Briefings to government
Comments on the proposed federal Sustainable Agriculture Strategy
Canada’s Sustainable Agriculture Strategy should require rigorous regulation of genetic engineering (genetically modified organisms or GMOs), and should support organic agriculture.
Comments to ECCC on Part 6 CEPA & New Substance Notification Regulations (Organisms) pre-consultation
January 30, 2022. Response to the Discussion Paper for Consultation: Review of Part 6 of the Canadian Environmental Protection Act, 1999 (CEPA) and the New Substances Notification Regulation (Organisms), for the regulation of “animate products of biotechnology.”
Comments submitted to ECCC on GM fruit fly “EntoEngine”
January 28, 2022. Comments to Environment and Climate Change Canada in response to the Notification for a fruit fly for use in recombinant protein production: EntoEngine from Future Fields
Comments to the United States Department of Agriculture re: “Darling 58” GM American Chestnut
December 22, 2022. Release of this GE tree in the United States would directly affect the environment in Canada, could threaten the endangered American chestnut in Canada, and could undermine the future of American chestnut restoration efforts in Canada.
Response to ECCC: Protect the Monarch butterfly as an endangered species
December 2022: The COSEWIC recommendation to re-classify the Monarch butterfly as endangered was made in 2016. Monarch butterflies must be urgently classified as endangered, in order to protect then from a multitude of threats along their long migratory routes and at their overwintering sites, including the serious impacts of glyphosate use.
GMO regulatory changes jeopardize safety and remove transparency
July 2022. Briefing for Members of Parliament on concerns over Health Canada’s change to regulatory guidance and planned regulatory change, and the Canadian Food Inspection Agency’s proposals to exempt some genetically engineered seeds from regulation.
Proposals on GMO regulation jeopardize safety and remove transparency
April 2022. Briefing for Members of Parliament on the proposals from Health Canada and the Canadian Food Inspection Agency to exempt some genetically engineered foods and seeds from regulation, and on concerns over their impacts.
MP Briefing: Regulatory guidance proposals on gene edited foods and seeds
October, 2021. Health Canada and the CFIA are proposing to exempt many new genetically engineered foods and plants from government safety assessments and government oversight: Genetically engineered plants that have no foreign DNA – many of which would be produced through the new genetic engineering techniques of genome editing, also called gene editing – would be exempt from regulation if product developers do not determine a food safety or environmental safety risk.
CBAN comments to CFIA: Guidance for determining whether a plant is subject to Part V of the Seeds Regulations
September 7, 2021. CBAN response to the consultation questionnaire on CFIA proposed guidance for determining whether a plant is subject to Part V of the Seeds Regulations. The regulatory guidance proposed is in conflict with CFIA’s responsibility “to safeguard food safety, protect the health of plants and animals in Canada, and support market access both now and in the future.”
CBAN Comments to Health Canada re: primer on gene editing
June 23, 2021. Comments submitted by the CBAN to the Bureau of Microbial Hazards, Food Directorate, Health Canada RE: primer on gene editing, in the consultation on proposed new guidance pieces for the Novel Foods Regulations. The primer does not provide a scientific rationale for the regulatory guidance proposals. It does not reflect a rigorous scientific literature review nor the most current scientific knowledge – It is insubstantial, incomplete, imprecise, and inappropriate.