Proceedings of the Standing Senate Committee on
Agriculture and Forestry
Issue 14 - Evidence - Meeting of September 16, 2014
OTTAWA, Tuesday, September 16, 2014
The Standing Senate Committee on Agriculture and Forestry met this day at
5:01 p.m. to study the importance of bees and bee health in the production of
honey, food and seed in Canada.
Senator Percy Mockler (Chair) in the chair.
The Chair: I welcome you to this meeting of the Standing Senate
Committee on Agriculture and Forestry.
Dear witnesses, thank you very much for accepting our invitation.
My name is Percy Mockler; I am a senator from New Brunswick and chair of the
At this time, I would like to ask the senators to introduce themselves.
Senator Mercer: I'm Senator Terry Mercer from Nova Scotia. I'm the
deputy chair of the committee.
Senator Robichaud: Good afternoon. My name is Fernand Robichaud, and I
am a senator from Saint-Louis-de-Kent, New Brunswick.
Senator Maltais: Good afternoon. I am Ghislain Maltais, senator from
Senator Enverga: Tobias Enverga from Ontario.
Senator Beyak: Senator Lynn Beyak, northern Ontario.
Senator Oh: Senator Oh, Ontario.
Senator Dagenais: Good afternoon. I am Jean-Guy Dagenais, senator from
Senator Ogilvie: Kelvin Ogilvie, Nova Scotia.
The Chair: Thank you, senators. I will also ask the senator to
introduce herself, please.
Senator Tardif: Thank you, chair. I apologize for the delay. I'm
Claudette Tardif, senator from Alberta.
The Chair: The committee is continuing its study on the importance of
bees. Our order of reference given by the Senate of Canada is that the Standing
Senate Committee of Agriculture and Forestry be authorized to examine and report
on the importance of bees and bee health in the production of honey, food and
seed in Canada.
In particular, the committee shall be authorized to examine this topic within
the context of:
(a) the importance of bees in pollination to produce food,
especially fruits and vegetables, seed for crop production and honey
production in Canada;
(b) the current state of native pollinators, leafcutter and honey
bees in Canada;
(c) the factors affecting honeybee health, including disease,
parasites and pesticides in Canada and globally;
(d) strategies for governments, producers and industry to ensure bee
Honourable senators, we have today, and I want to officially welcome, from
the Office of the Auditor General of Canada, Julie Gelfand, Commissioner of the
Environment and Sustainable Development; and Andrew Ferguson, Principal.
The Commissioner of the Environment and Sustainable Development provides
parliamentarians with objective, independent analysis and recommendations based
on performance audits that measure federal government departments' sustainable
development objectives. The commissioner also oversees the environmental
Again, as we thank you, we invite you, witnesses, to make your presentations.
They will be followed by questions from the senators. The meeting will conclude
at six o'clock.
Ms. Gelfand, would you please make your presentation?
Julie Gelfand, Commissioner of the Environment and Sustainable
Development, Office of the Auditor General of Canada: Thank you for this
invitation to appear before the committee today. I am pleased to join you this
afternoon to discuss our March 2008 report on pesticide safety and
accessibility. With me today is Andrew Ferguson, Principal, from the Office of
the Auditor General of Canada.
Let me begin by giving you a brief overview of our mandate. On behalf of the
Auditor General of Canada, the Commissioner of the Environment and Sustainable
Development provides parliamentarians with objective, independent analyses and
recommendations on the federal government's efforts to protect the environment
and foster sustainable development.
We carry out these responsibilities under several acts. Under the Auditor
General Act, our office conducts performance audits and monitors departmental
progress on whether activities designed to respond to federal environment and
sustainable development policies are being implemented effectively and are
We also manage the environmental petitions process that enables Canadians to
obtain responses directly from federal ministers on specific environmental and
sustainable development issues under federal jurisdiction.
Under the 2008 Federal Sustainable Development Act, our office reviews and
comments on the Federal Sustainable Development Strategy. We also monitor and
report on the extent to which federal departments contribute to meeting the
targets and goals set out in that strategy. My first report will be submitted on
I would now like to turn to our report on pesticide safety and accessibility,
which was presented in Parliament on March 6, 2008. As you are well aware,
pesticides play an important role in maintaining Canada's food supply. However,
many pesticides are designed to be toxic, and when used improperly, they can
have serious consequences for human health and the environment. Adverse effects
can range from respiratory tract problems to cancer, and the death of fish or
At the time of our audit, there were approximately 5,000 pesticides
registered for use in Canada. From information recently provided to us by the
Pest Management Regulatory Agency, we understand that there are now
approximately 7,000 pesticides registered for use in Canada.
So in 2008, there were 5,000 registered pesticides; we are now, six years
later, at 7,000 registered pesticides.
Our 2008 audit examined the progress made by the federal government in
selected aspects of managing the safety and accessibility of pesticides since
our previous audit in 2003. The objective of our audit was to determine whether
the agency was making satisfactory progress in systematically and consistently
applying its evaluation and re-evaluation policies and procedures; providing
timely access to new, possibly safer pesticides; and meeting its targets for
re-evaluating older pesticides.
We also examined at that time whether the Canadian Food Inspection Agency had
made satisfactory progress in increasing the number of active ingredients tested
in fresh fruits and vegetables as part of its National Chemical Residue
In our 2008 audit, we concluded that the Pest Management Regulatory Agency,
PMRA, had applied its procedures for evaluating new pesticides consistently,
completely and with adequate documentation. It ensured that companies applying
to register a new pesticide submitted all the information needed, at the
required standard of quality, to assess the risks associated with the pesticide.
Mr. Chair, I understand that your committee is interested in my perspective
on the length of temporary registrations of pesticides. For this, a little
context may be helpful. In our 2008 audit, the agency explained that during the
evaluation of a pesticide, the PMRA may conclude that additional information is
required to confirm the results of its risk assessment. The agency may therefore
grant a conditional registration that imposes additional safety measures to
allow the temporary use of the pesticide, pending receipt of the additional
information from the registrant. During the time that a pesticide is deemed
conditional, the registrant is expected to complete and submit the information
that is required to confirm the agency's assessment of risk.
Permission to use the pesticide is temporary; full registration is granted
only when the required information has been submitted to the agency, and the
agency has reviewed and accepted it.
When the agency grants a conditional registration for a pesticide, it issues
special notices. These notices spell out the additional information required.
For example, the agency has called for additional scientific information from
the registrant for a fungicide called Quintec, which now has a conditional
registration. According to the special notice, the agency requested additional
data to address, among other things, uncertainty with regard to the chronic risk
of the fungicide to aquatic organisms. Acute toxicity studies have been
requested by the agency for bees and predators, as another example. The special
notices can be reviewed on the PMRA website.
In our 2008 audit, we found that 13 per cent of new pesticides registered in
the 2006-07 fiscal year were conditional. We also found nine pesticides that had
temporary registrations with a 10- to 20-year duration. We indicated in our
report that this length of time cannot be considered temporary. That number of
10 to 20 years does not sound very temporary to me.
Our concern at the time of our audit was that the agency was not receiving
timely information on these pesticides — information that was required to
confirm its assessment of risk to human health and the environment. The agency
indicated that it would monitor and use its authority under the Pest Control
Products Act to limit the length of conditional registrations.
We have not re-audited this question to determine the current status of
conditional registrations. However, we did ask the agency to provide us with
additional information. They indicated to us that there are now 7,011 pesticide
products currently registered for use in Canada, 88 of which have been granted
conditional registration. Of these 88, 28 have been conditionally registered for
more than five years and eight of them for more than 10 years.
In my view, the key concern is that some pesticides are in temporary use for
prolonged periods of time, pending receipt of information considered necessary
by the Pest Management Regulatory Agency to confirm that they do not pose
unacceptable risks to human health or the environment. Furthermore, during this
time, new products containing the same active ingredient can be introduced into
the marketplace, thereby expanding the use and reliance on these products that
have conditional registrations.
In closing I want to add that the government has an important role to play in
protecting the environment and the health of Canadians, and in moving toward
sustainable development. Our office is keenly interested in improving
accountability by informing Parliament and Canadians on the quality of the
government's management of environmental issues, and making recommendations for
In our 2008 report, we said that more work needed to be done by the Pest
Management Regulatory Agency, PMRA, to reduce the number and length of
conditional registrations. We noted that a similar recommendation was made by
this committee in its June 2014 report on agriculture and innovation.
Honourable senators, this concludes my opening statement. We would be pleased
to answer any questions the committee members may have.
Senator Mercer: Madam, you gave an interesting presentation. Some of
it is startling and would be shocking to Canadians who are interested in this.
Among all of your references to everything that you were asking questions
about in your audit, bees did not come up as a primary topic. I am concerned
about that, as well, that bees as a primary pollinator of food products all
across the country — I thought it should have been there.
However, nine pesticides have temporary registrations for a 10- to 20-year
duration. That was in your 2008 audit. It is now 2014. I hope you will tell me
that in 2015, when the Office of the Auditor General will have all kinds of
spare time after it finishes the current studies you're doing elsewhere —
Ms. Gelfand: No comment.
Senator Mercer: — the Auditor General's office will give you the
resources to go back and examine this in detail. Can you tell me what your plans
Ms. Gelfand: We have put forward a plan for our next reports for next
year. At this time, the possibility of going back to look at the PMRA and the
Pest Control Products Act is still a possibility for our next report — not the
one that I am delivering in 2014, but potentially in the future.
Yes, we do follow up audits; this is a regular thing that we do. We could
look at this in more detail again in the future.
Senator Mercer: I would encourage you to do so.
We are in a crisis situation. The Ontario Bee Health Working Group tabled
their document in March 2014. It is critical of the use of pesticides. Indeed,
the Province of Ontario has indicated that they will ban the use of
neonicotinoids in agriculture in Ontario. This is a huge step forward — or
backward, depending on which side of the argument you are on.
However, it underscores the magnitude of the problem here — namely, that PMRA
is the lead agency in pest management, and now we have a province going off on
its own. I am not criticizing Ontario for this, but they are going off on their
Shouldn't PMRA, the Government of Canada and Agriculture and Agri-Food Canada
be taking the lead in this? This is a national problem, but now this province is
going off. I know agriculture is a joint responsibility of the federal and
provincial governments, but we now having one very significant province going
off and banning the use of neonicotinoids when we have not had any direction at
a national level. Hopefully this committee, in our conclusions, will give some
Ms. Gelfand: I do appreciate your interest and concern. I have been in
my position now for six months, and I realize that the biggest decision I make
is what to audit and when. This issue, obviously, is of concern to Canadians and
to this chamber. Therefore, it will rise up higher in our risk assessment. There
is a possibility that we could look at this issue.
We have asked the PMRA for additional information on the 88 conditional
registrations that are conditionally approved at this point. We noted that 35 of
the 88 are neonicotinoids. That is 35 out of 88. This information comes to us
from the department; it is not part of our audit and we have not verified it. We
would encourage you to ask the PMRA that question. But the information they sent
us — unverified, unaudited — is that 35 of the 88 are neonicotinoids.
Senator Maltais: Thank you. I have two quick questions. Ms. Gelfand, I
would first like to congratulate you and thank you for your report. Were I not
shy, I would say that you are the first witness to tell us the plain, hard
truth. We have tortured many people here, but we have not obtained many answers.
So I just learned that there are 7,011 types of pesticides in Canada. It is
not surprising that the bees are confused.
I also did not know that there were so many insects in Canada. I do not think
that 7,000 of them exist in Canada. It cannot be true that there are so many. We
will not count them ourselves; we will ask the auditor to do it.
If we add up registered pesticides, those that are in the process of being
registered and the ones not registered, as well as pesticides that are
registered temporarily and permanently, the number is huge.
Has Agriculture Canada provided you with any figures on this? Are we sure
that so many pesticides have been identified by scientists in 2014? Do we really
need 7,000 pesticides poisoning us? That amounts to a lot of pesticides in the
Ms. Gelfand: You are right; that is a lot of pesticides. We cannot
tell you whether it is too much or not enough. That is the figure the Pest
Management Regulatory Agency has given us. It is the number of pesticides the
agency has registered.
Senator Maltais: If those 7,011 pesticides are all somewhat harmful,
it makes for a good dose of formaldehyde. That is pretty strong stuff. Are they
so necessary? The majority of producers — and I am talking about producers, not
about scientists or manufacturers — said that there were not enough pesticides,
that 14,000 would be needed. If I put myself in producers' shoes, I wonder how
they can control 15, 20 or 30 types of pesticides. What has me worried are the
consequences. You are the commissioner of the environment, so I assume that is
also a concern for you, since this issue has terrible consequences.
Ms. Gelfand: Absolutely.
Senator Maltais: Mr. Ferguson, you work for the Office of the Auditor
General. What do you check the bees for?
Andrew Ferguson, Principal, Office of the Auditor General of Canada:
We have not audited bees in my history with the office. We have not done that
work, but it seems to be an emerging issue. One of the other senators mentioned
it was not covered in our 2008 audit. That is because at that time, the issue
had yet to emerge as a major concern in popular science, so it was not covered.
Certainly now it has emerged as an issue.
Ms. Gelfand: What is important to note is that, when a pesticide is
presented and granted a conditional registration, the active ingredient can be
used in a number of products. So the information provided to us by the agency
indicates the years during which several pesticides were registered, and we see
that the active ingredient is starting to appear in many other products. When a
conditional registration is granted, producers — not farmers, but pesticide
producers — can use that active ingredient and create new pesticides before
obtaining a final registration. That is clearly a concern for the environment,
for the producers.
Senator Maltais: I have one last question. Have you assessed over time
the possibility of limiting the number of pesticides to be registered in Canada?
If new ones are registered, could others be removed? If new pesticides are
needed, should not the ones less needed be removed? If not, will we not end up
Ms. Gelfand: All my office can do is consider the objectives
established by the federal government and determine whether those objectives are
being met. If the government requests that the number of pesticides be limited
to 8,000, our role is to ensure that the rule is followed. If the federal
government does not set any sort of an objective in terms of pesticides, it is
not up to us to do so.
Senator Tardif: Thank you very much for your presentation, Ms.
Gelfand. If I understand correctly, the 2006 Pest Control Products Act requires
all pesticides to be re-evaluated every 15 years. In the 2008 report, the
commissioner indicated that the re-evaluation of old pesticides was a fairly
long process, as new data had to be analyzed. That process takes two years in
the United States, but four years in Canada. Why does it take twice as long to
carry out that evaluation in Canada?
Ms. Gelfand: That is a very good question, but I do not have an answer
to it. That was not my report. I do not know whether we have the information.
Senator Tardif: This is an issue to monitor, since it was raised in
the commissioner's report from 2008.
Ms. Gelfand: All we can do is provide you with data and tell you the
truth about what is happening. We are providing you with our findings, which are
verified through an audit. It is not up to us to determine what the reasons
behind those findings are.
Senator Tardif: Whose role would that be?
Ms. Gelfand: Parliament would have to request that information from
Senator Tardif: I have another question.
The question is on what we call the precautionary approach in the regulation
of pesticides. This approach allows the PMRA, for example, to monitor the
question of pesticides.
Do you think the PMRA has the tools it needs to ensure that this
precautionary approach is applied in the agency's evaluation of pesticides?
Ms. Gelfand: I do not think we considered that specific matter in the
2008 audit. We examined other issues, and we found that the agency had conducted
an evaluation — which was complete — and that the agency was receiving all the
information. I do not think we conducted the audit based on the precautionary
principle, unless I am mistaken.
Senator Tardif: No?
Ms. Gelfand: No.
Senator Tardif: That is the principle that informs this organization's
work, correct? So it seems to me that this is something to consider in future
Ms. Gelfand: You are giving us some ideas for our next audit, and that
Senator Enverga: Thank you for the presentation. Yes, what we are
trying to give you are some questions to ask them. One of the questions that I
would ask is that, in your report, you said that adverse effects can range from
respiratory tract problems to cancer or the death of fish, and it says there,
too, that there are serious consequences for human health and the environment.
Did they ever report any human health problems that are caused by these
pesticides? Have there been reports about that?
Ms. Gelfand: Have we audited that?
Senator Enverga: Yes.
Ms. Gelfand: I don't believe we have audited that.
Senator Enverga: You haven't?
Ms. Gelfand: I do not believe so.
Mr. Ferguson: No, we haven't audited your question decisively. It is
documented in scientific journals.
Ms. Gelfand: Academics.
Senator Enverga: Maybe we can ask that question. They always say only
the fish and certain insects. However, we should think more about mammals or
those kinds of other information, especially humans.
Another thing is that they say there's a temporary timeline, let's say four
years, right, but then do we know how widespread it is when they spread those
pesticides? How far is it? Is it just one province or the whole country? How do
they apply those pesticides? Do we have any information about that?
Ms. Gelfand: My understanding is that each pesticide has information
associated with about how it's applied. If it's been registered by PMRA, I'm
assuming that it would be a national rule about how you apply it.
Mr. Ferguson: Yes, they are registered for specific uses and
applications, so each pesticide is registered to be used for a specific
application. If somebody applies to use that pesticide for another application,
they need to register it again for that application.
Senator Enverga: Oh, for that application. Okay.
Another question is this: On these pesticides — I know we are talking about
humans right now — did they ever have a study about how the pesticides can get
through the food chain? Is there anything like that?
Ms. Gelfand: I would recommend that you ask PMRA. This would be a
question for scientists as opposed to for auditors.
Mr. Ferguson: This is the type of information they ask of the
registrants in order to substantiate the risk assessment.
Ms. Gelfand: They must have that information.
Mr. Ferguson: If that kind of information is missing, they will ask
the registrant to provide it.
Senator Enverga: There are 7,000 pesticides. How many of them are
being used right now? Do you have any information about that?
Ms. Gelfand: The agency told us that there were 7,011 registered
pesticides in Canada.
Senator Enverga: But we're not sure if they are being used at all?
Mr. Ferguson: We assume that, if it is registered, somebody asked for
it and is using it.
Senator Enverga: That's all I have. Thank you. I just wanted to make
The Chair: Thank you, and you can rest assured, Senator Enverga, that
you will have the opportunity to ask questions to PMRA.
Senator Enverga: I'm waiting for that.
Senator Robichaud: Ms. Gelfand, your paragraph 19 speaks volumes. You
state the following: ``In closing, I want to add that the government has an
important role to play in protecting . . .'' You said this at the beginning, as
well. You also state that your office is keenly interested in improving
accountability by informing Parliament and Canadians on the quality of the
management of environmental issues.
You also say the following: ``In our 2008 report, we said that more work
needed to be done by the agency to reduce the number . . .''
What kind of follow-up do you do for this kind of a report? In your
presentation, you say that there are some serious shortcomings that could have a
major impact on the environment and health not only of animals, but also of
humans. Yes, Parliament has a role to play, and I gather from your paragraph
that we may not be playing it as well as we should.
How often do you follow up on those recommendations? There is not much point
to them if they are gathering dust on a shelf.
Ms. Gelfand: That is a very good question. It is up to me to decide
when we should review the audits we conduct on each topic.
For instance, we are currently wondering whether it is time to review the
2008 report. We produced another report on a different topic in 2011; is it time
to review it? So we very regularly conduct follow-up audits on a number of
topics. We carried out audits in 2003 and 2008 on very similar issues. At some
point, we have to check whether the recommendations have been implemented.
Senator Robichaud: I think it is high time you looked into this issue
again to see whether your recommendations have been taken into account. You are
talking about 2008, and we are now in 2014. Some products have had temporary
permits for 10 years. You should not wait too much longer.
Ms. Gelfand: I understand you. My role is to serve parliamentarians.
If parliamentarians ask us to work on a given topic, it is my job to provide you
with the information you request. So I am taking your interest in this matter
very seriously. We will ask our team what year we are supposed to carry out a
review on this — whether it is in 2015 or 2016.
Senator Robichaud: I think that time is of the essence, since many
farmers, as well as consumers, depend on the follow-up done on those pesticides.
I am surprised there are so many of them. On the other hand, I am not surprised
because we see them on store shelves. I also think that good practices are not
always followed, and that may be the source of the problem. But that is just a
I invite you — and I hope that the committee will consider this in its
recommendations — to carry out a follow-up to your report as soon as possible.
Ms. Gelfand: You are welcome.
Senator Ogilvie: I just want to come back and make sure that I
understood what I thought I heard you say earlier with regard to the number of
pesticides. Of the 7,011 pesticide products currently registered, if I heard you
correctly, that's not 7,011 different chemical entities. That's 7,011 different
products. Is that correct?
Ms. Gelfand: That's correct.
Senator Ogilvie: So the same chemical entity could be in a number of
Ms. Gelfand: That's correct.
Senator Ogilvie: Okay.
Ms. Gelfand: Different mixtures could be in different products.
Senator Ogilvie: Exactly. Then did I also hear you correctly in
answering that, of the 88 conditionally registered pesticides, 35 are neonics?
Ms. Gelfand: According to the information that the PMRA sent us
recently — so this is not verified; this is management giving the commissioner
some information to provide to you — 35 out of the 88 are neonics, yes.
Senator Ogilvie: But it's conceivable that all 35 could have the same
Ms. Gelfand: I have the list here. Eighteen of them have the chemical
called thiamethoxam. Fifteen of them have clothianidin, and two of them have
imidacloprid. Who comes up with these names? Unpronounceable.
The information from the PMRA is that, exactly.
Senator Ogilvie: This is exactly where I wanted to get to in the sense
of putting the numbers in perspective. So, of those 35, there are actually three
different chemicals that are involved.
Ms. Gelfand: Active ingredients, yes.
Senator Ogilvie: Because the implication in a question earlier was
that there are thousands of chemicals in the environment, and it's really
important for us to understand whether there are 7,000 different chemicals out
there or whether it's the mixtures that contain many fewer different chemicals
but simply packaged differently or whatever.
So, to come back to my last question, of the 35 neonics that are currently,
according to the information you received, on conditional registration, there
are three different chemical entities involved?
Ms. Gelfand: Three different active ingredients that are neonics, yes.
Senator Ogilvie: Those are chemical entities, yes, thank you.
Ms. Gelfand: That's right.
Senator Mercer: Science comes up with the crazy names.
Senator Dagenais: I would like to come back to paragraph 15 of your
report, where you state the following:
We also found 9 pesticides that had temporary registrations with a 10- to
A few lines below, you mention that, at the time, the agency was not
receiving timely information on these pesticides. On the website of the Pest
Management Regulatory Agency, it is clearly indicated that the agency must
provide information in a timely manner.
Given what it stated in your report, am I to conclude that the agency did not
receive information in a timely manner?
Ms. Gelfand: Yes, that is correct in the case of the pesticides you
are talking about. They were registered again, and the duration has been 10 to
Senator Dagenais: So, we can assume that the information was not
provided in a timely manner?
Ms. Gelfand: You could come to that conclusion.
Senator Beyak: Thank you very much for an informative presentation.
I'm a new member, and for the benefit of the other new members, I have a couple
of timeline questions. Could you tell me when the federal government began to
study bee health? There was a big change in pesticides about 20 years ago, when
we got rid of all that we thought was bad and brought in all that we thought was
good. Has there been a collapse of this magnitude in the bee colonies in history
from those studies? Do you know?
Ms. Gelfand: I don't believe I'll be able to answer those types of
questions because our audit did not look at the issue of what were the federal
government's objectives and strategies around bee health. I think you'll need to
ask an academic or somebody who studies bee health. What we looked at in our
audit was whether or not the PMRA was properly doing its job. We made
conclusions back in 2008 that generally showed there were many things that they
were doing well, but we were very concerned about the conditional registration
of pesticides, particularly the ones that were conditionally registered in a
temporary way for long periods of time.
Senator Beyak: Thank you very much. Perhaps the chair or the clerk
could fill us in on that at some point in the future.
The Chair: Senator, we'll ask the clerk to look into it and to follow
up and then we'll be back to you on that.
Senator Beyak: Thank you.
Senator Mercer: I'd like to follow up on Senator Ogilvie's question in
scaling down the potential problems to three different chemical makeups, and
then to go back to your paragraph 15 where you say nine pesticides had temporary
registrations with a 10- to 20-year duration. The odds are pretty good that none
of those are neonics because neonics are not that old. Can you enlighten us on
Ms. Gelfand: We have information, again from the PMRA, that shows
registrations of neonics beginning in 2000, 2003, and you recently, just today,
got an email from the PMRA indicating that a neonic was registered in 1995 and
is still in conditional registration, and that's that chemical imidacloprid.
Senator Mercer: So some of them are then.
Ms. Gelfand: Since 1995, 2000 and 2003. Again, as Andrew would tell me
to say, we trust but have not verified. So we trust management to tell us the
truth. We have not verified this information. Back to you to ask them these
Senator Mercer: We will.
Senator Maltais: In 2008, there were 5,000 products. We agree that
these are all chemical products. I will use arsenic as a very concrete example.
If you put it in someone's cake or steak, that person will die. Call it what you
want, but arsenic is a poison. All chemical products whose goal is to destroy
something are harmful to health, and I do not recommend that a human being
consume those products.
What worries me is that 2,000 chemical products — pesticides — were
registered in a 7-year period. I want to go back to my fist question, which was
whether 2,000 products could be removed.
Is each of the currently registered products necessary to good crops and the
normal development of agriculture in Canada? I think there must be a way to
eventually limit that. If another 2,000 are added in your next report, there may
be 10,000 chemical products. Whether we are talking about neonicotinoids or any
other products, they are harmful to animals, humans and fish in rivers and
lakes. When will all this stop? When will pesticide producers stop? How long is
Canada supposed to tolerate this level of production?
Ms. Gelfand: Unfortunately, that is not a question I can answer. That
is a question you can put to the agency — whether, if it registers another 2,000
products, it will deregister 2,000, as well. That is a question for the
The Chair: Senator Maltais, if I may, those questions will be put to
the PMRA, so we will have an opportunity to go over them.
Senator Maltais: My last question is for the commissioner of the
environment. What do you think about all those chemical products in the Canadian
Ms. Gelfand: I think that products with temporary registrations that
last 10 to 20 years are clearly a concern. As for the number and quantity of
pesticides, that is not a question for me to answer.
Senator Robichaud: Have you asked the agency what the extent of use
was for those chemical products with temporary registrations? If they are being
extensively used, that could raise some serious questions.
Ms. Gelfand: That is in English, and I am now thinking in French.
Mr. Ferguson: I will answer in English to be sure that you can
Senator Robichaud: Yes.
Mr. Ferguson: We did some background research just on the
neonicotinoid pesticides. This is publicly available information from scientific
journals. These pesticides are the most widely used insecticides in the world.
So they are widely used and they are used in connection with seed treatments,
fungicides, insecticides and so forth. They are very widely used.
Senator Robichaud: That we've been told many times, but those that are
on a temporary —
Ms. Gelfand: These are all on temporary.
Mr. Ferguson: These are the active ingredients that are the main
Senator Robichaud: And they are being used widely?
Ms. Gelfand: Yes.
Senator Robichaud: It's not all of them. Quite a few of them have
Mr. Ferguson: I'd have to go back to check how many of these active —
we know of three primary ingredients that are neonicotinoids. I'm not sure how
many chemicals would be in that class. There may be only three that are in the
class called neonicotinoids, and they are used in different products. So there's
a proliferation of products that contain this active ingredient. We know of
Senator Robichaud: Like you mentioned.
Mr. Ferguson: But I don't know how many more there may be. I don't
Ms. Gelfand: And the 3 active ingredients lead to 35 different
pesticides. Thirty-five different pesticides contain the three active
ingredients you were told about.
Senator Robichaud: But those active ingredients are present in
registered insecticides, correct?
Ms. Gelfand: On a conditional basis, yes.
Senator Robichaud: Just conditional? Have none of them been registered
Ms. Gelfand: We would have to ask the agency to clarify that. The
question is the following: have any neonicotinoids been granted permanent
registration? To our knowledge, the answer is no, but we have not verified that
information. That is another question you should put to the PMRA.
Senator Enverga: One quick question. With all this conditional
registration, are they being applied on a controlled environment?
Ms. Gelfand: The conditional registrations allow the companies to use
these pesticides according to the rules of their application.
Senator Enverga: Which is not necessarily controlled, as in
Ms. Gelfand: Each pesticide, when granted a registration, has
information about its use, and that information is supposed to be given to the
producer, and the producer is supposed to use that pesticide in that way.
Senator Enverga: Thank you.
Senator Tardif: You mentioned that, to your knowledge, there's no
permanent registration of neonicotinoids. Are there some in other countries? How
do we compare with other countries on this issue?
Ms. Gelfand: I unfortunately have not looked at that issue. I don't
have any specific information. We have not benchmarked it yet.
Mr. Ferguson: We know that there are restrictions in different
countries for these substances, but we also understand that there may be
different reasons why those restrictions may be in place. It may be different
climate conditions that would necessitate putting restrictions. So we don't know
why those restrictions necessarily are in place.
Senator Tardif: So we don't know if other countries have conditional
registrations or if they are permanent?
Mr. Ferguson: We know that other countries have a similar process
where they do grant conditional registrations pending more information to
confirm their risk assessments, but we don't know how they have performed
because we have never audited foreign.
Senator Tardif: And you don't have benchmarks?
Mr. Ferguson: No.
Senator Dagenais: In closing, is your organization feared by pesticide
manufacturers, especially when they know you could take up to five years before
issuing your recommendations? Do they really fear you?
Ms. Gelfand: You are talking about pesticide manufacturers? I cannot
answer, since our performance audits apply to the federal government. We look at
what the federal government says it will do. The government puts forward its
objectives, and we determine whether they are being met — whether the government
has implemented measures to put in place processes that will enable it to
achieve its objectives. So we have no direct relationship. We provide
parliamentarians with information on the federal government's efforts toward the
achievement of its objectives.
Senator Dagenais: But I am sure that pesticide manufacturers must see
the recommendations you issue to the federal agency. If they are not favorable
to them, I assume they must still be concerned about your recommendations.
Ms. Gelfand: They may be.
Senator Dagenais: Thank you very much, Ms. Gelfand.
Senator Robichaud: In your audit, do you verify the registration
process the agency uses — how much importance it attaches to data that comes
from countries like the United States — and what role does that play in the
Ms. Gelfand: From what I understand, the information requested by the
agency comes from the individual who is trying to register the pesticide. So the
agency requests from the pesticide manufacturer all the information it needs,
and it is up to the manufacturer to provide all that information to the agency.
Senator Robichaud: But you do not evaluate the actual process? You are
satisfied with the information provided or the process used?
Ms. Gelfand: In 2008, we evaluated the process the agency was using,
and we were satisfied that it was complete, coherent, and so on, for all
Senator Robichaud: You answered my question. Thank you.
The Chair: Before we close, the chair would like to ask one question,
with the indulgence of the senators.
You mentioned that in 2008 approximately 5,000 pesticides were registered in
Canada, and in view of the audit that you undertook in 2008, do you have any
recommendations for PMRA in order for them to improve their neonics reassessment
currently, as we look at those 7,011 pesticides? Would you have any
recommendation? And I will respect if you don't want to answer that question.
Ms. Gelfand: It would be difficult for me to answer that question, as
we would need to audit, once again, how well they're doing now. But we would
probably say that, at least from 2008, we were concerned back then about the
conditional registrations, the fact that they were temporary but have lasted
anywhere from 10 to 20 years. That concern is still relevant.
Senator Mercer: You've been there six months. You should have had this
Ms. Gelfand: That's why he's here.
The Chair: There is no doubt, senators, PMRA will be coming back.
Senator Enverga: Yes.
The Chair: With this, to the witnesses, thank you very much for your
very professional presentation.
Honourable senators, I now declare the meeting adjourned.
(The committee adjourned.)