Highlights of Montreal Roundtable on GM Food

April 10, 2001

Prepared by:
The Canadian Biotechnology Advisory Committee (CBAC)

Consultation Participants

Stakeholders

Michel Provencher – Direction du Patrimoine Ecologique
Jurgen Quandt – Aventis Cropscience Canada
Denis Couture – Union des Producteurs Agricoles
Joseph Caron – Action Réseau Consommateur
Daniel Chez – Ministère de l’Agriculture, des Pêcheries et de l’Alimentation
Jeff Wilson – AgCare
Chris Guillon – Warnex Pharma
Claude Lapointe – Novartis Canada
Serge Paquette – Natrel Inc.
Jean Lefebvre – Association des Manufacturiers de Produits Alimentaires du Québec
Michel Caron – Centre de Valorisation des Plantes
Irene Strychar – Faculty of Medecin, University of Montréal
Shane Morris – University Guelph

Technical Resources
Mireille Prud’homme – Health Canada
Louise Laferrière – Canadian Food Inspection Agency (CFIA)

Canadian Biotechnology Advisory Committee
Peter Phillips
Suzanne Hendricks

Canadian Biotechnology Secretariat
Kelly Brannen
Suzanne Fortin

Media Relations
Carl Martin

Facilitation Team
Lyle Makosky
Jean Ogilvie
Elaine Gaudet
Jeff Moffett
Yvon Gauvreau
Sebastien Malherbe

Stakeholder Workshop Objectives

The current series of stakeholder workshops on Genetically Modified (GM) food has two main objectives:

• To enable stakeholders to explain positions and rationale on key issues, propose and respond to promising policy directions, and describe benefits and consequences of preferred directions.
• To enable stakeholders to identify trade-offs in policy options and values or principles that could underpin decision making.

Themes/Issue Areas

In order to effectively address the various themes and issues and identify and discuss potential ways ahead, stakeholders were divided into two break-out groups. One group was invited to focus on Themes A and B. The other focussed on Theme C. (Theme D was not discussed in detail during this workshop but participants were invited to comment on Theme D in plenary in the afternoon.) Theme E was discussed by all participants during a second set of break-out groups in the afternoon. Each discussion group was created using a “stakeholder mix” approach, meaning each group ought to have a mix of the perspectives represented (e.g., NGO/Consumer Group, Government, Industry, Academia and Health Industry), and with consideration to language preferences. (Note: This workshop was conducted bilingually, and the Highlights Document reflects the bilingual nature of the discussions. Once translated, separate English and French versions will be available.)

Theme A: Good Governance

• Transparency
• Opportunities for public involvement

Theme B: Information provision

• Information provision to support informed choice
• Labelling

Theme C: Risk and Benefit Considerations

• Environmental stewardship
• Post-market monitoring for risks and benefits

Theme D: Regulatory System

• Separation and independences of regulatory functions
• Capability and capacity in the regulatory system
• Ensuring safety during research and development activities

Theme E: Social and Ethical Considerations

• Broader social and ethical considerations

For background information on these issues, please refer to the consultation document entitled “Regulation of Genetically Modified Food” available on the CBAC web site at www.cbaccccb. ca. For each of these themes and issues, the text below summarizes the preferences and other views expressed by participants in the session. The information should not be considered to represent consensus positions of the participants.

Theme A - Good Governance

Transparency and opportunities for public involvement

Participants noted that it is necessary to be open and transparent about “our sound regulatory system”, and that GM foods be considered within the context of the broader food system. The group recommended that there be clear communication using an educational approach.

Development of a communication plan

A first way forward is to develop a long-term communication strategy to enable the Canadian public to have a rich and balanced understanding of GMF processes. We have to recognize that there are a wide variety of publics needing different levels and types of information. Communication is required about the regulatory process in general – what the process is for, how it works, what the benefits are, how it is safely maintained, etc. Many different channels are required; we cannot assume that because information is on the web, it is accessible, or that the process is transparent. The strategy requires a much more pro-active educational “blitz” approach, engaging the public at the local level – for example through women’s groups, church groups, and working with professionals such as dieticians to take the information out to their constituencies. Government tends to think in terms of national campaigns, but that is not sufficient for the level of learning required. A second important role that government could play would be as a source of credible information that public leaders could go to for information that could then, in turn, be disseminated at the local level.

A critical element of the communication plan is the appointment of a “figurehead” or champion among the government stakeholders whose key responsibility is communication to the public about what the government is doing. While it is clear that the regulatory arm of government cannot take an advocacy role for any specific aspect of biotech, it is legitimate that it take an advocacy role vis-à-vis its own processes. Defending (with passion and eloquence) the regulatory system and the decisions it has made is not the same as defending products, and a more active role on the former would counteract some of the misinformation. This role could be played by someone like the head of the CFIA. Such a champion would be informed by many different sources, but would lead the government “voice” to the public, ensuring a co-ordinated message from the many different departments and agencies with responsibility in this area.

A final consideration with regard to a government communication plan is to look carefully at the success of lobbyists on this front. They work at the grass roots, local level; they build a strong foundation of understanding and they have excellent spokespeople capable of attracting public support. Messages need to be well founded on facts, but they need to be delivered taking into account human feelings and perceptions, because this is how attitudes are formed. The basic rule is “never leave the podium empty”. Government could be well served using a similar approach, with its own messages about how the regulatory system works to ensure safety.

Communication of Product Decisions

As a second way forward the group felt that it was critical to publish information about product decisions immediately on approval of products, and that doing so would demonstrate government accountability and transparency. Although concerns were expressed around the real capacity to get this information posted in a timely way, it was felt that making the decision process available would demonstrate the objectivity of the process.

The group also felt that the public should have access to information on decisions that are under consideration, what procedures/process will be applied to the particular product, and where the product is in the process at a given time. (Without seeing the front end of the process, the final decision seems to come out of nowhere.) This would be an effective way to demonstrate transparency, but the need to protect proprietary information is also clearly important. Therefore, the group suggested that the information disclosed would be of a general nature (e.g. BT corn) and not include specifics such as the name of the proponent, the location of field trials, the gene construct, etc. The group recognized that as we get farther down the road with GM foods, products themselves will become more specialized so it may become difficult to reveal only general information. For this reason, it would be advisable to allow for an exemption to the disclosure under specific circumstances.

As for public involvement the group felt a need to develop a process for public input, say 60 days, prior to the final decision. This would demonstrate transparency and help to shift public perception that government is pro-industry.

There is a concern that limiting the access to information just for GM foods would be discriminatory, and should apply to all novel foods.

Other issues

There are many different and often conflicting messages circulating from different government departments with respect to biotechnology.

Theme B - Information Provision

Information provision

An issue raised with regard to the provision of information to the public is that, according to participants, research has shown that public confidence in information sources is lowest for government, followed by science and industry. Information from pressure groups was seen as the most credible.

A way forward with regard to accessing “a comprehensive and authoritative source of information” is to recognize that there are many diverse and excellent sources out there. Examples include the Council for Biotechnology Information, the University of Nebraska world wide information source for biotechnology products, and the Canadian Food Inspection Agency data base on information on Canadian products. Health Canada could play a key role in orienting people with questions related to biotechnology to an appropriate source of information. Health Canada could also play a key role in getting information out to the public at a number of levels – to public health professionals who will forward it to their contacts with the public, as well as responding to basic questions from members of the general public.

Labelling

There was a sense that labelling is inevitable given the strong consumer demand to do so, and the likely unwillingness on the part of public figures to resist this demand. There are, however, many concerns. Firstly, it is unfair that GM foods should be singled out for any kind of standard labelling practice just because they are coming on stream at this time. Many “grandfathered” foods that are in the system now may contain more dangers to the consumer (e.g. related to pesticide use), so providing real consumer choice would require the development of a labelling system that covers all food.

The key dilemma with labelling is that if we label negatively (“GM-free food”) this acts as a warning to consumers and increases the stigma that GM foods have. If we label positively (“this is a GM food”) the likely response of consumers, at least in the short-term, will be to avoid purchasing those foods. This would create economic stress on the part of the producers. One suggestion made is to focus on the safety process rather than the production process, by labelling “this product has passed the strict safety standards of the Canadian regulatory process”.

An advantage of a voluntary process is that it would give Canada some breathing space to wait and see how the mandatory processes undertaken by other countries work out. While the group did not have a clear path forward to recommend, they acknowledged the ongoing work of the CGSB which is struggling with this question.

The underlying values for themes A and B which could assist in developing policy in these areas are as follows:

• Risk-benefit – genetically modified organisms (GMOs) have the ability to solve many agricultural and environmental problems.
• Facts - 4 areas: socio-economic issues, environmental issues, health issues, and ethical issues. Facts need to be applied to these issues; we need to beware of misinformation. “Give us the straight goods”.
• Honesty – openness, accountability, and transparency.
• Business survival – the lowest price is the bottom line. A government position aligned with a market driven economy.
• Caution – safety issues, specifically health, must come first. It is important to establish and disseminate safety information, with the best information available today.
• Accountability/Leadership – responsible authorities are needed to take full responsibility for information disseminated to the public, and product approval decisions.
• Holistic – GM organisms and GM foods need to be considered within the broader food system.
• Knowledge – knowledge is the value that ties all values together. Knowledge is needed in order to deal with all other issues.

Theme C - Risk and Benefit Considerations

This section covers two themes, as well as real or perceived related risks.

• Environmental stewardship
• Post-market monitoring for risks and benefits

The process to be followed regarding these themes calls for a number of activities. The coming paragraphs give an idea of the scenario or the object of this group discussion, that is the risks and advantages pertaining to each activity.

Comments on issues

• The precautionary principle must be a fundamental principle and it must be applied during the analysis process.
• One should be prudent when is it said that "superior skills" are needed. Some words have a way of creating unwanted impressions.
• The solution regarding the problem of pesticides has been resolved as far as genetically modified organisms (GMOs) are concerned, this in the wake of years of research. Why bring this up again? The information regarding the efficiency of GMOs is not clear yet. We need a scientific consensus to reassure the public as to the healthiness of such products.

Environmental stewardship

There is a need for more basic research. But what type of research? Decisions must be made as to the type of research to be conducted by the private sector and that to be made by the public sector. We must also consider our ability to manage the stewardship. Our funds have shrunk and the internal resources of the government have been drastically diminished. Who should assume the costs?

A "life-cycle" process must include all facets of the cycle and implies tighter management. Who is going to defray this process? Who will be in charge of what? This management could be entrusted to industry, but the producers will not accept to shoulder the full cost. Before getting involved in a nebulous concept, a greater understanding of details is warranted.

Generally speaking, it is not enough to accept principles applied at the international level. One must also forge ahead. The principles of Cathagena and of the Codex Alimentarius would be a good starting point.

Citizens need to be reassured through a comprehensive process, but consumers are not in a position to assume the role of the evaluators. Proper assessment are indicated in order to make sure that the best possible information is at hand and that appropriate decisions are made.

Research and development is a key issue. We need to have the required scientific capabilities to properly underpin authorisation and monitoring. The public needs to be reassured and the various levels of government must have their say. Furthermore, research must not be skewed. Let us not forget that the viewpoint of a researcher impacts on research results. If the "invoice" is passed on to the farmer, there will be an impediment to the marketing of products. One must also take into consideration the research and development of alternative products. Have the costs and benefits of embracing GMOs been properly determined?

Post market monitoring for risks and benefits

There are differences between detecting GMOs and tracking them. But this question is related to that of labelling. It is important to be able to detect and follow GMOs in order to assure food safety. It is not clear that we possess the required technology in these fields, particularly regarding by-products.

Some countries demand that GMOs be identified and labelled. But at what level (e.g. % in a product) are we going to demand that a product be identified as a GMO?

Further, these processes are important for reasons of accountability. For the public to trust the industry, businesses must be able to back up those products for which they are responsible.

Statistics (for instance, consumption) are useful in terms of market analysis and marketing. Could we not use statistics produced by other countries?

The Canadian Food Inspection Agency systematically keeps tabs on certain products (for instance, Bt corn), while other products are not verified systematically but trough an ad hoc procedure.

Underlying values that could help develop policies in this field:

• Transparency - to ensure that the decision-making process is well understood by the public and that it can be monitored.
• Responsibility - existence of public authorities that can ensure the quality of products and of information.
• Prudence - stewardship regarding the environment and public health.
• Participation - to ensure that social choices reflect the values held by citizens, through real participation and debate.

Other values raised

• Positive and negative impacts on biodiversity and health - to ensure that the environment is protected, while protecting the health of citizens.
• Independence - keeping the role of stakeholders at arms length so as to avoid conflicts of interest.

Theme D - Regulatory System

Theme D was not discussed during the Montreal workshop.

Theme E - Social and Ethical Issues

Ethical and social matters

• A need exists regarding the hearing of groups or individuals who hold divergent points of view and who consider that GM foods are intrinsically bad.
• The forces at play are uneven. The discussion is centred on private interests.
• Globalisation is an important issue. Foods are transported across borders.
• It is important that one adopt an approach that gives individuals a choice and not impose a single track.
• Production intensification leads to a focus on a limited number of vulnerable species. What can one do to ensure that the public's concern about the environment is reflected in the regulatory process.
• Possibility of drawing inspiration from the European model - an ethics committee (biovigilance committee) made up of resource people qualified to make an ethical analysis.
  • A committee could also be mandated to deal with socio-economic matters in general (for instance, ethics, socio-economics); in effect a watchdog role.
  • The committee must be separate from the science-oriented evaluation process.
  • This filter must not become a barrier.
  • The parties involved and the stakeholders must be represented. A much larger representation is called for to air the very different points of view that exist.
  • Would this committee have a consulting or a decision-making role?
• Such bodies could slow down the marketing of products in Canada. Solutions must be pragmatic and there must be tools and resources to back them up.
• A number of these aspects (for instance, environmental and health issues) are already part of the current evaluation process.
• Encourage industry to develop key ethics policies as it has done regarding the environment and ensure proper monitoring of these mechanisms by the government.

Acceptability/Non-acceptability spectrum framework

Challenges

• Acceptability must be founded on criteria. We cannot circumvent the principles.
• The concept is not new. It is already used elsewhere.
• Can the current mechanism be improved so as to avoid setting up more committees.
• How will a consensus be arrived at? If the ethics issue is taken into account in its broadest sense, the situation will become even more difficult.

Advantages

• An option: broaden the CBAC mandate so as to include economic and commercial evaluations, as well as long-term impacts.

Summary of key values

Participants discussed values and principles related to governance and the regulatory system. The following values were raised and most widely supported:

Values for shaping the regulatory system

Top five:

• Risk-benefit
• Honesty
• Accountability / Leadership
• Knowledge
• Prudence

Other values discussed in groups and supported by some participants, but not selected as most important include:

• Benevolence
• Autonomy
• Justice

Values for shaping policy choices

Top five:

• Responsibility
• Transparency
• Participation
• Knowledge
• Prudence

Other values discussed in groups and supported by some participants, but not selected as most important include:

• Justice
• Autonomy
• Benevolence

Closing ideas and guidance to CBAC

This section outlines the suggestions made by participants as final thoughts/advice for future consideration by CBAC. These should not be considered to be consensus views of the participants.

• CBAC must ensure that NGOs are included early in the process. This is what will guarantee their participation. They must be given a chance to voice their opinions while there is still time to “make a difference”.
• CBAC must exercise caution when making decisions. It must ensure that all opinions are taken into account. This means CBAC will have to create its own decision-making path.
• Financial assistance to participating groups should be seriously considered to help them prepare for public consultations. Many NGOs cannot afford to participate in the consultation sessions due to lack of funds. Many of these groups are highly knowledgeable in the area of GMOs, and their participation would be of great benefit to CBAC.
• It is equally important for the views of international stakeholders to be well articulated. CBAC could act as a jury when government is considering foreign product approval.
• The final report must not be overly technical or complex so that it can be communicated clearly to all audiences.
• The regulatory system has been rattled due to the recent Royal Society report. CBAC must be capable of fielding all questions regarding this report, when consultations resume in the fall. CBAC should be prepared to answer questions on the following topics:
  • Follow-up on the Royal Society report
  • Recent report of the office of the Auditor General
  • Phase II of this consultation
• The consultation sessions need a broader base of input. The debate would have been made more inclusive if more civil society representatives and NGOs had participated. The issue of GMOs will require input from the public and stakeholders in round-table discussions. CBAC must ensure it continues to try to involve all stakeholder groups, but should not be paralyzed by abstention. People are not in a position to criticize the CBAC process if they are not willing to participate in making it better.
• Pursue an educational campaign focused on public information, with a balanced treatment of risks and benefits – one that incorporates a simplified description (with examples) of the regulatory process. If the GMO issue is to be resolved, initially, government must inform the public effectively. Information on GMOs exists, yet is not accessible to the average person seeking basic information.
• The impact of the media on people’s understanding and beliefs around the GMO issue should be examined. Equipped with this analysis, a proactive strategy should be developed to incorporate the media in the communications campaign with the public.

Please note that similar reports from each of the five CBAC stakeholder workshops on The Regulation of GM Foods, conducted across Canada from April 2nd to April 10th 2001, will be posted on the CBAC web site. As well, results from all five workshops will be integrated into a single roll-up report that will also be available on the CBAC web site by the end of the month.

Please visit the CBAC web site at www.cbac-cccb.ca or call the CBAC toll-free number at 1-866-748-2222 for additional information or documentation related to this or other CBAC projects.