Chemical/ Input: CHLORPYRIFOS

pest control worker spraying pesticides with sprayer on building wall

Chlorpyrifos is an organophosphate pesticide sprayed directly on growing crops, sprayed to kill mosquitoes, and sprayed on certain forest trees. In Canada the food crops affected include canola, flax, lentil, corn, strawberry, celery, cucumber, green peppers, pak choi, broccoli, brussels sprouts, cabbage, cauliflower, garlic, potatoes, barley, wheat, oats onions and carrots. The chemical degrades into transformation products including chlorpyrifos oxon, which is considered more toxic.

Chlorpyrifos has neurodevelopment effects on infants in utero and in their early years.  As a result, the US Environmental Protection Agency (EPA) and the European Food Safety Authority (EFSA) banned all food used of chlorpyrifos in *. , [confirm].  PMRA did not conduct a proper assessment of chlorpyrifos.  PMRA did purport to cancel all uses of it in Canada in December, 2021, but at the same time it is allowing it to be used until the end of 2023. Such “phase-out” uses are allowed pursuant to PMRA’s Policy on Cancellations and Amendments (Cancellation Policy).

Safe Food Matters call on PMRA to cancel all uses of chlorpyrifos immediately, and to cancel the Cancellation Policy.  If a pesticide is cancelled because it is harmful, there is no justification for continuing to use it.  We have gone to court against PMRA, together with Prevent Cancer Now, on these issues. Ecojustice is our legal counsel.

 

SFM’S WORK

Notice of Objection, environment   

SFM provided a notice of objection (NoO) to PMRA’s December, 10, 2020 environmental assessment of chlorpyrifos (RVD2020-14 Chlorpyrifos and Its Associated End-use Products (Environment)), and submitted it with other groups. The NoO is summarized and linked here Notice of Objection: Chlorpyrifos (environment).

On May 13, 2021, PMRA issued REV2021-02, Update on the Re-evaluation of Chlorpyrifos, in which it indicated it was cancelling and phasing-out all uses of chlorpyrifos.  In June PMRA wrote to SFM to propose that the NoO be closed. SFM did not agree to closure of the NoO, and has not received a response to the NoO.

On December 21, 2021, PMRA issued a “do-over” decision, REV2021-04, Cancellation of remaining chlorpyrifos registrations under paragraph 20(1)(a) of the Pest Control Products Act. There has been no correspondence from PMRA about the NoO following this second decision.

 

Chlorpyrifos Court Case  

On May 13, 2021, PMRA issued REV2021-02, Update on the Re-evaluation of Chlorpyrifos, in which it indicated it was cancelling and phasing-out all uses of chlorpyrifos (the Phase-Our Decision). Various groups, including SFM, were please with the decision, citing years of inaction and sitting on the sidelines by the part of PMRA. S

See this: MEDIA STATEMENT: After Green-lighting Chlorpyrifos in December, #Health Canada Finally Plans to Put Brain-Wasting #Pesticide Out to Pasture (delaying action for years, following rulings in EU, and US Federal Court of Appeals)

On June 14, 2021, FM and Prevent Cancer Now sued PMRA in federal court over the Phase-Out Decision, arguing it was unreasonable, and that a cancellation decision should require cancellation now, or in a few months (like in Europe), not in a few years.  See: Delay, Delay… by the PMRA.

On December 21, 2021, PMRA issued a “do-over” decision, REV2021-04, Cancellation of remaining chlorpyrifos registrations under paragraph 20(1)(a) of the Pest Control Products Act (the Amended Decision). It said the May 13 decision didn’t contain reasons, but this decision does provide reasons for the phase-out period.

On January 20, 2022, SFM and PCN, again with Ecojustice as counsel, sued PMRA in federal court over the Amended Decision. We argue the decision was unreasonable because it was full of contradictions, inconsistencies, and a lack of transparency in the agency’s decision-making process. For more, see: Lawsuit slams lack of transparency in Health Canada’s management of chlorpyrifos.

 

FILES AND PRESENTATIONS

Federal Court Chlorpyrifos Cases

T-121-22

2022 09 28 –  Applicants’ Memorandum of Fact and Law

2022 01 20 – Notice of Application – Safe Food Matters INC et al v. AGC et al (T-121-22)

2022 01 19 – First Affidavit of Dr. Elaine MacDonald

2022 03 07 – Second Affidavit of Dr. Elaine MacDonald

T-956-21

2022 02 10 – Second Amended Notice of Application, Court File No. T-956-21

2021 11 02 – Affidavit of Margaret Sears

2021 11 03 – Affidavit of Mary Lou McDonald

2021 11 17 – Affidavit of Elizabeth Gabel

2021 12 07 – Affidavit of Charlotte Ireland

2022 01 19 – First Affidavit of Dr. Elaine MacDonald

2022 03 07 – Second Affidavit of Dr. Elaine MacDonald

Regulatory Filings

2021 02 08 – Chlorpyrifos Notice of Objection to PMRA

 

WHAT YOU CAN DO

* Until chlorpyrifos is no longer in use in Canada, eat only organic varieties of foods that may have been sprayed with chlorpyrifos.  These include: canola, flax, lentil, corn, strawberry, celery, cucumber, green peppers, pak choi, broccoli, brussels sprouts, cabbage, cauliflower, garlic, potatoes, barley, wheat, oats, onions and carrots.

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