Seeds Canada has released its responses to the Canadian Food Inspection Agency’s winter survey on Seed Regulatory Modernization. According to Policy Director Lauren Comin, Seeds Canada hopes to shift the focus of the SRM process to ensure the best outcomes for the sector as a whole.
“Instead of simply rearranging the existing system based on what’s available, we should have started with a clean slate, and asked ourselves: ‘What does the seed sector, and more importantly, our customers, truly need?’ I wish the process had begun with that blank page approach. However, I understand that this might not have been in everyone’s best interest, as some of the current practices might not have fit into the new vision,” she says.
“Ultimately, it’s about shifting the focus from what we have to what we need.”
Seeds Canada’s 31-page response document was preceded this week by a shorter summary document. Both address the questions put forward by the CFIA in its latest survey dealing with variety registration, seed testing, common seed and seed exports and imports. It also includes alternative proposals that were submitted through the SRM Working Group.
Big-Picture Questions
In addressing CFIA’s “big picture” questions at the end of the survey, Seeds Canada is advocating for a path forward that emphasizes innovation. A significant issue for Seeds Canada is CFIA’s question of an industry advisory committee; CFIA is asking if a standing advisory body, providing recommendations and input to the CFIA on regulations and policy, should assist in future modernization and amendments to the Seeds Regulations. It also wants to know if survey respondents think an advisory body should work with the CFIA to recommend and set all standards, with CFIA ultimately being responsible.
Seeds Canada supports both ideas, and Comin says it looks forward to issuing Dr. Erin Armstrong’s report on Seeds Canada’s concept of a Multi-Stakeholder Advisory Committee (ISSB) that was announced late last year.
“This initiative is designed to benefit not only Seeds Canada’s members but also a broader spectrum of stakeholders. We wanted to ensure that we engaged with individuals outside of our usual circles, avoiding the trap of an echo chamber. Thus, we sought someone who could reach out to those who might not typically participate in our meetings or calls,” Comin says.
Seeds Canada’s aim is for the proposed advisory committee process to encompass perspectives from those who might still be affected but aren’t actively engaged with Seeds Canada. This ensures a more comprehensive understanding of the issues at hand, Comin says. “Additionally, we’re exploring processes beyond the seed regulatory space, recognizing that advisory groups like this have been successfully utilized in agriculture and other sectors.”
Data Safety and Privacy
When it comes to the survey questions on data collection within the SeedCert platform, Seeds Canada does not support the collection of additional information through further regulation. “Any collection of data by an alternative service provider that is over and above what is needed to provide that service, should not be enabled through regulation,” says Comin.
“Concerns about data safety, ownership, and potential future charges for accessing the data haven’t been adequately addressed by CSGA. They have been very dismissive of these concerns. It’s not a matter of distrust specifically towards CSGA; rather, it’s a broader concern about data security and proper usage.
Past data breaches in various sectors, including large corporations, credit card companies, and government agencies, highlight the need for caution,” she says.
“Despite robust security measures, breaches still occur, raising questions about the security of data collection and potential additional costs to the seed system. It’s essential to scrutinize the implications of collecting and managing data, regardless of the organization responsible, to ensure data security and prevent unnecessary costs.”
According to Comin, Seeds Canada recognizes that the current SRM process won’t immediately result in regulations that will put Canada on the leading edge and ready for the rapid onslaught of innovation that is sure to come.
“Seeds Canada has concerns that the process is not going to result in the changes that the industry needs. If we end up needing another seed regulatory modernization consultation in five years, that will signify failure of the process,” she says.
Seeds Canada encompasses all significant players in the seed sector, Comin notes — from seed growers to analysts, developers, distributors, and everyone in between.
“When we formulate our positions, we do so with the sector’s best interests at heart. We’re not advocating for additional contracts or revenue streams for Seeds Canada in our recommendations. Everything we propose is based on extensive consultations with our members and stakeholders,” she adds.
In concluding its responses to the CFIA’s survey questions, Seeds Canada states that CFIA should follow internal government processes to identify services and programs that could be delivered by a third-party alternative service delivery provider at a lower cost and without any interruptions to service or international obligations.
“While CSGA is one option, they are not the ‘default service provider’. Also, their proposal to provide additional services must stand up to assessment by CFIA,” Seeds Canada’s summary document says.
Seeds Canada’s comprehensive survey response document speaks for itself, Comin says, and encourages seed sector stakeholders to read either the full document or the summary.
“The positions and arguments are solid. I don’t feel the need to oversell it because it simply makes sense. We’ve carefully considered the needs of our customers and approached this from a practical standpoint, acknowledging the increasing costs of farming and the necessity of embracing new technologies to remain sustainable in the face of climate change,” Comin says.
“For us, ensuring that farmers can readily adopt new technologies, particularly from within the seed sector, is crucial for sustainability and adaptation. We can’t afford additional barriers hindering progress, especially when it comes to regulations.”
To read Seeds Canada’s responses, click here to visit its website.
