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Harmonization Proposal Deserves To Be Noticed
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Dear Friends,
The proposal below for the "Harmonization" of U.S. and Canadian pesticide
regulations under NAFTA has largely escaped public notice due to the
unacceptable way it was released by Health Canada's Pest Management
Regulatory Agency (PMRA).
Take a moment and look over the problems I've listed below. If you see the
same urgent need that I do, demand that this proposal be resubmitted for
public comment with a heading that mentions "pesticides" explicitly!
For Information on contacting the PM or your MP, go to the Canadians Against
Pesticides website: http://www.caps.20m.com/
Helen Jones
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THE FOLLOWING PROPOSAL IS CENTRAL TO
THE WAY PESTICIDES ARE REGULATED IN CANADA, BUT MANY MAY BE UNAWARE OF IT
BECAUSE THE WORD "PESTICIDES" DIDN'T EVEN APPEAR IN THE TITLE ....
"Harmonization of environmental chemistry and fate data requirements under
NAFTA"
The 45 day comment period began October 5, 2001
<http://www.hc-sc.gc.ca/pmra-arla/english/pdf/pro/pro2001-02-e.pdf>
Regulatory Proposal PRO2001-02
These proposed changes would weaken existing Canadian regulations in
significant ways.
Yet, those who normally observe and comment on pesticide regulatory
matters in Canada may have missed the 45-day window of comment which began
on October 5, 2001.
Another 60 day comment period should be offered beginning in January or
February of 2002.
It is important that this Harmonization proposal be re-submitted for public
comment
so that policy makers and ordinary citizens may have an opportunity to
provide
critical input. Road salt issues have just been given a 60-day period of
comment. A strong case can be made that this initiative surpasses road salt
in importance.
Pesticides are used widely in Canada, and their impact on air, soil and
groundwater should be carefully monitored and assessed. One of the ways
this proposal would weaken the requirements is to permit measurements made
in the U.S. to SUBSTITUTE for measurements in Canada, if in someone's
opinion, they are conducted "at appropriate sites in relevant ecoregions."
There are many potential problems with this. The tendency for pesticide
residues to concentrate in northern latitudes, for example, is only one
aspect of the environmental fate data that would be missed and go
un-assessed if these regulations are passed.
Additional criticisms of this proposal include the following 13 points:
BASIC ASSUMPTION:
The meaning of "environmental damage" includes physiological and genetic
damage to living organisms, including people.
1. "Harmonization" proposals for U.S. and Canadian regulatory policies
should STRENGTHEN regulations for environmental protection in Canada, not
weaken them as this proposal does.
2. Besides the legitimate concerns mentioned above regarding the role that
the substitution of U.S. sites will play in failing to measure and record
accurately the deposition of pesticides in the north by atmospheric
distillation (i.e., grasshopper or 'leap-frog' transport phenomenon), other
problems would arise. In addition to the under-reporting of pesticide
residues and their impact on human health, terrestrial and aquatic wildlife,
groundwater, etc., that this would lead to, there is nothing to guarantee
that the decision process about what shall constitute "appropriate sites" or
"relevant ecoregions" in the U.S. will not be somewhat subjective and open
to
possible abuse.
3. No requirement is included for measuring pesticides in precipitation in
Canada's vast areas of ice and snow. Spring thaws and ice melt in these
areas will inevitably result in large PULSES of pollution to the
environment, and these will go unmeasured and unassessed.
4. The requirement for shallow soil (thin layer) measurements appears to
have been cancelled with very negative consequences. This is where arsenic
leaching under playground equipment treated with copper chromated arsenates
(CCA) would show up, for example. Measurements at even a 6" depth have
apparently missed the heavy concentrations of arsenic deposited at these
sites in the first 2" of soil. Also, ignoring thin layer soil measurements
would appear to eliminate the possibility of measuring pesticide deposition
from precipitation anywhere in Canada. See the 1996 research by Wayne
Belzer et al., "Atmospheric Concentrations of Agricultural Chemicals in the
Lower Fraser Valley (DOE FRAP 1997-31), or that by Bernard D. Hill et al.,
1998, "Phenoxy herbicides in Alberta rainfall: cause for concern?" - or the
contributions of herbicides in erosion dust to airborne levels (see the work
of Larney et al. at the Lethbridge Research Centre, or Majewski & Capel
(1995)).
5. Some of the new proposed "Required" (R) categories appear to be made up
of collections of "Conditionally Required" (CR) categories, and therefore
are not as obligatory as they would first appear.
6. The distinction between "aged soil" and "unaged soil" has been removed.
Soil that has been recently disturbed such as at pipeline, highway, or other
construction sites, or in ploughed fields, etc., can have significant
problems with acid rock drainage (ARD), with runoff pH's being as low as 2,
on a par with stomach acid. Low pH hugely magnifies the leach rates of a
number of heavy metals in soils and pesticides, (e.g., mercury and arsenic);
these are amphoteric and leach much faster when soil pH's deviate from
neutral.
7. Because chemical pesticides are almost always fat soluble,
"Bioaccumulation" can generally be regarded as a given. The change in the
required assessments from "R" to "CR" (conditionally required) is worrisome
because bioaccumulation is no longer assumed to take place, and the decision
whether data should be gathered or not may be open to subjective influences.
Industry representatives sit on PMRA committees and have input into PMRA
decisions. This is not at all reassuring.
8. There is no mention of tracking the environmental fate of the breakdown
products or metabolites of pesticides. These all contribute significantly
to end point impacts, to synergism (when this occurs), as well as to
bioaccumulation.
9. In a number of areas, the new proposed regulations would require fate
data on only listed ingredients (TGAI), omitting assessments of the impact
of the full formulation (or end-use product (EP)). Since an increasing
number of "active" ingredients are being moved by industry into the
"unlisted" components, and because unlisted ingredients can be more toxic
than listed components, wherever EP assessments have been excluded, the real
effects of releasing pesticide products registered in Canada will be missed.
This is unacceptable environmental assessment regulatory policy
10. Effects on non-target organisms are widely acknowledged as a central
concern. This includes lower and higher plants, nitrogen fixing bacteria
and other essential simple organisms, beneficial insects (e.g.,
pollinators), all forms of wildlife (aquatic and terrestrial), as well as
people, including children. No data requirements have been included to
assess the hormone disruption effects of many pesticides and their formulant
combinations on non-target organisms, including human populations and
migratory species such as salmon. Many organochlorines, synthetic
pyrethroids, phenoxyherbicides, as well as other components such as mercury
and nonylphenols affect endocrine function. At least 850 different
pesticide products that are registered for household use are known to have
hormone disrupting effects, posing serious health risks to the entire
community, especially to children and the unborn. Many of these components
show up in both domestic and agricultural pesticides.
11. The use of High Volume Air Samplers in agricultural, northern, and
urban areas should be explicitly required with specifications as to sampling
grids, frequency and timing of sampling to represent seasonal peaks and
chronic exposures. From a demographic point of view, the largest numbers
of Canadians reside in urban areas and are therefore potentially affected by
pesticides transported in urban air from both long-range and proximal
sources (including agricultural and non-essential pesticide drift).
Assessing the exposure rates of urban dwellers must take a more prominent
and consistent place in regulatory policy, rather than being largely
neglected as it is at present.
12. The location of drinking water wells and associated groundwater
resources
must be identified and mapped, and an obligatory structure for regular well
water
sampling of pesticide residues and breakdown products, as well as
interactions with
other water components (i.e., organic matter and chlorine), needs to become
an
integral part of this proposal. Looking abroad, Canadian standards for
2,4-D in drinking water are set at 100 ppb, while European standards for
pesticides in drinking water are much more stringent - enough to sometimes
be exceeded by levels of pesticides in rainfall
of about 4 ppb. Harmonizing our standards with the U.S. could have the
negative
result of enshrining a status quo that needs improving, as well as
preserving the huge gaps in our existing data gathering on pesticide
residues in drinking water. This could make it extremely difficult to
upgrade our water quality monitoring and standards to match or exceed those
in Europe (which all Canadians deserve). Further, the U.S. has a Clean
Water Act, a Safe Drinking Water Act, and a Clean Air Act and Canada does
not. Thus, measurements in the US need not reflect conditions in Canada,
where these regulations do not exist. Substituting US measurements,
reflecting US conditions, under US acts will not serve the interests of
Canadian public health.
13. To effectively solve a problem, you have to first describe it.
Escalating health care costs are a fact everywhere in Canada.
Arguments against correcting this proposal's weaknesses and omissions
regarding the data Canada should require on the environmental fate and
impact of pesticides will be widely received as unconvincing, at best, if
they are based on cost. Gathering more complete and accurate environmental
fate data is cost-effective. Good science is built on a solid foundation of
accurate descriptive measurements. Thus, a proactive approach to
correcting and preventing environmental damage is to remedy some of the
existing weaknesses in the regulatory system identified by Canada's Federal
Commissioner of the Environment and by the Standing Committee on Environment
and Sustainable Development in the House of Commons report, "Pesticides -
Making the Right Choice for the Protection of Health and the Environment."
=================================
PMRA contact information:
Geraldine Graham (613-736-3692), Regulatory Affairs;
she will be away until January 14, 2002.
Grace Lewis, Publications Coordinator,
Pest Management Regulatory Agency, Health Canada, 2720 Riverside Drive,
A.L. 6605C, Ottawa, Ontario K1A 0K9,
[email: Grace Lewis/HC-SC/GC/CA@HWC (or) Grace_Lewis@hc-sc.gc.ca ].
==================================
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FULL STORY
http://novascotia.cbc.ca/editorServlets/View?filename=ns_pieguy141201
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