Usually it is the press who fumes about getting government papers that are heavily ‘redacted.’(That means that some/all of what had been contained in the notes has been deleted or blacked out.) I sat down a few days ago and wrote a piece about just what I thought about the current state of the fungicide re-evaluations at the Pest Management Regulatory Agency (PMRA). These products are the backbone of all our plant disease management programs in virtually every crop grown in Canada, and include: Bravo (Echo), Captan (Maestro), Rovral, Thiram, Ferbam, Ziram, Polyram and mancozeb. These are a virtual who’s who of multi-site fungicides that are excellent controls in their own right, but prop up all the other registered single-site fungicides to avert, prevent or at least mitigate the effects of pest resistance that develop quickly to single-site products. My first article actually got a little personal and included allegations that came from the heart.
I decided, upon proof-reading it, to start my own redacting process, just to spare any serious repercussions. Hence this new column, as all that was left of the old one was the title! Over the years of writing this column I have never been so het up about an issue. (About some people, yes, but not about a single issue.) In order to actually have a column this month, I decided to focus on how to fix the situation so it doesn’t happen again, down the road. The following will be some of the text of my comments to PMRA regarding their proposal to alter the re-evaluation approach.
I believe we both want to make sure that the registered pesticides available for use in Canada meet a global standard that assures the public of safety. It takes a partnership of users (growers), registrants, and regulatory officials to not only make sure the correct data is available to make such decisions, but also to ensure that products, as used, pose no unacceptable risk.
In order to make sure of the above, it takes a partnership approach all through the process. In the current process, that does not occur. The approach that you espouse in PRO 2016-02 only suggests consultation part way through the process. This is not a true partnership! Until all sides can work with trust and cooperation, you will never achieve what you are trying to attain. After careful examination of The Pest Control Products Act and Regulations, I can find no actual LAW that prevents you from doing any of the following. If you have internal policies, directives, and guidelines that you feel constrain change, please feel free to ignore them, change them, make exception to them, or likewise create a workable solution in spite of these prior self-imposed limits on activity. This is actually legal to do, notwithstanding some interpretations!
The start has to be with open and transparent communications with the other partners. It must start at the beginning of the re-evaluation process. Before a date has been set to commence a review, PMRA should already know what they have in terms of data, in the file of that active ingredient. That can determine what further data is needed before any risk assessment is calculated. The start of the process begins when all the partners first sit down, review what these data “gaps” may be, but only after careful examination of the current actual use patterns and comparison to current labels. There may well be uses no longer needed. There may be pending minor use expansions that need to be considered as well. Each partner needs to make commitments of what they can/will produce, and by a set date. Full and open disclosure helps to keep folks on time and keeping commitments. PMRA should not (ever more) have to make recourse to generic numbers, inappropriate databases, or to data not appropriate for use in Canada.
In the past we have seen the use of provincial water quality data; some of it highly questionable for use to predict pesticide levels in surface and/or ground water. Any and all such solicited data should come with a pedigree that is available to all. If a ‘witch-hunt’ of wells or water courses was conducted after a known spill, it should be so noted. (It may be interesting data, but not applicable to an estimation of soil/water residues following labelled use) If the data is from known field trials where active ingredient has been applied at known doses, yet non-detectable amounts are found in some sites, then by all means the standard use of half the level of detection makes sense. It does NOT make sense to use this technique when it is not known if the active WAS EVER APPLIED THERE! However, that has been done in the past and has led to widely exaggerated assumptions of levels in certain sites. Even worse, the use of a model to create a positive number of a residue in water is highly questionable when the actual use pattern would only be for a tiny fraction of the land area feeding an aquifer. What works in a model for a confined trial with a (tiny) amount of soil is inappropriate for Canada-wide decisions.
The current approach is very heavy on determining the worst case (and beyond that) of potential hazard. It has even more shortfalls in the mitigation of risk after examining the use patterns. Once again, the use of models falls far short of actual examination of the current use scenarios. Even registrants may be behind the current use scenarios due to the rapid changes that are happening in the field. Once again, a real partnership would mitigate that lack of knowledge. It would seem there is good confidence that growers will read and follow the instructions for the care needed in mixing, loading and application of the product. We were always taught that handling pure product before dilution with water was the most risky part of exposure to the pesticide. It appears that while there is confidence about this part of the exposure, there is angst about the exposure to (much lower) residues on the plant to the point that the use of the pesticide is now deemed unacceptable.
Part of this is because ‘estimates’ of field activities have been grossly overestimated. Part of this also has to do with the use of estimates of how much of the residues on a plant actually rub off onto a worker. Further, the estimates of the longevity of active residues of any/all pesticides on a leaf leave a lot to be desired. Lastly, but most importantly, there is no consideration for the use of protective clothing in post-application situations to reduce even the small amounts that could be transferred to a worker.
Once again an ‘unwritten’ rule ‘exists’ that since workers may not necessarily read a label, they would then be unable to know what clothing to wear in what fields. This is coming from the same folks who assume a grower will ensure the re-entry times are obeyed, the pre-harvest interval is adhered to, and that all safety equipment is used by themselves or any farm worker when applying the pure pesticide!
I am sure all your staff feel they are professionals. Would it surprise you to learn that growers are also professionals? Do they not deserve the credit for the Grower Pesticide Safety Course they take? Do they not get credit for the On-Farm Food Safety Courses they take? Nor the audits they must pass to stay in business? Then there are the workplace worker safety committees that all growers must create when there are five or more workers. This requires growers to meet with workers to discuss such issues, and to ensure compliance. Farmers take affront when it appears they are being treated the way it appears you have been treating them.
Partnerships work. We have lots of examples. The way to work in the future demands partnerships in order to be successful. We know that just as you are professional and want the best outcomes, we too expect better consideration of our skills and professionalism than the immediate past has shown.
The problems inherent in these eight re-evaluations may have been just the catalyst to ‘get it right’ down the road. We fully expect significant changes to the current proposals, based on the data that we and the registrants provide. Anything less would be unimaginable.
Your Partner, A Grower