Microsoft Word - Letter to chief science advisor - FINAL.docx

The document argues that the PMRA's regulatory decisions on pesticides like neonicotinoids, glyphosate, and atrazine lack transparency and scientific rigour, often relying on non-peer-reviewed or confidential data while ignoring public scientific literature.

• The authors claim the PMRA's regulatory process for pesticides contravenes the Canadian government's commitments to openness, transparency, and evidence-based decision-making, citing concerns about scientific integrity.
• Regarding neonicotinoids, the PMRA is criticized for conducting narrowly scoped evaluations and relying on non-public, non-peer-reviewed data, resulting in regulatory decisions that lag behind the European Food Safety Authority (EFSA), which planned to ban all outdoor uses of neonicotinoids by the end of 2018.
• The PMRA's evaluation of glyphosate is described as problematic due to an over-reliance on unpublished lab reports from the 1980s and 1990s and the use of Confidential Business Information (CBI) studies that are only accessible in person in Ottawa.
• The scientific review of atrazine was deemed too narrow, necessitating a secondary review and causing a multi-year delay in risk management for a pesticide that has been banned in Europe for over ten years.
• The authors highlight a systemic issue where pesticide registrants can legally review and provide feedback on the PMRA's interpretation of peer-reviewed literature, creating an imbalance in favor of unpublished data.

APA

Canadian Association of Physicians for the Environment (2018). Microsoft Word - Letter to chief science advisor - FINAL.docx. https://cape.ca/wp-content/uploads/2018/06/Letter-to-chief-science-advisor-FINAL.pdf

Chicago

Canadian Association of Physicians for the Environment. Microsoft Word - Letter to chief science advisor - FINAL.docx. 2018. https://cape.ca/wp-content/uploads/2018/06/Letter-to-chief-science-advisor-FINAL.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Microsoft Word - Letter to chief science advisor - FINAL.docx |date=13 June 2018 |url=https://cape.ca/wp-content/uploads/2018/06/Letter-to-chief-science-advisor-FINAL.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2018microsoft, author = {{Canadian Association of Physicians for the Environment}}, title = {{Microsoft Word - Letter to chief science advisor - FINAL.docx}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2018}, month = jun, url = {https://cape.ca/wp-content/uploads/2018/06/Letter-to-chief-science-advisor-FINAL.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }