Tell Health Canada: No Exemptions
Demand mandatory GMO safety assessments
Updated May 11, 2021
Take Action: Have your voice heard in the consultation
Deadline: May 24
- If you have one minute: Use the action box on the side of this page to send an email to Health Canada.
- If you have 10 or more minutes: See below or click here for the pdf guide to send your comments to Health Canada: firstname.lastname@example.org
New! May 11, 2021:
Health Canada’s proposed new regulatory guidance on genetically engineered foods
April 8, 2021
Health Canada has launched a public consultation on its proposal to remove government oversight for some genetically engineered foods, particularly those produced through the new genetic engineering techniques of genome editing (also called gene editing). These proposals would allow some GMOs (genetically modified organisms) into our food system without any government safety assessments – these would be unregulated GMOs that the government may not even know exist.
Health Canada wants your opinion on proposals to:
- Allow some genetically engineered foods onto the market without government safety assessments
- Allow unregulated GMOs to go unreported to the government
- Conduct lesser safety assessments for GMOs that are similar to previously approved GMOs
Stop corporate self-regulation. Demand mandatory, independent risk assessments for all genetically engineered foods.
Find more information and analysis below or click here for the pdf guide.
Read CBAN’s comments submitted to Health Canada or the summary of our comments.
Add your voice for the future of our food and democracy.
Health Canada has launched a public consultation on its proposal to remove government regulation of some genetically engineered (genetically modified or GM) foods.
If approved, the proposals would remove government oversight for some genetically engineered foods, allowing some GMOs (genetically modified organisms) into our food system without any government safety assessments – these would be unregulated GMOs that the government may not even know exist. Many of these GMOs are likely to be produced using the new genetic engineering techniques of genome editing, also called gene editing.
Health Canada’s proposals threaten food safety and democracy. Health Canada is proposing to abdicate its responsibility to ensure food safety and set a precedent of corporate self-regulation in the use of genetic engineering in our food system.
Government safety assessments already rely on confidential science submitted by product developers but, if these new proposals go ahead, Health Canada will not even check this corporate science. Allowing corporate self-regulation would be a significant move away from government oversight and review by independent government scientists. Multinational biotechnology and pesticide corporations and their lobby group CropLife Canada has asked for these changes because seed companies want easier, faster regulations for the new genetic engineering techniques of gene editing in particular.
Health Canada is proposing three changes:
- Allow some genetically engineered foods onto the market without government safety assessments: Health Canada is proposing to exempt some genetically engineered foods from regulation. This means that some GMOs would be allowed onto the market without government safety assessments. Specifically, Health Canada is proposing to allow product developers to assess the safety of their own GMOs if there is no foreign DNA inserted. This proposal overlooks the potential consequences of unintended and unexpected effects created by the process of genetic engineering, genome editing in particular (See CBAN’s report for discussion of the risks of genome editing).
- Allow unregulated GMOs to go unreported to the government: Health Canada proposes to set up a “Voluntary Transparency Initiative” that would not require, but would encourage private companies to voluntarily inform the government of any unregulated gene-edited GMOs that companies intend to put on the market.
- Conduct weaker safety assessments for GMOs that are similar (“identical”) to previously approved GMOs: Health Canada also wants to relax information requirements for the safety assessments of GM foods that have “identical” GM characteristics to those already approved. This proposal introduces “tiered” assessments that could mean “expediated service standards” (shorter timelines for a risk assessment) for some GMOs. More information and analysis on this proposal is forthcoming. Contact us if you have questions.
If accepted, these changes would set a critical precedent to allow corporate self-regulation of foods produced by new technologies. In fact, Health Canada’s consultation is the beginning of a multi-year process to “modernize” regulation for all GMOs, including GM seeds and GM animals. This is an important opportunity to press for transparency and strong regulation.
Take some time now to tell Health Canada you want mandatory, independent safety assessments of all genetically engineered foods.
Please see below for more information on how to send your comment. The deadline to send comments is May 24, 2021.
What is happening?
- There are two consultation documents, available upon request from Health Canada or click here.
- There are three proposals in this consultation. The consultation documents are 6 and 19 pages each but the actual proposals in them are short. For example, the proposal on gene editing is summarized on one page: Section 3 on page 5 of the document on “plant breeding.” Click here for Health Canada’s consultation documents.
- CBAN will soon provide more detailed analysis of the proposals with more background information. Subscribe to the CBAN e-news for updates or stay tuned to this page: www.cban.ca/NoExemptions
- The deadline to send your comment is May 24, 2021.
Why is it happening?
- Multinational biotech and pesticide companies and their lobby group CropLife Canada have asked for these changes because companies want easier, faster regulations for the new genetic engineering techniques of gene editing in particular. Click here for information on the corporate recommendations.
What is at stake?
- The role of government and the future of independent science: The public cannot rely on product developers and corporate science to ensure product safety – independent, peer-reviewed science and independent government oversight is essential to safeguarding public health.
- The role of the public in decision-making: Consumers and farmers should have input into decisions over the use of new technologies in our food system like genetic engineering, including as part of assessing the need to use the technology and the potential social and economic impacts.
- The future of food and farming: The new genetic engineering techniques of genome editing are powerful and could be used to produce many new patented GM foods, plants and animals.
- Food safety: Safety assessments of genetically engineered foods must consider potential unexpected impacts of the process of genetic engineering and not just focus on the product and the insertion of foreign DNA.
Decoding Health Canada’s language
- “Regulatory guidance”: The proposals are not changes to regulations but would change the “guidance” document, which interprets the regulations and instructs regulators on how to assess GMOs for food safety.
- “Plant breeding”: The biotech industry and Health Canada often refer to the new genetic engineering techniques of gene editing as “breeding” methods but this is not accurate or appropriate. Unlike breeding methods, genetic engineering techniques (including gene editing techniques) intervene directly in the genome to make changes.
- “Genetic modification”: The term “genetic modification” is commonly used interchangeably with “genetic engineering,” to refer to the new laboratory techniques of directly intervening in the genome of organisms to make changes. However, Health Canada uses the term “genetic modification” to refer to a broad category that includes conventional plant breeding as well as genetic engineering.
- “Biotechnology”: In the proposals, Health Canada does not use the term “genetic engineering” at all but instead uses the broader term “biotechnology.”
- “Pre-market notification”: When Health Canada refers to pre-market notification they are referring to the process where product developers submit information on their GMO to regulators for a safety assessment.
- “Retransformants”: This is not a common term but Health Canada uses it, for the purposes of regulation, to refer to plants that have been genetically engineered with the identical sequence of DNA as a previously-authorized plant of the same or similar species, to create the same GM trait.
Health Canada has two consultation documents (available upon request from Health Canada from their consultation webpage):
- Proposed Changes to Health Canada Guidance on the interpretation of Division 28 of Part B of the Food and Drug Regulations (the Novel Food Regulations): When is a food that was derived from a plant developed through breeding a “novel food”?
- Proposed Health Canada Guidance on the pre-market assessment of foods derived from Retransformants under of Division 28 of Part B of the Food and Drug Regulations (the Novel Food Regulations)
CBAN briefings on Health Canada’s proposals:
- CBAN Briefing – Proposal #1: Allow some genetically engineered foods onto the market without government safety assessments, April 8, 2021
- CBAN Briefing – Proposal #2: Allow unregulated GMOs to go unreported to the government (the “Voluntary Transparency Initiative”), April 8, 2021
- CBAN Briefing – Proposal #3. Coming soon.
- Click here for the full pdf guide.
For information on genome editing (gene editing):
- CBAN Factsheet – “Introduction to Genome Editing“
- CBAN Report – “Genome Editing in Food and Farming: Risks and Unexpected Consequences“
- GM Watch – List of recent studies: “Gene Editing: Unexpected outcomes and risks”
For information on GMO regulation in Canada:
- CBAN Report – “Are GM Crops and Foods Well Regulated?“