b'Why our Novel Traits LegislationMust Protect Export MarketsEARLIER THIS YEAR, Health Canada initiated a public con- been much discussion of the need for Health Canada and sultation concerning Canadas novel food regulations.the CFIA to provide clarity on what makes a food novel. As a working science professional actively involved andIt seems likely that our position will align with those well-versed in issues around GM, commercial seed testingof Japan, Australia, the United States and several South and international standards, I am of the firm opinion thatAmerican countries. All these nations are headed in a Canadas novel trait/food regulatory framework was well- direction where products of gene editing will not be part conceived at its inception and is robust enough to dealof their GMO legislation, but they will still have oversight with the issues associated with gene editing in agricul- requirements.tural products. Other countries have yet to resolve how they will I agree that there is now sufficient data of safe use todeal with gene editing, and their existing legislation will support faster approval of what would previously havedefault to cautionary regulation on par with GM products. been considered novel traits. However, decisions on non- Until a global consensus is reached, Canada must prepare novelty status must be documented, transparent, and notto and initiate testing of exports for gene edited events left to voluntary disclosure by developers or distributors. irrespective of our decision on their novelty.Also, the application of the novel traits regulations,Canada has no domestic support mechanism in place as split between Health Canada and Canadian Foodto enable non-government access to certified reference Inspection Agency, does anmaterial of regulated breeder materials for use in diagnostic excellent job of protect- development or routine testing, as other countries have. ing domestic consum- An alternate system has just been implemented for wheat ers of food/feed andmidge refuge testing in Canada, whereby breeders work growers but failswith a laboratory of their choice supplying proprietary to protect exportmaterials to develop or validate needed diagnostics. Similar markets forarrangements are used for proprietary licensed GM events.seed or prod- If such a partnership were implemented with regard ucts producedto gene edited plants and products, this would fulfill both from them. the need for more information beyond what is publicly Both of thedisclosed from regulatory approval documents and the above need toneed for reference material.be addressed. If we dont, Canada risks incidents akin to the past There hasFP967 CDC Triffid contamination of flax exports.KIM KENWARDRESEARCH & DEVELOPMENT MANAGER, 20/20 SEED LABSKim@2020seedlabs.ca|@2020SeedLabs|2020seedlabs.caSEPTEMBER 2021 GERMINATION.CA 27'