For three months last year, Health Canada invited feedback on new rules for “Novel Food Regulations” with a specific focus on plant breeding. Since 2006, the insertion of foreign DNA has triggered a Health Canada safety assessment of genetically modified plants and foods. As new genetic engineering techniques like CRISPR have been developed, plant breeders have the ability to make new gene modifications without the addition of foreign DNA. Under Health Canada’s recently adopted new rules, there will be no government oversight on foods and seeds genetically modified using these new gene editing techniques, allowing these genetically modified plants and foods into our food system and environment without any safety assessment. In the place of government oversight and regulation, Health Canada has enacted a “voluntary transparency initiative” inviting plant breeders to self-regulate the risks of their genetic products. In effect, genetically modified plants, foods and seeds have been deregulated.
Canadians can and should expect better from Health Canada as deregulating the genetic modification of food, plants and seeds carries a variety of risks including health risk, economic risk, food safety risk, and environmental safety risk. All Canadians – including our children and future generations – eat the foods produced in Canada. As the saying goes, we are what we eat. Dr. Sylvain Charlebois of Dalhousie University and a regular commentator on the food issues in Canada has noted that up to 75 percent of food products currently in Canadian grocery stores can contain genetically-modified ingredients without the labels making any mention of it (Hamilton Spectator, Jan. 11, 2022). Did you know that if you eat commercial salmon, you may have eaten genetically-modified salmon? Since last year, Aquabounty Technologies has operated an on-land fishery in PEI for genetically modified salmon. The salmon is available for sale in Canada, but Health Canada does not require the company to label it as genetically modified, meaning there is no way for salmon consumers to choose whether to eat it or not. (CBC, Oct. 14, 2021). How can we understand the health benefit or risk of our foods, plant or animal, if we don’t even know which ones have been altered and how they have been altered?
The export business
A separate concern is that Canada is a major international food exporter, and deregulatory changes to our food safety and security put our exports at risk. Remember the crisis caused when commercially useless animal products were repurposed to enrich cattle feed, leading to an outbreak of mad cow disease in Canada that shut down international markets for Canadian cattle? Given that many of our international trading partners in Europe, Australia and New Zealand already regulate genetic changes to plants and animals, do we think that deregulating the genetic modification of our food crops, plants and seeds and then selling those products internationally won’t cause a problem if deregulation misses a significant safety issue? Any perception in international markets that Canada is not serious about regulating potentially risky agricultural products puts the livelihoods of Canadian farming families at risk.
Once a novel plant or food is released into the environment, the spread of novel genes into new areas and new populations usually cannot be controlled. In some cases, novel genes have been found in wild populations nowhere near the original release site. For example, genetically modified genes from a domestic cotton plant grown in Mexico’s Yucatan peninsula escaped and travelled some 2,000 km before these novel genes were found in wild cotton plants – a transfer previously thought to be impossible (Emiliano Rodríguez Mega, Science News, February 16, 2021; see also Canadian Friends Service Committee biotech update, 2021). By choosing to deregulate the development and release of genetically modified plants, crops and seeds, the Canadian government risks introducing irreversible changes into the environment of all parts of Canada from coast to coast to coast.
Finally, although new gene editing techniques such as CRISPR are considered more accurate than earlier methods for developing GMOs, unexpected genetic changes still occur, which can be on-target, off-target, or completely unexpected (see, for example, Fu et al. in Nature Biotechnology, 2013; TestBiotech and CBAN, “Unintended effects caused by techniques of new genetic engineering create a new quality of hazards and risks,” March 2022). It is the potential for these still new technologies to cause significant unintended genetic changes with unknowable health, food safety and environmental safety risks that makes Health Canada’s current plan to deregulate the monitoring and safety assessments of genetically-modified plants, foods and seeds so concerning. As with all new technologies, the precautionary principle points us to use these new gene editing techniques with care and transparency.
Still time to speak up
The Faith and Life Sciences Reference Group of the Canadian Council of Churches believes that the development of biotechnology is not an end to be pursued for its own sake, but an instrument to be used for achieving greater goods including human health, social equity, environmental justice and the protection of biodiversity. Thus, we have been following the emergence of genetically modified organisms for the past 30 years. In 2002, for example, we were granted status alongside other intervenors to argue against the patenting of higher life forms in Canada, namely the Harvard onco-mouse. The Supreme Court agreed that the transgenic mouse, a mammal, should not be patented. More recently, we voiced our concerns about Health Canada’s new regulations by writing the Food Directorate and the Ministers of Health and Agriculture. We and other concerned groups received no substantive response before the new guidelines were enacted, but there is still time for Canadians to speak up and advocate for changes to these new rules.
The Faith and Life Science Reference Group of the Canadian Council of Churches is asking the government to do its regulatory duty and keep Health Canada and the Canadian Food Inspection Agency responsible for independently assessing the safety of all genetically engineered foods and plants in Canada. If you share our concerns about Health Canada’s effectively deregulating genetically modified plants and seeds, we urge you to call or write your Member of Parliament, the Minister of Health Jean-Yves Duclos, and the Minister of Agriculture and Agri-Foods Marie-Claude Bibeau. Encourage your friends and neighbours to do likewise. If you are a person of faith, ask your faith community to write to the Minister of Health or the Minister of Agriculture. If we speak together, we can tell our government loud and clear that we value a safe and secure food system for the health and well-being of all Canadians and the world.
what is the ccc?
The Canadian Council of Churches (CCC) is a broad and inclusive ecumenical body, now representing 26 member churches including Anglican; Eastern and Roman Catholic; Evangelical; Free Church; Eastern and Oriental Orthodox; and Historic Protestant traditions. These member churches represent 13,500 worshiping communities and comprise 85 percent of the Christians in Canada. The Canadian Council of Churches was founded in 1944.
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