This post is about providing comments on the third objective of the Pest Management Regulatory Agency’s (PMRA’s) consultation on the “Targeted Review” of the Pest Control Products Act (PCPA).
In Summer, 2021, there was public outcry to proposed increases to “maximum residue limits” of pesticides in food, and this consultation (set out in Discussion Document 2022-01) is the result. The extended deadline for comments is June 30, 2022.
Below at the heading “Objective 3 – Increased Use of Real-word Data and Independent Advice/Evidence” are our comments on the third and last objective. Our thoughts on the first and second objectives were provided in previous posts.
Background: By way of background, Discussion Document 2022-01 sets out 3 objectives, and asks for answers to questions on each. The list is in Annex 3. The first objective on “Modernized Business Processes” asked questions on setting MRLs and “Continuous Oversight”, and we discussed it in this previous post. We discussed the second objective “Improved Transparency” here.
Although this consultation is on a “Targeted Review” of the PCPA, PMRA says it will also take comments on the full Act, since the full PCPA currently stands referred to Parliament for a broader legislative review. A main point that is being missed in the “targeted review” is that risk assessments should focus on the ENTIRE pest control product (PCP) including all ingredients, not just the “active” ingredient, which is what the current approach is.
Why? Because we are exposed to the entire product (not just the one ingredient) in the “real world” – also because some of these ingredients are actually more toxic than the active ingredient, or render the active ingredient more harmful than it would otherwise be.
Send your comments on the consultation:
By email to PMRA Publications: firstname.lastname@example.org
Identify Discussion Document 2022-01
Provide: your full name and organization; phone number; mailing or emailing address.
Consider: cc’ing us at SafeFoodMatters@gmail.com
OR: Use the Consultation Comment Form
Fundamental Point: on the standard for comments: The main objective of the PCPA is to protect human health and the environment from the risks of pesticides (sec 4). If a “Targeted Review” proposal aligns with this objective, it is good. If it doesn’t, it is out of scope.
Below is a brief description of the third Objective and related questions of the consultation, and some suggested responses. Please revise, amend, or create your own responses as you see fit. PMRA is listening, so now is the time.
Objective 3 – Increased use of Real-world Data and Independent Advice/ evidence
In relation to this objective, a key concern is that PMRA does not currently directly access scientific literature. In order to be meet the primary objective of the PCPA of protecting health and the environment, the agency needs to have direct access to and understand directly the science and scientific literature on the risks of pesticides. Any reliance on third parties for science presents the risk of real or perceived bias in decision making. This does not align with purpose of the PCPA.
On August 4, 2021, Health Canada announced its desire to increase PMRA’s capacity to improve the review process and provide evidenced-based decisions. Direct access and review of the scientific literature on the part of PMRA is required for evidenced based decision making. Direct access is preferred over “advice” from an advisory committee, as currently contemplated, particularly since the committee is essentially closed-door and not accountable.
Question: Are there any issues PMRA should consider in terms of accessing, sharing and releasing comprehensive water monitoring and pesticide use data?
Response: The data should be supplied directly to the public, rather than requiring the public to request it from PMRA The wall between the public and access put up by PMRA is inefficient. It is also frustrating because it presents a delay to the member of the public in conducting their research and analysis.
In addition, for true evidence-based decision making, real-world data is required on pesticides in air. Pesticides can travel in air, and inhalation and dermal exposure are routes or exposure that require measurement of pesticides in air. For example, glyphosate has been found at locations very remote from the location of application (such as the Black Forest), having travelled there by air.
Additional “real-world” data required for effective protection of Canadians concerns the levels of pesticides in our food. The contamination of food by pesticides should be measured and reported on regularly. The consumption of foods by Canadians containing pesticides must be measured. Currently PMRA relies on outdated consumption data on what Americans, not Canadians, eat.
“Real-world” data is also required on the levels of pesticides in our bodies, for a true understanding of the risks to Canadians’ health. Bio-monitoring data should be established or accessed.
“Real world’ data is also required on the levels of pesticide in species in the environment and representative species, for a true understanding of the risks to the environment. Such data should be established or accessed.
Conclusion: A fundamental requirement for valid risk assessments of pesticide is access to real-world data on all exposure pathways, and measurement of real-world pesticide contamination. Direct access to and understanding of current relevant scientific literature and methodologies is also key. The data and information on pesticides must be as accurate and current as possible to best protect Canadians and the environment from the acknowledged risks of pesticides.
This data should be made available to Canadians directly, rather than requiring summary or filtering on the part of PMRA. This allows for understanding of the “real-word” data on the part of Canadians and the regulator, and for accountability of decision-making made on the basis of this data.