Proposed Re-evaluation Decision PRVD2019-05, Chlorpyrifos and Its Associated End-use Products: Updated Environmental Risk Assessment

The document argues for a total ban on chlorpyrifos in Canada, asserting that the PMRA's proposed re-evaluation decision does not go far enough. The authors claim that risks to pollinators, birds, mammals, and aquatic life are unacceptable and that current risk assessments underestimate exposure due to a lack of surface water monitoring data. They specifically challenge the safety of continued use in mosquito control and greenhouses, citing evidence of biodiversity in temporary pools and the inefficiency of label restrictions to prevent runoff.

• The signatory organizations support the proposed cancellation of most chlorpyrifos uses because risks to fish, aquatic invertebrates, mammals, birds, and pollinators are deemed unacceptable.
• The authors argue that PMRA risk assessments frequently underestimate environmental exposure because of a persistent lack of robust surface water monitoring data, a gap that existed for over a decade in the original 2003 assessment.
• The document contends that the PMRA's pollinator risk assessment is flawed because it ignores exposure from spray drift and soil/soil-water pathways, noting that 11 to 74 per cent of spray can drift one metre downwind.
• The authors challenge the PMRA's assumption that mosquito larvae control in temporary standing pools is low-risk, citing research from North Carolina, the UK, Australia, and Argentina that shows high insect diversity in such pools.
• The organizations question the effectiveness of proposed label restrictions to prevent greenhouse effluent from entering water bodies, citing similar failures with neonicotinoid pesticides.

APA

Canadian Association of Physicians for the Environment (2019). Proposed Re-evaluation Decision PRVD2019-05, Chlorpyrifos and Its Associated End-use Products: Updated Environmental Risk Assessment. https://cape.ca/wp-content/uploads/2019/08/NGO-comments-on-proposed-PMRA-ddecision-on-chlorpyrifos-July-2019.pdf

Chicago

Canadian Association of Physicians for the Environment. Proposed Re-evaluation Decision PRVD2019-05, Chlorpyrifos and Its Associated End-use Products: Updated Environmental Risk Assessment. 2019. https://cape.ca/wp-content/uploads/2019/08/NGO-comments-on-proposed-PMRA-ddecision-on-chlorpyrifos-July-2019.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Proposed Re-evaluation Decision PRVD2019-05, Chlorpyrifos and Its Associated End-use Products: Updated Environmental Risk Assessment |date=31 July 2019 |url=https://cape.ca/wp-content/uploads/2019/08/NGO-comments-on-proposed-PMRA-ddecision-on-chlorpyrifos-July-2019.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2019proposed, author = {{Canadian Association of Physicians for the Environment}}, title = {{Proposed Re-evaluation Decision PRVD2019-05, Chlorpyrifos and Its Associated End-use Products: Updated Environmental Risk Assessment}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2019}, month = jul, url = {https://cape.ca/wp-content/uploads/2019/08/NGO-comments-on-proposed-PMRA-ddecision-on-chlorpyrifos-July-2019.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }