A 2016 Action Alert
Well, the Super Bowl was fun!
Now we can tackle Health Canada’s end-runs on pesticides legislation and regulation, as described by the Commissioner for the Environment and Sustainable Development.
A Regulatory End-Run around a new, protective “uncertainty factor” introduced in the revised Pest Control Products Act (2002).
This was intended to cover inevitable uncertainties, because it is unethical to feed pesticides to pregnant women to see what happens to their children and subsequent generations. In the revised Act, pesticides exposures were to be lowered by a factor of ten around homes and schools, and to protect the most vulnerable, because of innate susceptibilities. Pregnant women, infants, children, women and seniors are among the most vulnerable. Use of this “PCPA factor” would have reduced or eliminated some common pesticides. In response to a request from Health Canada’s Pest Management Regulatory Agency (PMRA) for input in 2007, the Environmental Health Committee of the Ontario College of Family Physicians argued hard that this factor was a bare minimum requirement. Industry representatives flew to Ottawa, argued the opposite, and apparently won the day. The recent pesticides audit by the Commissioner for the Environment and Sustainable Development found that the factor was only used one time out of ten.
A recent example is Atrazine herbicide, that is proposed for continuing registration, with no application of the PCPA factor. The herbicide is being re-evaluated, because it was banned in the EU for exceeding 0.1 µg/L (micrograms per litre) concentration in groundwater. Canada’s groundwater guidance level is 5 µg/L – 50 times higher than the EU standard. This was calculated based upon experiments showing reduced body weight of offspring, and increased risks of ovarian cancer and lymphomas (classified as possible carcinogen), but no PCPA factor. The high permitted Canadian water concentration is not expected to be exceeded, so Atrazine is proposed for continued registration. Direct human scientific evidence is skimpy, but Atrazine gained notoriety following a series of studies, culminating in a report of functional feminization of male frogs, that reproduced by mating with another genetic male.
Contact Health Minister Philpott, asking Health Canada to respect the pesticide assessment precaution that was introduced in 2002 (see suggested text below*).
A Due Process End-Run with temporary pesticides registrations
Products have been approved for use for decades, despite:
- lacking answers to important scientific questions (this is why the registration is temporary),
- zero public consultation (consultation occurs after all the science is in hand), and
- secret scientific data (data is only available to the public after final registration is granted).
Although existing temporary registrations (granted up to 20 years ago!) are continuing, you can support ending new temporary registrations.
Health is losing out
Other end-runs include long delays between conclusive decisions that risks are unacceptable and pesticide bans. One example is Dursban (contains cancer-causing, neurotoxic chlorpyrifos), that was slated for a ban in 2000. In 2015, Edmonton still used Dursban to kill mosquitoes, having acquired Winnipeg’s leftovers after it abandoned the practice. According to Pesticide-Free Edmonton, contrary to the label and claims of the City, Dursban is sprayed in populated areas. Contravening the label is against the PCPA – i.e. against federal law.
[Thank you for taking action today!]
Meg Sears, PhD
Chair, Prevent Cancer Now
*Suggested text – it is great if you add your personal touch!
Health Minister Jane Philpott
Dear Minister Philpott:
In 2002, Parliament and the Senate passed a revised Pest Control Products Act, that included a new “uncertainty factor” (PCPA factor) to ensure that pesticide exposures would be lower, to protect vulnerable populations. This factor addresses the unknowable – what happens to people, who cannot ethically be experimented upon.
In her recent audit, the Commissioner for the Environment and Sustainable Development revealed that this factor was only applied one time out of ten. Please instruct the Pest Management Regulatory Agency to apply greater precaution, to be consistent with the intent of Parliamentarians and Senators when they passed the Pest Control Products Act (2002).
The recent re-evaluation of Atrazine is one example of proposed continuing registration of a pesticide that may cause cancer, with known endocrine disrupting effects, based upon an assessment that discounts the PCPA factor.
I also believe that organic agriculture, practiced for untold generations, can provide solutions to pest problems, and so I object to the slow pace of reassessments and discontinuation of pesticides that pose excessive risks.
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