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The consultation has closed, but this post is offered as a record of advocacy and policy reform discussions.
Temporary registrations permit use of pesticides before Health Canada receives all relevant data, completes assessments, or consults the public. This process has been subverting pesticide regulation for many years. The Commissioner of the Environment and Sustainable Development in the Office of the Auditor General reported “unsatisfactory” progress in 2008, addressing the heavy use of temporary registrations.
Elimination of the “temporary” or “conditional” option for new registrations would be a progressive step, but what about our long-standing backlog? Logically, Health Canada should nullify present temporary registrations until assessments and public consultations are complete.
Pesticide products with temporary registrations include 76 products, containing 34 different ingredients. For 18 products, Health Canada still awaits information from registrants – necessary data is indicated as “pending.” Past “pending data” has included crucial information such as neurotoxicity testing, and analyses of carcinogenic dioxin contaminants.
One current concern is neonicotinoid insecticides (“neonics”), that have serious impacts on pollinators. Twenty-four of the temporarily registered products contain neonics, including 18 combination products. The neonic list features imidacloprid, that was first “temporarily” registered in 1995. “Pending data” includes quantities of neonic measured in pollen and nectar, to further examine these effects. Other jurisdictions, such as the European Union and Ontario, have placed moratoriums on neonics.
As with antibiotics, resistance to heavily-used pesticides is growing. Industry response is to increase strength and numbers of chemicals in a product.
Canada typically only considers cumulative effects of pesticides in combination products when the mechanism of action is known and ingredients act in the same way. In practice, ingredients are chosen for their different, interacting modes of action, with hopes of synergistic toxic effects.
These complex interactions are not factored into Canadian pesticide assessment; therefore products with multiple ingredients are particularly concerning – new mixtures do not pass a complete suite of toxicity testing before registration. Applicants typically indicate that the ingredients do not interact, but the US EPA is taking action to deregister the herbicide mixture “Enlist Duo” following Dow’s claims of synergism to patent authorities. Enlist Duo is registered in Canada.
Prevent Cancer Now analysis of current pesticides with temporary registrations (as of January 20, 2016) indicates that they include:
Temporary registrations delay public consultation, and keep the public in the dark. The present standard is to provide access to test data only after public consultation and final registration. The Pest Control Products Act provides limited public access to test data for fully registered products, but protracted temporary registrations have denied access to this information. Final registrations may be challenged on the basis of the newly available information, but this is rare and has never been successful. The Parliamentary Health Committee (2015) recommended improving openness and transparency, to ensure that Canadians are able to provide meaningful and informed input into the decision-making process and to clearly understand decisions once they are made.
You may wish to copy and build upon the following text:
Subject: Consultation NOI2016-01
Re: Notice of Intent Regarding Conditional Registrations under the Pest Control Products Regulations
I support discontinuing granting of temporary, conditional registrations of pesticides, as currently proposed, and as recommended by the Parliamentary Committee (2015).
Temporary registrations put pesticides on the Canadian market, in our environment and in our food, with neither full assessment nor public consultation.
I also support nullifying current temporary registrations, as they include pesticides that are not permitted elsewhere, as well as mixtures that require thorough assessment because of interactions between multiple active ingredients.
The Parliamentary Committee also recommended improving openness and transparency, to ensure that Canadians are able to provide meaningful and informed input into the decision-making process and to clearly understand decisions made. For this, we need comprehensive, rigorous, systematic scientific reviews, and access to relevant data during consultations.
Your full name
Organization, if applicable
Complete mailing address, or email address
Please copy or share your letter with email@example.com, so we can track input.
Meg Sears, PhD
Chair and Science Advisor, Prevent Cancer Now