Letter re. molecular farming in Canada
Coalition For Imputability in Agriculture
Alliance pour Cibler l'Imputabilité en Agriculture
The Honorable Stephen Harper
Prime Minister of Canada
Office of the Prime Minister
80 Wellington Street
Ottawa (Ontario) K1A 0A2
Consultation by the Canadian Food Inspection Agency (CFIA) concerning Assessment Criteria for the Evaluation of the Environmental Safety of Genetically Engineered Plants intended for Commercial Plant Molecular Farming
The Honourable Prime Minister Stephen Harper,
We are appealing to you directly to urge your intervention to stop the attempt by various Federal government departments and / or agencies to authorize the commercial and the environmental release of genetically engineered (GE) plants intended for molecular farming. Should GE plants intended for molecular farming be authorized in Canada, it would inevitably lead to the contamination of the environment, the food chain and would further damage the ability of Canadian farmers to access overseas markets.
According to the Canadian Food Inspection Agency, plant molecular farming:
'is the use of plants in agriculture for the production of novel compounds rather than for the production of food or livestock feed. Potential novel compounds include pharmaceuticals, diagnostic products, vaccines, biologics, industrial chemicals, biodegradable plastics, etc.'
The 86 open field trials on molecular culture conducted in Canada (1994-2005) used the following GE plants: safflower (32), canola (28), tobacco (13), flax (4), white mustard (2), white clover (2), alfalfa (1) etc... . Over 80% of the field trials on molecular farming since 2001 are on plants genetically modified to produce industrial compounds.
Your intervention on this issue would be an opportunity for your government to break away from the previous Liberal government's irresponsible and secretive practices as well as to protect the environment, and the rights of the public, farmers and consumers. We would like to remind you of some of the very worrying conclusions reached by the Auditor General in her 2004 report concerning the Canadian Food Inspection Agency:
· '...the Agency may not be regulating the unconfined release of these plants in a consistent manner.
· Given that the next generation of plants with novel traits could pose new and more complex environmental risks, it is important that the Agency act on our recommendations if it is to be prepared to meet these future challenges.
· We found that there is a risk that undeclared and undetected plants with novel traits could be imported into Canada, and may therefore escape Canada's regulatory system. There is also a risk that unapproved ornamental plants with novel traits could be present in Canada.
· To support its decisions regarding unconfined release, we found deficiencies in standard operating procedures, a lack of complete documentation in the files, and incomplete definition of data quality standards to guide the evaluations. For example we found that the Agency did not have complete documentary evidence and, therefore, was not transparent about how it was evaluating the long-term effects on the environment before authorizing unconfined release of plants with novel traits.''
Currently, the Plant Biosafety Office of the Canadian Food Inspection Agency (CFIA) is holding online public consultations. The CFIA's introduction to these consultations states:
'As a science-based regulator, the CFIA will be seeking technical feedback on the approach it has taken in developing these guidelines, and will not be seeking feedback on socio-economic or ethical issues. These issues are not within the CFIA's mandate to address; however, these issues will be addressed by the appropriate federal government departments.' (our emphasis)
We are extremely disturbed by the approach adopted by the government: consulting first on technical details BEFORE consulting on broader socio-economic or ethical issues and before initiating a public debate on the overall merit of going ahead with GE plants for molecular farming.
As you know, the level of concern and scientific uncertainty regarding the safety of GE plants for food already approved commercially (like corn, soy and canola) is already very high among Canadians. Authorizing GE plants for molecular farming would be taking the risks and controversy to a much more serious and concerning level.
Are Canadians, consumers and farmers willing to accept having their food supply contaminated by industrial and pharmaceutical organisms? Are Canadians willing to take the risk of eating industrial or pharmaceutical products with their cornflakes? Canadians are expecting the government to act in a responsible manner on this issue.
If GE plants for molecular farming are authorized there will be contamination regardless of the measures taken to prevent such contamination. Such contamination has already occured even when alleged monitoring systems have been in place. For example:
1. ProdiGene case in 2001-2002.
'Despite all the alleged safety measures by the US Department of Agriculture (USDA), there has been at least two publicly reported cases of contamination of a food crop (corn) and food (soya) by a GE molecular farming crop in Iowa. The USDA revealed that 500,000 bushels of soya for human consumption had been contaminated by GE corn (harvested in 2001) designed to produce transmissible gastroenterisits virus (TGEV). More
than likely some volunteers from the engineered corn grew in the following season (2002), then pollinated and contaminated the neighbouring corn fields. Despite the fact that the USDA forced the company ProdiGene to pull up and incinerate a 155 acre corn field in September 2002, it is very likely that the volunteers from the GE engineered corn were able to contaminate the surrounding corn and the environment'.
2. 'In the North Dakota State University's Foundation Seedstocks Program non-GE natto soybeans had been contaminated with transgenic material, apparently in Chile during the production of seed. The EPA has also fined Pioneer Hi-Bred and Dow Agro Sciences for violating regulations to assure isolation of the experimental molecular farming crop and prevent pollen drift. Considering that, in 2002, about 300 acres of US cropland was planted with experimental molecular farming crops, the level of reported genetic contamination is quite staggering. However, some promoters of biotech anticipate that 10 % of US corn production will be devoted to molecular farming by 2010. Some 20 US corporations and universities conducted more than 315 open-air field trials in secret locations.'
3. In Quebec (in 2004) and Ontario (in 2002), there has been several officially reported incidents of GE pigs used as bioreactors for molecular farming that were mistakenly sent to the food chain. GE pigs, despite being relatively easy to monitor and control under laboratory conditions are nevertheless mistakenly finding their way into the food chain. Government and industry will not be able to prevent contamination from GE plants for molecular farming once released in the open environment.
In conclusion, we are urging you to act decisively to put good governance and rational process back into policy-making decision on this issue by:
1) Immediately halting the CFIA's 'technical consultations' on the commercial release of GE plants for molecular farming, at least, until a broader and open public debate on the socio-economic and ethical implications has taken place.
2) Re-examining the 2001 Expert Panel Report of the Royal Society of Canada (the highest scientific authority in the country), largely ignored by the previous Liberal government, with a view to effectively implement the 58 recommendations of the report and be used as the credible science-based framework for a broader public debate on agricultural and food biotechnology.
We hope that you will demonstrate leadership in this issue and show Canadians that your government can take decisive measures to protect farmers, consumers, the environment as well as good, independent and credible science.
Éric Darier, Ph.D.
On behalf of the following organisations:
New Brunswick Partners in Agriculture
Mr. Richard B. Fadden, President of the Canadian Food Inspection Agency
The Honorable Chuck Strahl, Minister of Agriculture and Agri-Food
The Honorable Tony Clement, Minister for Heath Canada
The Honorable David Emerson, Minister of International Trade
The Honourable Rona Ambrose, Minister for the Environment
The Honourable Stockwell Day, Minister of Public Safety
The leaders and critiques of the opposition parties
The members of the Agriculture and Environment Committees of the House of Commons
The members of the Agriculture and Forestry & Social Affairs, Science and Technology Committees of the Senate
Ms Sheila Fraser, Auditor General of Canada
Ms. Johanne Gélinas, Commissioner for the Environment and Sustainable Development
The Provincial and Territorial Agricultural and Environmental ministers
Ms. Patricia Demers, President of the Royal Society of Canada
Contact: CFIA / ACIA, c/o Greenpeace, 454 Laurier Est, Montréal (QC) H2J
1E7. Tel. (514) 933-0021, ext. 15; Fax : (514) 933-1017.
CFIA definition available at:
3 Report of the Auditor General (2004) Canadian Food Inspection Agency --
Regulation of Plants with Novel Traits.
4 Welcome to CFIA's online consultation on plant molecular farming
5 Union of Concerned Scientists, Pharmaceutical and Industrial Crops, A Growing Concern Protecting the Food Supply in an Era of Pharmaceutical and Industrial Crops (Washington, 2004)
6 See more details from the Greenpeace's petition no.94 to the Commission for Environment and Sustainable development submitted by Greenpeace in September 2003:
7 Anthony Laos, CEO of ProdiGene quoted in The Nation, 'The Three Mile Island of Biotech' 30 December 2002.
9 CFIA news release 'Joint Action to Control Release of GM Animal Material' 16 February 2004 (http://www.inspection.gc.ca/english/corpaffr/newcom/
2004/20040216e.shtml); 'Three dangerous little pigs', Globe and Mail 20 February 2004; 'Des porcs transgéniques se retrouvent à l'écarrissage' Le Soleil, 18 février 2004 p. A3; 'Trois carcasses de porcs transgéniques dans la moulée de poulets...par erreur' Le Journal de Montréal, 18 février 2004; 'Sécurité alimentaire - Tous les morceaux de l'histoire des trois petits cochons transgéniques sont réunis', Le Devoir 18 février 2004.
In the US, 386 offspring of GE pigs were also sent not disposed safety, see :
10 Elements of Precaution: Recommendations for the Regulation of Food Biotechnology in Canada (2001) http://www.rsc.ca/