CAAR advocates agriculture needs with PMRA

Health Canada's Pest Management Regulatory Agency (PMRA) has posted a Notice of Intent regarding the process of modernizing its post-market pesticides program.

As CAAR members may recall, consultations took place between March 21 and June 30, 2022 based on a discussion document that was shared online titled: Further Strengthening Protection of Health and the Environment: Targeted Review of the Pest Control Products Act.

Transformation Steering Committee meetings, Technical Working Group sessions for different pillars, and meetings with FPT partners were also held.

All non ag NGO’s advocated following European Commission mandate of 50 per cent reduction of pesticide use in Canada.

A ‘What We Heard’ report titled Consultation on further strengthening protection of health and the environment: Targeted review of the Pest Control Products Act, was then published.

The first meeting of this second round was held on December 19, 2022, and focused on agricultural non-crop sectors and non-agricultural sectors, including Structural/Premise, Forestry and Woodlots, Livestock (honeybees), Companion Animals, Aquatic Uses, Turf (for turf pests), Indoor Plants/Plantscapes, and Antimicrobials.

Each of these use patterns have their own unique set of information needs and challenges including specialized products (e.g., termiticides, fumigants, rodenticides), marketing type (e.g., domestic class market versus commercial/restricted), complexity of the sector (e.g., livestock production – animal, premise, feed/fodder), limited use pattern and application data collected or available.

Many organizations participated in the process.  There was lots of discussion regarding: European Commission pesticide policy; California pesticide policy; retail reporting of sales to farmers – Spain; farmer online reporting of pesticide application – Portugal; and embracing COP15 Canadian commitments.

Health Canada says that it's a “Science-based focus” but they were open to receiving comments that were not science or data substantiated.

Health Canada also stated at the time that for ‘use scenario’s, frequency, degree of application (volume or per cent of area)’ it was difficult to collect real world data. CAAR believes that a significant volume of Canadian fertilizer and pesticide types, rates and application(s) data is captured online by crop insurance.

With the Notice of Intent the Health Canada website says "We heard from some stakeholders, namely pesticide manufacturers and user groups, that amendments to the Pest Control Products Act were not needed at this time and that much of the transformation agenda could be implemented through existing policy and regulatory channels. We also heard from some non-governmental organizations (NGOs) that the PMRA should undertake a broad review of the Pest Control Products Act, and several comments and suggestions were received in support of amendments to the legislation. This proposal, which complements several policy initiatives currently underway, is a key step as part of Health Canada's initiative to strengthen the protection of human health and the environment from risks posed by pesticides and improve transparency of its decision-making process." 

Health Canada says that it will focus its attention in the following areas:  T

  • Facilitate access to confidential test data (CTD), including for research and re-analysis purposes;
  • Increase transparency for MRL applications for imported food products;
  • Give the Minister the explicit authority to require the submission of available information on cumulative environmental effects and require the Minister to consider cumulative effects on the environment during risk assessments where information and methodology are available; and
  • Strengthen consideration of species at risk by giving the Minister the explicit authority to require the submission of available information on species at risk. 

Retailers will need to ensure they participate in this process as much as possible.  For more information, please contact CAAR Executive Director Mitch Rezansoff at 204-989-9303.

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