Low Level Presence
Legalizing GM Food Contamination
In 2011, the Canadian government started consultations on a proposal to allow 0.2% or higher of our food to be contaminated with genetically modified (GM) foods that have not been approved by Health Canada as for safe human consumption. This will allow GM foods to contaminate imports to Canada even if they have not yet been approved as safe by Canadian regulators, but have been approved as safe in at least one other country that is deemed trustworthy by Health Canada. The federal government calls this “Low Level Presence” or LLP and argues that this “low level” of contamination from unapproved GM foods is not harmful.
2018: Canada has developed a policy model on “Managing Low Level Presence of Genetically Modified Crops in Imported Grain, Food and Feed” in order “to stimulate domestic and international discussions”. This policy model appears to replace earlier (2011-2015) policy proposals for implementation in Canada.
April 2018 – CBAN Article: Setting up a Spiral of GMO Contamination: Legalizing “Low-Level Presence” of Unapproved GMOs
Published in British Colombia Organic Grower, Volume 21, Issue 2. Spring 2018.
What is “Low Level Presence”? “Low Level Presence” (LLP) is the proposal to allow our food to be contaminated by a percent of genetically engineered foods that have not been approved for safe eating by Health Canada, but that have been approved for human consumption in at least one other country. Health Canada would create a list of trusted government regulatory systems and accept LLP contamination originating from those countries. LLP would change Canada’s existing “zero-tolerance” policy for such contamination in imports to Canada. LLP is different from “adventitious presence” which is the industry term for contamination of our food by experimental GM crops and animals that have not been approved anywhere in the world.
Which other countries have LLP? Canada would be the first country in the world to allow LLP. Currently, every country has “zero-tolerance” for contamination from GM foods that they have not approved as safe. In July 2011, the European Union allowed up to 0.1 percent of animal feed could be contaminated by GM grains that are not approved in the EU.
What is the Canadian government’s rationale for LLP? LLP is a trade policy. The grain industry operating in Canada wants other countries to establish LLP so that they do not reject exports from Canada that are contaminated by GM foods they have not yet approved: “In the industry’s view, Canada could serve as a model to influence countries with trade-restrictive LLP policies by adopting alternative domestic LLP policy approaches.” (Agriculture Canada presentation on LLP) “If trace amounts of such unapproved genetically modified product are found in import shipments, in a country where the genetically modified crop is not approved, often times these imports will be rejected…The unpredictability of rejection of such imports is a growing concern, given the potential economic impacts low-level presence will have on global trade.” (FAQp5)
- CBAN Press Release – July 7, 2015: Canada Close to Allowing Unapproved GM Food Contamination in Imports
- CBAN’s comments: “Low Level Presence” (LLP) policy proposal, 2015
Government documents on the earlier policy proposal:
LLP is unacceptable and unjustifiable from a health and safety point of view:
- LLP is trade policy at the expense of public health protection. The goal of LLP is to accept GM contamination in imports to Canada, by removing the restriction of Canada’s own safety assessment in certain cases.
- LLP overthrows Canada’s “science-based” regulation of GMOs because LLP assumes that certain GM foods are safe before our own government regulators assess safety.
- LLP creates exceptions to Health Canada’s safety assessment of GM foods (already highly criticized as inadequate), whereby government regulators review scientific data to determine human health safety. The introduction of LLP will further undermine our international reputation for food safety as well as the confidence of Canadians in our food system.
- The LLP policy accepts that GM contamination will keep happening and opens our doors to such contamination.
- Case Study: Agriculture Canada to remove Health Canada from safety assessment of some GM foods, by Lucy Sharratt, CBAN in The Harper Record: 2008-2015, Canadian Centre for Policy Alternatives
- Civil society statement for the FAO Technical Consultation on Low Levels of Genetically Modified (GM) Crops in International Food and Feed Trade, March 2014
- “Canada Wants the World to Relax its GMO Standards” Ashley Renders, VICE Magazine, February 6, 2014
- CBAN Testimony to the House of Commons Agriculture Committee, March 7, 2013
- Press Release, March 7, 2013: Changes to GM Food Safety Regulation Debated: Proposal for “Low Level Presence” would remove Health Canada from safety evaluation of some GM foods
- CBAN comments on LLP proposal, Agriculture Canada online consultation, January 2013
- “Low Level Presence Sacrifices Food Safety for Trade Policy: LLP is indefensible from a public health and safety standpoint” Submission to Government Consultations on LLP, from the Canadian Biotechnology Action Network, 2011
- Press Release, November 29, 2011: Federal Government Proposes to Side-Step Health Canada’s Regulation of Genetically Modified Foods: Trade policy would sacrifice safety, say groups.
- “Legalizing Contamination from Unapproved GM Food: Regulation? Who Needs it!” by Lucy Sharratt, CBAN, November 2011
- Government report from September 2011 consultations (released December 2012).