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

A June 2018 letter from four health and environmental non-profits to Canada's Chief Science Advisor, Dr. Mona Nemer, requesting an investigation into the scientific integrity and transparency of the Pest Management Regulatory Agency (PMRA). The authors argue that the PMRA's regulatory processes for pesticides like neonicotinoids, glyphosate, and atrazine contravene government commitments to evidence-based decision-making by relying on non-public data and ignoring peer-reviewed science.

• The authors allege that the Pest Management Regulatory Agency (PMRA) lacks transparency and scientific integrity, specifically claiming that its regulatory processes contravene the Government of Canada's commitments to openness and evidence-based decision-making.
• Regarding neonicotinoids, the authors state that PMRA pollinator assessments relied heavily on non-public, non-peer-reviewed data, leading to regulatory decisions that lag behind other jurisdictions. They note that while the European Food Safety Authority (EFSA) planned to ban all outdoor uses of neonicotinoids by the end of 2018, the PMRA's proposed restrictions were more limited. Additionally, the PMRA proposed phasing out imidacloprid by 2021 at the earliest, which the authors argue ignores scientific evidence necessitating an immediate ban.
• The evaluation of glyphosate, which took over seven years, is criticized for dismissing certain studies without scientific rationale and relying on unpublished lab reports from the 1980s and 1990s instead of peer-reviewed literature from the 2000s. The authors express concern that the use of Confidential Business Information (CBI) studies—accessible only in person in Ottawa—may misrepresent the weight of evidence due to repeated reference codes.
• The PMRA's review of the herbicide atrazine is described as too narrow, necessitating a secondary review after public consultation. The authors claim this inefficient process has caused a multi-year delay in risk management, leaving Canadians exposed to a pesticide that has been banned in Europe for more than ten years.

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} }