Proposed Domestic Policy on the Management of Low-Level Presence of Genetically Modified
Crops in Imports and its Associated Implementation Framework
CHFA Response (in bold) to Online Questionnaire
Submitted January 16, 2013
A: Information about you
Question 1: Are the views expressed your own, that of a corporation, association or other?
own
a corporation
an association
other, please specify
Question 2: Please provide the name of the association/business you represent, as well as the
association/business coordinates.
Canadian Health Food Association
235 Yorkland Blvd., Suite 302
Toronto, ON
M2J 4Y8
Question 3: What is your primary business or professional focus? Please select all that apply.
agricultural producer
retailer/grocer
seed company
restaurant/food service
crop marketer or handler
farm organization
miller
industry association
crusher
consumer association
grain exporter
organic sector
processed food/beverage exporter
academia
grain/food transportation
federal government
food/beverage manufacturer
provincial government
feed manufacturer
municipal government
ingredient manufacturer
general public
Other, please specify (for example: Corporation X): __________________________
Question 4: Where do you live? If representing a corporation or association, where are your
Canadian headquarters?
British Columbia
Alberta
Saskatchewan
Manitoba
Ontario
Quebec
New Brunswick
Nova Scotia
Prince Edward Island
Newfoundland and Labrador
Northwest Territories
Nunavut
Yukon
Question 5: If applicable, where do you do business? (Check all that apply)
British Columbia
Alberta
Saskatchewan
Manitoba
Ontario
Quebec
New Brunswick
Nova Scotia
Prince Edward Island
Newfoundland and Labrador
Northwest Territories
Nunavut
Yukon
United States of America
Europe
Asia
Latin America
Australia
Africa
Other, please specify
Question 6: Identification of respondents
Would it be acceptable for us to contact you/your organization to follow-up on the responses
provided, if required?
Yes/No
B: Questions for discussion
Objective
1. Does the proposed LLP Policy and Implementation Framework provide sufficient transparency
and predictability on how the Government of Canada will manage occurrences of LLP:
in imported grain? If not, please explain why.
Yes/No
As a growing number of Canadians are electing to use GMO-free products, the proposed LLP
Policy and Implementation Framework should address the need for increased transparency of
organic safeguards.
in other imported food and feed products? If not, please explain why.
Yes/No
CHFA members are adamant that the producers, processors and sellers of organic products in
conjunction with consumers of these products, be protected from GMO contamination,
whether it is intentional or unintentional. Stakeholders in this sector expect organic products
to be free of contamination and deserve to have access to an environment where they can
grow, produce, sell and consume products that are untainted. CHFA is speaking on behalf of
those individuals within the organic sector who support the rights of consumers to have
access to safe and uncontaminated organic foods.
Organic producers strive to ensure their crops are free of any contamination and their
consumers have the right to know that the food they purchase is free of any form of
contamination. Unfortunately, the organic industry has not been afforded proper
consideration in the development in this proposed policy. These concerns have been welldocumented in the ÉcoRessources Consultants report entitled “Challenges and approaches in
mitigating risks associated with the adventitious presence of GM products in organic crop
production in Canada”, as copyrighted by Agriculture and Agri-Food Canada. Contamination,
even at a low level, dishonors the clean organic standards that many companies strive to
maintain.
Scope of the Policy
2. Is the scope of the proposed Policy appropriate?
Yes/No
Action Level Questions
An objective of the Action Level is to address potential trace amounts of LLP resulting from dust
or other sources. For the purpose of the proposed Policy and Framework, an Action Level of 0.1%
or 0.2% is proposed and will apply uniformly to LLP in grain of all crop types. Provided that a GM
crop has been approved for 100% food consumption in at least one country using the Codex
Food Safety Assessment Guideline, when LLP of that GM crop is detected at concentrations
below the Action Level, no enforcement action would be triggered because the LLP is unlikely to
pose safety risks below the Action Level.
3. Do you support the inclusion of a common low Action Level for all crops to manage potential
trace amounts (e.g. dust) of LLP in imported grain?
Yes/No
Please explain your answer with examples, as appropriate.
The fear among the 1000+ companies we represent is that the proposed low margin of
acceptance for LLP in imported grain will grow larger over time, therefore discrediting the
purity and transparency of the organic industry for consumers.
As our interest is to ensure that Canadian consumers continue to have access to
uncontaminated natural health and organic products, any acceptance for LLP is strongly
discouraged.
4. What would be the positive or negative impact for you, your business, or the stakeholders you
represent if an Action Level is established?
As stated in our previous response to Low Level Presence Policy Approaches in November
2011, “CHFA recommends that the government apply the most restrictive approach possible
to managing LLPs” as our members continue not to support any level of contamination as
acceptable.
Furthermore, stakeholders who participated in the Redfern Research report entitled “Policy
Approaches for Managing Low Level Presence of Genetically Modified Crops Imported into
Canada - Report on Stakeholder Consultation”; view the proposed policy as a “risk to the
economic health of Canada’s organic sector”. In line with this perspective, our members seek
increased rigour in the current policy regarding LLP.
5. Does an Action Level of 0.1% meet the objectives described in the proposed Policy? Please
explain your answer with examples, as appropriate.
Yes/No
Please see the response provided for questions 3 and 4.
6. Would an Action Level of 0.2% meet or better meet the objectives described in the proposed
Policy? Please explain your answer with examples, as appropriate.
Yes/No
Please see the response provided for questions 3 and 4.
Threshold Level Questions
Crop-specific Threshold Levels will be set for individual crop types and will be higher than the
Action Level. The Threshold Levels will be set to reflect achievable levels for unintentional
presence based on best management practices for each crop type while respecting the realities
of the systems in place that support the commercial trade of agricultural commodities around
the world. These Threshold Levels will only be applicable for an individual GM crop after a
Canadian LLP risk assessment has determined that the presence of the GM crop at the proposed
level is unlikely to pose a food, feed or environmental safety risk.
7. Do you support the inclusion of a Threshold Level, where a LLP Risk Assessment has been
conducted by Canadian regulators, to manage higher trace amounts of LLP in imports?
Yes/No
CHFA supports a zero tolerance approach to LLP as organic standards do not permit any GMO
material. The only acceptable threshold level to ensure consumers are fully aware of the
products they consume is zero.
8. What would be the positive or negative impacts for you, your business, or the stakeholders
you represent if Threshold Level(s) are established?
Please see the response provided for question 7.
9. Do you support having crop specific Threshold Levels, as described in the proposed Policy?
Yes/No
It is premature to discuss the relevance of threshold levels until a policy respecting organic
production can be implemented.
10. Do you agree with using the biology of the crop (e.g. rate of outcrossing) and the grain
handling practices as considerations in establishing the Threshold Levels? Please explain your
answer with examples, as appropriate.
Yes/No
It is premature to discuss the relevance of threshold levels until a policy respecting organic
production can be implemented.
11. Should additional factors be considered when establishing the Threshold Levels? If yes, what
other factors should be considered and why?
Yes/No
The proposed policy neglects the impact on organic farmers as it becomes an increasingly
difficult challenge for them to produce organic crops and livestock for the consumer.
With dwindling availability of certain organic crops, we suggest that the Government of
Canada consider the current availability of the organic crop in Canada so as not to extinct this
alternative.
12. The proposed Expert Advisory Committee(s) will be made up of a diverse representation of
stakeholders who will use their knowledge and background to set appropriate LLP Threshold
Levels. Do you have any views on who should be members of these committees?
It is imperative that expert organic representatives be included in the Expert Advisory
Committee. The following individuals should be considered:
Dr. Andy Hammermeister, Director of the Organic Agriculture Centre of Canada
Dr. Ralph Martin, Loblaw Chair in Sustainable Food Production, University of Guelph
Dr. Derek Lynch, Canada Research Chair in Organic Agriculture
General Questions
13. Would the importation of LLP of unauthorized GM crops have an impact on Canadian
exports and/or re-exports, such as processed food and feed products? If yes, please explain your
answer with examples, and give details on the likelihood of occurrence.
Yes/No
In the report entitled “Policy Approaches for Managing Low Level Presence of Genetically
Modified Crops Imported into Canada - Report on Stakeholder Consultation”, produced by
Redfern Research, Table D shows that more than half of the stakeholders that provided an
opinion agreed that replacing current policy with new LLP policies may hurt or endanger
Canadian agriculture export sector. CHFA supports this position as it is likely that organic
exports would be placed at risk due to GMO-contamination concerns.
14. What impact would the proposed monitoring and enforcement strategy have on your import
activities? (if applicable)
In the report entitled “Policy Approaches for Managing Low Level Presence of Genetically
Modified Crops Imported into Canada - Report on Stakeholder Consultation”, produced by
Redfern Research, stakeholders expressed “relatively few concerns about the regulation of
Low Level Presence as it is currently conducted in Canada. They note that this aspect of the
Canadian regulatory system has not created any significant barriers to imports or trade”.
In addition to the expressed satisfaction with the current policy, permitting any level of
contamination into our food system allows the opportunity of GMO material to escape into
the environment and taint or eliminate organically produced product.
With respect to monitoring and enforcement activities, CHFA and its members encourage the
Government of Canada to adopt the 10 recommendations ÉcoRessources Consultants in their
report entitled “Challenges and approaches in mitigating risks associated with the
adventitious presence of GM products in organic crop production in Canada”.
15. Should Canada be the first country to implement an LLP policy like the one being proposed
here? Please explain your answer, considering the impacts such a decision could have on your
sector or area of interest?
Yes/No
Given the previously discussed organic import and export challenges that will result from this
proposed policy, Canada should NOT lead this endeavor internationally as it is likely to put
Canadian producers, importers, and exporters at a disadvantage. As equivalence agreements
are in place with Canada, the United States, and the European Union, these nations should
instead work collaboratively in order to promote a consistent approach.
The proposed LLP policy is not in the best economic or sustainable interest for producers,
processors, sellers or consumers.
16. Please provide any additional viewpoints or considerations concerning Canada's proposed
LLP Policy and Framework. Please explain your answer with examples, as appropriate.
CHFA is an industry association representing over 1000 companies nationwide that are
involved in the manufacture and sale of natural health and organic products. As such, our
interest is to ensure that Canadian consumers continue to have access to uncontaminated
natural health and organic products. In August 2010, Agriculture and Agri-Food Canada
(AAFC) released a report entitled The Canadian Organic Sector, Trade Data and Retail Sales
(2008). Findings from the report highlighted that the value of organic food products sold in
Canada through all retail channels was estimated at $2 billion in 2008. This represents a 66%
growth since 2006 and represents approximately 2.5% of total food sales at the retail level.
This is significant growth and is a great achievement for the organic sector. All indications are
that Canadian consumers will continue to expect uninterrupted access to organic products
without fear of contamination by genetically modified materials. CHFA’s goal is to ensure that
the growth of this in-demand sector continues.