Seed industry experts examine what the new variety registration process will mean for the future of the industry.
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After about a decade of turbulence in seas of red tape and confusing clarifications, Canada’s seed industry is moving toward smoother waters._x000D_
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The variety registration process, according to three who are deeply involved in it, appears set to sail smoothly in 2016 and beyond. Here are some of their thoughts on what has passed, and what’s ahead._x000D_
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Registration Review_x000D_
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“It’s a positive step,” says Patty Townsend, Canadian Seed Trade Association CEO. “It may not be perfect, but it’s certainly a positive step to a better environment for investment and innovation in agriculture.”_x000D_
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The process of changing old registration systems for seed varieties began in 2007 as part of a government-wide initiative to cut red tape._x000D_
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Working with the seed sector through the National Forum on Seed, the government came up with a framework for a three-part registration system. It set the stage, but after a few years of operation, it was realized that more needs to be done._x000D_
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“So the government took a fresh look at the variety registration system and put out a proposal with four options for variety registrations going forward,” Townsend recalls._x000D_
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The Variety Registration Review began in January 2013 with a letter from the Minister of Agriculture to all 14 variety recommending committees in Canada. It asked them to focus on cutting red tape, while fulfilling their mandates for insuring seed safety and quality._x000D_
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“The options were considered by the industry,” Townsend says. “There was a whole bunch of input. A year ago or so, the government came up with a proposal for something they thought would best represent the industry’s input, and that proposal was just endorsed by the minister.”_x000D_
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On April 14, Agriculture Minister Gerry Ritz announced upcoming changes to streamline and modernize the way crop varieties are registered in Canada. The changes include:_x000D_
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• Streamlining variety registration into a two-tier system: Basic and Enhanced._x000D_
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• Model Operating Procedures (MOPS) to streamline the recommending committees._x000D_
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• Incorporation by reference, allowing value chain consensus to fast-track administrative changes and cutting process time by up to 24 months._x000D_
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Under the interim three-part system, it took forages, and oilseed type soybeans up to three years to move from their original Part I designation to Part III. Going forward, the registration system only has two parts and Part III becomes Basic registration._x000D_
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Moving from Enhanced to Basic will continue to be an option, but the process will be shortened to about one year or less. A big difference is that it no longer requires a regulatory change._x000D_
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Once the new system is implemented, Townsend says the new applications for a Basic seed registration will go directly to the Canadian Food Inspection Agency (CFIA). The CFIA takes the information provided along with a fee, considers it, and decides yes or no. The ‘window’ for making that decision is eight weeks._x000D_
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Basic registration is simpler and serves a double purpose._x000D_
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“Basic registration is for things like forages and crops where change is slow and resources are limited,” she says. “It also is for situations that are the opposite — where change is very quick, where you need expeditious registration, or where you just don’t have the ability to bring together a recommending committee, or for where the industry thinks it isn’t necessary. It’s good to have that option as well.”_x000D_
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Enhanced registration will be very different from Basic, but streamlined compared to the past._x000D_
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“Enhanced registration applications will proceed to an officially recognized recommending committee,” she says. “The committee will determine what information and data it needs to recommend the variety for registration. That system had to be very substantially streamlined. That process is underway. Recommending committees may still use parameters for performance, for quality and disease.”_x000D_
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Canada had 14 of these committees when the review began. Operating procedures varied widely with internal rules, by region and by crop type._x000D_
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“This is where we had all the diversity across the country. Some recommendations were specifically for some provinces and some crop kinds, some only had a quality guideline. In wheat, we were looking at a huge number of parameters around performance, quality and disease,” Townsend says._x000D_
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To standardize and simplify the committee system, MOPs are being implemented. The guidance document for recommending committees was sent out for feedback in 2013 to recommending committee members._x000D_
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After consultation, a second document has been drafted. It is going to a wider audience for a 30-day consultation period this summer._x000D_
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Townsend says, “Each committee has to comply with the Model Operating Procedures that lay out rules for voting, the kind of data, the years of testing, whether they can use internationally generated data or privately generated data, and more. These have begun to come into use and are making the process much more efficient.”_x000D_
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Another issue is whether the Ag Minister can accomplish the substantial regulatory changes before the mandated Oct. 19 federal election. It’s anyone’s guess. Townsend isn’t optimistic, noting that it’s already July._x000D_
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Implementing Incorporation by Reference is a significant challenge, she says. This is the commitment to take Schedule III out of the Seeds Act regulations and make it a stand-alone document, referenced in the regulations._x000D_
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Schedule III is the list of crop types that are subject to variety registration. When the reconstruction is approved by the government, the former Schedule III crop types would be “incorporated by reference” in the Seeds Act._x000D_
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“Incorporation by Reference means you’d still have to determine if there is consensus to make the change, but you wouldn’t have to go through Treasury Board and postings in the Canada Gazette and another consultation. That would help to speed things up for the seed trade,” Townsend says._x000D_
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Moving Ahead_x000D_
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“My estimate is that Incorporation by Reference will be in place by sometime in 2016,” says Mark Forhan, chief of the Variety Registration Office for the CFIA, in Ottawa, Ont._x000D_
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However, he believes, most parts of the turbulent past few years are already receding. Much has been accomplished and adopted._x000D_
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The minister’s directed review was led by AAFC, Strategic Policy Branch and resulted in “a lot of really good, constructive input” from stakeholders._x000D_
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“It was very clear that there was a need for change,” Forhan says. “We focused on the things that could be changed and on where there was consensus._x000D_
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“There were a lot of mixed opinions across the board on what people wanted but the net result was a proposal to the minister, and the minister made the announcement in April.”_x000D_
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Now, a process is underway to put the simplified system in place._x000D_
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Variety recommending committees are taking the lead in the changes._x000D_
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“They’ve taken a huge step in the right direction because they’ve been involved in this throughout the whole process,” Forhan says._x000D_
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“We’re hoping to have the Model Operating Procedures (MOPs) posted this fall, September or earlier, to formalize it — but by that time most committees already will have aligned with it,” he says. “They’ve had the document for over a year. So, the MOPs will be the first thing you actually see.”_x000D_
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The regulatory amendment process led by CFIA’s Seed Section will take months, at least, to produce the structure that supports the simplified system._x000D_
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Whenever the regulatory amendment changes are approved to formalize the new Basic or Enhanced structure for variety registration, they are more likely to arrive like quiet waters after a storm, peacefully._x000D_
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“The big changes that are going_x000D_
to have a significant impact on the industry already are, or will be, running in 2016. Oilseed soybeans and forage crops already have been moved into what will be called Basic registration. Stakeholders for crops that are left in Enhanced registration have indicated to us very clearly that, by and large, that’s where they intend to stay,” Forhan shares._x000D_
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“It was good to bring all of this up into review and ask the questions. It got each crop sector soul-searching and asking what’s best for the development of the crop, do we really want to stay in Enhanced or do we want to move to a lower regulatory stream,” he says._x000D_
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Basic and Enhanced crops will no longer be ‘locked in stone,’ in Schedule III of the Seed Regulations._x000D_
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“In the future, Schedule III will be removed from the regulations and exist as an official document within the CFIA, and there will be a proper process for making changes to the document,” Forhan says. “A rationale for changes will be submitted along with proof of consensus. It will remain an industry stakeholder-driven process and, at any point a crop can move regulatory streams._x000D_
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He adds, “From the feedback we’ve had, the various crop sectors very much want this in place. They want flexibility to change quickly if the situation changes. When finished, our regulations will be much more responsive to the industry and to the market.”_x000D_
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A Push for Exemption_x000D_
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As a former plant breeder and member of the Canadian Plant Technology Agency board of directors, Dave Harwood looks forward to the full implementation of the new variety registration system._x000D_
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“Any time there is an effort to streamline, it’s a step in the right direction,” Harwood says. “It can only help. Allowing plant breeding organizations to operate more efficiently and to reduce the time they spend on non-value adding processes, is helpful. It allows more resources to be deployed for real value-adding activities like plant breeding and seed production.”_x000D_
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Harwood, of Chatham, Ont., now serves as technical services manager responsible for the DuPont Pioneer seed technology product line management in Canada. He recently completed six years as an active CSTA board member._x000D_
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Harwood was part of a group of trade members that prompted CSTA to adopt the position that oilseed soybeans should be exempt from variety registration, similar to corn varieties._x000D_
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“Our position through the entire variety registration consultation process was one of moving all field crops, including oilseed soybeans, to the same treatment as corn where there’s no requirement for variety registration,” Harwood says. “Corn is exempt from registration._x000D_
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“We’re happy the government has moved soybeans to the classification it has now (Basic), it’s more business-friendly, but we would have liked a full exemption.”_x000D_
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Still, he says, the net result of the review and restructuring is positive. His efforts to move soybeans into a simpler classification were rewarded in the past year as the process was quicker, and less onerous. “With the new classification for soybeans, we take everything except the information about performance from the provincial recommending committee and submit it to CFIA,” Harwood explains. “We didn’t need to wait for a committee to come to a ruling to initiate our application._x000D_
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“We weren’t constrained by committee timelines. It saved us months and workload, enabling us to introduce our seeds to the growers in time for the planting season. We are appreciative that soybeans have moved to that classification in the new system and view it as an improvement.”
