No Ban Needed - CropLife

"We encourage
responsible use of pesticides
for all their uses including:

• urban green spaces,
including lawns and gardens
• agriculture/horticulture/
forestry/industrial
vegetation management
• structural pest control
• golf courses and
recreational
sports turf
• personal use
including insect repellents
and pool chemicals".

CropLife Canada's
Nov 7, 2011 Presentation
to Special Committee,
See Slide 5.

No IPM in Nova Scotia

Since April 2011,
IPM lawn care companies 
in Nova Scotia
must use the same 
"allowable" products 
as everyone else 
on
residential, commercial, 
government and
institutional properties.

For the allowable 
pesticides list, click here.
For exceptions, click here.

For education info
released March 22, 2011, 
click here.

Use Safely

"If you choose
to use a pesticide
in or around your home,
you are responsible
for using it safely".

Government of Canada
website.

Labelled Use is Dangerous

"However, one need only
to read
the pesticide label
of many typical
household pesticides
to realize
that these are
dangerous substances -
in the sense
that they are quite
capable of causing
significant health and
environmental impacts.

For example:
Avoid breathing
of spray mist.

Avoid repeated
contact with skin . . .

Avoid contamination
of aquatic systems
during application."

West Coast Environmental Law Association
Nov 7 2011 Presentation
to Special Committee on Cosmetic Pesticides.

Unnecessary Risk

"The government 
believes 
the use of pesticides 
to control weeds and insects 
for purely 
cosmetic reasons 
presents an 
unnecessary risk 
to our families and pets,
especially when 
we can have 
healthier
lawns and gardens 
without chemicals."

Ontario Ministry of the
Environment Pesticide website.

Low Risk Pesticides

For excellent info on
landscaping problems,
and low risk
"environmentally friendly"
pesticide products,
see Revelstoke's 
Environmentallly Friendly
Pesticides brochure.

Weed N Feed Bans

Weed N Feed 
is a herbicide/fertilizer 
combination product 
with 3 active ingredients:
2,4-D
Dicamba
Mecoprop (MCPP)

Click on the toxic ingredients
to find out why
seven provinces have
Weed n Feed bans:

Alberta  2010
New Brunswick  2009
Newfoundland and Labrador 2012
Nova Scotia  2011
Ontario  2009
PEI  2010
Quebec  2003

Health Canada's
Dec 31, 2012
"uncoupling" ban of
herbicide/fertilizer products
did not stop sale of
Weed N Feed ingredients.

When will these
toxic ingredients
be banned in Canada? BC?

Reconsider RoundUp Safety

"The French team,
led by Gilles-Eric Seralini,
a University of Caen
molecular biologist,
said its results
highlight the need
for health agencies
to reconsider
the safety of Roundup.

'The authorizations
for using these
Roundup herbicides
must now clearly
be revised
since their toxic effects
depend on, and
are multiplied
by,
other compounds used
in the mixtures.' ”

Weed-Whacking Herbicide
Proves Deadly
to Human Cells
Scientific American
June 23, 2009.

2003 Roundup Ban

In Sept 2003,
Denmark was the first
country to ban
spraying glyphosate,
the active ingredient
in Monsanto's
Roundup herbicide:

“The chemical has,
against all expectations,
been sieving down
through the soil
and polluting
the groundwater
at a rate five times
more than
the allowed level
for drinking water. . .

This is very surprising,
because we had
previously believed
that bacteria
in the soil broke down
the glyphosate
before it reached
the groundwater.”

Third World Network's Biosafety Information Service
September 16, 2003.

When will Health Canada
decide on acceptable
glyphosate residue limits?

All Insects Pesticide Target

"Pesticide use kills
beneficial insects
as well as targetted insects."

Gardening for pollinators
brochure.

Thompson Shuswap
Master Gardeners
Association.

Help BC go Pesticide Free!

The Canadian Cancer Society
continues to lead BC's
health and environmental
groups' advocacy for a
province-wide ban.

See Coalition's Feb 3, 2012
ban statement.

Review ban legislation
given to BC's Environment
Minister in 2010.

Join the CCS's "Pesticide Free
BC" Facebook discussions.

Take action! to help BC
go pesticide free.
Health Canada protects Canadians . . .  wrong!

Many Canadians think because pesticides are for sale, they must be safe . . . wrong!

Many Canadians think pesticides are subjected to a rigorous, independent scientific approval process . . . wrong!

Health Canada Responsibilities
Health Canada's Pest Management Regulatory Agency (PMRA) registers all pesticides that are sold, used, manufactured or imported in Canada under the federal Pest Control Products Act 2002 c.28 (PCP Act).

Under the PCP Act, PMRA's responsibility is to: 
"protect human health and safety and the environment by regulating products used for the control of pests."
The multi-stakeholder volunteer Pest Management Advisory Council provides advice on Health Canada's pest management programs, including product registration. 

The leader of Canada's "plant science" and traditional chemical pesticide industry, CropLife Canada, is a Council member.  
 
This industry supports continued use of Health Canada's "safe and effective" pesticide products by properly trained Integrated Pest Management (IPM) applicators . . . on BC's lawns, sport fields, school yards, play grounds and golf courses.

Not surprisingly, the industry opposes pesticide bans . 

See left sidebar"No Ban Needed - CropLife".

PMRA's Conflict of Interest
As the federal Parliamentary Standing Committee on Environment and Sustainable Development May 2000 report states, PMRA is in a conflict of interest as it performs two conflicting tasks: 
  • by registering industry's products for public use; and
  • by regulating industry to protect human health, public safety and the environment.
See top right sidebars . . . "PMRA's Conflict of Interest" and "Biased PMRA Studies".

Use Pesticides "Safely"
Health Canada advises Canadians, when using pesticides, to use them "safely". 

There are many who do not accept that traditional, highly toxic cosmetic pesticides can be used safely.

The Ontario Government's pesticide website is very clear that their use  "presents an unnecesary risk to our families and pets, especially when we can have healthier lawns and gardens without chemicals." 

This unnecessary risk is why the Ontario Government's ban on the sale and use of cosmetic pesticides came into effect April 22, 2009.

Also see left sidebars . . .  "Use Safely", "Labelled Use is Dangerous", "Unnecessary Risk" and "Low Risk Pesticides".

PMRA's Product Registration Flaws
There are very serious flaws in PMRA's product registration process because:

Human health, public safety and environmental impacts are not adequately considered before PMRA registers a pesticide for sale and use in Canada.  
 
PMRA's biased "rubber stamp" registration of pesticide products submitted by industry is flawed for at least nine reasons . . .

1.   Most of PMRA's 7,000 registered ingredients were approved when safety, human health and environmental impact standards were lower.

Many ingredients would not be approved under today's stricter standards.

PMRA is reviewing "old" ingredients but many ingredients allowed in Canada are banned in many countries.

In August 2013, Ecojustice filed a lawsuit against the Government of Canada alleging that the Minister of Health and PMRA acted unlawfully when they refused to review three pest control ingredients that are banned in many countries.

In Canada, seven provinces prohibit the sale and use of some form of 2,4-D (in New Brunswick and PEI, 2,4-D is the only banned ingredient).

Yet, 2,4-D is the ingredient that PMRA decided in its’ May 2008 Re-evaluation Decision “meets Canada's strict health and safety standards, and as such is acceptable for continued registration in Canada".

PMRA confirmed in its' July 2013 Re-evaluation Note that "no further changes are needed" for the regulation of 2,4-D.

See right sidebars . . . "2,4-D is OK - PMRA", "2,4-D Bans" and "Why Originally Approved?". See left sidebar "Weed N Feed Bans".

PMRA's February 2010 re-evaluation of fertilizer-pesticide combination products did result in an "uncoupling" ban on their sale in Canada effective December 31, 2012.

It is noteworth that PMRA's "Weed N Feed" decision is presented as a landscaping industry concern, not a health or environmental priority:

"The PMRA decision to uncouple fertilizer-pesticide combination products is not based on the health or environmental risk assessments but rather the nature of combination products. 

Combination products remove the flexibility of applying spot applications of the pesticide due to the need to accommodate the fertilizer, which is designed for broadcast application to the entire lawn surface at specified times of the year."

See PMRA's February 2, 2010 Re-evaluation Note. 
 
On February 2, 2010, PMRA also initiated a re-evaluation of glyphosate , the active ingredient in one of the world's most used herbicides, aka Roundup.

Denmark banned spraying glyphosate in September 2003 because of groundwater contamination.

Time will tell if PMRA's glyphosate re-evaluation results in a Canadian ban.

See left sidebars . . . "Reconsider RoundUp Safety" and "2003 RoundUp Ban".

2.   PMRA relies on test data from studies financed by the chemical industry (mostly product manufacturers). 
 
PMRA does not do independent testing . . . none!
 
3.   Industry tests for high dose exposures on animals (toxicity) not humans (epidemiology).
 
Epidemiology is what links human diseases to pesticides.

Human illnesses and cancers linked to pesticides include asthma, Parkinson's Disease, impaired fetal and child development, and immunological effects from hormone/endocrine harm.

PMRA relies on confidential, animal toxicity data supplied by manufacturers, not epidemiological research that would address human health impacts.

See "Misguided Committee" right sidebar.

The Nuremberg Code forbids testing humans with a drug or chemical that may cause harm and provide no direct benefit. This is why no testing of pesticide ingredients is done on humans.

4.   Toxicity tests are done on animals, usually rodents like rats. 
 
Since 2004, scientists know that rats have detoxification genes that humans do not.

Dogs are considerably more sensitive to 2,4-D than rats. Dogs are not used as test animals.

5.   Toxicity tests are done for high dose exposure levels.

Since the 1990s, scientists have reported that high dose tests do not reveal health problems caused by chronic, low dose exposure from endocrine disrupting chemicals.  
In 2009, the American Chemical Society (ACS) acknowledged that endocrine disruption at low exposure levels exists and that this undermines the conventional toxicology approach of high dose animal experimentation. 

See "Need Low Dose Tests" right sidebar and the ACS's Public Policy Statement on Testing for Endocrine Disruption.

In Canada, when a pesticide is reviewed for registration, no tests are done on acute or chronic low does exposure levels that effect humans. 

The exclusion of low dose testing contributes to Health Canada's weak public health protection standards.

See right sidebars . . . "Need Low Dose Tests", "Missed Low Dose Harm" and "Low Dose, Big Effects".

6.   Only active ingredients are evaluated.
 
A pesticide manufacturer discloses only active ingredients . . . what kills the pest.

7.   Evaluation is done on each active ingredient, one at a time. 

Although the federal PCP Act requires cumulative assessment of chemically similar pesticides, this was not done in 2008 when PMRA re-assessed herbicides containing 2,4-D and allowed their continued registration.

Also, PMRA does not consider the toxic effects of product mixtures that can be combined by users and also does not consider the toxicity of pesticide mixtures when actually applied.

8.   There is no requirement to consider if safer, less toxic products (or methods) can kill the target pest.
 
"Inert" ingredients (aka formulants) are not disclosed to PMRA.  
Formulants are confidential, proprietary trade secrets and make up an unknown amount of a product . . . the binders, solvents and wetting agents that make a product stick, spread or penetrate. 

PMRA is not provided with toxicity analysis on formulants, yet these undisclosed ingredients may be more toxic than active ingredients.  

The toxicity of undisclosed ingredients in Health Canada's registered products is not known.

It is obviously not in the interest of those who submit products for PMRA's approval to show that their product is not necessary! 

PMRA is not required to consider if a safer alternative product or pest management method exists.

9.   A pesticide product is registered for use if risk is "acceptable". 

If a product's assessment  is below Health Canada's "acceptable risk" threshold and if the product does what it is advertised to do and kills the target "pest", the product can be registered for use in Canada.

Given the flaws in product assessment, "acceptable" risk must be questioned.

Industry & BC"s Ministry of Environment (MOE) Support Health Canada
The plant science landscaping industry is very public about their support for Health Canada and their use of Health Canada's "safe and effective" products.

BC's MOE also suports Health Canada's regulatory approval process.

See CropLife Canada, MOE and PMRA's 2011 presentations to BC's Special Committee on Cosmetic Pesticides.

Canadians are NOT Protected
Ask yourself: Who does Health Canada protect? . . . the health of Canadian kids? or the powerful chemical landscaping industry?

Health Canada does NOT protect Canadians from harmful pesticide use. The sidebars exemplify how Health Canada and PMRA continue to fail Canadians.

PMRA’s biased, rubber stamping of synthetic pesticide products is wrong and must be changed.

Health Canada's lack of protection is why there are . . .

Educate yourself why cosmetic pesticides must be banned across Canada . . . to protect all Canadians.

Find out about the harmful active ingredients in Canadian pesticide products by using: 

For more on Health Canada and PMRA’s failings, see . . .

For more info on . . .
  • The BC Ministry of Environment's promotion of IPM and the seven provincial bans, click here.
  • Industry opposition to pesticide laws, except those that allow continued IPM pesticide use, click here.
  • For low risk pesticides and sustainable land care practices, click here.

  • To advocate for strong ban legislation in BC, click here.
 
Last Updated on Friday, 04 October 2013 08:57
 

PMRA's Conflict of Interest

" . . we asked ourselves
whether
it is possible
for one agency,
the Pest Management
Regulatory Agency (PMRA),
to perform
two virtually
conflicting tasks,
namely that of
approving
chemical pesticides
as requested
by industry
while
at the same time
regulating them
in order
to protect
human health."

Pesticides,
Making the right choice
for the Protection
of Health and the Environment.

Parliamentary Standing Cttee
on Environment and
Sustainable Development. 
May 2000 Report.

See Chair's Preface to Report.

Biased PMRA Studies

" . . . the researchers
who have carried out
the studies
that are presented
to the PMRA
are paid
by the company
which is making
the product
they are examining.

The company
will have designed
the experiment
in a way most likely
to make their product
look good.

And if the test
goes badly
for the product,
the company's unlikely
to forward it
to the PMRA."

"Bias Built into
Feds' Pesticide Use Review
BC Doctor"
The Tyee.ca  Oct 22, 2011

Why originally approved?

"It is very pleasing
that EFSA (European
Food Safety Authority)
now acknowledge
there are significant
environmental risks
associated
with these chemicals.

It begs the question
of what
was going on
when these chemicals
were first approved.

Rachel Carson's Silent Spring
was 50 years ago
but we have not
learned the lessons."

"Insecticide 'unacceptable'
danger to bees,
report finds."

The Guardian
January 16 2013.

2,4-D is OK - PMRA

". . . data and information
submitted. . . support
the regulatory decision
for 2,4-D and
no further changes
are required."

 

Health Canada's
Pest Management
Regulatory Agency (PMRA)
July 2013 Re-evaluation
Update of May 2008
Re-Evaluation Decision.

2,4-D Bans

2,4-D is
banned in
Denmark, Norway & Sweden.

Newfoundland & Labrador,
Nova Scotia, Ontario
and Quebec
have banned 2,4-D.

New Brunswick and PEI
have banned
some 2,4-D products.

Alberta has banned the sale of herbicide/fertilizer products containing 2,4-D.
 
When will 2,4-D be banned
in Canada?  in BC?

Misguided Committee

" All this explains
why the PMRA
(and its recent fans,
members of BC's
Special Committee on
Cosmetic Pesticides)
and
the health
and medical community
reach opposite conclusions
regarding pesticides
and human health.

The doctors rely upon
the real-life human
epidemiological research,
rather than the
confidential
industry-produced
animal test data
or the PMRA's
evaluation reports
of
this test data."

"Misguided Recommendations,
Due to Reliance
on a Deficient
Regulatory System."

Prevent Cancer Now website.

Need Low Dose Tests

"Like the hormones
whose actions
they disrupt,
endocrine disrupting
chemicals
can follow what
endocrinologists call
bi-phasic, or non-monotonic,
dose response curves.

This makes it
impossible to predict
the effects
of low-dose exposures
based upon
high-dose experiments.

The effects can be
not only
different,
but opposite.

While well established
in medical endocrinology,
such responses
have been
less well understood
in traditional toxicology."

Public Policy
Statement 2009 - 2012
American Chemical Society

Missed Low Dose Harm

"Because all
regulatory testing
has been designed
assuming that
'the dose
makes
the poison,'
it is highly likely
to have
missed
low dose effects
and
led to
health standards
that are too weak."

Does 'the dose
make the poison?'

Pete Meyers & Wendy Hessler
Environmental Health News
April 30, 2007.

Low Dose, Big Effects

“We conclude that . . .
the effects of low doses
cannot be predicted
by the effects
observed at high doses.

Thus, fundamental changes
in chemical testing
and
safety determination
are needed
to protect human health.”

"Hormones amd
Endocrine-Disrupting
Chemicals: Low Does Effects
and Nonmonotonic Dose Responses"
Endocrine Reviews, June 2012.

See Environmental Health
News March 15, 2012
article on study.

Reduce Exposure Warning

"The Ontario College
of Family Physicians (OCFP)
is
strongly recommending
the public
reduce
their exposure
to pesticides
wherever possible."

"Ontario Family Physicians
Warn of Pesticide Dangers"
CNW Newswire
June 19, 2012

For OCFP's executive summary
and report, click here.