“Always leave the Earth better than you found it. ” -Rupert Stephens
Genetically Modified Organisms
Canada is the third largest producer of genetically modified organisms (GMOs) in the world. As the cultivation of GMO crops intensifies and expands, ecological risks are emerging, such as super weeds, pest resistance, and adverse effects on non-target organisms. GMO animals such as fish are also being developed, raising additional concerns about potential environmental risks. As yet, there is little information available on the potential adverse effects of GMOs on aquatic ecosystems.
Environmental scientists do not yet know what long-term impacts on biodiversity and ecosystem function could result from dispersing GMOs and related products such as herbicides and Bt toxins (Bacillus thuringiensis toxins) in the environment, what effects they could have on indigenous microorganisms and invertebrates in streams and soils, and what threats they might pose to water quality.
The research activities in Environment Canada address the deficiency of much needed regulatory information and relevant field data on potential environmental effects of the commercial release of GMOs. Little information about their long-term effects on aquatic ecosystems is available. Federal GMO policy makers and regulators require sound scientific information generated from Canadian aquatic ecosystems to validate and refine GMO policies. Environment Canada scientists conduct a wide range of research to ensure the health and sustainability of Canadian aquatic ecosystems.
Water S&T Research
To detect and monitor the spread and persistence of GMOs in aquatic ecosystems, Environment Canada researchers are studying the survival of free transgene DNA in water samples from different sources and potential horizontal gene transfer, and the possible presence of GMO related products such as Bt toxins in wetlands and ponds, occurring as a result of leaching and runoff. They have also conducted studies to examine the survival of model microbial GMOs in laboratory microcosms and make pre-release predictions about their environmental fate.
Scientists are building a molecular database on biodiversity and functional gene abundance in aquatic ecosystems. This information serves as baseline data of pre-GMO release conditions to compare with post-release conditions to enable researchers to detect and monitor trends and adverse changes in biodiversity and ecosystem functions.
A federal government initiative, led by Environment Canada, is applying DNA microarray technology and other molecular techniques to better characterize microbial biotechnology products and detect the presence of indicator species or potentially harmful microorganisms.
In addition, Environment Canada is developing and applying genomics techniques to characterize the role of a particular, natural organism – as defined by genetic activity – in the functioning of an aquatic ecosystem, so that changes in that role, as a response to the presence of GMOs, can be perceived and monitored, and the consequences of the GMO presence to ecosystem functioning can be better understood.
To learn more, visit these websites:
- Environment Canada: Threats to Sources of Drinking Water and Aquatic Ecosystem Health in Canada – Ecosystem Effects of Genetically Modified Organisms
Letters of Concern
I hereby submit this petition to the Auditor General of Canada under section 22 of the Auditor General Act.
Signature of petitioner: [Original signed by Karen Hamilton]
Date: September 7, 2010
Title of petition: Accountability for Labelling of Genetically Modified Organisms
Concerns about GMOs, including their impacts on the environment, human health, sustainable agriculture and society more generally, are discussed in this petition, therefore, this issue fits within the purpose of section 22 of the Auditor General Act.
According to the Government of Canada’s BioBasics website, genetic modification is a “chemical change to a gene’s DNA sequence.”1 Thus a genetically modified organism is an organism which has undergone a chemical change to a DNA sequence in one or more genes.
GM soy, corn, canola, cotton (cottonseed oil) and, in 2008, sugar beet have been rapidly incorporated as ingredients in food products in Canada. It is generally estimated that approximately 75% of processed food in Canada could contain genetically modified ingredients.2 In addition to these major GM crops, biotechnology research is turning its focus to fish and animal products.3
To date, GMOs introduced by biotech companies have focused almost entirely on two traits: herbicide tolerance and insect resistance. Many Canadians question whether these traits offer advantages to consumers or to the environment. The potential impacts include the elimination of beneficial insects, contamination of soils, and toxicity or allergenicity in humans.4
The effects associated with GMOs – particularly their impacts on conservation and the sustainable use of biodiversity – have garnered international attention. Therefore provisions for dealing with GMOs were included in the United Nations Convention on Biological Diversity in 1992, and in the Cartagena Protocol on Biosafety in 2000. Although Canada has yet to ratify the Cartegena Protocol on Biosafety, as a signatory to the Convention on Biological Diversity, Canada has agreed to regulate, manage, or control risks associated with the use and release of living modified organisms associated with biotechnology.5
Canadians have identified specific concerns about GMOs, related to the environment, human health, sustainable agriculture and social issues, which are discussed in more detail below. Given these concerns and Canada’s commitment to control risks associated with GMOs, it would be appropriate that the Canadian Government should develop a policy of domestic mandatory labeling to ensure Canadians are aware of the presence of GMOs in products they are purchasing.
The use of GMOs could harm beneficial non-target species such as butterflies, bees and birds; enhance existing pests; create new pests; accelerate species extinction; and disrupt ecosystem processes and functions.6 The full extent of these effects is not clearly known, as independent scientific study has only just begun to examine these questions. The development of herbicide-tolerant weed species across the US, and recently in Canada, has been expedited by the use of herbicide tolerant genetically engineered (GE) crops. These weeds and the problem of herbicide-tolerant volunteers is leading to increased use of glyphosate as well as to the use of more human-toxic herbicides such as 2-4,D.7 GMOs cannot be fully controlled in the environment. They can, and do, escape from their fields and find their way into non-GMO fields, potentially contaminating those fields and making the crops less valuable economically.8
GMOs may pose health concerns for humans. These health concerns include toxicity (to organs such as the liver and kidneys), allergenicity, antibiotic resistant pathogens, and reduced reproductive capacity.9 Health Canada has recognized the potential for health effects by establishing Post-Market Surveillance of Drug Products Derived from Biotechnology to monitor these drugs and their effects, although the status of this project is unclear.10
Genes from GMOs have been found to travel great distances by means of pollen and other debris.11 Therefore, it is possible that transgenic material can find its way to the fields of organic farmers. The Canadian General Standards Board’s management standards for organic production systems state that materials and products produced through genetic engineering are not compatible with the general principles of organic production.12 Any product that is certified organic under Canada’s new Organic Products Regulation may not use GMOs. 13 Organic grain farmers in Saskatchewan have already lost their export and domestic markets for organic canola and the use of this crop in their rotations, due to contamination from GM canola.14 The use of insect-resistant GMOs, such as Bt crops, may cause pest populations to evolve a resistance to pesticides and insecticides. As a result, it will become more difficult for traditional and organic farmers to effectively manage pests, as they will no longer be sensitive to commonly used pesticides.
Farmers have traditionally retained the ability to save and replant seeds from their previous harvest. However, biotech companies have secured patents on the genetically modified seeds, enabling them to legally prohibit the traditional and cost saving measure of seed saving. Those farmers who continue to save seeds from GMOs are subject to lawsuits by large biotech firms.15 The result is that multinational firms now control many of the world’s seeds, and charge high prices for the ability to use their seeds. There has been a dramatic rise in the average price of seeds since the mid-1990s when the biotech era began.16 Additionally, since the only advantage of GMOs to farmers is their ability to withstand applications of specific brands of herbicides – those produced by the same companies that produce the genetically modified seeds – farmers are increasingly dependent on a few large biotech firms for major inputs. The entire practice is making farming unaffordable for smaller farmers.17
It is questionable whether GMOs provide benefits to the international community. The majority of GMOs are used as feed for animals in wealthy countries. People in poor and developing nations still continue to suffer high levels of famine and receive little benefit from GMOs.18 This is so because impoverished farmers in developing nations are generally unable to afford GMO seeds and pesticides. This is exacerbated by the fact that the price of some GMO crops, such as grain has been increasing dramatically in recent years. The Center for Food Safety estimates that GMO seeds may cost two to four times as much as conventional seeds.19 Therefore, GMOs are ineffective at helping alleviate global hunger and malnutrition.
Aside from these direct impacts, there are other social and ethical implications, such as the deliberate movement of genetic material across the species barrier, and the ability of biotech companies to patent genetic material. This means that corporations not only ‘own’ genetic material – the basis of living organisms – but can also enforce those ownership rights in potentially inequitable ways. In terms of exerting ownership over seeds in Canada, a biotech company has gone so far as suing a farmer whose field was contaminated by the company’s GMO. Farms growing genetically modified ‘Roundup Ready’ canola, sold by Monsanto, surrounded Percy Schmeiser’s farm. As a result of gene transfer from pollen dispersal as well as seed dispersal, seeds that Schmeiser was saving were gradually increasing in the genetically modified variety sold by Monsanto.20 After discovering the presence of their GMOs on the farm, Monsanto brought a lawsuit against Schmeiser for patent infringement. Although GMO seeds had contaminated Schmeiser’s farm, Monsanto was successful in court. While the initial damages for ‘profit’ were set aside at the Supreme Court of Canada, Schmeiser was responsible for paying all his own legal fees. It is likely that these legal costs could severely cripple, if not bankrupt the average farmer.21 This presents legal and ethical challenges about the right to own a life form, and how this is impacted by the high mobility of GMO seeds.
Applying the Precautionary Principle
There may be unknown effects associated with both production and consumption of GMOs. The Rio Declaration states that “where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”22 The need to embrace the precautionary principle is also articulated in the Convention on Biological Diversity.23 The long-term impacts on the environment, particularly biodiversity, and human health is unclear at this time. A precautionary approach would include labeling. Although the social, ethical and environmental effects of GMOs are not fully understood, there is scientific evidence that suggests that they may be harmful. Therefore, as long as these products are available for sale and consumption in Canada, the consumer ought to have a right to know what is contained in their food, in order to be able to make an informed consumption choice. Labeling would allow consumers to avoid GMOs as a precaution, even though their full impacts are unknown.
The Royal Society of Canada in a 2001 report commissioned by Health Canada, the Canadian Food Inspection Agency and Environment Canada, recommended that where a prima facie case can be established for the possibility of serious harms to the environment or human or animal health, a lack of high scientific confidence in the existence or level of risk cannot be used as an excuse to allow unregulated use of the product. Further, the report stated that if there is the prospect of risk to human health, ecosystems, or biodiversity, the product should not be approved until uncertainty has been reduced to a minimum level.24
The Use of Labeling
Labeling of GMOs has been mandated in a number of countries, including the European Union (EU), Hong Kong, Australia, New Zealand, China, Japan, Russia, the Republic of Korea, Saudi Arabia, Taiwan, Thailand, the Philippines, Brazil, Chile, and Israel. Globally there are over forty countries that have regulated mandatory GMO labelling.25 Labeling of GMOs permits consumers to exercise choice in their purchases – it allows them to know what they are supporting through their purchases as well as what they are ingesting. It also allows consumers to perform their own risk assessment, and choose if they are willing to accept the risks posed by particular GMOs.26 These choices will likely be made due to a number of factors that include “perceived or potential health risks or benefits, perceived or potential environmental risks or benefits, a fundamental ethical opposition to genetic modification or any kind, religious beliefs, food quality and price, broader societal concerns… and lack of confidence in the regulatory system.”27
There are various methods by which GMOs can be labeled. Below, the policies used by the EU, Hong Kong, Australia and New Zealand, China, Japan, and Russia are reviewed.
The European Union has had mandatory labeling for products containing genetically modified corn and soy since 1997. As of 2003, the union requires labeling human and animal foods which contain GMOs. All foods that are GMOs, or contain GMOs or products derived from GMOs, must have a label stating “this product contains genetically modified organisms.”28 Products that contain traces of GMOs below 0.9% need not be labeled as containing GMOs.29 All GMO labeling is controlled by the European Food Safety Authority, which requires specific testing to ensure that GMOs will not affect human or animal health before they will be approved.30
Hong Kong introduced voluntary labeling of GMOs in food products in 2006.31 However, the country also required that if voluntary labeling was used, it must follow a standardized system set out by the Centre for Food Safety. Essentially, on the list of ingredients, the words ‘genetically modified’ must appear in parentheses beside those ingredients that are genetically modified. Products recommended for voluntary labeling are those that have lowered nutritional values, higher levels of toxicants, the presence of allergens, or animal genes.32 For pre-packaged items, labeling is recommended for those items where 5% or more of the ingredients are genetically modified. Additionally, legislation prevents the use of the label “GMO free” unless proper documentation is provided to show that no GMOs were used in the product.33
Australia and New Zealand both have mandatory labeling of GMOs in food products. As of 2001, mandatory labeling is regulated under Standard 1.5.2 of the Australia New Zealand Food Standards Code. All genetically modified foods (including unpackaged foods, such as loose vegetables) and ingredients must be identified on the label as genetically modified, in a method similar to that used in Hong Kong.34 Any genetically modified additives and processing aids must also be identified, though only if they are present in the final product.35 There is an exemption for products that unintentionally have a genetically modified content of no more than 10g/kg or 1% per ingredient. However, the manufacturer must have actively sought to avoid GMOs in their product.36
Mandatory labeling of GMOs was introduced in Japan in 2000, and like many other countries, applies to both fresh and processed foods.37 In Japan, the labeling is broken down into three categories: genetically modified, no segregation practice with GM products, and not containing GM products. While the first two of these labels are mandatory, the third (not containing GM products) is a voluntary label. However, it cannot be used for products for which no GMO is available. These descriptions are to appear in parentheses after the ingredient to which they apply on the food label. If the GMO is used in processing the product, but is no longer present after processing, then no labeling is required.38
Russia has required mandatory labeling of GMOs in food where the product has a GMO content of 0.9% or greater since 2004.39
Labeling in Canada
The Canadian Biotechnology Advisory Committee (CBAC) proposed the use of voluntary labeling in its 2002 report. The report also recommended that five years after implementing a voluntary labeling system, the system be reviewed, at which time mandatory labeling should be considered.40
In 2004, the government accepted the Voluntary Labeling And Advertising of Foods That Are and Are Not Products of Genetic Engineering, which was created through a process of the Canadian General Standards Board as the National Standard of Canada.41 To date there has been no review of the use of this voluntary labeling standard, nor does there appear to be any review planned.
In October 2001, a private members bill, Bill C-287, proposed mandatory labeling of GMOs through the Food and Drugs Act. The bill proposed that any food containing more than one percent of a GMO had to be labeled that it was or contained an ingredient that was genetically modified, specifying the identity of the ingredient.42 The mandatory labeling would apply to all food products except those deemed by the Minister to be unlikely to be a significant or essential part of a diet. However, these exempted products would have had to have a label stating they were exempted from declaring any GMO content.43 The bill was defeated in the House of Commons.44
In 2008, private members bill C-517 was introduced to require mandatory labeling. The bill would have required products found to contain GMOs to be published on a Government of Canada website accessible to the public. Following publication, the product would be required to be labeled with the statement “This product or one or more of its components has been genetically modified.”45 Bill C-517 was defeated in the House of Commons by a vote of 101 to 156.46
Cost of Labeling
The European Commissioner for Health and Consumer Protection stated in 2001 that the introduction of their GMO labeling regime in 1997 did not result in an increase in costs. The Commissioner went on to state that similarly, the introduction of mandatory labeling in Norway did not result in any price increases or disruption in trade.47 Therefore, existing systems of GMO labeling indicate that no extreme costs would be incurred in implementing such as program.
The costs of implementing a mandatory labeling system for GMOs in Canada has been estimated to cost approximately US$35 to US$48 per person per year for the system. However, commentary on this study suggests that this estimate is higher than actual costs it used upper bound aggregate estimates of costs, such as assuming that 70% to 80% of processed foods would incur the full cost of segregation.48
When estimating the costs of mandatory labeling in Quebec, it was found that the system would cost approximately CAD 161.75 million (US $20 per person) to set up, and then approximately CAD 28.37 million per year thereafter (US $3.50/per person/per year).49
Petition question and/or requests:
- Does Health Canada, Agriculture and Agri-Food Canada, Environment Canada, or any other responsible departments plan to evaluate the effectiveness of voluntary labeling standard, as recommended by the Canadian Biotechnology Advisory Committee? If not, please explain why Health Canada, Agriculture and Agri-Food Canada, Environment Canada, or any other responsible departments do not intend to evaluate the effectiveness of voluntary labeling standard.
- How is Health Canada, Agriculture and Agri-Food Canada, Environment Canada, or any other responsible departments monitoring the use of the current voluntary standards?
- Has Health Canada, Agriculture and Agri-Food Canada, Environment Canada, or any other responsible departments carried out an analysis to assess labeling in other jurisdictions? If so, please explain how this analysis has informed the position of Health Canada, Agriculture and Agri-Food Canada, Environment Canada, or any other responsible departments on labeling of GMOs.
- What circumstances would be needed for Health Canada, Agriculture and Agri-Food Canada, or any other responsible departments to implement mandatory labeling of GMOs?