b'Respondents gave a thumbs-up to having oneSRM WHAT WE HEARD REPORT: national body establishing and determining the seed crop varietal purity standards to issue a seed cropREACTIONScertificate.The Canadian Food Inspection Agencys What We Heard report has elicited reaction by a whos-who of the seed regula-tory landscape. We interviewed three of them about what they Survey respondents said: think about the findings.Having a single national body has built trust in Canadas seed system in both domestic and international markets.The Canadian Seed Growers Association (CSGA)Lauren Cominshould remain as the one national body. Policy Director, Seeds CanadaNational consistency is important; one body is simpler and more transparent. Delving into the report, I cant say I found a wealth of value in it. To be honest, I didnt expect to. Its a tall order to distill allMultiple bodies will create confusion in thethe nuances into a survey for the public without a crash coursemarketplace as well as with Canadas internationalin regulatory intricacies. My expectations were deliberately low, partners. given the nature of the topics. This was crucial because whatThe entire value chain needs to be involved inunfolded in the report affirmed the complexity of the issues. setting field standards. Faced with the prospect of change in such a convoluted land-scape, the default inclination often leans towards maintaining the status quo.Specifically, the Incorporation by Reference (IBR) aspect stood out. Its a powerful tool for modernization and regulatory Reaction was mixed to removing Schedule I (Gradeamendments. Weve already seen its application in the Seeds Tables) from the Seeds Regulations and usingRegulations, where certain documents are subject to updates Incorporation by Reference. either by the CFIA or external entities. Its a highly effective tool, a point that might not be fully grasped by those who responded skeptically. Concerns about public trust and the fear that industry might have too much influence in making Survey respondents said: changes are valid but somewhat misplaced. The IBR processThey are concerned about accessibility of thedoesnt involve industry casually rewriting regulations at will. Incorporation by Reference (IBR) document. While acknowledging the challenges, I appreciate the neces-There was support for IBR if the CFIA remains insity for the broader public to comprehend the intricacies of control of the reference documents. these processes, which can be a daunting task within the scope Changes to the grade tables need to be carefullyof a general consultation. considered through the Canada Gazette process, which is more transparent and open than the IBR process. They are concerned that consultation on changes for an IBR document will not be broad enough.They felt farmers must be part of the consultation process for changes to the grade tables.Source: CFIA What We Heard ReportJANUARY 2024GERMINATION.CA 37'