Conclusion of the Transformation Agenda: Nothing Transformed

On August 4, 2021, Health Canada announced:

it was pausing proposed increases to pesticide Maximum Residue Limits (MRLs), including for glyphosate
the Pest Management Regulatory Agency (PMRA) would receive $42 million over three years “to further strengthen its human and environmental health and safety oversight and protection”- the Transformation Agenda.

 

Three years later, and $42 million later, nothing has been transformed. The PMRA is consulting on 4 proposed regulations, that do NOT strengthen protection from pesticides. Two of them do nothing, and two actually make matters worse.

This is despite the fact that PMRA received almost 20,000 comments from members of the public on the proposal to increase MRLs of glyphosate.  It dismissed 94% of the comments, and intends to carry on as usual.

Proposed MRL Regulation

PMRA says in the consultation document that:
“the current MRL setting process protects human health and does not require changes”.
However, the current process does not protect human health.  …Read More

Kids, Candy, and Scary Stuff

 

Some of the fun things about Hallowe’en are the kids, the costumes, and the candy.   We have some scary news about the candy.

Health Canada wants to up the levels of pesticides allowed in sugar. Big time. It has proposed to increase allowable levels of two pesticides used on sugar beets – by 200 fold and 10 fold:

Azoxystrobin (AZ) – from 0.5 to 5 ppm (10x)
Fludioxonil (FL)  – from 0.02 to 4 ppm (200x)

Why? So Canada’s levels will match the US levels.

You may recall in 2021 there was a “pause” put on maximum residue limits (MRLs) because of proposed glyphosate (Roundup) increases. In June, 2023 Health Canada lifted the “pause”, and these two chemicals, combined in a Syngenta product, are the first up.  Syngenta made the request.

The problem isn’t just the increases. It’s the lack of scientific backup. The scientific methodology is completely flawed, as stated in the assessment, …Read More

“Highly Uncertain” Science Used for Pesticide Limits

Pesticide limits for sugar beet roots – the first up for MRL increases after the “pause” – are based on uncertain science
Confidential test data reveals there is “High uncertainty of [the] MRL estimate” for two increases of pesticide maximum residue limits (MRLs) on sugar beet roots (used for sugar products), which were requested by Syngenta and proposed by Health Canada. The proposed MRLs, which are 200 times and 10 times higher than current levels, were calculated using the OECD Calculator. The output page of the calculator flags in red that there is high uncertainty because small data sets were used.

Health Canada does not mention these uncertainties in its proposals for the two pesticides, PMRL 2023-34 for Fludioxonil (FL) and PMRL 2023-38 for Azoxystrobin (AZ). The proposed increases are from 0.02 to 4.0 ppm for FL, and from 0.5 to 5.0 ppm for AZ.

Notably these are two of the very first …Read More

Update 2 on Increasing MRLs: Comments due Sept 8 2023 and MRL Issues Summary

Health Canada has extended the comment period for proposed regulations on MRLs until September 8, 2023.  On June 20, 2023 it announced it was seeking comments on its Notice of Intent NOI2023-01 for new regulations on pesticide maximum residue limits (MRLs).

The new MRL regulations require publication of a notice when there is a proposed increase. That is all. No substantive changes are being made to the MRL process.

The comment period for the NOI was extended from August 19 until September 8, 2023.

See our previous post on the NOI and suggestions for comments.

Below is an executive summary/ explanation of the MRL issues.
Context:  Government Paused and is Now Increasing MRLs
– In Summer 2021, the government paused a proposal from Bayer/ Monsanto to increase the MRLs for glyphosate/Roundup allowed on lentils and beans/peas by 3 and 4 fold.

– The pause was because there was huge public outcry and it was election time.

– Health Canada is head …Read More

Update: PMRA Transformation Agenda, Increasing MRLs and Action

“Tractor Fertilize Field Pesticide And Insecticide” by aqua.mech is licensed under CC BY 2.0.
Update: PMRA Transformation Agenda, Increasing MRLs and Action
Resignations, Increasing MRLs, and Weak Proposals
Remember two years ago?  It was election time. Health Canada proposed higher levels of Roundup in food at the request of Bayer/Monsanto, the public screamed foul-play, and the government paused the proposal.

A “transformation agenda” was kicked off to fix the Pest Management Regulatory Agency (PMRA), a new team was brought in, and a Science Advisory Committee was established to provide advice to PMRA.

So here we are, two years later, $42 million later, thousands of hours of consulting on the “transformation agenda” later… and what’s the update?

The Chair of the Science Advisory Committee has resigned, citing an “obsolete regulatory system that protects the pest industry more than it protects Canadians”.
PMRA is going ahead with increases of pesticides allowed in foods – the “pause” was lifted on June …Read More

Comments on Targeted Review of PCPA

Some types of Foods Affected by Pesticides, Gene-editing

This post provides the detailed comments submitted by Safe Food Matters to the Pest Management Regulatory Agency’s (PMRA’s) consultation on the “Targeted Review” of the Pest Control Products Act (PCPA).

Comments SFM on Dis Dic 2022-01vFinalDownload

By way of background, In Summer, 2021, there was public outcry to proposed increases to “maximum residue limits” of pesticides in food, and this consultation was the result. Discussion Document 2022-01 set out 3 objectives, and asked for answers to questions on each. The list was set out in Annex 3.

We previously wrote about these objectives. 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, and the third objective “Increased Use of Real-word Data and Independent Advice/Evidence” here.

PMRA also said it would take comments …Read More

Consultation on Targeted Review of Pesticides Act: MRLs and continous oversight

The Pest Management Regulatory Agency (PMRA) is consulting with the public on 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 is the result. The deadline is June 30, 2022.

Discussion Document 2022-01 sets out 3 objectives, and asks for answers to questions on each. The list is in Annex 3.

Here are our thoughts on the first objective, “Modernized Business Processes” and related questions.

NOTE: This consultation is on a “Targeted Review” of the PCPA, but 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 here is the focus of reviews should be on the ENTIRE pest control product (PCP) including all ingredients, not just the “active” ingredient, because we are exposed to the entire …Read More

Glyphosate MRL Proposal Not Based on Sound Science

PMRA’s Proposal to increase glyphosate in legumes is not consistent with science or the law
Here’s an update to the glyphosate MRL story, the story of Health Canada’s Pest Management Regulatory Agency’s (PMRA) proposal to permit more glyphosate in foods.  Safe Food Matters Inc. (SFM) and Prevent Cancer Now (PCN) received information on the “confidential test data” underlying PMRL 2021-10 (the Proposal). The data was received from PMRA on January 28, 2022, more than eight months after the date it was requested, May 12, 2021. 
The groups report that the scientific and legal basis for the Proposal is ill-founded. This article provides a summary of the submission of SFM and PCN on the Proposal, which was provided to PMRA on April 13, 2022 (further to an extension granted to the two organizations).  The full submission can be downloaded here.  
The comments make various points. First, PMRA did not have jurisdiction to increase the glyphosate maximum …Read More