Proposed Cumulative Risk Assessment Framework, PRO2017-01

The document argues that the PMRA has failed to meet legal requirements under the Pest Control Products Act (PCPA) to assess cumulative pesticide risks since 2006. While welcoming the proposed framework, the signatories recommend that cumulative assessments be integrated into individual pesticide registration and re-evaluation decisions, rather than occurring after them. They call for a precautionary approach to grouping pesticides by common mechanisms of toxicity, the inclusion of epidemiological data for outcomes like cancer and endocrine disruption, and the expansion of the framework to cover cumulative environmental risks. Additionally, the authors contest the PMRA's characterization of the 'PCPA factor' as a policy rather than a scientific uncertainty factor and urge for improved monitoring of human and environmental pesticide exposures.

• The PMRA has not yet assessed the cumulative health effects of pesticides approved for use in Canada, despite legal requirements in the Pest Control Products Act (PCPA) that have been in place since 2006.
• The signatories argue that the re-evaluation of individual pesticides should not be considered finished until cumulative risks have been assessed, and that these assessments should influence decisions on registrations, maximum residue levels, and special reviews.
• A 2015 audit by the Commissioner of the Environment and Sustainable Development found that the PMRA lacked evidence in some cases to support conclusions that no common mechanism of toxicity existed, and in other cases had not yet determined if an assessment was warranted.
• The authors recommend a precautionary approach to grouping pesticides, suggesting that the PMRA should proceed with cumulative risk assessments when there is uncertainty about toxicity mechanisms, placing the burden on registrants to disprove common mechanisms.
• The signatories suggest that the PMRA adopt a weight-of-evidence approach for outcomes such as cancer and endocrine disruption that incorporates epidemiological data and systematic review methods, rather than relying solely on biochemical groupings.
• The document disputes the PMRA's classification of the 'PCPA factor' as a 'policy' uncertainty factor, asserting instead that it is based on the scientific understanding of the increased vulnerability of infants and children.
• The authors recommend expanding the proposed framework to include cumulative environmental risks, noting that the same methodologies used for human health could be applied to environmental assessments, such as those for pollinators.

APA

Canadian Association of Physicians for the Environment (2017). Proposed Cumulative Risk Assessment Framework, PRO2017-01. https://cape.ca/wp-content/uploads/2018/03/1.Comment-letter-on-PMRA-Cumulative-Risk-Assessment-Framework-April-17-2017.pdf

Chicago

Canadian Association of Physicians for the Environment. Proposed Cumulative Risk Assessment Framework, PRO2017-01. 2017. https://cape.ca/wp-content/uploads/2018/03/1.Comment-letter-on-PMRA-Cumulative-Risk-Assessment-Framework-April-17-2017.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Proposed Cumulative Risk Assessment Framework, PRO2017-01 |date=14 April 2017 |url=https://cape.ca/wp-content/uploads/2018/03/1.Comment-letter-on-PMRA-Cumulative-Risk-Assessment-Framework-April-17-2017.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2017proposed, author = {{Canadian Association of Physicians for the Environment}}, title = {{Proposed Cumulative Risk Assessment Framework, PRO2017-01}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2017}, month = apr, url = {https://cape.ca/wp-content/uploads/2018/03/1.Comment-letter-on-PMRA-Cumulative-Risk-Assessment-Framework-April-17-2017.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }