Written by Christopher P. Dufault
Many of you will have heard that the Pest Management Regulatory Agency (PMRA) is undergoing a transformation process for which consultations began earlier this year. This effort is being made possible by additional funding for PMRA of $42 million over three years that was announced by the federal government in August 2021. So, you may ask, what is PMRA aiming to transform, and how is the Fruit and Vegetable Growers of Canada (FVGC) participating in this process in support of growers in Canada?
Details of PMRA’s transformation project
PMRA has announced that its transformation project is intended to “further strengthen environmental and human health protection through modernized business processes,” “improve transparency and access to information,” and “increase the use of real-world data and independent advice.” Additionally, PMRA is conducting a targeted review of the Pest Control Products Act (PCPA), being the legislation under which it operates. Let’s break this down by subject area.
One of the goals of modernizing business processes is to streamline how PMRA will schedule the future re-evaluations of pesticides. Currently, the PCPA mandates that all pesticidal active ingredients must be re-evaluated every 15 years to determine whether they are still considered safe to humans and the environment, and provide value to the user. To make better use of resources, PMRA is proposing that the PCPA be revised to permit an approach of “continuous oversight” in which pesticides having greater risk are identified and re-evaluated more often and those with lesser risk, less often.
Regarding transparency, PMRA is exploring whether it should provide the public with plain language summaries of its decisions on pesticides in addition to the scientific documents that it already publishes. As well, PMRA currently has a reading room in Ottawa in which the public can read scientific review documents to which they have requested access. PMRA is considering what data the public wishes to see and how that information can be made more available to them in the future, such as through an online site. Additionally, PMRA is assessing how it can improve consultations with the public on its proposed regulatory decisions.
As to “real-world data” PMRA is looking to obtain up-to-date data on how crops are grown and how pesticides are actually used in the field. Without such data, PMRA must assume the most conservative scenarios when conducting risk assessments. That is, PMRA must base these assessments on pesticide labels (assuming use of the maximum rate and number of applications, 100% crop treated, etc.), rather than on actual use data. Such field-realistic data, when included in risk assessments, can make the difference between an active ingredient and its uses remaining registered or being de-registered.
Another aspect of “real-world data” is that PMRA is planning to develop a national water monitoring program for pesticides. In the absence of such data, PMRA must run models to predict pesticide fate in aquatic systems which tend to be more conservative than real-world data. Again, such data can make the difference between keeping and losing an active ingredient that is being re-evaluated.
PMRA is also consulting on the procedural aspects of establishing import Maximum Residue Limits (MRLs). Additionally, an expert panel, the “Science Advisory Committee” has been established to provide “independent scientific expertise” to PMRA regarding its more challenging decisions.
Finally, a targeted review of the PCPA was announced earlier this year in PMRA’s Discussion Document DIS2022-01. (Link here: https://bit.ly/3tCx85J)
The public was asked to comment by June 30 on several questions in this document to help PMRA to determine what, if any, changes are needed to the PCPA.
How FVGC is participating
PMRA has established a Transformation Steering Committee (TSC) to oversee, with PMRA, the transformation process over the next few months, as well as five Technical Working Groups (TWGs). FVGC has representation from its staff and Crop Protection Advisory Group (CPAG) on the TSC and each of these TWGs. The five TWGs are focussed on Modernized Business Processes, Transparency, Pesticide Use Information, Water Monitoring Information, and MRLs. FVGC’s participation is intended to ensure that PMRA’s proposed process improvements are effective and science-based, and still take account of growers’ needs.
Regarding the PCPA, FVGC has worked closely with other commodity group stakeholders and CropLife Canada to share information and to develop common responses to the questions posed by PMRA in DIS2022-01. Our view is that the PCPA is currently fit for purpose and that if any changes are to be made to it, they should be minimal. Most changes of an operational nature should be made instead to the Regulations that accompany the PCPA, which would provide greater flexibility.
A concluding note
PMRA hopes to wrap up all its consultations through its various TWGs by the autumn of 2022. Until then, the other TWG members and I will be working hard on this endeavour for Canada’s fruit and vegetable growers. We all want to see that human health and the environment are protected while still ensuring access to the crop protection tools needed for successful crop production.
Christopher P. Dufault is Acting Manager, Crop Protection, at the Fruit and Vegetable Growers of Canada. He headed the Re-evaluation and Use Analysis Section at PMRA until his retirement from the federal government in 2012 and was editor of The Grower in 1980-81. He has been an Ottawa-based consultant since 2013.