Parliament will soon be breaking for summer and with a fall federal election coming, a different assembly of representatives will be heading to Ottawa in October. With sitting MPs and those running for office campaigning around their constituencies this summer, opportunities exist to help promote the challenges faced by crop protection. As a new parliament reconvenes in October, there are a few key actions that would go a long way in helping to support effective regulation of crop protection in this country. Here are a few key issues to keep in mind if you’re talking to your current and/or future representative in Ottawa.
The regulation of crop protection products in Canada is the responsibility of the Pest Management Regulatory Agency (PMRA). This includes registration and re-evaluation of all active ingredients for both domestic and commercial uses including agriculture. The Pest Control Products Act requires that the PMRA perform re-evaluation of each registered crop protection material every 15 years to determine if uses are acceptable for current standards.
The current re-evaluation program at PMRA is not sustainable – as noted by PMRA itself. Due to many new active ingredients registered since cyclical re-evaluation began, the workload from this process continues to increase. There are 25 active ingredients currently scheduled for re-evaluation commencing in 2019, 34 in 2020 and 50 in 2021. Not to mention that individual re-evaluations are becoming more complex. Re-evaluation workloads are already exceeding available resources at PMRA resulting in delayed decisions and the future demand is unsustainable.
The PMRA must modernize the re-evaluation program to keep up. However, more resources are needed to get the job done. Especially if the PMRA is to consider additional information in its analyses as requested by agriculture. A well resourced and effective PMRA is a benefit for growers and promotes confidence in Canada’s regulatory system and for our trading partners. To enable PMRA to make the best possible analysis, in light of is increasing workload, sufficient funding is needed to support timely decisions.
Aside from its own resources, another significant challenge for PMRA during re-evaluation has been access to water monitoring data in Canada. Any detections of and the levels of crop protection materials in freshwater bodies are considered in the environmental assessments, as they should be. However, this has been a consistent data gap for the PMRA as much of this data has been of limited quality or non-existent for active ingredients of interest.
There are recent notable re-evaluations where a lack of Canadian data left uncertainties in the scientific analysis conducted. This is even stated in some PMRA decision documents, for example “…robust monitoring data were available for areas of Ontario, Quebec, and Saskatchewan. Monitoring data were typically scarce or not robust for other areas of Canada.” Like any other data gap, without real world information, models will be used and these are typically deliberately conservative. Current water monitoring data are largely collected by provinces and some non-government organizations. There is no standard program between provinces and the intensity and volume of sampling varies widely across Canada. No single point of coordination exists.
Federal participation and coordination of water monitoring activities are needed to generate robust and comprehensive data for all areas of the country. Environment and Climate Change Canada is well suited for this mandate. A national water monitoring program would not only help PMRA in making more accurate assessments but also to reinforce to the Canadian public that agriculture takes its environmental impact seriously, this performance is being measured, and acted upon based on real world data – not models.
An invaluable initiative for Canadian horticulture has been the Minor Use Program led by Agriculture and Agri-Food Canada’s Pest Management Centre. Without its existence we would not have nearly the number of crop protection registrations for horticulture in Canada. The program has been a great success and its importance will not diminish with the number of uses now being cancelled through re-evaluation. There will be key gaps in the coming years as labels change or as products are withdrawn. New registrations are needed and Minor Use must continue to be well supported to serve the needs of Canadian growers.
Finally, as written about previously in the Crop Protection Column, Canada maintains an antiquated policy of a 0.1 ppm general maximum residue limit (MRL). Essentially all countries that still do employ a GMRL have now set a limit of 0.01 ppm or 10 per cent of the Canadian limit. Only New Zealand also still retains a GMRL of 0.1 ppm. Many other countries simply avoid having a general MRL altogether, including Australia and the United States, and establish their own specific MRLs for all approved active ingredients.
As discussed in that previous article, having this much higher general MRL simply means Canada is an easier market to access for foreign food exporters. Exporters from Canada do not share this advantage. Canada should eliminate this generous allowance and align with other countries globally, either adopt the 0.01 ppm standard or transition to a no-default policy and set each MRL. The Canadian Food Inspection Agency should then be prepared to enforce this standard – rejecting or removing product that doesn’t meet MRLs.
Canada’s regulatory system for crop protection is complex and rigorous. Improvements are possible and needed and will not only help growers but boost confidence in our regulatory system.