Further to:
2005-12-03 Transgenics (GMO): HERBICIDE TOLERANT WHEAT, BACK AGAIN, INPUT DEADLINE JAN 7
This adds (details follow the points):
– red herring argument and how to address it: BASF’s process is mutagenesis, not transgenics as in Monsanto’s RR wheat. From my telephone conversation with the CFIA, this is the argument they try to use. If you are prepared, it is easy to cut them off. Don’t go there, it’s not the issue.
– my letter to CFIA did not address the bogus idea that this pilot project constitutes “transparency”. Will someone please?
– curiosity of web-site text “the CFIA and HEALTH Canada” when the CFIA is part of AGRICULTURE Canada.
– an apology to you: my letter to François Guimont, President of the CFIA (earlier email) was dishonourable in its venting of anger. I vow not to go that route again.
Please see that this gets as wide circulation as possible. There is a lot at stake. Thanks.
Sandra
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Canadian Food Inspection Agency (CFIA) Accepting Comments on Submission for Approval and Release of Herbicide Tolerant Wheat
November 8, 2005
Biotechnology Notices of Submission Project – Wheat (ALS1b) which has been bred for herbicide tolerance (URL no longer valid).
If you would like to provide comments on this submission, a feedback form is available from the web-site.
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DEADLINE
http://www.inspection.gc.ca/english/plaveg/bio/subs/subliste.shtml
Jan 7, 2006.
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COMMENT AND LETTER TO THE CFIA
We and others each put months of volunteer time into the battle to stop the introduction of herbicide-resistant wheat (2003-04).
Thousands of people and many organizations from Canada and other countries joined hands in the effort. The Government of Canada was/is a joint-developer with Monsanto of seeds developed to be resistant to chemicals.
Under the storm of protest, Monsanto announced that it was withdrawing its application for licensing (May 10, 2004). The Government didn’t have to take a stand.
Here it is back again, this time from the chemical company BASF (not Monsanto).
My letter to the Canadian Food Inspection Agency (CFIA) is appended. (The CFIA is responsible for the licensing of seed (crops) which are the basis of our food supply.)
I have left 2 messages for François Guimont, the President of the CFIA, 613 225-2342, requesting a phone call from him. The receptionist tried to hand me off to “an expert” on herbicide-tolerant wheat. I said, no, that François is responsible for the operations of the CFIA, that the matter is critical and I will speak with François. (The matter needs to be discussed with him, and by more people than me.)
(UPDATE: Stephen Yarrow, head of the Environmental arm of the CFIA phoned. I spent an hour and a half on the phone discussing the basis of objection to herbicide-tolerant wheat. With all the work we have done, it is not difficult to refute their arguments.)
They do not expect us to be well informed from many different angles. If you persist you will discover, I think, that they actually come over to our side. I should have a recording of the conversation! … they know when they’ve been called on a silly argument. Probably not enough people call them. Please, take the time. My call by itself will not be sufficient.
François Guimont, President, 613 225-2342
The CFIA web-site says: “Currently, the CFIA and Health Canada post decision documents on the Internet after a product has been approved. They have not previously posted information about products that are under review, as will be the case in this pilot project.” Kerry investigated the CFIA web-site and advises that the licensing of these seeds is further advanced than we know.
This application from BASF is a “pilot project” with regard to PROCESS. I think we have little alternative than to see it as an opportunity and hit it as hard as we can, regardless of what has already been licensed by the CFIA.
The information above takes you to the web-site from which you can register your input to the CFIA. By Jan 7.
A point I did not make in my letter to the CFIA, which someone else needs to do: the idea that the Government can achieve “transparency” by posting each application on a web-site as it comes up, implies that citizens have nothing to do but sit and watch the Government web-site and then launch a campaign every time it steps out of line. This is not transparency, but policing.
If the licensing follows the right principles, and if actions are principled, citizens might gain some confidence in the system of regulation and governance. If the regulations and laws are out-of-date (the Patent Act), they are the source of the problem and need to be changed. That things are being done “according to the law” is not an excuse. (See my letter to François.)
This charade of “transparency” will be an attempt to deal with all the flack heaped upon the Government in the past over round-up resistant(RR) wheat and other related campaigns such as Bill C-27, Plant Breeders’ Rights Act, C-28 Interim Marketing Authorizations, the Whistle-blowers Legislation, etc. The charade needs to be challenged for what it is – it is not transparency.
(Aside: People in our network have been involved in the “Smart Regulations” “Government Directive on Regulating” (GDR) campaign, deadline for input Dec 23. You can see the connection: here the CFIA is running a “pilot project” to be “transparent”. The GDR is in precisely the same vein – an attempt to deal with all the flack directed at the Government. We have used this BASF application as input to the GDR as part of the illustration of growing non-compliance with the laws and regulations in Canada and why that is happening. Please ask me if you would like a copy of our correspondence with the Privy Council about “Smart Regulations”.)
It has been pointed out that this licensing application is not about “transgenics” as in the case of Monsanto’s RR Wheat. BASF uses a different process called “mutagenesis” to develop its herbicide-tolerant wheat. This is a red herring argument which can be avoided by focussing on the CRITERIA being used to “develop” our food supply – see the letter to François. The criterion is resistance to chemicals; nutritional value is not a criterion.
Curiously, the text reads “the CFIA and Health Canada”. The CFIA is part of AGRICULTURE Canada. One interpretation is that the reference to “Health” is an effort to convey the impression that Health is a priority (not agriculture and transnational corporations).
I know that the CFIA works with the Pest Management Regulatory Agency (PMRA) which is part of Health Canada. (The CFIA licenses the seeds that are tolerant to the herbicides licensed by the PMRA. The “clients” of both agencies are the same.) So I read the text as “Currently, the CFIA and the PMRA post decision documents …”. I believe that is the statement as it should read, if it is to reflect truth.
People familiar with the pesticide debate know that the Auditor General’s Dept has stated emphatically in 4 consecutive reports starting in 1988 that the PMRA is not getting the job done. From experience we know that conflicts-of-interest abound between the PMRA and the chemical industry it is supposed to regulate. It sees the industry as its “clients”.
The CFIA and the PMRA are very much sister organizations. Hence the statement, “The CFIA and Health Canada …”
(UPDATE: Stephen Yarrow says it is not the PMRA, it is a different part of Health Canada that is involved in evaluating the nutritional value of the herbicide-tolerant wheat and they have said that all is ok.)
My letter to François Guimont included 3 statements related to the security of his job because of the failure of the CFIA to carry out its mandate to protect the Canadian food supply. The statements were a consequence of my anger. I should have exercised self-discipline, for more than one reason.
From a strategic point-of-view, it is much more effective to add more people to my distribution list, to add new troops, than it is to indulge myself. I have now added more people, and feel much better with that tactic! My apologies to you.
Cheers!
Sandra
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Sent from
http://www.inspection.gc.ca/english/plaveg/bio/subs/2005/20051108e.shtml
on or about Dec 3, 2005:
FROM:
Sandra Finley
Saskatoon, SK
306-373-8078
TO: François Guimont, President of the CFIA
By the thousands, Canadians have told you that we do not want our food supply developed by the criterion that it be resistant to chemicals. Our food supply is to be developed according to the criterion:
– is the seed more nutritious than other varieties (of wheat, in this
example)? Does it make a positive contribution to the nutritional value of our food supply?
We fought for months and months to put a stop to herbicide-resistant wheat developed jointly by Monsanto and the Government of Canada. Now here it is back again, only this time from BASF.
You have 4 issues to address:
– GOVERNANCE (In whose interest are these undertakings?)
– HEALTH (Our food supply. Health is dependent upon food supply. What is the criteria for seed selection?)
– ENVIRONMENT (Introduced species do not have enemies. They proliferate and become weeds. Common sense, science and experience ALL reinforce the fact that crops engineered to be resistant to chemicals bring about an increase in the use of chemicals. Farmers now apply a round of glyphosate to kill the plants they don’t want, and then turn around and apply 2-4D to kill the plants that are resistant to the glyphosate. I know. I am from Saskatchewan. We have 10 years of experience with RR canola which is now a weed growing in shelter-belts, gardens and in other unwanted places.
Roundup won’t kill it. You, the CFIA, has no credibility here.)
– OWNERSHIP OF LIFE FORMS. The Patent Act was never meant to apply to life forms. It was intended to cover mechanical devices. In at least 4 different places in the Schmeiser decision the Supreme Court of Canada told the Government that the legislation had to be changed. Has that been done?
The earlier “Harvard Mouse” decision also pointed out to the Government that the Patent Act required an update. Has it been done? Have YOU, François Guimont, done anything to insist that the Patent Act be changed? Whose interests do you serve?
Transnational corporate interests more and more determine the food that is grown. They do not develop seed using the selection criteria of nutritional value. And they attempt to appropriate that which belongs to the commons.
You, the CFIA, are party to the attempted appropriation.
The Government almost shut down a whole industry (cattle) when it was suspected that just ONE INDIVIDUAL’s food production might be injurious to the public good (health). What do you do when it is suspected that crops developed with the criterion that they be resistant to chemicals, crops that serve a corporate interest, might not be in the public interest?
The health of the population, and therefore medicare costs, are dependent upon the nutritional value of our food supply.
According to a Globe and Mail report, the nutrition found in fruits, vegetables, and other food crops has declined significantly since the 1950’s. That is YOUR responsibility.
CRITERIA USED:
The licensing process for new varieties of wheat, barley, oats, etc. uses criteria such as disease resistance, yield, and now, resistance to chemical applications.
CRITERIA NOT USED: nutritional value, taste, impact on environment, contribution to the common good.
Plant Breeders do not have Rights. They have RESPONSIBILITIES.
The purpose of the Government and its Legislation is to defend THE COMMONS.
Seeds are an essential part of the commons; they form the basis of our food supply. It is the RESPONSIBILITY of ANYONE who is tampering with the food supply to use the following selection criteria.
Before any seed is released into the environment or licensed for use:
– NUTRITIONAL VALUE (in the case of seed that becomes food): is the nutritional value of the seed superior to that of hallmark original varieties? If the seed (food) does not make a improved positive contribution to the value of the food, therefore to the health of the citizens, it will not be licensed for use. It is well documented that the nutritional value of food has significantly declined over the last 50 years. That does not bode well for public health. There is a connection between our food supply and escalating disease rates (health) and medicare costs.
– ENVIRONMENTAL CONSEQUENCES: will it perform like an “introduced or invader species” such as wild oats, purple loosestrife or zebra mussels? If so, it will not be licensed. Anyone who releases such organisms into the environment must pay the “external costs” of eradication. Do you know how many millions and millions of dollars are spent, year after year, to try and control wild oats (an introduced species? Do YOU pay for it?)
– TASTE: Food that contributes to the healthfulness of the citizens must be appetizing, or it will be shunned in spite of its nutritive value. SO: What is the taste performance of the proposed seed: it must at least be as tasty as hallmark original varieties.
– COMMON GOOD: WHOSE INTERESTS ARE YOU SERVING? THE RESPONSIBILITY OF GOVERNMENT.
Visionaries implemented a seed development process in Canada which used public money for the common good (e.g. Agriculture Canada Research Stations and scientists). They understood that allowing inferior seed from producers to enter the food production system undermines the value of the crop for citizens collectively.
They understood that:
~ the goals of the individual or corporation (minimize costs, maximize
revenues) can be at odds with the interests of the community, ~ use of inferior seed by some individuals promotes use of inferior seed by everyone because those with higher costs will be driven out of production if they don’t adopt the same lowest-cost production. (The common good (health) and the environment are the losers.) ~ the role of Government is to serve and protect the public interest.
Historically, Agriculture Canada did that well, up until the 1980’s when Government POLICY changed (“public-private partnerships”).
TODAY, the Government is WRONG in its understanding of its role. A necessary criterion for deciding whether a new seed will be introduced is: whose interests will be served by the introduction? Seeds are part of the commons.
If it cannot be demonstrated that the society at large will benefit from the seed, then it must not be licensed. (The very name of the Act – PLANT BREEDERS’ RIGHTS – states a bad situation, a serious misunderstanding.)
Canada has a long history of exemplary seed development based on community interest. The evidence is that we HAVE floundered by succombing to private, commercial, interest-based seed selection criteria.
From John Kenneth Galbraith’s “The Economics of Innocent Fraud – Truth for our Time”, published in 2004 : “… As the corporate interest moves to power in what was the public sector, it serves, predictably, the corporate interest. That is its purpose. …One obvious result has been well-justified doubt as to the quality of much present regulatory effort. There is no question but that corporate influence extends to the regulators. … Needed is independent, honest, professionally competent regulation … This last must be recognized and countered. There is no alternative to effective supervision. …”
Tax-payers provide salaries for Government employees to perform work that is in the public interest. ANY Government employee whose work is in collaboration with an industry, ESPECIALLY if the employee’s official work is related to the regulation of that industry, MUST resign their Government position.
I am very angry that I and others must expend so much time and energy to try and force people to do their job.
Yours truly,
Sandra Finley
(contact information)
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(REFERENCE:
If you do not know the story of the CFIA, it is well enough told in the movie THE FUTURE OF FOOD, an American movie with Canadian content. What is described about the U.S. situation is true of the Canadian. For more information about the film:
http://www.thefutureoffood.com/
“Already playing to packed houses in the U.S., this award-winning documentary offers an in-depth investigation into the alarming changes happening in the corporate-controlled food system. With beautiful and haunting images, it reveals the disturbing truth behind the unlabeled, patented, genetically engineered foods that have quietly filled grocery store shelves for the past decade. Released in the States in September, THE FUTURE OF FOOD opened in Calgary on Nov. 18th, Vancouver on December 1 with a special benefit screening in Saskatoon on December 2.”“THE FUTURE OF FOOD has inspired food and farming communities all over the world,” says Producer-Director Garcia. “We are very pleased that audiences across Canada will have the opportunity to see the film and educate themselves about what is happening to agriculture today.”)