MARCH 2018 GERMINATION.CA 33 What is the cost of implementation? Who pays? TRACEABILITY It is at the heart of the next-generation seed system. In fact, traceability is — in many respects — the product of the seed system of the future. The green paper vision seeks to expand the strengths of the pedigreed system to all seed via a Product Profile (with all relevant information about every seed product for sale) and a new Seed Sale Listing System (tracking seed sold in in Canada, like MLS does for real estate). Is this the best way to bring the benefits of traceability to all players in the seed system? TIERED RISK ASSESSMENTS Today, new seed products are subjected to lengthy risk assessments and approval processes. This is the case regardless of the inherent risk of a new product that might be very similar to an already-approved product. As a result, innovations come to market slowly and smaller players opt out, as they lack the resources to navigate the unpredictable processes. Can you see a risk-based, tiered system making it more efficient to bring innovation to market? “The way things are today, with the high cost of bringing new plant genetics to market, we eliminate many of the smaller players. If we can allow some small- and medium-size players to stay in the game, that benefits us all.” Kevin Runnalls, President, Canadian Seed Growers’ Association Who determines level of risk? What do we mean by risk? Risk to whom? If there are ramifications as a result of a risk assessment, who is liable? Who is responsible in a case of novel trait that wasn’t assessed at a high enough risk level (example: Triffid flax)? Will early innovators be unfairly penalized if the risk of their innovation is assessed as too high? “When I think of malting barley or food-type export soybeans, for which you could in theory have IP-traceable programs that don’t actually use certified or pedigreed seed, I think the intent of everything in the green paper as it relates to protection of IP bringing all seed into the system is correct. We just need to ensure we think about any unintended consequences of the regulatory changes we make.” Jeff Reid, General Manager, SeCan How do we get common seed sellers into the system? How do we implement traceability of farm saved seed, and who pays for that?