Microsoft word - feedbackformcompletedcsta.doc

9.0 PROPOSAL FEEDBACK FORM
FEEDBACK FORM

Note: Following is a suggested form to provide feedback to the CFIA
regarding proposed changes to the Weed Seeds Order. Feedback
received in any format is welcomed and will be reviewed by CFIA
officials.
Please respond by September 15, 2011
A. DEFINITIONS:
1. Prohibited Noxious: The species is not yet present in Canada, or is present and is under official control as it has not yet reached its full ecological range. Official control is used to prevent further spread of the species and with the goal of eradicating the species. The species must be a weed whose presence in seed could affect the value and/or intended use of the seed lot; and/or could have potential impact on the economy, human health and/or animal health. This determination would be based on a Pest Risk Assessment type process. The species must have identifiable seeds that can be visually distinguished from those of other species, or in rare instances, from entire genera. 2. Primary Noxious: The species is present in Canada and has not reached its full ecological range. The species must be a weed whose presence in seed could affect the value and/or intended use of that seed lot; and/or could have a potential impact on the economy, human health or animal health. This determination would be based on a Pest Risk Assessment type process, when deemed to be necessary. The species must have identifiable seeds that can be visually distinguished from those of other species, or in rare instances, from entire genera. 3. Secondary Noxious: The species is relatively common and widespread in Canada. The species must be a weed whose presence in seed could affect the value and/or intended use of the seed lot. The species must have identifiable seeds that can be visually distinguished from those of other species, or in rare instances, from entire genera. CSTA accepts the proposed definitions for Class 1 – Prohibited Noxious and Class 2
Primary Noxious, but only if all of the species placed within those classes truly meet
the definitions. That is not the case with the CFIA draft proposal as it currently exists.

DO NOT SUPPORT the proposed definition for Class 3 – Secondary Noxious

This class should be more clearly defined than proposed. We support the following
definition:
“The species is relatively common and widespread in Canada. The species
must be a weed whose presence in seed could affect the value and/or
intended use of the seed lot. The species must have the potential to be a
serious weed in certain crops, but be relatively easy to eradicate with current
crop and seed plant management practices. The species must have
identifiable seeds that can be visually distinguished from those of other
species, or in rare instances, from entire genera.’
B. STRUCTURE:
1. Currently Primary Noxious does not apply to Grade Table XIV (Lawn or turf mixtures of two or more kinds of seeds) or Grade Table XV (Ground cover mixtures composed of seed of two or more kinds other than cereal mixtures, forage mixtures, and lawn or turf mixtures). Should Primary Noxious apply to Grade Table XIV (Lawn or turf mixtures of two or more kinds of seeds) of Schedule I? __________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Applying Class 2 to tables XIV and XV would have extremely negative consequences for
Canada’s turf seed sector. Currently, on average 5 – 10% of the turf seed produced annually
contains one or more of the following weeds: Couch Grass (Quack Grass), Cleavers and
Canada Thistle. However, under the current Weed Seeds Order structure, turf grasses that do
contain these weeds are still marketable, and provide a less expensive option to consumers
who wish to establish ground covers or revegetate damaged areas. It is important to note
that lawn and turf does not generally produce seed because it is cut regularly.
CFIA’s proposal to apply Class 2 to all tables would make these grasses unmarketable. The
economic damage to the industry would be extensive. Growers would exit the industry for
fear of producing an unmarketable crop; seed companies would find it very difficult to secure
supplies for their historical needs, and these supplies would almost certainly come at a much
higher cost.
2. Should Primary Noxious apply to Grade Table XV (Ground cover mixtures composed of seed of two or more kinds other than cereal mixtures, forage mixtures, and lawn or turf mixtures) of Schedule I? Under the current Weed Seeds Order structure, grass seed mixes that do contain these weeds
are still marketable, and provide a less expensive option to consumers who wish to establish
ground covers or revegetate damaged areas. CFIA’s proposal to apply Class 2 to all tables
would make these grasses unmarketable. The economic damage to the industry would be
extensive. Growers would exit the industry for fear of producing an unmarketable crop; seed
companies would find it very difficult to secure supplies for their historical needs, and these
supplies would almost certainly come at a much higher cost.
3. Do you have any further comments regarding the proposed amendments to the Weed
Seeds Order that you wish to share? __________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ C. SPECIES PLACEMENT

1. Please provide feedback on species placement on the Weed Seeds Order by completing Scientific Name
Common Name
Agree Remove
/ Rationale
(Source: GRIN)
Classification
Proposed
Reclassify
(Weed Seeds
Classification
Order, 2005)
(June 2011)
Manitoba. Its seed has been found in imports from the EU for years. squarrosa (Boiss.) Gugler (=Centaurea virgata var. squarrosa) Crupina vulgaris (=Rhaponticum repens (L.) Hidalgo) Elytrigia repens (= Elymus repens (L.) Gould) Euphorbia esula Glyphosate tolerant Canola has made the weeds relatively easy to control in the field. Glyphosate tolerant Canola has made the weeds relatively easy to chalapense (= Lepidium chalepense L.) Lepidium draba subsp. draba (= Lepidium draba L.) Linaria spp. Senecio jacobaea (= Jacobaea Tansy ragwort vulgaris Gaertn.) Setaria faberi Silene latifolia subsp. alba noctiflora (Night-flowring Catchfly). Number of seeds producers and methods and ease of control are the same. They should be in Class 3 with Silene noctiflora remain not in the U.S. and the U.S. market
listed in
established in much of Canada and has likely reached ecological limits. Has little effect on seed establishment or quality. Daucus carota subsp. carota maritimus & R. acetosella) Amaranthus powellii S. Watson Powell’s amaranth Fallopia japonica (Houtt.) Ronse Decr.) Ricinus communis L. Solanum ptychanthum Dunal Eastern
10.0 IDENTIFICATION OF RESPONDENT

Affiliation: Canadian Seed Trade Association your own or,
On behalf of the Canadian Seed Trade Association
Suite 505, 39 Robertson Road, Ottawa, Ontario Please identify yourself by selecting from the choices below. Select all that apply. The Canadian Seed Trade Association represents the common interests of 130 member
seed companies. It is our sincere hope that CSTA’s input will be weighted to recognize
our structure and representation.

-------------------------------------------------------------------------------------------------------------------------------------------- The CFIA appreciates your time and effort toward improving the Canadian plant regulatory framework. Responses received during the consultation period will be reviewed and considered in finalizing the proposed changes to the Weed Seeds Order and any required regulatory amendments. Please note, however, that it may not be possible to respond individually to any comments received.

Source: http://cdnseed.org/wp-content/uploads/2011/08/WSOFeedBackFormCompletedCSTA.pdf