International Trade committee  Yes, potentially there are. As I said, India has had the ability to impose an import duty on pulses, which had been done in the past. That's a protectionist measure to—

International Trade committee  Yes. We don't see, in the immediate term, any likelihood of it being imposed. We are trying to inject some long-term stability into the regulatory environment, and removing it takes it off the table at some point. India is investing in biotechnology to enhance its pulse production, they are protein-deficit.

International Trade committee  Thank you, Mr. Chairman and members of the committee. Thank you for the opportunity to speak to you today on your discussions around the comprehensive economic partnership agreement between Canada and India. Pulse Canada is the national industry association representing pulse growers as well as the processors and exporters of pulse crops that are exported to 160 countries around the world.

International Trade committee  Japan has its own system. Canada has its own system. Many countries around the world that don't have the technical ability rely on Codex, the international food safety standards body. It was set up in the sixties by the World Health Organization and the FAO, the Food and Agriculture Organization of the United Nations, to provide that food safety standard.

International Trade committee  No. I wouldn't want to look at it that way, because it's really an international community that comes together to set a safety standard. Taken to regulatory harmonization's natural end, it would be Codex that would establish one standard for the world. That would mean that governments and regulatory bodies around the world would have to defer to—

International Trade committee  Individual countries decide that they want to have their own standards in place, which I think is all right, but what we need to have is a harmonized approach in terms of the timing, the process, and the assessment of risk factors. Those could then be tailored to an individual country's need, but we're not going to have huge differences, four- and five- and ten-fold differences, in safety standards between one country and an international standard.

International Trade committee  I'll answer quickly. PMRA and the Japanese regulators seem to be working very well together. We receive advance notice from Japan when they plan to introduce or change MRLs, so it in fact is an example of a country that's working very well. I think where we could perhaps make some improvement would be to have Japanese regulators more involved in global joint reviews, so that they're more involved earlier on and work towards harmonizing their system with what other regulators in Europe, Australia, Canada, and the U.S. have now moved towards.

International Trade committee  Here's the challenge we have with Japan, in that Japan's regulatory system does not start looking at establishing an MRL, a maximum residue limit, until it's registered for use in Canada or the United States. The challenge is that farmers can legally use a product, but Japan does not have an established tolerance for that product and may not for a couple of years.

International Trade committee  Yes. And that's exactly the same system that Codex uses. What we are trying to push for across all crops, because we all face the same issue, is to basically push for regulatory reform so that there's a linkage, harmonization, and more mutual recognition of data. We're seeing that with global joint reviews in the registration of products.

International Trade committee  Well, I'll relay again my discussion with a member of the Japanese pulse importers from the trade side. He also feels that there is an interest in innovation and a strong interest in human health and environmental protection. We already are a big trading partner with Japan, so I think what we are doing is just talking about how we can expand that trade.

International Trade committee  We have been very supportive of the transportation policy direction that the minister and Mr. Merrifield noted back in March. As I said in my presentation, we've been working with a coalition of exporters from the coal sector, the automotive sector, forestry products, and fertilizers to talk about how we can make a good system work better.

International Trade committee  We have a very complex logistics system in Canada, especially if we take a look at pulse exports to Japan, which all go in containers. You can imagine the number of steps between moving them from a farm to a processing plant and arranging equipment—whether that be a container in an inland position or a hopper car or a boxcar—to move them to a port position where they have to be reloaded into ocean-going containers and booked on vessels, and we have to find space at the port for them.

International Trade committee  I haven't heard anything from the trade side that would suggest that the Japanese people or that Japanese trade is concerned about the standards we have in place. I'll give you my perspective. Traditionally regulators in all countries have looked at their responsibilities and have not worried as much about collaboration with other regulators.

International Trade committee  Thank you, Mr. Chairman and members of the committee. Thank you for the opportunity to speak to you today. Pulse Canada has been in existence for 15 years, and we have been steadfast supporters of bilateral trade agreements, because market access really is a prerequisite to our success as an exporting sector in agriculture.

Bill C-18 committee  Well, I think you raise some key points. The discussion around a service level agreement is to define performance, to find repercussions if performance standards aren't met, the performance standards that would be agreed to by a shipper and a carrier. So I think we'd look to service level agreements to define a lot of those performance metrics that were part of it.