As Healthy Lawns Information Coordinator for Landscape Ontario, Ken Pavely works actively with members and municipalities on Landscape Ontario members’ behalf to help develop programs to reduce pesticide use through responsible and effective plant health care strategies. One of Pavely’s ongoing functions is to present a balanced and rational defense to anti-pesticide allegations, which all-too-often misquote scientific studies as proof of a pesticide’s potential for harm. In his position as Landscape Ontario’s ambassador for responsible pesticide use, Pavely contacted the federal Pest Management Regulatory Agency (PMRA) for clarification on their position regarding the effects of pesticides on human health and other issues. The following is the official response from PMRA.


May 16, 2001 Dear Mr. Pavely:

This letter is in response to your request concerning the federal position on the issues of human health effects of pesticides and the adequacy of federal regulation for pesticides.

     I would like to share with you some information about the comprehensive evaluation of potential risks posed by a pesticide conducted by the Pest Management Regulatory Agency (PMRA) on each pesticide product proposed for use in Canada.

     Extensive health, environmental and value studies must be submitted to the PMRA before a new pest control product can be considered for registration. Today, we require that these studies include acute short-term and long-term repeated exposure studies in animals over a range of doses, including very high doses to maximize the potential for identifying toxic effects. In addition, reproductive and development toxicity studies, genotoxicity studies and lifetime cancer bioassays in two species are also required. Environmental studies on non-target plants, on beneficial insects and predators, and on birds and other animals are also submitted for assessment. All of these studies must be carried out to the detailed international specifications accepted by the PMRA. The laboratories that prepare the studies must comply with an international standard of Good Laboratory Practice.

     The PMRA carefully evaluates these studies and makes registration decisions based on rigorous scientific assessments. Only products that pose no unacceptable risks to health or the environment of Canadians will be accepted for registration in Canada. At the present time, this evaluation includes considerations of all population groups, including adults, teenagers, children, infants and embryos, and extensive environmental considerations.

     The tests and studies done in areas such as reproductive and developmental toxicity examine for any effects of the pesticides on the entire life cycle of an animal. The tests cover exposure in the womb through to adulthood and also examine for effects on the offspring.

     When considering the acceptability of a new pesticide or a pesticide under re-evaluation, the PMRA specifically takes into consideration whether there is a possibility that children are exposed. Exposure assessment includes factors such as a child’s size, diet and child-specific activities that may lead to increased exposure, such as putting their hands in their mouth or crawling on a surface that might be contaminated with pesticide residues.

     Every effort is made by the PMRA to ensure that pesticides to be registered or to be re-registered following re-evaluation for use in Canada do not pose unacceptable health risks to infants, children and the unborn. In addition, whenever scientific approaches emerge that can enhance the PMRA’s assessment process, especially where children’s exposure is concerned, the Agency integrates this new knowledge into pesticide risk assessments. We do not need to amend the legislation to include these new scientific requirements.

     I believe that the Canadian pest management regulatory system provides a regime that meets international standards for the prevention of unacceptable risks from pesticides.

     At the federal level, the Pest Control Products Act (PCPA) is the primary legislation for the regulation of pesticides in Canada and governs their importation, manufacture, sale and use. The PCPA entrenches the authority for risk assessment and risk management based decisions, whereby the risks and value of a product must be considered acceptable by the Minister for it to enter and remain on the market in Canada. The legislation also includes provisions to facilitate enforcement of compliance with the PCPA and Regulations. It should also be noted that provincial pesticide legislation plays an important role in the overall process of pesticide regulation in Canada. Provinces can and do impose further restrictions to the use of pesticides based on their detailed knowledge of their region.

     Overall, I do believe that the Canadian legislative regime has served Canadians well in preventing unacceptable risk from pesticides. The amendments to the PCPA that are under consideration will further strengthen our capacity, and more importantly, will enhance the openness of the regulatory process and decision making.

     Health Canada’s role in pesticide regulation is not limited to the evaluation of new products. The PMRA has introduced an enhanced program to systematically re-evaluate older pesticides to ensure that they meet current-day standards. Regulatory action will be taken on any product that is found to result in an unacceptable risk of harm. Currently, the PMRA is re-evaluating organophosphate pesticides. Children’s exposure is a specific focus of this initiative.

     Health Canada recognizes that there are a variety of techniques that can reduce or avoid the use of pesticides in preventing and managing pests. There are some instances, however, where an infestation of pests, whether insect, weed or plant disease, may require the use of pesticides. Urban landscapes are not immune to pest infestations; therefore, acceptable solutions are available when needed.

     On October 16, 2000, Minister Rock announced that an Action Plan for Urban Use Pesticides has been developed through a partnership effort between the PMRA and the provincial and territorial governments. The Action Plan is one of the first steps that the government will be taking as part of its response to the Report of the House of Commons Standing Committee on the Environment and Sustainable Development, Pesticides: Making the Right Choice for the Protection of Health and the Environment.

     The Government believes that a key approach to reducing pesticide risk and advancing sustainable pest management is to combine rigorous health and environmental standards for new products and re-evaluation of older products with the development and promotion of the use of practices such as Integrated Pest Management that emphasize prevention and that can lead to a reduced reliance on and use of pesticides. This combined approach should make a strong contribution towards achieving the goal of sustainable pest management, while maintaining a choice for Canadians on whether or not to include pest control products as an option for managing pests.

     The PMRA is working with the Federal/Provincial/Territorial Committee on Pest Management and Pesticides to implement a Healthy Lawns Strategy, one of the three components of the Action Plan.

     The Healthy Lawns Strategy will place particular emphasis on pest prevention, the use of reduced risk products and the application of pesticides only when necessary. The PMRA, provinces and territories will develop training materials and programs to educate homeowners on healthy lawn practices, which minimize the need for pesticides, and work with organizations to enhance the training of lawn care and landscape services providers and green space managers. Copies of the Action Plan for Urban Use Pesticides, including the Healthy Lawns Strategy, can be found through the PMRA’s Healthy Lawns web site at www.healthylawns.net. The web site provides information on reduced risk pest management and pest prevention strategies for lawns and turfgrass. Background information about the Healthy Lawns general Stakeholder Meeting, held on March 1 and 2, 2001, is also available on the web site. I encourage you to visit the Healthy Lawns web site on a continuous basis for updates on the Healthy Lawns Strategy. I hope the information I have provided will be helpful to you.

Yours sincerely,
C.A. Franklin, Ph.D.
Executive Director
Pest Management Regulatory Agency