Broader policy activity was again the theme of 2023. There were numerous consultations from the Pest Management Regulatory Agency (PMRA) focused on its Transformation Agenda and other initiatives. Funding continues to be a challenge with the Pest Management Centre (PMC) of Agriculture and Agri-Food Canada and OFVGA had to take an active role in ensuring the Pest Management Priority Setting Workshops (i.e. the minor use meeting) continue to happen in person.

Minor Use Program

The lack of additional funding for the Minor Use Pesticides Program of PMC remains a key concern for the edible horticulture sector. Many new crop protection registrations would not happen for fruit and vegetables without the work of the PMC. The target for PMC over the five-year Canadian Agriculture Partnership (CAP), which ended in March 2023, had been to research a minimum of 40 minor use projects per year. Yet over the past several years, due to budget constraints, the PMC has taken in fewer projects. It is believed, again for 2024, that the number of new projects selected will be around 30. Fewer projects at PMC means fewer label expansions submitted to PMRA and ultimately a smaller crop protection toolbox for growers. Seeking new funding for PMC remains a priority.

The annual Canadian Pest Management Priority Setting Workshops typically held in March are a critical venue to bring together growers, consultants, extension specialists, registrants, regulators, and government to discuss pest management issues and identify potential solutions for minor use crops. There is no other similar event in Canada. Again because of budget limitations, the PMC was proposing to move this to a virtual format for 2024. However, the Ontario Fruit and Vegetable Growers’ Association (OFVGA) and the Fruit & Vegetable Growers of Canada (FVGC) stepped to help organize the meetings so they could remain in person. With support from numerous sponsors, we are excited to be working together with PMC to provide an in-person priority setting workshop to be held March 18-20^th in Gatineau, Québec.

PMRA – Transformation

Several areas of activity continue at PMRA with regards to the ongoing transformation program. In June 2023 the Minister of Health announced that the review of the Pest Control Products Act concluded that the act remained fit for purpose and did not need any substantive changes. Changes were proposed however to the Pest Control Products Regulations to include additional criteria during environmental assessments by PMRA for cumulative environmental effects and for species at risk. Health Canada acknowledged in the proposal that this area of science is not well developed and “all pesticide regulators, including PMRA, are facing challenges with the lack of standard methodologies to assess the cumulative effects of pesticides on species.” Furthermore, OFVGA believes PMRA already has the authority in its mandate to conduct assessments and provide protections for species at risk. Considering these realities, OFVGA’s submission did not support these proposed amendments.

Work continues to increase the use of real-world data through the water monitoring program and the pesticide use information pilot. Approximately 1,300 water samples were collected in the first year of the water monitoring program in 2022. PMRA detected no concerns for human health in any of the samples. A very small number of samples exceeded levels of concern for environment and these are being explored further. This data will help during re-evaluation and special reviews to provide real world context. Similarly, PMRA is exploring a pesticide use information pilot which is seeking to survey specific crops in winter of 2024 for crop protection use information to better understand how products are used by growers in the field.

Finally, PMRA is proposing to move to a new model for reviewing active ingredients called the Continuous Oversight approach. This approach represents a significant change from the current process to managing active ingredients based largely on set timelines for initiating reviews (i.e. 15 year re-evaluation cycle). Alternatively the PMRA is proposing to actively monitor active ingredients on a continuous basis for new information that might change the risk assessment – if new data is found that PMRA determines needs to be reviewed closer, a special review may be triggered. PMRA has this option now, but it is largely reactive to decisions in other countries or when active ingredients get reviewed for other purposes (such as label expansions).

Potential issues may be identified sooner allowing time for further data to be generated or mitigation measures to be implemented before becoming a larger issue in re-evaluation. Re-evaluation should also have more predictable outcomes (i.e. dramatic shifts in the label should be rarer). On the negative side, if PMRA does not have the resources to follow through on Continuous Oversight thoroughly, we may find active ingredients put “on hold” for further label expansions (such as minor uses) due to lack of resources to review issues identified by Continuous Oversight. A public consultation is expected in early 2024 on this policy and OFVGA will be making a submission.

There are many moving parts when it comes to the PMRA Transformation Agenda. The biggest question mark at this point is funding. The original three-year funding for transformation initiatives ends in March 2024. Will this funding be renewed or what will happen to this agenda if it is not -- those questions remain.

PMRA – Tank mix policy

A new guidance policy on the use of tank mixes of crop protection products was published late in December 2022. For tank mixing to be permitted under the new policy, there must be text on the product label that specifically allows for tank mixing. This updated guidance replaced a previous blanket policy which permitted unlabelled tank mixes unless they were otherwise prohibited on the label.

It was extremely concerning, however, that the initial version of the new policy did not include any transition time for growers to adjust and for labels to be updated by registrants. As it was published, it was immediately in effect and labels without specific tank-mixing statements couldn’t be mixed. As this was a completely unworkable scenario, OFVGA and FVGC met with PMRA in March 2023 to discuss our concerns. It was agreed that a two-year implementation period be extended to growers, meaning compliance with the new policy on tank mixing will now be required by December 21, 2024.

In discussions with registrants and from monitoring new labels issued in 2023, most companies have elected to include the general tank-mixing statement on their labels. This provides the most flexibility for growers to continue to tank mix to their preferences, provided the tank-mix partner label(s) allow. Growers will have to be aware of these new tank mixing requirements going into 2025.

PMRA – Re-Evaluations

Re-evaluation decisions in 2023 were generally focused on products other than synthetic crop protection materials. Decisions were completed for zoxamide (Gavel/Zing), pyrethrins (Pyganic), and 1‑methylcyclopropene (SmartFresh). All remain registered for use with updated labels.

PMRA – New crop protection active ingredients

A total of eight new active ingredients to Canada were registered by PMRA on edible horticulture crops with their first label in 2023 (Table 1). In addition, numerous label expansions were completed on existing active ingredients by registrants or through the User Requested Minor Use Label Expansion (URMULE) program by submissions from the PMC, by OMAFRA, or by other provinces.

Table 1: New active ingredients registered on edible horticulture crops with their first label in 2023.