The Pest Management Regulatory Agency (PMRA)
Background to Regulatory Process
The management of pesticides was moved from Agriculture and Agri-Food Canada (AAFC) to Health Canada (HC) in 1995 and the PMRA was created under HC.In 2000, the PMRA initiated a review of all pesticides registered prior to 1995 and created a special review stream for lawn and turf pesticides under the Action Plan for Urban Use of Pesticides.
The original Pest Control Products Act (PCPA) came into force in 1980. It was Canada’s tool for regulating pesticides until mid-2006.
The old Act had been thoroughly criticized by the Commissioner of Environment and Sustainable Development, the Standing Committee on Environment and Sustainable Development, and many other groups and individuals across the country.
In response to this, the PCPA was revised, and the new Act received royal assent on December 12, 2002. By the time regulations were drafted, it came into force on June 28, 2006
One aspect of the old Act (and new) is that it states that pesticides cannot be advertised for their "safety." This was reinforced by the findings of Office of the Auditor General through petitions process.1Problems with PMRA:
Possible Conflict of Interest:
- Some $8 million or 25% of the PMRA's funding comes from the pesticide industry (source:
CTV W5: "The Perfect Potato" aired on October 25, 2002);
- Pesticide regulation was transferred to Health Canada to ensure protection of health, but the PMRA is yet to resolve its apparently conflicting dual roles of approving pesticides while also protecting human health.
Over-Reliance upon Industry Science:
- PMRA does not conduct in-house lab tests; rather it predominantly relies upon studies financed by the pesticide industry:
- Industry science is frequently not published in peer reviewed literature;
- Industry science is generally hidden from the public eye because the pesticide industry requests that the PMRA treat their studies as proprietary information;
- The PMRA has or is currently relying upon 80+% of pesticide evaluations and reassessments that originate from the United States2; and,
Questionable Regulatory Process:
- The government has an unenviable track record of approving pesticides only to later resort to phasing out their use due to mounting health and environmental concerns. Some phased-out pesticides include: aldrin, dieldrin, DDT, heptachlor, toxaphene, chlordane, endrin, Dursban, Diazinon, racemic Mecoprop (to name just a few);
- The PMRA does not necessarily know or evaluate the breakdown products or formulant chemicals;
- Room Without a View: the new Act now provides for a public Register of Pest Control Products (a public examination room). However, access to the industry's science is excessively restrictive, as outlined here. The PMRA's online Registry is available here;
- The establishment of a new National Pesticide Sales Database was announced by the PMRA in late 2006. After much delay, this database will be made available to the public, following data submission by the industry, expected late by 2008;
- 2,4-D developmental neurotoxicity study(ies) have not, as of November 2006, been received by the PMRA. According to the PMRA, they are not expected for at least another year. Despite public concern from the medical and independent scientific community, the PMRA continues to permit 2,4-D to be registered in Canada while lacking these crucial studies.
- There are currently no Canadian licenced medical doctors on staff at the PMRA (as of May 2006). The PMRA is therefore arguably lacking the properly medical knowledge necessary for adequately assessing the human medical consequences of pesticides;
- The PMRA largely relies upon rat studies. In April 2004 the genome of the rat was published in the prestigious journal "Nature". An important finding was that rats have genes that do not exist in people for detoxification of chemicals, and therefore are a poor model for toxicity testing. (There is a reason that rats can live in sewers and garbage dumps, and people cannot.) Dogs are much more sensitive to 2,4-D, but the dog data was put aside in favour of the more robust rats;
- The PMRA does not disclose pesticide formulants ("inerts") contained in a particular pesticide to the public, claiming that it is proprietary information from the manufacturers. Thus, the public is not told to what they are being exposed. Some of these formulants can be very toxic, perhaps even more so than the active ingredient(s);
- The PMRA's use of an "independent" science advisory panel is not an assurance that there is independence of industry financial ties (or a conflict of interest) -- rather the PMRA views "independent" as "indicating that the panel members of the Science Advisory Panel are independent of PMRA, in that none are PMRA staff members and that none took part in PMRA's assessment process"; and,
- There is no balancing of benefit and risk. There has to be proof of efficacy - that the pesticide does what it claims - but risk / benefit assessment doesn't come into it at all. What may be deemed an "acceptable" risk to one person may not for another.
- The Pest Management Regulatory Agency undertook to re-evaluate 405 registered and approved pesticides by 2006. By February 1, 2007, only 60 per cent of these had been reviewed or were being reviewed. Of these, 40 per cent were either expired or removed from the market and most of the other 60 per cent have had their permitted uses restricted. (as extrapolated from the PMRA's datasheet -- click here to view). The PMRA's datasheet reveals 246 chemicals (in the left column) have been reviewed or are in the process of being reviewed and 99 products in the far right column that have expired or are to be discontinued. Most of the remainder need new labelling with restrictions etc. (we at CHO thank Healthy Calgary for providing us with this valuable information)
What do others think?
- Canada's Commissioner of the Environment and Sustainable Development, Johanne Gelinas, conducted a comprehensive audit in 2003 which revealed that:
- Ottawa is not managing pesticides effectively, nor can it honestly say that pesticide use in Canada is safe;
- Too many pesticides are given temporary registrations despite significant data gaps;
- Temporary registrations are too frequently renewed, without review;
- Health Canada has done little to understand the health impacts of pesticides;
- In 2003, there were only 1 or 2 researchers within Health Canada itself doing pesticide research. (source: Neil Maxwell, Principal, Environment and Sustainable Development, Office of the Auditor General, Feb. 28, 2005 pesticide conference held at Ben Franklin Place);
- Of the more than 7000 pesticides ingredients registered in Canada, the vast majority were registered before 1995. These have therefore never been studied according to modern health safety standards. These standards were upgraded in the amended Pest Control Products Act (2002), but this is not yet in force [sic: it is now in force - as of June 2006]. Today's reassessments are still not as stringent as modern legislation would require. Children's high vulnerability to the smallest pesticide exposure, and cumulative effects of pesticides with similar mechanisms of toxicity are not fully assessed; and
- Current legislation does not require that pesticide formulations ("off the shelf" products) be tested, only their "active ingredients" are subject to scrutiny. Studies have found that many of the components may be even more toxic than the active ingredient.;
"The Committee firmly believes that a moratorium on pesticide use for esthetic purposes is necessary until science has proven that the pesticides involved do not constitute a health threat and some light has been shed on the consequences of their use in urban areas."
1. Office of the Auditor General, Environmental Petitions, Petition no. 87, submitted by Earth Action. Source: click here.
2. 80+% figure stated by Wendy Sexsmith, PMRA, at the "Standing Committee on Environment and Sustainable Development" on Thursday, October 23, 2003. Charles Caccia, Chair.