Letter on Low Level Presence (LLP) Policy to Agriculture and Agri-Food Canada and USDA


Date Sent
October 9, 2014
U.S.-Canada Bi-Lateral Working Group
Assitant Deputy Minister Fred Gorrell and Under Secretary Michael Scuse
Science-based Low Level Presence (LLP) Policy
120.54 KB, PDF

Dear Mr. Gorrell and Mr. Scuse:

We jointly write to emphasize the importance of a harmonized, science-based low level presence (LLP) policy. As a part of the Tri-National Accord, senior agricultural officials from Mexican states, United States (U.S.) states, and Canadian provinces met in Chicago, Illinois from October 7 to 9, 2014. This was the twenty-third in a series of rotating conferences intended to improve understanding and strengthen collaboration among the agricultural sectors of three neighboring countries.

In addition to discussion on a Tri-National basis, the U.S. states and Canadian provinces engaged in discussion through the U.S.-Canada Bi-Lateral Agriculture Accord Working Group (WG). One priority identified by the working group is the need for continued work toward the development of an internationally accepted, science-based LLP policy to more smoothly facilitate the trade of genetically modified (GM) crops.

LLP is defined as the unintended presence, at low levels, of GM material in traded commodities where the genetic event has been approved in at least one country, but not by the importing country. Trace amounts of approved GM crops may become mixed with other varieties or crops in that country during cultivation, harvest, transportation, storage or processing. Even when best management practices are strictly followed, an approved GM crop may be present at low levels in the traded commodities. With the increasing number of GM products being developed globally for commercial production and the preponderance of asynchronous approvals, low level presence is unavoidable.

For this reason that delegates at the Tri-National Accord held in Saskatoon, Saskatchewan in 2013 issued a joint statement, which was part of the Accord Communique, encouraging a show of leadership and continued cooperation between Canada and the U.S. to address the negative trade impacts of LLP through efforts including:

Working towards an effective, pragmatic and robust North American LLP policy;
Synchronization of regulatory approvals between Canada and the U.S.; and
Development of mutual recognition agreements to facilitate the timely sharing of information and collaboration among regulators to reduce duplication and increase the timeliness of safety reviews and approvals.

LLP is not a safety issue, but a regulatory one. The WG wishes to acknowledge the show of leadership and cooperation between our two countries for their advocacy work on promoting a global solution. Currently, zero tolerance policies impede the supply chain and disrupt trade. This makes it even more important for all governments to develop a pragmatic approach to managing low level presence. As we work with stakeholders and advance our interests with trading partners, provinces and states would be pleased to offer our assistance in promoting LLP initiatives internationally and building further awareness of approaches to managing GM events.

Minister Ron Kostyshyn, Manitoba
U.S.-Canada Bi-Lateral Working Group

Director Jamie Clover Adams, Michigan
U.S.-Canada Bi-Lateral Working Group