REPORT OF CANADA'S COMMISSIONER OF THE ENVIRONMENT

by Cam Dahl, Executive Director, Grain Growers of Canada

Recently, Canada's Commissioner if the Environment released a cathing report on the operation and efficiency of the Pest Management Regulatory Agency (PMRA). This report concluded what farmers have known for some time - significant changes are required at the Agency.

Some highlights from the report include:

• PMRA is not meeting deadlines for the evaluation of newer and possibly safer pesticides. The Commissioner notes that this failure to meet deadlines continues despite improvements to the submission and registration process;
• Slow progress has been made in re-evaluating older and widely used pesticides against today's higher environmental and health standards;
• The evaluation process for new pesticides needs to be strengthened; and
• Joint reviews with the United States (US) are not achieving planned gains. The Commissioner noted that the Agency has had problems coordinating priorities and schedules with US evaluators.

For years farmers from across Canada have expressed significant frustration with the operation of the PMRA, especially the lack of movement towards a harmonized pesticide regulatory system in Canada and the US.

This frustration is especially apparent for farmers who utilize chemicals for minor crops. The ongoing failure by the PMRA to resolve this issue has resulted in significant cost increases for many farm families. While much study and review of this problem has taken place, little progress has been made towards a solution. It must be noted that the so-called "minor" crops represent over $4 billion in annual production in Canada every year.

Farmers' need for an increasingly flexible North American regulatory system will continue to grow as our agriculture industry adapts and diversifies.

Farm groups' efforts to bring political attention to this problem have been successful. In May of 2002, the House of Commons Standing Committee on Agriculture and Agri-food recommended that a special advisor on minor use be appointed with:

"a special focus on the harmonization issues with the United States, such as the equivalency of similar zone maps, and the consideration of data that already exist in an OECD country"

While a minor use advisor has been appointed, it is clear from the Environment Commissioner's report that real progress towards harmonization has not been made and that the goal of effective consideration of data generated in other jurisdictions has not been met.

Problems at the Agency have a negative impact on trade, as well as denying Canadian farmers access to newer and more effective chemicals. These trade concerns will be exacerbated if the PMRA does not meet its objectives for both the evaluation of new pesticides as well as the re-examination of older products. As noted by the Environment Commissioner, the Agency is currently not meeting either of these goals.

If the PMRA fails in these twin objectives. Canadian farmers may be increasingly faced with the situation of being forced to use older chemicals that may have been de-listed in the US. This failure will deny our farmers future access to markets in the US, because they have developed a policy of zero tolerance for chemicals that are no longer licensed for use south of the border. This is despite the fact that, because the market for food in North America is open, Canadian consumers purchase products produced with chemicals used in the US, even when these chemicals have not managed to navigate the Canadian approval process.

The Environment Commissioner noted that one of the key purposes of joint reviews with the US is to reduce agriculture trade irritants between our two countries. Unfortunately those that manage the PMRA are ignoring this important message. In a letter dated October 20, 2003, the acting Executive Director of the PMRA stated that they consider the Canadian and US systems to be "largely harmonized" and that differences have "not created significant impediments to date". This letter was sent in response to a joint submission, to the PMRA and the US Environmental Protection Agency, from the GGC and the US National Association of Wheat Growers.

The GGC and our member organizations will continue to pressure the Agency to recognize the need for change and adopt the recommendations of the House of Commons Standing Committee and the Environment Commissioner.

There is an even greater concern highlighted by the Environment Commissioner's report. Comments from the Commissioner have left some Canadian's wondering if the pest control chemicals used by farmers are safe. It is important for farmers to understand, and emphasize to Canadian consumers, our continued confidence in the safety of the pesticides that are in use today.

We know that developers spend years researching and testing to deliver safe pesticides to farmers. For example, it takes about 10 years, up to 160 tests and roughly $300 million to bring a pest control product from laboratory to market.

No pesticide can be registered for use in Canada unless it has been proven to regulatory authorities that the product poses no unacceptable risk to the public or the environment. The Environment Commissioner herself has indicated that the regulatory framework, through which these products must pass, is sound.

It is very unfortunate that ongoing operational concerns at the Agency are clouding these facts. A continuation of these problems could begin to erode consumer confidence in Canadian agriculture, which is a very serious issue for Canadian farm families.

The Grain Growers of Canada will continue to pursue our long-term goal of a system where registrants submit one application to a joint review process, and labels are issued which are good in either country.

A joint system solves problems for registrants, regulators, and address the many frustrations of producers on both sides of the Canada - US border. We strongly encourage and request that EPA and PMRA re-double their efforts to conclude the process and merge the registration systems into one seamless joint procedure.