2008-05-27
Manitoba Forage Council Inc.
125 Patterson Cres.
Brandon, MB
R7A 6T7
Carole Swan
President, Canadian Food Inspection Agency
59 Camelot Drive
Ottawa
ON K1A 0Y9
Dear Ms Swan;
Re: Introduction of glyphosate tolerant alfalfa (RRAlf)
I am writing in my capacity as Chairperson of the Manitoba Forage Council Inc..
The Manitoba Forage Council Inc. is very concerned about and opposed to the introduction of glyphosate tolerant alfalfa (RRAlf). Our concerns can be summarised in the following points:
- Potential for loss of gene confinement
Periodic harvesting (i.e. cutting hay fields) to eliminate flowering plants is not a physically possible option for controlling all pollen flow of the RRAlf stands for these reasons:
- Most alfalfa varieties in the market are “synthetic” varieties made up of alfalfa collections with similar growth habits, maturity rates, and tolerances to simulate an individual variety. Therefore heterogeneity within a variety causes plants to initiate flowering at various times in the season – a physiological function that will compromise attempts to confine gene flow through timed harvesting operations.
- Alfalfa is a plant that shares a physiological ability with few other agricultural commodities called “indeterminate growth.” This is a biological term used for plants that will continue to flower until environmental conditions physically inhibit physiological function (i.e. frost, drought) – a physiological function that will compromise attempts to confine gene flow through timed harvesting operations
- Since the introduction of alfalfa to Manitoba, research has shown that the optimum harvesting stage to maximize yield and feed quality is approximately 10% bloom. As a result, most alfalfa grown for livestock feed in Manitoba is harvested between 1 and 10% bloom stage – a production practice that will compromise attempts to confine gene flow. Inclement weather can easily delay cutting until flowering and pollen production has reached a much higher percentage, or even full bloom.
- Potential negative impact on export market opportunities for forage seed and hay products. Once the RRAlf gene is introduced into the environment it may be spread uncontrollably by pollinating insects regardless of the intended use of the crop, thereby creating the likelihood of further contamination with the gene. Honey bees can travel and transfer pollen up to a two mile radius and be moved miles over night by the beekeeper, further compounding the problem of gene confinement. The practice of internationally trading common seed provides the vehicle to potentially transfer it to any Manitoba alfalfa seed or hay, and subsequently beef and milk product – compromising key international markets. There is significant reason to believe that this contamination may become a very serious non-tariff trade barrier.
- Potential negative impact on organic markets including milk and beef products.
The organic market is an important and developing market for milk and all meat (beef, bison, sheep, goat and elk) products which could be very seriously affected with the introduction of RRAlf. Most of the recent growth in the bison market has been to Europe.
- Potential negative impact of the loss of glyphosate as a tool for terminating stands of alfalfa in Manitoba.
Glyphosate is used by many producers in terminating stands of alfalfa. With the introduction of RRAlf this important production practice may be compromised.
- Limited agronomic need
There is limited agronomic need for this technology in Manitoba as over 90% of alfalfa grown in Manitoba for livestock feed is sown with multiple grass species (susceptible to glyphosate) to manage feeding strategies, extend pasture longevity and mitigate pest infestations.
We are therefore requesting that the CFIA reconsider the position taken with regard to the introduction of RRAlf and that immediate action be taken in the following areas:
- Place a moratorium on further field testing and trials in Canada until a complete environmental and economic impact assessment can be completed with all sectors of the forage industry.
- Arrange for the destruction of existing field trial stands.
Background Information and Discussion
Manitoba Forage Council Inc. – The Manitoba Forage Council (MFC) is a not-for-profit organization representing over 400 forage producers across Manitoba. The MFC Board of Directors consists of 20 elected members consisting of forage growers and advisory representation from the Manitoba Dairy Producers, Manitoba Cattle Producers Association, Manitoba Sheep Producers, Manitoba Forage Seed Association, Manitoba Agriculture, Food and Rural Initiatives, The University of Manitoba, Faculty of Agriculture and Food Sciences, Agriculture and Agri-Food Canada, Ducks Unlimited, and various other Trade people.
Discussion
Currently, there are no GMO or HT forage or forage seed varieties registered or being multiplied in Canada. However, the Monsanto Company and Forage Genetics International (FGI) received clearance from CFIA for events J101 and J163 glyphosate tolerant alfalfa (RRAlf) for unconfined release into the environment and for use as livestock feed and clearance from Health Canada for food safety approval on July 28, 2005, the first for a perennial forage or turf species. Two further hurdles in the regulatory process are a herbicide label approved by the Pest Management Regulatory Agency (PMRA) for use of glyphosate (Roundup herbicide) on RRAlf and approval by CFIA for an RRAlf variety. Monsanto and FGI placed a voluntary moratorium on field testing and trials in Canada in 2005 and recently indicated an end of this moratorium, and therefore a movement to market with this technology in alfalfa. Monsanto said trials would be established in 2008 to gather information required for a herbicide label from PMRA for a RRAlf crop. An approved herbicide label could be in place by 2011. The final hurdle would then be the registration of an RRAlf variety by CFIA which could easily be met by 2011.
In 2007, a US court decision placed these same RRAlf events back onto regulated (not available for use) status based upon the ruling that the United States Department of Agriculture – Animal and Plant Health Inspection Service (USDA-APHIS) had not fully carried out their regulatory responsibilities during their review of the petition for deregulation in which they carried out an Environmental Assessment (EA). The court cited in particular that USDA-APHIS did not consider the economic impacts of the deregulation of these materials and ordered USDA-APHIS to place the events back on regulated status (as of March 23, 2007) and for USDA-APHIS to prepare an Environmental Impact Statement (EIS), as provided for by US law, on RRAlf including the potential economic impacts of these events if released. It is anticipated that this process will take approximately another 12-24 months to be concluded (late 2009 or 2010). USDA-APHIS has also been preparing an EIS on RR creeping bentgrass (pre-deregulation) since 2005 with no defined end date. These two examples indicate the complexity of the scope of an EIS and that a thoroughly researched decision is not easily or quickly achieved.
Debate continues over the agricultural sustainability of relied use on herbicide technologies for crop management. Debate also continues over the long-term effects of various GMO technologies in terms of food and feed safety and the consumer issues surrounding the GMO environment. Given the important role forages are shown to have in the environment, the argued economic and environmental benefits of HT forages need to be further researched comparing benefits to Canadian forage producers and the potential of environmental risks. There is the potential for pollen flow of the RRAlf gene if grown in proximity to alfalfa seed production fields and to a lesser extent tame or feral alfalfa and this could jeopardize all of the current export markets for alfalfa seed. While previous trials were conducted under regulatory conditions including the addressing of pollen flow potential, these current trials do not. Due to zero tolerance of the trait in jurisdictions into which Canadian alfalfa is currently exported, the increased risk due to larger areas seeded and with no prescribed and/or regulated stewardship protocols, pollen flow is inevitable. A cessation of these field studies is essential until at least the US situation has been resolved to protect the Canadian forage seed industry.
In conclusion the Manitoba Forage Council wishes emphasize our very serious concerns regarding the introduction of RRAlf. We ask the CFIA to take immediate action in addressing this situation.
We look forward to your response to our concerns.
Sincerely,
Jim Lintott
Chair
Manitoba Forage Council Inc.
Copies:
Stephen Yarrow, Director, Plant Biosafety Office, CFIA
Honourable Gerry Ritz, Minister of Agriculture and Agri-Food Canada
Honourable Rosanne Wowchuk, Minister of Agriculture, Food and Rural Initiatives, Province of Manitoba
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