Consultation on Targeted Review of the Pesticide Control Products Act

The submission argues that the current pesticide regulatory framework in Canada is inadequate, citing historical failures to prevent unacceptable risks and a reliance on risk assessment over hazard prevention. The authors advocate for a 'planetary health' approach that integrates climate change, biodiversity, and environmental justice into pesticide regulation. They propose 22 detailed recommendations across four areas: lifecycle approach to business practices, improved risk assessment for vulnerable populations, increased transparency in decision-making, and a more rigorous application of real-world data and Maximum Residue Levels (MRLs). Key goals include a 50% reduction in pesticide use by 2030 and the adoption of the precautionary principle.

• The authors argue that pesticide regulation must be integrated into a broader 'planetary health' framework, noting that pesticides can damage soil biodiversity, which in turn impairs carbon storage and sequestration capabilities.
• The submission highlights significant human health concerns linked to pesticide use in Canada, including elevated breast cancer risks in Essex and Kent counties, Ontario, and the detection of banned DDT in the breast milk of Inuit women in the North.
• The organizations recommend that Canada align with European Union goals by requiring the ministers of health and environment to create a plan to reduce pesticide use and risk by 50 percent by 2030.
• The authors critique the PMRA's reliance on 'risk assessment' (likelihood of harm) and advocate for 'alternatives assessments' based on a hazard prevention paradigm to eliminate the concept of 'acceptable risk'.
• The submission calls for a modernized lifecycle approach to pesticide regulation, including the elimination of purely administrative renewals and the requirement that post-market reviews be completed within three years or face automatic registration suspension.
• The authors demand expanded risk assessments that specifically account for cumulative impacts and windows of vulnerability for pregnant women, children, workers, Indigenous people, and racialized communities.
• The document proposes significant transparency reforms, including the revocation of confidential test data provisions and the requirement for better documentation of how the PMRA considers statutory criteria in its decisions.

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} }