Written by Bryan Embree for presentation to the House of Commons Standing Committee on Health Hearing on the Labelling of GM Foods - 2002.

The Ontario Public Health Association has several concerns about genetically modified organisms (GMOs) in our food supply. The complete discussion can be found in our position paper entitled Protecting our Food Supply: Public Health Implications of Food Biotechnology [PDF, 161kb].

In particular, we are concerned about the long-term health impacts of GMO food consumption on the Canadian population and our ability to determine these impacts under the current system. We are not opposed to the production of GM food if it is safe, but we realize that the only way to determine if it is truly safe, in the long term, is to monitor, over time, the health of Canadians who consume it. We understand that tests are conducted by Health Canada that determine the presence of toxins and allergenic proteins in GMOs, and that, if discovered, these products are not permitted to enter the marketplace for human consumption. We applaud that effort since it is an integral part of a short-term monitoring process that must be in place. What we are concerned with, however, is the long-term impact of GMO food consumption on humans.

Currently, there is no way to monitor the long-term effects of GM food consumption on the population. All research methodologies require "variables" for assessment purposes. As it is, there is no variation in the population on the issue of GM food consumption - most, if not all Canadians are consuming GM foods, unwittingly and in unknown quantities. Any long-term research (monitoring) of the effects of GM food consumption on population health requires the identification of at least two groups - a group composed of consumers of GM products and a group that consists of non-consumers. It is out of the two groups that the "variable" is created for assessment purposes.

It is our strong belief that, given choice, there would be a reasonably large segment of the population that would chose not to consume GM food products, given the various uncertainties, including possible health effects, that could be associated with its consumption. The question of "choice" is at the heart of the matter. Choice requires options. As it is, no one in Canada knows what they are consuming and the only way to rectify this problem, which is also the only way to make long term research possible, is to mandate the labelling of GM food products.

Notwithstanding the fact that mandatory labelling may yield some economic consequences, the fact is that public safety must be weighed against these costs. The GM food issue is a unique situation in the marketplace - with all other products consumers have the option of purchasing the item or not. Normally, consumer demand determines the success of products in the marketplace. Here, we are purchasing GM food as a society, not as individuals. We understand that, in this unique circumstance, market force determinations of the success of GM food products does not operate, and, as a result, it is incumbent on regulators to intervene to create "choice" outside of normal market mechanisms.

We are not suggesting the GM food production be discontinued. We do recognize, however, that without "choice" there will be no opportunity for research on the long-term effects of GM food consumption on the population of Canadians. We assert that the Canadian government, as the body responsible for agriculture in Canada, must take the cautious, thoughtful and planful route to permitting GMOs into our food supply. The next generation of GM foods will be far more complex than what exists currently, leading to increasing and more fundamental alterations to food items. Given the obvious risk involved in this magnitude of alteration of our food supply, we believe that the Canadian government, as a protector of public interest and public safety, must implement a plan for the long-term monitoring of the effect of GM food consumption that mandates labelling as the vehicle for doing so. There is no other way.

I am, personally, a member of the Association of Public Health Epidemiologists of Ontario (APHEO). I work in the Health Department in the Region of Waterloo in the role of epidemiologist. There are about 36 of us in Ontario in the various health units, and many more across the county. Our role is to describe patterns of disease and to undertake research into the causes and consequences of presumed risks to health. Under the current GM food implementation plan, there is no possibility for public health epidemiologists to perform the much-needed assessment of the long-term risk of GM food consumption on human health. We understand that the long-term risks can be quite different from short-term risks. There are many examples in human health studies that show major differences in outcomes between the long- and short-run. We, as a group, are trained in the various methods and methodologies of research. We have the tools at our disposal to conduct research of various kinds, but, in this instance, we can not procure the required data to proceed with this research. We cannot separate groups of consumers of GM food products from non-consumers, the basic prerequisite for the assessment of long-term effects. Without this ability, no long-term monitoring can occur. Clearly, without the "choice" provided through the labelling of genetically modified foods, public health epidemiologists will never have the ability to conduct long-term research into this most fundamental health issue.

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