Canada’s regulator for crop protection products is facing a growing stack of re-evaluations for existing pesticide ingredients.
There are several hundred active ingredients due for review by Health Canada’s Pest Management Regulatory Agency (PMRA) in the next decade.
CropLife Canada — the organization that represents manufacturers of some of these products — has several concerns about the looming deluge of re-evaluations: mainly, that the PMRA doesn’t have the capacity to process the reviews in a timely fashion, as the agency has not stayed up-to-date with internal timelines for re-evaluations. The second concern revolves around the PMRA’s re-evaluation process not allowing for proper consultation.
“There are resource concerns for us at PMRA for the workload issues, and then there’s also the process questions. If they start to do this with all these other products that are coming down the pipeline for re-evaluation, this is a significant issue for us,” says Pierre Petelle, president and CEO of CropLife Canada in the interview below.
Under the current process for reviewing previously-registered products, the PMRA publishes a proposed re-evaluation decision before opening up public consultations to accept comments and new information from stakeholders, including registrants and producers.
The problem with these proposed decisions is that the proposed part is often lost in media coverage and activist messaging, says Petelle, citing the current proposed re-evaluation decision regarding the insecticide imidacloprid as an example.
“The narrative out there was that Canada was banning imidacloprid, and the activist groups were cheering them on to say ‘yes, well done,'” he says. “So now for them to take in the new data provided as part of the consultation, if it’s valid information that changes their assumptions, they’re obligated to make those changes. We’re just predicting the pushback from these groups would be tremendous if the product was allowed to remain in the market, as it should, based on the data.” (continues below)
Petelle suggests the PMRA engage the companies that sell crop protection products earlier in the process when there’s a re-evaluation or a risk concern with a compound.
“There needs to be a scientific dialogue with the registrant — step one. Because there may be data that the registrant has; there may be assumptions that the regulator’s making about the use pattern that are no longer correct; the kind of equipment being used may have changed. They don’t know that unless they start that conversation with the registrant.”
Given Canada is a relatively small player in the global crop protection market, it’s important the regulatory approval process doesn’t scare companies away, says Petelle, noting there could be opportunities to work with the U.S. Environmental Protection Agency.
“When it comes to new active ingredients, PMRA is at the forefront, whereas on the older products, on the re-evaluations, we’re working in a silo; we’re not really paying attention to what the U.S. EPA is doing, or other jurisdictions. And so we’re getting decisions out of Canada that are not always in line with other jurisdictions where our farmers are competing against.”
Petelle’s colleague Maria Trainer shared an update on the pesticide re-evaluation pipeline at the CropSphere Conference in Saskatoon in January, where she outlined the three primary streams in the PMRA’s re-evaluation process:
- in 2001, Health Canada launched a program to re-examine 401 active ingredients registered before 1995. Of the original 401 chemistries, there were still 35 re-evaluations to be finished, noted Trainer. The PMRA reports over 20 percent were identified for discontinuation, and ‘very few’ were accepted for continued use without label changes;
- cyclical re-evaluations are required every 15 years under current legislation. Trainer noted 74 were underway or done, with another 369 to be initiated between 2018 and 2028. The re-evaluation process for a specific chemistry usually takes two to five years;
- special reviews are unpredictable and can be initiated if new information comes to light or if there are reasonable grounds for concern. A special review is also required if another OECD member country restricts use of an active ingredient. (This is one of the ways Canadian farmers can be impacted by European countries’ pesticide policies.) There were 23 special reviews underway in January, said Trainer.
Click here to view the slides from Trainer’s CropSphere presentation.
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