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We Hear You: Rewriting Circular 6

During the Canadian Seed Growers’ Association annual general meeting in July, the membership voted to update the Canadian Regulations & Procedures for Pedigreed Seed Crop Production, more commonly known as Circular 6, for the 2017 crop production year._x000D_
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While the motion was written with 2017 as the target, it is important that we take a cautious and balanced approach as we weigh the advantages and disadvantages of various options before proceeding. The reality is that modernizing Circular 6 is going to take time. It will require a multi-phased approach, and communication with all stakeholders has to be a critical part of the strategy._x000D_
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A Bit of History_x000D_
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Although its primary, traditional mandate is varietal purity of seed crops, the CSGA has been in the business of mechanical purity standards for over 90 years. The earliest version of Circular 6, from 1924, referred to “standards adopted by the CSGA in respect of purity of variety and kind, freedom from disease, vigour and uniformity of growth and maturity.” As early as 1929, CSGA standards specified that the crop must not have more than “one head of another variety or distinct type in an area containing approximately 10,000 heads” and “the same standard of purity in regard to other kinds of which the seeds are not easily removable by machinery.”_x000D_
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So, when we hear concerns that the mechanical purity standards are too high, and that the advances in cleaning and sorting technologies have not been accounted for, we are being asked to reverse a long history of tradition._x000D_
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Industry has told us that today’s optical sorters can clean seed much better than five and even 10 years ago, making it possible to separate seeds similar in nature._x000D_
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One example is wild oats in oats. Normally, a maximum of five wild oats in 10,000 oat plants is the maximum allowed.  However, over the past several years, a Wild Oats Research Project has permitted fields of pedigreed oats with up to 15 wild oats in 10,000 oats plants to be certified provided the seed has been cleaned to a Certified No. 2 standard._x000D_
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To get a better grasp on the whole issue of mechanical impurities in seed crops, CSGA is conducting an online survey of seed growers, variety developers and distributors, seed testing labs, CFIA and seed graders._x000D_
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One possibility that has been identified is to set standards where growers can opt in, but it’s not necessarily a requirement that is imposed. That’s just one option. This survey will tell us more and give us direction to best serve the industry as a whole._x000D_
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Short-Term Changes_x000D_
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In addition to the mechanical purity review, we’ll also look at the rules associated with industrial hemp seed production. Industrial hemp seed production was only legalized about 18 years ago. At the time the rules were written, everyone was very cautious. We looked to Italy and Ukraine, two countries with very stringent national regulations, and essentially built a system based on those standards_x000D_
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Since then, we’ve accumulated loads of experience, and there’s consensus that we could relax the requirements, which are overly burdensome and costly. We will look at this more closely to bring about changes while maintaining a high level of quality and providing assurances to producers without placing undue burden on seed growers and breeders._x000D_
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The other area that deserves attention is the certification of hybrid cereals. We’ve already seen hybrid rye come into Canada from Germany. In Europe, they are producing hybrid barley, and variety developers in both the United States and Canada are working toward commercializing hybrid wheat._x000D_
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While we do have some procedures in place for hybrid cereals, they are old. We will work to update those procedures and build in production method flexibility. One aspect of hybrid cereal seed production needing a thorough review is the potential requirement for hybridity testing._x000D_
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Long-Term Improvements_x000D_
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Increasingly, seed growers, assignees, licensed seed crop inspectors and others reference Circular 6 through the Internet, which provides an excellent opportunity for the CSGA to revamp the way that the rules and procedures for pedigreed seed crop production are presented. It will be possible in the future to have a digital document with hyper-links to definitions, best practices, photographs and other information to enhance Circular 6 and make it more useful._x000D_
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Those are a few of the pieces that we have already started working on or are thinking of, but thoroughly updating Circular 6 is going to take a few years and will require a multi-staged, multi-stakeholder approach. Please let us know what’s important to you by participating in surveys, responding to questionnaires, attending consultations or forwarding your views to CSGA._x000D_
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Mike Scheffel, Managing Director, Policy and Standards, CSGA

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