E-Delivery

Alberta Pulse Growers published the first installment of this ongoing dialogue Can Canadian Producers Remain Compe ve in Our Pest Management Regulatory Environment? in its Summer 2017 edi on of Pulse Crop News. This discussion con nues with a focus on growers' increasing concern over the re-evalua on process at the Pest Management Regulatory Agency (PMRA). Specifically, does the re-evalua on process allow for adequate levels of scien fic scru ny and does the PMRA have sufficient professional exper se in agriculture to allow it to regulate this increasingly complex sector of the Canadian economy? THE RE-EVALUATION PROCESS Alberta Pulse Growers, among other Canadian grower groups, has become increasingly frustrated with the PMRA's re-evalua on process and other post-registra on assessments of a range of safe, efficacious, cost- effec ve and widely used pest management tools. Stakeholders expect this re-evalua on process to be science-based. Science consists of asking ques ons, gathering and examining all available data, analyzing the informa on, drawing logical conclusions and then communica ng this informa on in a clear and concise manner to stakeholders. The Government of Canada follows this science-based scenario it its work within the global trade community. The result is that Canadian commodity producers and processors have access to somewhat stable and predictable global markets while Canadian consumers maintain reliable access to sufficient quan es of healthy food. Unfortunately, in two recent re- evalua on decisions, the proposed termina on of the use of imidacloprid and the proposed cancella on of all uses of lambda-cyhalothrin, the PMRA overlooked a substan al quan ty of informa on which may have be er informed the decision-making process and possibly enhanced the value of the report. In addi on, the PMRA then went on to make decisions that were not based on all of the most up- to-date and accurate data available. The ques on that stakeholders may be asking is: In overlooking important informa on and not using all of the data available in its re-evalua on decisions, is the PMRA's process something other than science-based? The process followed by the PMRA in a number of recent re-evalua on decisions appears to have placed a key group of stakeholders in a posi on of passive observance, rather than that of ac ve par cipa on. In its proposal to phase out all agricultural uses of imidacloprid, as an example, the PMRA took a different posi on than that of the United States (US). The US Environmental Protec on Agency (EPA) concluded in its own assessment of imidacloprid that it was ". . . in general agreement with recent findings published by Canada's Pest Management Regulatory Agency. . ." yet the EPA made no proposal to phase out the use of imidacloprid in the US. This discrepancy may be a ributed to key differences in the re-evalua on process in Canada compared to that of the US. While the Canadian re-evalua on decision includes a dra risk assessment and proposed mi ga on measures that are open to consulta on, the US EPA, publishes only a dra risk assessment. This allows US stakeholders to address risks and propose poten al risk mi ga on strategies up-front, before the EPA publishes the final dra decision. This key difference permits US grower groups, among other stakeholders, to assess the poten al impact of any decisions before a proposal is made to phase-out a pest management tool. The value of the EPA's process is that the Agency does not risk overlooking important informa on and is confident THE PEST MANAGEMENT REGULATORY AGENCY (PMRA), RE-EVALUATION DECISIONS AND LACK OF PEST MANAGEMENT TOOLS THE CURRENT CANADIAN PESTICIDE REGULATORY ENVIRONMENT Ron Pidskalny, M.Sc., P.Ag. Strategic Vision Consul ng Ltd. Con nued on Page 22 2 0

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