One major difference separates the regulatory systems for crop protection product re-evaluations in Canada compared to its counterpart in the United States. Both countries have the regulatory requirement to protect human health and the environment. No one objects to this goal. We can be thankful as Canadians that we have a robust system in place for protecting ourselves and the environment in which we live. However, in the context of food production, the risks of using crop protection products should also be balanced with the benefits of their use. This is the crucial advantage that the U.S. has over Canada in our regulatory systems – the benefits side of the equation.
Crop protection products have provided tremendous benefits to society by allowing farms to produce far more food using less labour and less land with huge reductions in year-to-year variability of the food supply, its quality, and its cost. Increased access to fruit and vegetables throughout the year has without doubt improved the nutritional quality of our diets leading to better human health. Everyone in society has benefitted from our increased ability to control pests, diseases, and weeds over the past century. This should not be forgotten. So how can this be acknowledged in the regulatory context?
An example can be found by looking south. Under the United States Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Environmental Protection Agency (EPA) must consider the benefits of use in making its regulatory decisions. When evaluating acceptable risk for product registration or re-evaluation, there must be consideration of “economic, social, and environmental costs and benefits of the use of any pesticide.” The United States government acknowledges that access to crop protection products has substantial benefits to society. Therefore, to ensure all aspects are considered, FIFRA requires EPA to balance these risks and benefits in the decision-making process.
To accomplish this careful balancing task, the EPA conducts complex risk and benefits assessments that employ the best scientific and economic analyses currently available. There are still rigorous evaluations of risks for human health and the environment and this must importantly weigh into any decisions. It is up to EPA’s Biological and Economic Analysis Division (BEAD) to conduct the benefit analysis for a particular use. Benefits that are considered in the analysis include improvements in yield, quality, and/or decreased cost of production, taking into account the efficacy and cost of alternatives. Benefits may be achieved through many different ways with crop protection products that, for example, reduce management complexity of the crop, provide a new mode of action facilitating resistance management, or have lower impact on non-target organisms compared to alternatives. These are not necessarily directly financial outcomes but lead to improved crop management and also minimize overall impact on human health and the environment.
Benefit assessment includes consideration for the consequences of eliminating or greatly restricting the use of an active ingredient. A decision to mitigate one risk might have consequences by increasing risks from other sources. Purdue University Extension in Indiana provides an example of such considerations in the Purdue Pesticide Programs publication ‘Pesticide Benefits Assessment.’ If a key herbicide is eliminated in a cropping system, increased tillage to control weeds might be the only alternative. While tillage may be an effective option for weed control, its costs might include: additional time, increased fossil fuel emissions, soil erosion, soil sedimentation of water bodies, and decreased land productivity over time from lost topsoil. While there may be certain risks related with the use of the herbicide, the risks associated with alternative methods need to be considered. It is the role of the Risk Manager at EPA to balance the risks with the benefits assessment in its decisions.
In Canada, to date, we do not have consideration for the benefits side of the equation weighing in our re-evaluation decisions on crop protection products. The risk assessment to human health and the environment is conducted and a regulatory decision is made. End of story. But is this the right balance for society? If the availability of alternatives is not considered in Canada, how can we be sure that the quantity, quality, or cost of domestic food production will not be severely impacted by a particular decision? Or will the mitigation of one particular risk lead to an increase in another, such as in the tillage example?
We are currently regulating our crop protection products with only one side of the story. Protecting human health and the environment is indeed of critical importance. However, until we make regulatory decisions with a holistic view of crop protection – including an understanding of the benefits of use – it will be impossible to make regulatory decisions that ultimately provide the best outcomes for society.