Every December we get inundated with Christmas-themed movies. Our favourites from childhood are still aired every year and include: ‘Miracle on 34th Street’ (Written by Valentine Davies), ‘It’s A Wonderful Life’ (Written by Phillip Van Doren Stern as a short story called ‘The Greatest Gift’), and ‘A Christmas Carol’ (Written by Charles Dickens). There are many more new movies each year but another old favourite is a made-for-TV movie seldom shown now called ‘Silent Night, Lonely Night’ starring Lloyd Bridges and Shirley Jones.
I watch most of them because I am a sucker for how they always work through the problems and in the end everything turns out well for all concerned. Maybe it’s because I am seeking the perfect ending that keeps eluding me (us) when it comes to dealing with pesticide issues. Maybe the promise of a good ending is just what human nature has been programmed to look/hope for.
With that in mind, I am going to look for some ‘resolution’ of current issues bearing in mind that New Year’s resolutions rarely last for a full year!
In the spirit of transparency, the Pest Management Regulatory Agency (PMRA) will publish the names of all those staff members who participated in a registration or re-evaluation decision (as the U.S. Environmental Protection Agency already does). This would allow us to be able to directly contact the ‘right’ person(s) with new/different information than what was used for each proposed decision segment. Likewise, each of those folks should have key contact names/numbers for registrants and stakeholders on speed dial to immediately clarify (anything) that they need to reach those decisions. It must be a two-way street so the final decision can be agreed by all to be appropriate from all the available data.
In a perfect world, the PMRA would be provided with the appropriate human and financial resources to undertake their responsibilities and to do their work well and on time. There is a train wreck coming at them (and us) fast unless serious changes are made to their ambitious plans for re-evaluation. The crash will come, at a price to growers that we do not want (nor can afford) to pay. There is just too much for the PMRA to do if the work-plan is to be completed within the proposed time-frame. I have long been a proponent of ‘work smarter not harder’ but NO ONE can work that much smarter! There are just too many actives that need to be re-evaluated. There are just so many total staff hours to do the job. Canada is NOT aligned with the U.S. re-evaluation cycle and does not (cannot?) take advantage of using a joint working approach on these.
It’s funny really. We can and do such joint work on brand new actives as routine activity, but seem to be averse to doing it where there is a much bigger need! If we are several actives ‘behind’ the U.S. schedule of work we should simply park the intermediary ones and immediately start on joint work (using the EPA work plan schedules) from here on. The savings of staff time alone would provide the resources needed to complete the others ‘in time’ (15-year cycle) as well as by using the already completed EPA reviews on all those intermediary actives. Simple solutions are often the best!
One area that continually seems to be a sticking point is the reliance that PMRA puts on foreign data sources that in turn reflect foreign use patterns, foreign crop production practice, and foreign worker job requirements and the times of such activity. In a perfect world there would be a Canadian version of such factors. While not impossible to produce, it is not cheap to conduct surveys for every crop out there. Perhaps they should consider an ‘expert panel’ that could be convened and used when such Canadian data is needed in a review, to ‘get it right.’ The PMRA could reference those folks by name as their source if that is what is needed for comfort.
A perfect world needs changes from where we are today. Pesticide use patterns vary every season for a host of reasons. The Crop Profiles do a good job of providing an ‘average’ seasonal crop protection program. However, registrations are required that cover worst case scenarios. The 2017 season is a good example. When late blight showed up very early in the Ontario processing tomato crop, there was an immediate need to shorten the spray interval, and to maintain a protective fungicide from late June until September, with increased total amounts needed for the season. Fortunately there were still protective fungicides available to do so.
Growers still remember what happened when a lack of suitable rotation partners led to the loss of every registered insecticide for control of Colorado potato beetle. In other crops, the loss of pesticides for apple scab, botrytis, powdery mildew, red mites, cut worms and other pests have all been attributed to the loss/absence of suitable rotation partners or simply poor pesticide use management. When faced with imminent loss of a crop and therefore income for the farm, growers will use what they have now, and next year is next year. Unless we have suitable choices, bad choices will be forced upon us. Growers need good control products since pests are inevitable. They need labelled use patterns that account for worst case scenarios. These may be seldom (hopefully never) utilized, but still need to be on a label. Any regulatory decision should not be made taking this worst case scenario as the norm. It is to cover all eventualities rather than every day, every year. Somehow the bridge of understanding between these differences needs to be crossed. (Another modern Christmas Movie called ‘The Bridge’ [written by Karen Kingsbury] is recalled as I pen this!)
We tried to make it a better world this summer by taking PMRA staff on farm tours. Moreover, we want more practical experience being made available to all regulatory staff in the coming years. While it was gratifying to hear the staff say how much they appreciated the chance to actually visit a farm this summer, it is just as disheartening to realize there are another 300+ that we need to get out there. It is just not the same to do a video ‘virtual’ tour. Getting one’s hands and feet into the soil, seeing the actual production equipment and the production site, handing the crops, talking with the farmer and all the others on a tour during the visit and on the bus, and getting a bit damp from the shower that (for the farmer) means a better crop but also means he has to fire up the sprayer once the tour leaves (because he needed to be sure all re-entry times were met to accommodate the tour) are all part of the tour experience. Maybe ‘Santa’ can arrange more tours and gain ‘permission’ for many more staff to be able to get away from their desks to take part. I know about their work load, but I also know that the knowledge gained will make staff more productive, and more than compensate by such efficiency gains.
Lastly, I would like to think that in this perfect world we are all taking the time to help mentor along some new staff. At a meeting in late November it became forcibly evident that a lot of old faces and colleagues have moved along (retired) this year. There were lots of new shining faces present from those who are picking up the reins. They can benefit from your knowledge being passed along too. Experience is gained just one day at a time, but upon a retirement 30+ years can be ‘lost’ in a heart’s beat.
Resolve to share what you have with those who are picking up your torch!
Happy New Year!