Closing the Resource Gap at Health Canada’s Pest Management Regulatory Agency

The COVID-19 crisis has prompted strong recognition of food security issues among Canadians, both food affordability and the ability to produce food domestically. Alongside COVID-related government investment to support Canada’s agricultural sector, longstanding challenges remain in achieving timely pesticide regulation. To keep pace with the needs of growers and other pesticide users, federal statutory authority, obligations, and capacity to assess and regulate pesticides must be expanded.

Assure adequate funding to update pesticide risk assessments. As required by law, PMRA initiates a re-evaluation of each registered pesticide on a 15-year cycle. However, PMRA cannot keep pace with a workload of both aging files and an increasing backlog, exceeding capacity and existing resources.

PMRA recently undertook a review of the re- evaluation program, which resulted in a proposal for a more integrated approach. While the new approach is intended to achieve greater efficiency, increased funding is essential to avoid problems with performance, further delays, and limits to PMRA’s ability to respond to stakeholder expectations and emerging issues. This situation threatens to undermine the integrity of Canada’s pesticide regulatory regime.

Moreover, PMRA must also complete re-evaluations for pesticides registered before 1995, which pose unknown risks, never having been assessed in Canada using modern scientific methods. Thirteen large and complex historical reviews remain incomplete. Additional, dedicated resources are needed to clear this backlog.

Launch a pesticides water monitoring program. A key element of the new integrated approach to pesticide re-evaluation is early and ongoing identification of changes in pesticide use and exposure. Thus, success of the new approach will require investment in a systematic approach to collecting robust water monitoring data. Currently, PMRA  does not conduct water monitoring and available data from other federal departments, provinces, and stakeholder associations often lack the level of detail needed for exposure assessment calculations. (see also Canada Water Agency recommendation)

Upgrade label requirements. Re-evaluations routinely result in changes to use requirements and these are specified on the product label. The label is the key interface between a pesticide risk assessment and its end use. In 2019 PMRA launched a “Label Improvement Initiative” that requires additional resources to address identified problems such as label consistency and clarity, as well as implementation issues.

Fund compliance and enforcement.  In 2018-19 PMRA conducted 217 “Compliance Outreach” educational activities and just 780 inspections, over 500 fewer inspections  than in 2016-17. This number equates to less than 1% of the 193,000 farms in Canada (not to mention non-agricultural uses of pesticides). The rate of compliance by sub-sector ranged from as low as 8% (mainly due to illegal imports) up to 100%, with a multi-year problem of non-compliance among pest control operators (exterminators) apparent from multiple fines levied in this sector again during 2019. Across all pesticide uses, a more robust compliance and enforcement program is needed to ensure that end users properly implement risk-reduction requirements and restrictions, particularly label changes.

Recommended Investment:

An additional $80 million over two years [Health Canada] to upgrade post-market pesticide regulation and enforcement as follows:

•   $65 million for PMRA’s post-market review program (roughly double the current annual spending).

•   $5 million for PMRA to launch a water monitoring pilot.

•   $2 million for PMRA to implement its Label Improvement Initiative.

•   $8 million for Health Canada to expand pesticide compliance and enforcement activities.

Lisa Gue –
Kathleen Cooper –