b'CSGA SPONSORED CONTENTresponsible for oversight of the entire process. Thisprocess and outcomes. While a renewed public-private would provide additional flexibility and enable innovativepartnership is key, and the industry is ready to take on options for system oversight resulting from digitalizationmore responsibility, continued investment by CFIA in the and other emerging technologies.Seed Program is key to support a robust and competitive Given the current role of Seeds Canada (as the suc- Canadian agriculture sector. cessor organization to the Canadian Seed Institute) in the oversight of the RSEs and accredited labs, CSGA wouldRecommendation: The CFIA should increase its work closely with Seeds Canada and the CFIA to exploreinvestment in science support for the Seed Program, options to design the new system. commit to continued engagement in international standards development organizations, and commit to succes-Recommendation: Common seed of cereals, pulses,sion planning to ensure that appropriate and adequate human and oilseeds should be subject to strengthenedresources are available.regulation to meet minimum standards for purityCFIA should continue to invest in its Seed Program and and germination. the laboratories that provide science support, particularly Common seed of cereals, pulses and oilseeds is notvariety verification testing given the fast pace of innovative regularly monitored, nor are the regulations consistentlyplant breeding techniques. CFIA is encouraged to explore enforced by the CFIA.opportunities for inclusion of biochemical and molecular CSGA proposes that common seed should either beinformation in the definition of variety and the determina-sampled, tested, and graded similarly to pedigreed seedtion of varietal identity. Doing so will help keep Canada or, as an alternative, they should be sold only by personsan international leader in promoting new technology. known to the regulator without a grade name. This wouldThe ongoing presence of CFIA officials in interna-enable tracking by the regulator with the option for occa- tional standards development organizations (such as the sional inspections to ensure basic quality is being met toInternational Seed Testing Association, Association of protect the buyer of the seed. The CFIA could respond toOfficial Seed Analysts, OECD Seed Schemes, Association complaints and take compliance action on those who sellof Official Seed Certifying Agencies, and the American seed that does not meet minimum requirements. Association of Official Seed Control Officials) is crucial. Staying engaged at these international venues allows for Recommendation: Common seed of small-seededenvironmental scanning and building relationships, which agricultural crop kinds should be sampled, tested,benefits the Canadian seed sector and Canadian agriculture. and graded by people authorized to do so, as cur- Finally, by committing to succession planning, the rently done for pedigreed seed. CFIA will ensure the Seed Program is adequately staffed. Common seed of small-seeded agricultural crop kinds is sown widely in a variety of growing conditions. It isCONCLUSION: THINKING BIGa particular risk for the introduction and spreading ofCSGAs mission is to advance the seed sector and, with its weeds. Therefore, common seed of forage grasses andpartners, deliver and promote a flexible, responsive, and legumes should be subject to a higher standard of pro- cost-effective seed certification system supporting Canadian duction and oversight and be sampled, tested, and gradedagriculture. However, Canadas seed regulatory framework is by authorized parties. complex and sometimes not well understood. Now is the time Much of this seed is already processed by RSEs, andto talk with colleagues about what a modern seed system for the current Seeds Regulations specify that it be tested byCanada looks like. What is working? What isnt? A robust and a recognized lab. However, there are no requirements forresilient seed system is essential to all Canadians.record-keeping or samples to be retained unless an RSE has processed the seed. Common seed of small-seededPlease do not hesitate to contact CSGA at (613) 236-agricultural crop kinds should be subject to similar qual- 0497 or email communications@seedgrowers.ca with any ity controls as pedigreed seed. questions or concerns. CFIA COMMITMENTSSeed Regulatory Modernization has been described as a once-in-a-generation opportunity to review and revise Canadas seed regulatory framework. A lot is riding on the JULY 2021 GERMINATION.CA 29'