism to insure the industry is protected.
• No major problem is seen with the current system but improvement is always possible.

WS 012 - Ontario Corn Producers Association

• Strongly feel that further consideration of a registration requirement for hybrid corn is inappropriate.
• Determining the need for merit-based registration for any given commodity should be the sole jurisdiction of stakeholders with direct financial implications for that commodity.
• For corn the approval process for novel traits has operated effectively and has proceeded independently of merit-based variety registration.

WS013 - Ontario Corn Committee

• Letter expressing concern that the issue of registration of corn varieties is to be reconsidered.

WS014 - PMRA

• Letter declining participation.

WS 015 - Keith Downey

• The present system does weed out a significant number of candidates and ensures producers that the varieties have a known level of disease resistance and are good yielders with acceptable oil and protein content.
• To discard the registration system would result in producers having to rely on commercial advertising as a sole source of information.
• Opposition to 100 % private data.

WS 016 - ECORC

• There is no proof that the current registration system poses harm to the industry, it may slow the release of a cultivar by 1-2 yrs but what is really lost.
• Fees for registration are not exorbitant.
• Choices are simple, either support and strengthen the registration system or eliminate it and harmonize with the US.

WS 017 - Dairyland Research International

• If there are minimum standards then varieties should be evaluated in a statistically correct fashion.
• In the US most states do not have a recommended list there is data published in a State summary.
• Novel traits should be controlled by the marketing company.

WS 018 - CSTA

• Key elements of change in recent times include: more private involvement in cultivar development, recognition of regional adaptation, diversification of varieties with special traits and declining public sector testing resources.
• The CSTA supports the principle and mandates of the Variety Registration System.
• It is important to recognize that variety registration sets a minimum standard for sale.
• The challenge for each crop committee is to determine which traits are critical for the health of the industry.
• Given the wide range of growing conditions in Canada it is clear that any variety can not be adapted to all locations and hence the mandate to exclude non-adapted varieties needs to be interpreted to mean that a variety must be adapted to some location in Canada.
• The CSTA draws distinction between testing for registration and testing for recommendation.
• The CSTA recognizes that novel trait testing requirements are not linked to variety registration.
• If a species does not appear to have any traits that are critical to the health of the industry and should be set as minimum standards then remove the species from registration testing.
• The CSTA requires that procedures be science based and predictable.
• There should be clear guiding principles for recommending committees.
• The VRO should not expect that one crop committee can be used as model for all.

WS019 - Canadian Nature Federation

• Letter expressing interest in the review process.

WS 020 - Andre Comeau

• The registration system is needed for two reasons: The public needs protection from harmful toxins that may be present in foods and environmental issues need addressing.
• Scientific groups that produce cultivars need to recover a return on investment.
• Registration is based on merit only in Western Canada, but East may be moving the right direction regarding disease and hardiness.
• Provision of patents for plants would be helpful to obtain new varieties.
• Need strong and able leadership to deal with difficult issues such as PNTs that involve political as well as science issues.

WS 021 - Western Potato Council

• Representatives split concerning the need for registration, amongst the supporters there was moderate support for change to improve relevancy, responsiveness and time lines.
• Representatives not supporting registration do not support merit principle, tend to include social and political factors and do not support better than.
• Modest agreement to extend the time frame of interim registration.
• For representatives who support registration is should be science based, include trade factors and be oriented to better than.
• Modest agreement that recommending committees provide objective evaluations, that foreign or other province data can be used and all valid data be accepted.
• Moderate to strong support for a cataloging system, registration with or without merit is required for seed certification.
• Overall it was difficult to reach consensus on many issues with possible exception of cataloging.

Recommendations:

1. A two tiered system of registration be adopted which would enable registration without merit, ( catalog system) and registration with merit ( current system.)
2. Cultivars registered without merit would require data needed by CFIA for certification and Health Canada. Registration with merit to follow current system.
3. The cultivars registered by the two systems would be included on two separate lists but could move between lists according to the agency responsible for the variety and the availability of required data.

WS 022 - Pickseed

• Variety registration should remain a separate consideration from the issue of GMOs.
• Ontario forage system is the most user friendly, importance of regional or provincial recommendation diminishing. Farm performance and corporate reputation are key factors.
• In forage crops most of the committees have unrealistic standards, downsizing has resulted in the closing of some stations, many test sites are located in inappropriate regions. Test protocols bear little resemblance to production practices of real producers.
• In the past we have supported the concept of variety registration for forages. However, the present system is failing to provide service to agriculture. It has been emasculated, demoralized and reduced to the role of a bureaucratic obstacle; - nothing more. It simply clouds, delays and obstructs the delivery of improved genetics to producers.

Recommendations:

1. Harmonize forage testing across provinces.
2. Open and restructure committees to be more transparent and balanced.
3. Assure that criteria for supporting recommendation and registration reflect what is practical and needed.
4. Retain a registration system which would serve as a registry of available varieties; adaptable, that do not cause harm.
5. Recommend a change to seed laws that all forage seed sold under the grades of the Seed Act be of a class of pedigreed seed of such registered varieties.

WS 023 - CFIA

• Need to understand that Canada has to accommodate developments in international cooperation in domestic acts and procedures.
• Minimally a catalog of known varieties is needed to know what varieties are in the market and what they contain, many countries require knowledge of composition for approval of shipment - Trade Issue - failure to the needs and interests of trading partners represents a danger for commodity markets.

WS 024 - OOPSCC

• Letter received from E. Cober.
• The Ontario Soybean Industry, as represented by OOPSCC, currently recognizes the value of variety registration for oil-seed soybeans and is confident that the process can be made flexible enough to provide fast access to improved varieties.
• Full registration after one year of yield testing.
• OOPSCC currently supports the maintenance of merit equal to or superior to checks, yield important but other factors affect consideration, OOPSCC is the best qualified organization to determine which traits are of importance to the industry.

WS 025 - Glenn Seed

• Letter expressing dissatisfaction with the survey as constructed.

WS 026 - Glenn Seed

• Letter ( Jan 28, 1999), expressing concern regarding the reinstatement of a registration requirement for corn.

WS 027 - Health Canada

• Letter from N. Hansen -Trip concerning Industrial Hemp - the letter refers to a past commitment of the CFIA to establish cultivar registration for Cannabis.
• Only two keys factors: that the variety is recognized as a true variety and the THC level is below 0.3 %.
• The requirements for industrial hemp could be met with a form of cataloging.
• The criteria for inclusion of varieties on the list of approved cultivars of Cannabis sativa is attached.

WS 028 APERC

• Telephone interview regarding the review process.
• General agreement that cataloging of a new variety should include a variety description, a measure of TGA concentration in comparison to a standard and an assessment of reaction to Bacterial Ring Rot and Potato Wart.
• There is support for the concept considering market use and acceptance in registration.
• Membership was more or less split on preference for a cataloging system rather than a registration system.
• Regional committee decisions need to be respected.

WS 029 - Ontario Pulse Committee

• Letter received from Coloured Bean Sub-committee.
• Details of the proposed changes to the registration and certification system for coloured beans.
• Proposal suggest a modification of current regulatory system would be acceptable for beans - no comments concerning other crops or general issues.

WS 030 - Saskatchewan Seed Growers Association

• Letter regarding Resolution that marketability and other international trade factors must be included in within the context of merit for canola.

WS 031 - V. Walker

• Letter received concerning speciality crops.
• Market place very diverse thus a meaningful merit system has been elusive, the registration process has become rather automatic.
• Not clear how registration system is protecting industry from harm.
• Most important to test varieties and obtain performance data.
• Favour disbanding the Special Crops Sub-committee and changing to an enhanced testing system with cataloging of varieties.

WS 032 Warkentin/Vandenberg

• We need good performance data for cultivars of all crops, best from Provincial Trials. Probably only wheat and possibly barley, canola, and GMOs require registration. All other crops are suitable to cataloging.

WS 033 - Bob Morgan

As past chair of the PRRCG I have three concerns with the operating protocol of this registration recommending committee:

1. voting/decision making process,
2. quality testing and cost recovery,
3. data requirements.

• appended document details these concerns

WS 034 BCCSGA

• Letter expressing a resolution: That the BC Branch of the CSGA appeal to the CFIA to change the current definition of harm to the industry to include the impact on international canola markets.

WS 035 -PRRCG-Barley and Oats Sub-Committee

• Letter describing attempts to obtain consensus on registration need for oats and barley.
• Apparent diversity of opinion eventually voted 21-11 in favor of keeping a registration system.

WS 036 - AgrEvo

• It is the position of AgrEvo that testing for registration purposes be restricted to analysis of fatty acid profiles and glucosinolate levels relative to standards such that candidate lines can be shown to meet the definition of canola.
• Continued evaluation of canola for agronomic characteristics be discontinued for registration but may be used for information purposes, until better systems evolve.
• AgrEvo believes that evaluation of oil and protein levels be discontinued as a requirement for registration.
• It is the opinion of AgrEvo that, for the purposes of defining "harm to the industry, it is critical that any adopted wording be restricted in scope such that harm may only be defined with respect to meeting the canola definition, and nothing else. No special consideration should be given to PNTs, other than that they should have received food, feed and environmental clearance from the respective agencies of the Government of Canada.

WS 037 - Seeds of Diversity Canada

• Letter and documents expressing concern for conservation of genetic resources.
• Free market should dictate what varieties should be grown by a farmer under what growing practices he or she chooses.
• Variety Registration system is restrictive.
• Canada not to follow EU model of variety registration, maintain two parallel systems one for large scale commercial growers and one for small scale farmers.

WS 038 - Stokes Seed

• Letter regarding concerns about the survey.
• Only have registration to accommodate bulk commodity crops where uniformity of quality is an issue.
• Err on side of less government interference.
• Who will pay for cataloging and who will check the validity of all of the names?

WS 039 - Sask Seed Potato Growers Association

• Must continue to operate under a strong variety registration system as it reduces the chances of disputes over purity and trueness to type.
• Merit system based on better than rather than equal to, equal to only brings seed quality down, true for all crops.

WS 040 AAFC - Crops & Livestock - PEI

• Where quality and disease resistance are important to marketing and production then registration is a benefit.
• Prefer better than as a vehicle to promote the steady improvement of varieties.
• Must define harm.
• Must have science based evaluation, accurate data is mandatory regardless of system used.
• Catalog system is excellent for extension information for producers.

WS 041 - NB Ag - Potato and Horticulture Branch

• Regulations need to be changed in order to permit seed lists to include information concerning non-registered varieties as this info is needed for U.S. trade.
• Garden potato varieties are exempt from registration but because of this sale directly to consumers is not possible, this is illogical.
• There needs to be some sort of system in place to provide information to those wanting to grow varieties.
• Need realistic registration fees.
• For potatoes there is no current means of determining "overall merit."
• Base requirement for potato alkaloid measurement and ring rot.

WS 042 - Saskatchewan Canola Development Commission

• Strongly support variety registration system and that high quality standards must be maintained.
• Domestic and international market impact on present and future markets should be assessed before allowing full registration.
• Board supports regulations allowing for contract production of speciality canola varieties providing market impact and potential contamination of the commodity canola crop is assessed.
• To obtain full registration variety must meet criteria of merit including agronomic, disease and quality factors.

Resolution:

The variety registration process have two levels of recommendation to the Variety Registration Office:

1. A specific grain type recommending committee which would consider science based quality, disease resistance, as well as market acceptability.
2. The present variety registration office, which after receiving a recommendation to register from a grain type specific recommending committee, would apply the science based data for consideration for full variety registration.

WS 043 AAFC - NB - R. Tarn

• In potatoes, there are major difficulties in making decisions on the basis of merit or harm.
• Information is need to describe variety performance and to compare varieties.
• At the lowest level such descriptions can be provided as part of a cataloging system.
• For the foreseeable future pressures of market demand will continue to be the determining factor for which variety the industry grows.
• The power of wholesalers to buy on tuber appearance, and the power of processors to contract on the basis of process quality, makes all other characteristics secondary.
• Registration often gives too much weight to yield.

WS 044 Al Slinkard

• Compulsory variety registration should be restricted to those crops that have exacting quality standards and are treated as bulk commodities, e.g. wheat, barley and canola.
• Compulsory registration for smaller acreage crops is becoming difficult to justify in terms of costs - suggest voluntary system.
• Now is not the time to eliminate the system but some crops should be removed: e.g. Faba bean, lentil, Canarygrass, lupin and safflower.

WS 045 Crop Development Centre, U. Sask

• The current system can be completely discarded and replaced with simple cataloging.
• The rapid movement of world commerce toward the use of identity preservation renders the current system obsolete and obstructionist.
• The current system should be dropped for every species that does not have a statutory or legal definition of quality.
• Trade factors should have some consideration.
• Merit: only for demonstrated catastrophic harm to the industry by disease, or large-scale harm to the industry or statutory requirements.
• Continue registration on hard red spring wheat, durum wheat and canola, (barley?).
• Catalog okay, should be voluntary.
• Registration is not needed for seed certification or inclusion in OECD.
• Canada's broad definition of novel traits is out of line with the rest of the world and allows for mischievous and costly application of the current rules.

WS 046 Cargill Ltd

• We believe the present merit based variety registration system is inherently an impediment to Canada's ability to remain competitive on the world market.
• The present system is not driven by the realities of a free marketplace where producers can make varietal selections based on economic yield and processing customers can move quickly to respond to changing consumptive patterns.
• The system is designed to encourage conformity rather than innovation.
• Quality assurance has been a key factor in the pooling system for grain handling. Therefore, industry stakeholders must define the minimum quality criteria that the varieties of each crop type must achieve for unrestricted production.
• A variety registration process is needed as a cataloging process to understand the products that enter the general system of production and handling in Canada. The nature and quality of these products needs to be defined. All crops should be cataloged.
• A variety registration system in Canada is not needed to protect the Canadian producer.
• The registration system should be a catalog system not a merit system. The market place should define value.
• The use of agronomic data for registration should be for information only.
• A catalog system for novel traits should be instituted.

WS 047 Cargill Ltd

• Defining harm only as our domestic consumptive market limits the scope in most crops to less than 35 % of the total production.
• We would define harm as follows: "Harm is the aggregate reduction in present and future global marketability of a product caused by the introduction of a new quality or trait, after taking into consideration any new value created by the introduction of that quality or trait."
• We have the capacity to maintain the identity of products throughout the system without causing harm.

WS 048 Quality Assurance Consulting Inc.

• Letter in support of development of hemp cultivars.

Document prepared by:

The FAAR Biothechnology Group Inc.
S.J. Campbell Investments Ltd.
Goodfellow Agricola Consultants Inc.

March 1999

  Review Document