There’s something rotten in the state of Canada, and sections of the ag industry are up in arms about it.

On August 4, 2021, the Government of Canada announced it was delaying its decision on proposed increases to the Maximum Residue Limits (MRLs), including glyphosate, until at least the spring of 2022, and then provided some investment news. And then on August 15, 2021, a federal election was announced.

However, the earlier announcements have caused members of Canada’s agricultural world to raise a collective Spockian eyebrow in dismay.

Announced by the Honourable Patty Hajdu, Minister of Health, the Honourable Marie-Claude Bibeau, Minister of Agriculture and Agri-Food and the Honourable Jonathan Wilkinson, Minister of Environment and Climate Change, it was also explained that the Canadian government would begin consulting on specific provisions of the Pest Control Products Act (2002) to consider, among other elements, ways to balance how pesticide review processes are initiated in Canada and increase transparency.

Further, it was announced that a $50-million investment in Health Canada’s Pest Management Regulatory Agency (PMRA) and Agriculture and Agri-Food Canada’s pest management research, to be supported by Environment and Climate Change Canada, would be initiated.

The breakdown of monies:

• $42-million invested over three years in the PMRA to strengthen its human and environ- mental health and safety oversight and protection, including improving the availability of independent data to better support pesticide review decisions and the transparency of decision-making;
• $7-million invested to Agriculture and Agri-Food Canada—details not provided;
• $1-million to Environment and Climate Change Canada in supporting work, to accelerate the research, development and adoption of alternative pest management solutions.

The PMRA is a Canadian government agency specifically responsible for the regulation of pest control products, and is a branch that reports to Parliament through Health Canada. It provides access to pest management methods while also minimizing human health risks and harm to the environment by “using modern evidence-based scientific approaches to pesticide regulation, in an open and transparent manner.” The PMRA provides new product evaluation, post-market reviews, and performs compliance and enforcement working with provincial, territorial and federal departments.

Said the Honourable Bibeau, “With today’s announcement, we are confirming that no decision on any increases to pesticide limits on food will be made before next spring. Meanwhile, we will review the framework underlying the review process of the PMRA and strengthen its capacity to conduct those reviews. Furthermore, research investments announced today will also give farmers greater access to better products and to adopt new and alternative approaches to pest management that reduce risk while addressing the concerns of Canadians.”

The Honourable Wilkins added: “The Government of Canada showed its commitment to enhancing the protection of Canadians’ health and the environment by strengthening CEPA (Canadian Environmental Protection Act, 1999), including providing for a right to a healthy environment. I am pleased that we have now committed to further action by reviewing specific provisions of the PCPA (Pest Control Products Act) to enhance the transparency of decision-making, and to increase funding for science such as water-monitoring to support evidence-based decisions on the use of pesticides. I look forward to engaging with my colleagues to advance the protection of the environment.”

The decision to defer a decision on MRLs limits until 2022 has exasperated many in the Canadian agriculture landscape. While MRLs were established to ensure the food Canadians eat is safe, the government announcement, while hitting pause on proposed increases to MRLs, did single out glyphosate as why its review was put on hold.

Glyphosate is the main active ingredient in the widely used herbicide Roundup, used to control weeds and sometimes to help dry crops before combining, and is a relatively inexpensive but effective product.

 

The Back-Story

The delay to increase the proposed MRL limits concerns the chemical compounds glyphosate, picoxystrobin, dimethomorph, dicamba, ametoctradin, pyridate, mandipropamid, benzovindiflupyr, sulfoxflor, boscalid, sethoxydim, pyrozasulfone, bromoxynil, and flonicamid. It also affects the proposed re-evaluations of brassica hirta (mustard seed powder), sodium alpha-olefin sulphonate, and tebuconazole.

It should be pointed out, that despite the Government of Canada delaying the possible resetting of MRL limits, the non-decision does keep the limit as status quo—in other words, nothing has changed. The amount and the frequency of application remain the same.

MRLs for glyphosate, for example, will remain at: 15 ppm (parts per million) for oat groats, oat bran and rolled oats; 10 ppm for barley bran and pearled barley; five ppm for dry peas, chickpeas, wheat germ and wheat bran; and four ppm for dry beans and lentils.

Current Canadian MRLs—as well as the proposed ones—are set at levels well below the amount that could pose a risk to consumers, be it seniors, infants or adults.

MRLs are set by individual nations, globally, as standards for imported foods, meaning that Canadian farmers who export, are subject to that nation’s MRL limits, just as other nations exporting here are subject to Canadian limits.

In the Analysis of Glyphosate Residues in Foods from the Canadian Retail Markets between 2015 and 2017 published by the American Chemical Society in April of 2020, it was noted: “Health Canada determined that there was no long-term health risk to Canadian consumers from exposure to the levels of glyphosate found in the samples of a variety of foods surveyed. The high level of compliance (99.4 percent of samples with the Canadian regulatory limits) and the lack of a health risk for noncompliant samples indicate that, with respect to glyphosates, the food available for sale in Canada is safe.”

As part of its annual Joint Meeting on Pesticide Residues, in May of 2019 the Food and Agriculture Organization of the United Nations (FAO)/World Health Organization (WHO) recommended the use of new glyphosate MRLs for consideration.

Bayer CropScience then submitted an application that requested to align certain MRLs with those being proposed.

In response to Bayer’s application, Canada launched a public consultation on imported dry beans and peas, and tree nut glyphosate MRLs in May of this year.

Because the Government of Canada has delayed its decision on glyphosate, all proposed increases to MRLs currently under consideration by Health Canada will be paused until all evidence and submissions have been further reviewed and assessed.

Lisa Gue, national policy manager of the David Suzuki Foundation called the federal government’s decision to delay the decision on raising MRLs “an encouraging sign that concerns about pesticide regulation in Canada are at last being heard.”

As for the government funding issue, Gue added that it “could be a real game-changer” and that “Canada desperately needs a comprehensive, national water monitoring program for pesticides to support environmental and human exposure assessments, and a system for tracking pesticide use. This needs to be a priority.”

The Foundation aside, there is much consternation within the Canadian ag industry regarding the delay, with ire also raised over the federal government’s decision to invest $42-million in the PMRA.

As part of its 2019 Executive Summary, the Canadian Grains Council (CGC) stated that “Canada’s strength in science and innovation place within reach the ambitious agri-food export goals of the Government of Canada, and that PMRA will play an increasingly critical role.”

A virtual meeting held on September 2, 2021 by Canada Grain Council members and its partners —was a spirited affair as it sought to develop a coordinated advocacy approach to the political intervention.

 

Cry Havoc!

The Canada Grain Council called the government decision to delay along with its monetary investments a slippery slope, having noted that it is the first-ever intervention by elected officials in scientific decision-making at PMRA.

The concerns are even more poignant when put into context of a federal election having been called and three federal ministers making the announcement about the delay to the review of the MRL limits—a safe but otherwise scientifically-proven chemistry for farming.

Is it a self-serving decision? It depends on which side of the argument one is on.

According to the government of Canada, the MRL delay will only enhance the process and provide greater transparency to the review. Public perception within the agriculture community, however, sees it as political interference.

Recent concerns of urban voters around glyphosates, such as the herbicide Roundup, have some wondering if the MRL limits delay was a way to avoid controversy for the Government immediately prior to the election. (This magazine went to press before election day.)

Consider also that Health Canada is responsible for setting the MRL limits for pest control at limits below levels of global health mandates.

Gord Kurbis, Vice-President, Trade Policy – Crop Protection with the Canada Grains Council noted that Canada’s science-based regulatory system is among the best in the world, and it means that the food Canadians eat is safe.

He said that the Canadian agricultural sector depends on innovation and having access to safe and efficient tools to protect their crops and relies on the PMRA to make risk and science-based decisions on pesticides.

But, he noted, the Canada Grains Council and its members “are adamant that our regulatory process be left free of political interference.”

“While there is not enough detail in the Government’s recent announcement on the pausing of MRL assessments to determine whether this process is at risk, we do expect (the Canadian) government to allow science to prevail. We must hold ourselves to the same high standards we expect of like-minded countries around the world,” Kurbis stated.

He continued that the Council supports the Government’s focus on more transparency in the regulatory process. “This has the potential to bring even more confidence in our regulators and even greater public trust of our industry overall.”

Kurbis said that the Canada Grains Council is also pleased to see the PMRA receive more funding to support its reassessment process—including the monitoring of pesticide occurrence in water. “Canada’s grain value chain has been asking for this since 2019.”

Keeping politics away, Kurbis said that the Council advocates “for a science-based approach to regulatory decision-making. We know that when given a level playing field, Canada can and will continue to lead the world in the production and export of safe, quality food.”

Mitch Rezansoff, CAAR Executive Director added: “The PMRA is worldwide-regarded for its credibility and for its sound science approach. Glyphosate is a safe product used by our farmers, and all registration agencies worldwide recognize it as safe, too.”

He was less complimentary to the government of Canada’s recent announcement to add an advisory panel to the PMRA, however. “The Federal Government is politicizing—looking to have ideology within the PMRA, which lessens the PMRA’s independence.

“The PMAC (Pest Management Advisory Council) is a multi-stakeholder group that is already in place that fosters communication and dialogue among stakeholders and with the Pest Management Regulatory Agency (PMRA), and provides advice directly to the Minister of Health on policies and issues relating to the federal pest management regulatory system. A second panel or council is not required.”

The PMAC includes representatives from Agrium Advanced Technologies, Bayer CropScience, CropLife Canada, SC Johnson, Syngenta, BASF, DuPont Canada and more.

CropLife Canada, an Ottawa-based representative of crop protection companies creating plant biotechnology, pesticides and herbicides for both urban and agriculture use, concurred, and noted it had multiple concerns.

Pierre Petelle, President and CEO, CropLife Canada told CAAR Communicator: “Our sector is concerned with the apparent arbitrary decision to suspend certain MRL setting and the message this sends to our trading partners. While we support increased regulatory transparency, it is important that the regulatory process does not become politicized. The need to maintain a science-based, regulatory process is important for the vitality of the sector and the credibility of Health Canada/PMRA as a trusted regulator, in Canada and internationally.

“MRLs are established all over the world as a tool for facilitating global trade and are not an indicator of health and safety. For the sake of public confidence, it is important that this distinction be maintained. Canadians should be reassured that the food they eat is safe,” continued Petelle.

“As a major agriculture exporter, we rely on the harmonization of MRLs with other nations. In fact, the refusal of some nations to recognize MRLs can cause damaging non-tariff trade barriers. Canadian agricultural commodities face ongoing challenges when exporting to the European Union, where certain MRLs are lowered arbitrarily and without scientific rational. With the announcement of a suspension of changes to MRLs, we are left to wonder about possible consequences for Canadian agriculture exports. It is vital for our government to continue to defend and protect the integrity of the Canadian science-based regulatory system.

Patelle summed up, “In order to remain innovative, the Canadian agricultural sector needs access to safe and efficient tools to protect their crops. Pesticides are an important tool for farmers to produce sustainable, affordable and high-quality food. CropLife Canada recently released a report, Helping Canada Grow, which highlights the benefits of pesticides and plant breeding innovations.”