Canada's regulatory process for genetically engineered foods and crops has both strengths and weaknesses. Like those in the United States, the European Union, Australia and New Zealand, it can be improved in terms of transparency, information and public participation. In fact, consumers and their representatives are expressing a lack of confidence and deep concerns on this subject, particularly in focus groups.
Among these concerns is the lack of information and tools to understand and master all the issues at stake, and to participate adequately in the regulatory process. Few of the consumers we met had a clear understanding of the Canadian regulatory process and the players involved.
Many of them were also frustrated by their lack of ability to grasp all the issues involved in approving a GMO. So we need to start by giving consumers the tools, the material to think about. While GMOs are increasingly present in fields and on plates, and the need to regulate their use is pressing, the citizen-consumer seems to be voiceless. Yet they must be able to influence decisions, directly or indirectly.
To this end, organizing more public debates and publishing all the studies available to government departments would be possible solutions. We need to believe that the authorities regulating genetically engineered foods and crops are making informed decisions, and that they have all the information they need to justify them. The same must be true for Canadian consumers.
For example, when a notice of application for approval is published, they must be informed of the location of the experimental sites and the municipalities concerned. The final decision document should describe the measures taken to limit harmful effects and to deal with GMO residues, as well as the effects monitoring plan and the emergency action plan.
Generally speaking, any public information and participation process should be conducted from a perspective of transparency and awareness. According to the consumers we met, public participation should also be indirect: in addition to direct consumer involvement through the two 60-day public comment periods and public hearings, citizens would like to be represented by representatives who can devote time and resources to this purpose, such as consumer organizations and environmental associations. They should be systematically informed of the receipt of a request for approval via an electronic mailing list.
Although consumers' main concerns are health and the environment, they are also concerned about the ethical and social-economic impacts of the GMOs being evaluated. So, while the regulatory process must involve a committee of scientific experts, it must also leave room for two additional advisory committees dedicated to these two issues.
The committee's work on socio-economic issues would make it possible to integrate important non-scientific questions linked to the approval of a GM product, such as the usefulness of the GMO for agriculture and society versus its potential dangers, the impacts of the patentability of a seed and a species (intellectual property rights on a seed), the repercussions of the decision on the quality of life of consumers and animals, integrity and knowledge of the food source, impact on agriculture, environmental impact, freedom of choice for consumers, freedom of choice for farmers, impact on the agro-industry, impact on employment, sustainability of communities, impact on trade practices of other countries, respect for or impediment to sustainable development.
In the same way, the work of the ethics advisory committee would make it possible, taking into account the diversity of Canadian cultures and diets, to assess the values and objectives of food and nourishment, the value, role and benefits of agriculture in our society, and the diversity and independence of farmers.
In order to ensure their application, these additional structures and mechanisms will have to be the subject of legal provisions that will be inserted into current procedures through amendments to existing laws. The context seems favourable: a number of laws relating to health and food, including the Food and Drugs Act, are currently being reviewed by Health Canada as part of Legislative Renewal.
Generally speaking, consumers prefer a regulatory approach based on the precautionary principle rather than substantial equivalence. This is in line with their desire to be informed about the presence of GMOs in food, through systematic labelling of their presence.
Our 21 recommendations are intended to be constructive, realistic and applicable. They are in line with the work carried out over several years by Health Canada, the CFIA and Environment Canada, notably through pilot projects, to improve information and public participation in the regulatory process.
