Canadian pesticide regulatory system – Evolution over transformation

Canada has one of the most robust pesticide regulatory systems in the world. It’s a system that is held up internationally as a gold standard for its science-based underpinnings. Health Canada’s Pest Management Regulatory Agency (PMRA) puts the protection of human and environmental health at the forefront of its decision making, while ensuring that safe and effective pest control products get to market in Canada to support the important work farmers do to grow our food.

In the context of the current dialogue both domestically and internationally around food security and sustainability, we must not take for granted the role the PMRA plays in this. Without timely access to safe and effective pesticides Canadian farmers simply cannot sustainably grow enough food to meet the demands of Canadians and those around the world who desperately need it.

Last year a politically motivated decision triggered the launch of what Health Canada calls the PMRA Transformation Agenda. To suggest that this world-class regulatory system needs such a drastic transformation is to critically misunderstand the rigor of the system and the work of the more than 300 scientists dedicated to pesticide evaluation at Health Canada.

Targeted change for greatest impact

There are certainly important improvements needed to the system but these equate to an evolution of the current system and a building on past success rather than the immense transformation that is being proposed. In fact, the PMRA, in consultation with industry stakeholders, has been working on some of these key improvements for many years. This has been a long process of carefully identifying meaningful changes that could improve the efficiency and effectiveness of the system while helping to build public confidence in it. These include:

1. Modernizing business processes, including allowing for earlier and more meaningful engagement with stakeholders as soon as there are identified areas of concern. For example, timely engagement on draft risk assessments would allow for better informed proposed risk assessments going out to the public for consultation. This would reduce an influx of additional information near the end of the review phase, which can lead to dramatic changes to the final decisions, reducing confusion among the public and building confidence in the system.
2. Improving access to robust water monitoring data, which will help the PMRA make more informed decisions that reflect actual product use rather than overly conservative modelling. This will help assure the public that risk mitigation measures are working and that water is safe.

Straining already stretched resources

With the PMRA’s resources already stretched to the limit, a transparent prioritization of initiatives, such as those listed above, would better enable the agency to deliver on its core mandate. Instead we are seeing desperately needed new funding for the PMRA be diluted over many other transformation efforts. Rather than gaining efficiencies, the PMRA is placing additional strain on its already taxed evaluators.

The recent work done by the PMRA, in consultation with industry, on modernizing business processes and improving the access to robust water monitoring data has taken years of careful consideration. This is a stark contrast to the hastily constructed Transformation Agenda that seems to lack focus and be more driven by deadlines rather than the quality of the work.

The Pest Control Products Act is fit for purpose

The Pest Control Products Act (PCPA), which was the subject of a recent public consultation under the Transformation Agenda, is one of the most robust and transparent pieces of legislation in this country. It was developed just 20 years ago after years of consultation. As recently as 2020, stakeholders recommended to the Minister of Health that the PCPA was fit for purpose and that any required improvements to the system did not require legislative change.

Despite the heightened public and political attention on the PCPA today, the facts remain the same: legislative changes are not required as the Act continues to be transparent and protects both human health and the environment.

In response to greater public interest in the pesticide regulatory system and a desire to build public trust, the government should be focusing significant efforts on better explaining the regulatory process and the science behind it to Canadians in meaningful ways rather than trying to upend the existing system.

Actions speak louder than words when it comes to committing to science-based decision making

In all of this, it’s important for the government to remember how important the regulated parties and broader agriculture industry is in this process. Pesticide regulation is extremely complex and the registrants of these products generate an immense amount of high-quality data that are essential to the process. And the agriculture industry is a wealth of information on the realities of real-world product use that allows regulators to make decisions grounded in reality rather than models. The plant science industry – and agriculture industry writ large – should be consulted prior to any significant changes to the system.

Throughout the last year the government has continued to say it is committed to science-based decision making but its actions haven’t always followed suit. In the summer of 2021 it announced the freezing of increases to Maximum Residue Limits without any scientific justification, putting at risk Canada’s hard earned global reputation on science based regulation. Today, the freeze remains in place with no answers for it.

More recently Health Canada struck a new Scientific Advisory Committee composed of members largely without any substantial agricultural expertise to provide scientific advice to the PMRA. This committee will now consider broad, esoteric questions and drain staff resources at PMRA at a time when focus is desperately needed. It seems as though science isn’t always a determining factor in the Transformation Agenda and we believe that this is a dangerous road for Canada to travel.

To view a summary of CropLife Canada’s response to the PMRA consultation DIS2022-01 click here.

Pierre Petelle,
President and CEO, CropLife Canada