Office of the Auditor General, environmental petitions
Questions 17 and 18 for Health Canada, made precise.
The letter ·
Re: Petition 550 - clarifications requested
Hello,
Petition 550. Here is what questions 17 and 18 mean.
Question 17. "Living modified organism" has its meaning in Article 3(g) of the Cartagena Protocol on Biosafety. It is a living organism with a novel combination of genetic material obtained through modern biotechnology, as defined in Article 3(i). It covers the plants released in Canada under the 3 decisions named in the petition. Their seed and the plant material used in food and feed are included. The modifications are of 2 kinds: inserted foreign DNA, and gene edits that leave no foreign DNA. The question asks how Canada reports on both kinds to the Conference of the Parties. That covers the national reports under Article 26 of the Convention and the Biosafety Clearing-House.
Question 18. The question asks which department or agency has a duty to count or register the genetically engineered organisms released in Canada. The duty may come from an Act, a regulation, a Cabinet directive or a ministerial instruction. The instruments in issue include Part 6 of the Canadian Environmental Protection Act, 1999 and the New Substances Notification Regulations (Organisms). They also include Part V of the Seeds Regulations, the Feeds Regulations and Division 28 of Part B of the Food and Drug Regulations. The question covers plants, animals and microorganisms with either kind of modification. Where no instrument places that duty on anyone, the reply states so.
This exchange goes into the public record at https://dzyuban.com/legal/record/
Respectfully,
Danilo Dzyuban
The answer ·
Good morning,
Our contact at Health Canada has reached out to us requesting clarifications on questions 17 and 18 of petition # 550. Her email is below:
Following a meeting with the other related departments, we are seeking some clarification on specific wordings in Environmental Petition #0550 to help subject matter experts answer the questions properly.
In question 17, the petitioner seeks enumeration of "living modified organisms" released in Canadian territory. This term is extremely broad, given the definition of "organisms" and "modified" respectively. Could the petitioner clarify which types of "organisms" and "modifications" they are referring to for the purposes of this question?
In question 18, the petitioner seeks identification of "the mandate to enumerate genetically engineered organisms" in Canada. Could the petitioner clarify which specific mandate, authority, document, or legislative requirement they are seeking information about? In addition, could the petitioner clarify which types of "genetically engineered organisms" they are referring to in this question?
I will provide your clarifications to our contact once I receive them from you.Kind regards,