Saskatoon, Saskatchewan
April 12, 2007
The
University of Saskatchewan's Crop Development Centre barley
breeding program has been developing low phytate barley for a
number of years, and in February 2006 received unanimous and
unqualified support for registration from the Barley and Oat
Subcommittee, Prairie Registration Recommending Committee for
Grain for our first low phytate barley variety, identified as
HB379.
This type of barley is a
significant innovation and would have a significant impact on
the Canadian monogastric (swine and poultry) feed industry. The
lower level of phytate and hence higher level of available
phosphorus means lower input cost for the feed industry due to
the reduced need for phosphorus to be added as dicalcium
phosphate, and/or less enzyme supplementation to break down the
phytate. As phytate also binds minerals, low phytate barley has
higher mineral availability and thus a reduced need for mineral
supplementation. Most importantly, low phytate barley means less
phosphorus in animal effluent. Thus, not only does the low
phytate trait offer a potential economic advantage via lower
production cost, but it offers a partial solution to the issue
of phosphate pollution from livestock operations, thus providing
both economic and environmental benefit in the same package.
Unfortunately, to date we have
been unable to register and release HB379 low phytate barley
under the normal variety registration procedures for a feed
barley variety in Canada. The
Canadian Food Inspection
Agency (CFIA) has, without any sound scientific rationale or
consideration of relative risk, ruled that HB379 is a “novel
feed”. Despite more than eight months of repeated efforts on our
part to provide the CFIA with sound scientific rationale as to
the error of their decision to regulate HB379 in this way, we
have been unsuccessful.
It is our scientific opinion that
Feed Section's ruling that HB379 must be treated as a “novel
feed” is unreasonable. The lack of any evidence of harm that
would result from registration of this new barley variety, the
significant potential environmental and nutritional benefits of
this new barley variety, the existence of livestock feeds in
Canada with much lower phytate and much higher levels of
available phosphorus, the fact that levels of phytate and
available phosphorus are not even routinely evaluated in
Canadian feed, while also noting that barley varieties with this
same trait are now available to competing farmers in the USA,
lead us to this conclusion.
This issue is much larger than
just HB379 barley. The rigid interpretation of the definition of
novelty by the CFIA essentially means that any new innovation or
significant change to any crop subject to registration may be
caught in this regulatory minefield, rendering useless much of
the innovation delivered to the agricultural industry via plant
breeding.
In view of this roadblock in the
development and further availability of low phytate barley for
the benefit of Canadian agriculture, we are holding an open
meeting to discuss this specific case and the broader issue of
“novelty” with our R&D funders, our crop and livestock industry
collaborators and any other interested parties as follows:
Monday, April 23, 2007
1:30 pm
Room 2E25, Agriculture Building,
51 Campus Drive
University of Saskatchewan
Saskatoon, Saskatchewan
We invite and strongly encourage
you or a representative from your organization to attend this
meeting. We will outline what low phytate barley is, what its
potential application and benefits are, how we went about
producing it, and the unsuccessful and frustrating process we
have gone through over the past nine months in discussion with
CFIA, including the science and logic-based rationale we
provided to them to demonstrate that their decision is both
unnecessary and unsound. We will then entertain discussion on
next steps in our efforts to provide this valuable new
innovation to Canadian agriculture.
Please advise us if you plan to
attend at 306 966 5855, or email
brian.rossnagel@usask.ca.
We look forward to seeing you and
having your input on April 23, 2007.
Sincerely yours,
Brian Rossnagel
Barley & Oat Breeder, Crop Development Centre, University of
Saskatchewan
Graham Scoles
Associate Dean Research, College of Agriculture and
Bioresources, University of Saskatchewan
Dorothy Murrell
Managing Director, Crop Development Centre, University of
Saskatchewan
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