Consultation - Janv. 2002 - Page HTML

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January 17, 2002

Dear Sir/Madam:

In August 2001, following national consultations, the Canadian Biotechnology Advisory Committee (CBAC) released an Interim Report entitled, Improving the Regulation of Genetically Modified Foods and Other Novel Foods in Canada. The report contains six broad recommendations and 24 specific recommendations that relate to the regulation of Genetically Modified (GM) Foods and other novel foods. At that time, the Committee invited stakeholders and the general public to provide input on the draft recommendations, in order to inform CBAC’s final report to the Government on 31 March, 2002. To this end, the committee set a comment period ending 31 January 2002 to receive input on any aspect of the Interim Report, with special emphasis on the draft recommendations.

I am writing to remind you of this 31 January deadline, and, if you have not already done so, to encourage you to provide CBAC with input.

For your convenience, the committee’s interim recommendations are summarized below. (The full report may be downloaded from the CBAC website.) Comments may be sent directly to our website, or by telephone, mail or fax.

I appreciate your attention to this matter, and look forward to receiving your reply.

Yours sincerely,

Dr. A. Naimark, Chair
Canadian Biotechnology Advisory Committee

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Summary of Interim Recommendations

Good Governance

1. Structure, Organization and Operation of the Federal Food Regulatory System

CBAC recommends that the federal government enhance the structure, organization and operation of the federal food regulatory system for GM and other novel foods. It should adopt a series of measures to further systematize and integrate its different regulatory bodies, and to clarify the separation of governments regulatory role from its promotional activities. We also recommend that an assessment be undertaken to determine whether it would be advantageous to apply this recommendation more widely to the entire Food Safety System.

• Appoint a Chief Food Safety Officer for GM and other novel foods;
• Establish an ADM Committee to oversee GM and other novel food regulation for Canada;
• Assess current practices and clarify roles to ensure a high degree of separation of regulatory functions from other functions;
• Publish Standard Operating Procedures;
• Auditor General should monitor and publicly report on the regulatory bodies.

2. Evaluation of Long-term Health and Environmental Impacts

CBAC recommends that the federal government launch a significant effort related to the monitoring of long-term health and environmental impacts associated with GM and other novel foods.

• Establish a long-term research program to address the hazards and benefits of GM organisms that are part of the human food chain;
• Require effective detection methodologies as part of the application process;
• Develop food consumption data on all foods;
• Establish a deadline for reassessing new information as part of the approval of a new product.

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3. Transparency

CBAC recommends that the federal government become more effective and transparent in communicating all features of the GM and other novel food regulatory system, including the scientific basis for regulatory decisions related to human and environmental health and safety.

• Continue to involve the public in the development of laws, regulations, policies and programs related to the food regulatory system;
• Improve information and communications about the regulatory system;
• Maintain a readily accessible public record of products under review and their status;
• Communicate risk assessments and proposed product decisions in advance of the decision and provide a public comment period;
• Continue policy of non-disclosure of detailed field trial locations at this time. Re-examine pollen drift and determine if current buffer zones are adequate; provide additional information to farmers within 5 km of test sites;
• Release the detailed scientific and technical data re. Health and environmental assessments (explore options for enabling disclosure);
• Publish information on inspection programs and findings related to measures required in relation to safety;
• Publish information on the research program and results re: health and environmental safety of GM food, plants and feed.

4. Information and Informed Choice

CBAC recommends that the government put in place mechanisms to help Canadians make informed choices about the foods they consume. The government should allocate new and additional resources for providing Canadians with a centralized service for accurate and comprehensive information on GM and other novel foods, the food regulatory system, and food standards and regulations. The government should also ensure the development of an approach to labelling foods regarding genetic modification that, combined with the information service, is effective in helping Canadians make informed food choices.

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• Establish a centralized food information service within government;
• Develop reliable information for use by intermediates e.g. health care professionals;
• Develop a labelling system regarding GM content including:
  • set of clear labelling criteria (e.g. via CGSB)
  • statements to be verifiable; verification program needed;
  • implemented voluntary, initially, to test system;
  • seek international harmonization;
  • revisit, if not sufficient to allow choice.

5. Environmental Stewardship

CBAC recommends that the government strengthen its environmental stewardship over GM foods, other novel foods and the organisms from which foods are derived. A comprehensive national research program related to long-term impacts, improved environmental assessments of regulated products and the use of conservative standards of safety as the basis for product approvals is needed.

• Establish a national research program to improve knowledge about long-term effects of GE organisms on ecosystems;
• Establish measures to strengthen product assessments;
• Publish a report on how to integrate a stronger ecosystem perspective in environmental risk assessments;
• Take a precautionary approach to ensure a conservative safety standard for environmental and health concerns related to GM and other novel foods.

6. Other Social and Ethical considerations related to GM Foods

CBAC will continue to consider the health and environmental safety, ethical, social, economic and broader societal considerations that influence people’s acceptability of different kinds of GM foods. Attention will be focussed on developing methods to enable meaningful dialogue on these factors and to better identify the criteria and values at play in people’s evaluation of specific foods.