CropLife Canada’s response to the PMRA Science Advisory Committee on Pest Control Products

The plant science industry supports an independent, science-based and transparent pesticide risk assessment process in Canada. Health Canada’s Pest Management Regulatory Agency (PMRA) is world renowned for the rigour of its regulatory process, which includes hundreds of independent scientific experts. The Canadian public would benefit from Health Canada putting more effort into clearly explaining the processes and decisions made around pesticides rather than creating a politically-motivated advisory committee.

If the Science Advisory Committee on Pest Control Products were to be focused on very specific areas to add scientific expertise above and beyond what that the PMRA itself has, the committee could add scientific value to the review process. Unfortunately, the committee’s current mandate appears so broad, even reaching beyond scientific questions, and will serve to duplicate existing work and may impact the PMRA’s ability to fulfill its mandate and deliver science-based decisions in a timely manner.

These timely decisions are critical to supporting the innovation, competitiveness and sustainability of Canadian agriculture. Creating this committee undermines the public’s trust in Canada’s science-based regulatory system and its highly trained independent experts.

Assessing Maximum Residue Limits (MRLs) is specifically noted as falling under the purview of this committee. The reality is that there is no scientific justification for an additional layer of review for MRLs, which are set based on internationally accepted standards. This very point illustrates that the motivation behind the advisory committee appears to have little to do with science.

Just as the Government of Canada has been steadfast in its defense of the science behind vaccines, the agriculture industry deserves that it explains and defends the science behind agricultural innovations like pesticides.