Consultation on Targeted Review of the Pesticide Control Products Act

A joint submission by the Canadian Association of Physicians for the Environment (CAPE), Environmental Defence, Wilderness Committee, and Safe Food Matters Inc. providing recommendations for the targeted review of the Pest Control Products Act (PCPA) and the transformation of the Pest Management Regulatory Agency (PMRA).

• The submitting organizations argue that the PMRA has historically failed to manage pesticides effectively, citing a 2003 review by the Federal Commissioner of the Environment and Sustainable Development and a 2016 audit that found the agency allowed the use of pesticides it deemed to pose "unacceptable risks to humans and the environment".
• The authors advocate for a shift from a risk assessment paradigm to a hazard prevention paradigm, specifically recommending "alternatives assessments" to eliminate the concept of "acceptable risk" and prioritize the selection of less hazardous chemicals.
• The submission proposes 11 specific priorities for the PCPA review, including a goal to reduce pesticide use and risk by 50 percent by 2030 to align with European Union targets, the prohibition of cosmetic pesticides (except minimum risk products), and the regulation of treated seeds under the Act.
• The organizations recommend significant reforms to the lifecycle approach of pesticide regulation, including the elimination of purely administrative renewals, the conversion of the five-year renewal period into a legislative requirement, and the implementation of a more robust recall regime for products with data deficiencies or uncertain risks.
• The submission calls for expanded risk assessment requirements to include cumulative impacts and specific vulnerabilities for pregnant women, children, workers, Indigenous people, and racialized communities, while emphasizing that personal protective equipment (PPE) should be the "last line of defence".
• The authors demand increased transparency and a culture shift within the PMRA, specifically calling for the revocation of confidential test data provisions in the Act and the requirement for better documentation of scientific analysis at all decision points.
• Regarding Maximum Residue Levels (MRLs), the submission recommends that MRLs be made a condition of registration, that the "limit of quantification" be the default MRL in all cases, and that MRLs be reviewed during registration renewals and amendments.

APA

Canadian Association of Physicians for the Environment (2022). Consultation on Targeted Review of the Pesticide Control Products Act. https://cape.ca/wp-content/uploads/2022/07/Joint-Submission-Consultation-on-Targeted-Review-of-the-Pesticide-Control-Products-Act-June-30-2022.pdf#new_tab

Chicago

Canadian Association of Physicians for the Environment. Consultation on Targeted Review of the Pesticide Control Products Act. 2022. https://cape.ca/wp-content/uploads/2022/07/Joint-Submission-Consultation-on-Targeted-Review-of-the-Pesticide-Control-Products-Act-June-30-2022.pdf#new_tab.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Consultation on Targeted Review of the Pesticide Control Products Act |date=28 June 2022 |url=https://cape.ca/wp-content/uploads/2022/07/Joint-Submission-Consultation-on-Targeted-Review-of-the-Pesticide-Control-Products-Act-June-30-2022.pdf#new_tab |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2022consultation, author = {{Canadian Association of Physicians for the Environment}}, title = {{Consultation on Targeted Review of the Pesticide Control Products Act}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2022}, month = jun, url = {https://cape.ca/wp-content/uploads/2022/07/Joint-Submission-Consultation-on-Targeted-Review-of-the-Pesticide-Control-Products-Act-June-30-2022.pdf#new_tab}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }