b'COMPARING CSGA, SEEDS CANADA RESPONSES TO THE FIRST SRM SURVEYIn response to the first Seed Regulatory Modernization survey released in February, the Canadian Seed Growers Association (CSGA) and Seeds Canada released their recommended responses to the questions presented, to help members craft their own responses to the Canadian Food Inspection Agency (CFIA). We boil down some of the big ones to show their respective stances on the biggest issues tackled in the survey:Doug Miller is executive directorLauren Comin is regulatory affairsQuestion: Should Canada continue to have a national variety for the Canadian Seed Growersmanager for Seeds Canada. registration system?Association.CSGA Response: Yes, the variety registration system continues to evolve and provides flexibility to the value chain to decide how feedback in order to develop recommendations for membervarieties are assessed/approved. As a grain exporting country, response. Canadas variety registration system also helps maintain market Seeds Canada Regulatory Affairs Manager Lauren Cominaccess and streamlines bulk grain handling, CSGA says.says Seeds Canada appreciates the addition of open text boxes Seeds Canada Response: This issue is too complex for a yes or to the survey format, allowing the public a chance to provideno answer. Variety registration should be made available to those specific answers to complicated questions. crops and value chains that see value in the process.For instance, with only a black-and-white answer to the variety registration question, it is impossible to account for allQuestion: Should Schedule III be removed from the the nuances and complexities involved in different crops andSeeds Regulations and instead rely on Incorporation by sectors, she says. Reference?Each crop and sector have their own unique challenges and CSGA Response: Yes, but we also need to consider the requirements, and we need to make sure that our regulationsunintended consequences of a crop kind opting out of variety can address these differences in a thoughtful and effective way.registration, specifically around the legal risk and challenges that Ultimately, we need to balance the desire to simplify regulationthis would pose to certifying seed lots as well as our international with the need for flexibility for future innovation, to create anobligations.environment that supports the success of our entire industry.Seeds Canada Response: Yes, but a process is needed to ensure For its intent and purposes, Seeds Canada believes partici- updates are performed. Seeds Canada recommends forming an pation/placement within a national variety registration systemindependent seed stakeholder advisory body (what it calls an should be decided on a crop-by-crop and crop-by-use basis byIndependent Standards Setting Body/ISSB) to vet updates and the stakeholders of that crop value chain. When it comes tofacilitate industry consultation.having one national body in charge of certifying seed, Seeds Canada supports separation of standard setting and serviceQuestion: Should Canada continue to have one national body delivery by a single stakeholder group and has already proposedestablishing and determining the seed crop varietal purity its idea for an Independent Standards Setting Body (ISSB) tostandards to issue a seed crop certificate?allow for inclusive governance, better reflecting the diversity of CSGA Response: Strongly Agree. CSGA has delegated authority the sector. under the federal Seeds Regulations to set varietal purity For Comin, the fact that the findings of two other SRMstandards/certify seed crops. Separating standards and service task teamsseed testing and common seedhave yet todelivery not only worsens current inefficiencies, but also risks be released means there are a lot more discussions yet to belower standards and higher costs.had. Two other task teams relating to information and import/export of seed had yet to begin their work at press time. Thats Seeds Canada Response: Agree/Strongly Agree. However, a lot more work to be done before the process comes to its com- Seeds Canada disagrees with this body answering to a single pletion in 2025, Comin notes. stakeholder group within the seed value chain (i.e. CSGA), which We need to ensure that any changes we make will provideit says is a conflict of interest. Seeds Canada is opposed to any more flexibility and not less. While there is a lot of focus onsituation where government delegates both the authority to set removing red tape, we need to be cautious and understand thepolicy & the authority to enforce that regulation to the same entity.potential impacts of these changes, Comin says. 16GERMINATION.CAJULY 2023'