Consultation on strengthening the regulation of pest control products in Canada

The document provides a detailed critique of the Pest Management Regulatory Agency's (PMRA) Notice of Intent 2023-01, arguing that proposed regulatory changes are insufficient to protect biodiversity and human health. The coalition demands mandatory cumulative risk assessments that go beyond 'common mechanisms of toxicity,' more protective thresholds for species at risk, greater transparency for confidential test data, and the establishment of domestic MRLs based on Canadian use patterns rather than international trade alignment.

• The coalition argues that the proposed requirement to assess cumulative environmental risk only when a 'common mechanism of toxicity' is known is an inappropriate limitation that ignores holistic ecological harm, such as the depletion of prey species for birds or atmospheric damage.
• The authors contend that the PMRA's claim that no methodologies exist for cumulative environmental risk assessment is inaccurate, citing existing frameworks from the US EPA and the European Food Safety Authority (EFSA).
• The document asserts that current species at risk assessments are inadequate because they rely on representative species rather than the most sensitive ones and fail to account for non-toxicological stressors or habitat loss.
• The coalition recommends that the PMRA employ an uncertainty factor of at least ten for each uncertainty when sufficient data or methodologies for cumulative or species-at-risk assessments are unavailable.
• The statement criticizes the current process for accessing confidential test data (CTD) as being intentionally delayed and overly restrictive, hindering public engagement during comment periods.
• The document claims that the PMRA uses US-based food consumption data (DEEM-FCID) for dietary exposure assessments, which may not accurately represent the eating habits of Canadians.

APA

Canadian Association of Physicians for the Environment (2023). Consultation on strengthening the regulation of pest control products in Canada. https://cape.ca/wp-content/uploads/2023/09/2023-09-08-NOI-to-amend-PCPR-ENGO-joint-comments.pdf#new_tab

Chicago

Canadian Association of Physicians for the Environment. Consultation on strengthening the regulation of pest control products in Canada. 2023. https://cape.ca/wp-content/uploads/2023/09/2023-09-08-NOI-to-amend-PCPR-ENGO-joint-comments.pdf#new_tab.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Consultation on strengthening the regulation of pest control products in Canada |date=8 September 2023 |url=https://cape.ca/wp-content/uploads/2023/09/2023-09-08-NOI-to-amend-PCPR-ENGO-joint-comments.pdf#new_tab |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2023consultation, author = {{Canadian Association of Physicians for the Environment}}, title = {{Consultation on strengthening the regulation of pest control products in Canada}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2023}, month = sep, url = {https://cape.ca/wp-content/uploads/2023/09/2023-09-08-NOI-to-amend-PCPR-ENGO-joint-comments.pdf#new_tab}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }