Proceedings of the Standing Senate Committee on
Agriculture and Forestry
Issue 29 - Evidence
OTTAWA, Thursday, December 13, 2001
The Standing Senate Committee on Agriculture and Forestry met this day at 8:30 a.m. to examine international trade in
agricultural and agri-food products, and short-term and long-term measures for the health of the agricultural and the
industry in all regions of Canada.
Senator Leonard J. Gustafson (Chairman) in the Chair.
The Chairman: Good morning, everyone.On the subject at hand this morning: the gopher situation that seems to go along with
the drought in Saskatchewan and parts of the West, I will ask Senator Sparrow, who has done a lot of work in this area, to make a
few comments before we begin with the witnesses.
Senator Sparrow: I wish to welcome Richard Aucoin who is here from Health Canada. I have had an opportunity to meet him on
other occasions in and outside Ottawa at meetings on the problem of gophers. I appreciate the committee being prepared to review
I assume that the delegation from Regina can hear us. I am pleased that they are able to take part in what I consider to be a rather
important meeting. Hopefully they will explain the background of the licensing aspect of a strychnine poison that has been used for
the control of gophers, the changes that have been made throughout the years in the use of that strychnine poisoning, and the
problems that those changes have created for the farming community in the control of gophers.
These are serious problems. For people who live in areas of the country that do not have that problem, I appreciate that it can be
difficult to understand the situation. I am sure the witnesses today will explain the background to us, and then we will have the
opportunity of asking questions. I wish to thank the witnesses for appearing here this morning.
The Chairman: Our first witness this morning is Mr. Richard Aucoin, Acting Director of the Pest Management Regulation
Agency with Health Canada. I am given to understand that each witness will have about 30 minutes for statements and questions.
Please proceed with your statement.
Mr. Richard Aucoin, Acting Director, Efficacy and Sustainability Assessment Division, Pest Management Regulatory
Agency, Health Canada: In keeping with its responsibilities for safeguarding the health and safety of Canadians and their
environment, the government took action in 1992 to restrict access to liquid strychnine concentrate for gopher control. Agriculture
Canada was the regulatory body responsible for pesticides at that time, but pesticide regulation has undergone significant reforms
In 1995, the government approved the formation of the Pest Management Regulatory Agency,
PMRA, reporting to the Minister of
Health. This brought together under one organization the work that had been previously done by Agriculture and
Environment Canada and Health Canada. The federal legislative authority for the regulation of pesticides in Canada is the Pest
Control Products Act, the PCPA.
Under this act the minister is prohibited by law from registering a pesticide for use unless it is determined that the human health
and environmental risks posed by the pesticides, as well as its efficacy and benefits for the intended uses, are all acceptable.
Provinces and territories have some complementary legislation. They are responsible for regulating sale, use, transportation and
disposal of pesticides within their jurisdictions consistent with the conditions of use imposed by the Pest Control Products Act.
The fundamental mandate of the Pest Management Regulatory Agency is to protect human health and the environment by
minimizing the risks associated with pest control products. Going back to the action taken by Agriculture Canada in 1992 with regard
to the liquid strychnine product for gopher control, it seems clear to us that the restrictions were deemed necessary to prevent
unacceptable risk of harm to public health, animals or the environment. Misuse of liquid strychnine, which is a highly toxic pesticide
product, has been associated with poisonings of non-target species, including pets, wildlife and possibly humans.
This action was take in response to issues being raised by a series of groups such as the Royal Canadian Mounted Police, the
Canadian Veterinary Medical Association and the Association for the Protection of Fur-Bearing Animals. We have also had
correspondence from Saskatchewan Crime Stoppers and local police forces. These groups have raised serious concerns regarding the
relatively wide availability of this strychnine product.
Fears were expressed that children could be poisoned by strychnine. Cases of dog and wildlife poisonings were cited. The use of
such an extremely toxic and "excruciatingly painful" mode of pest control as strychnine poisoning was being denounced. Even with
this ban in place, there continued to be reports of strychnine poisonings of dogs in Saskatchewan and Alberta to fairly significant
Strychnine is a highly acute toxic pesticide that acts quickly on the central service system causing frequent and violent
convulsions, which eventually lead to death through respiratory failure. There is no effective antidote for strychnine poisoning.
Poisoning wildlife and domestic animals using bait laced with strychnine is illegal under not only the Pest Control Products Act but
also the cruelty to animal's section of the Criminal Code as well as provincial wildlife acts.
All the above-ground uses of strychnine, including its use for ground squirrel control, have been prohibited in the United States
since 1988. It is illegal to use strychnine for pest control in most European countries, because, it is prohibited by the Bern Convention
on the Conservation of European Wildlife and Natural Habitats.
Prior to taking this action, Agriculture Canada consulted on the strychnine issue with agriculture and wildlife control officials in
Alberta, British Columbia, Manitoba and Saskatchewan and the Canadian Association of Pest Control Officials, a federal-provincial
group of pesticide regulators and environmental officials. The decision taken on liquid strychnine concentrate was a collective one
with the provinces and was implemented by Agriculture Canada.
During this time, no economic impact studies were carried out regarding the withdrawal of this liquid concentrate product from the
marketplace. This was due to the fact that the government was confident that safer, ready-to-use products, available to replace the
farmer-prepared bait made from liquid concentrate, would provide the same level of control against gophers. It was reasonable to
assume this, given that the ready-to-use products had similar or slightly higher concentrations of strychnine as the baits prepared by
farmers using the liquid concentrate.
Since there was no indication that farmers would suffer any economic hardship due to the withdrawal of the liquid strychnine
concentrate product beyond some small increased costs to them for having to purchase
ready-to-useto use bait product rather than
using their own farm available grain, the economic impact studies were not considered necessary at that time.
It was only some years later, after the discontinuation of this liquid concentrate that the ineffectiveness of the ready-to-use bait
began to be reported to the PMRA.
When problems with the effectiveness of the ready-to-use strychnine products began to arise it was initially suggested that the poor
performance might be attributed to the level of strychnine in ready to us baits not meeting the guaranteed concentration, to
palatability problems with the baits, or to baits not being applied at the optimum time to maximize control of gopher populations.
From 1996-98 the PMRA launched an investigation involving sampling and analyzing of strychnine products at the formulating
plants and in the market place to be sure that the strychnine levels were meeting the prescribed concentration on the label. Also, a
label improvement program was undertaken in 1997 to upgrade the directions on the labels of strychnine products to make sure that
everyone was aware of the optimal timing of bait placements.
Since 1999 the registrants of strychnine products have been required to submit to us quality control results on several batches of
their product for review prior to the product being released into the marketplace for the upcoming use season. We wanted to ensure
that those guaranteed levels of strychnine were there.
To investigate some of the palatability factors that seemed to be important, in 2000-01, we granted research permits to Alberta
agriculture to assess the efficacy of various baits against gophers. These baits included those made fresh from a 2 per cent strychnine
concentrate solution, as well as baits made from alternate grain substrates such as made from canary seed. The results of these
research trials conducted in 2000 and 2001 were to be submitted to the PMRA for review to help make a case for the PMRAs further
consideration of the use of 2 per cent strychnine concentrate.
The results of these trials indicate that although commercially available ready-to-use 4 per cent strychnine bait products are
somewhat effective; they achieve approximately 60 to 66 per cent control. However, factors that improved bait uptake and
consequently improved gopher control include the type of bait substrate used as well as the freshness of the bait. Alberta's research
indicated that freshly made 4 per cent strychnine bait made with the liquid concentrate gave approximately 93 per cent control versus
the ready-to-use products that gave 60 to 66 per cent control.
Perhaps at this point it is important to clarify that throughout this statement when we talk about "gophers" we are talking about
Richardson's ground squirrels. There is also another animal called "pocket gophers," which are a different pest.
According to both Saskatchewan agriculture and Alberta agriculture, the number of gophers in Alberta in agriculture was
extremely high this year primarily because of an increase in the gopher populations over the last number of years due to several mild
winters and warm, dry spring conditions. Both the governments of Alberta and Saskatchewan requested emergency registrations of
the 2 per cent liquid concentrate to deal with this serious infestation problem. The PMRA granted those registrations. These were
limited term registrations for this year only.
Due to the risks associated with making liquid strychnine concentrate widely available, access to and use of the concentrate was
highly restricted. A program was put in place by the governments of Alberta and Saskatchewan that allowed only the agriculture
field men in Alberta and recognized pest control officers in Saskatchewan to have access to the liquid strychnine concentrate. These
officials would supervise the mixing of the strychnine baits, which would then be provided to the farmers. The farmers would come
to these mixing stations to obtain the pre-mixed product.
On November 16, 2001, the PMRA met with Alberta and Saskatchewan pesticide regulatory officials and other stakeholders,
including Senator Sparrow, to review the results of the research into strychnine from the past several summers and primarily to assess
the restricted access program that was in place for the emergency registrations this past summer. The agriculture field men who were
present and who administered the program in Alberta clearly indicated that the freshly mixed strychnine bait was a very effective
product. There were a number of discussions regarding difficulties with logistics and distribution of the liquid concentrate. A number
of options for improvement were put forward at that time.
Discussions also took place on the availability of the liquid strychnine concentrate in the future. Two options were presented,
which are the only options available to us under the Pest Control Products Act. The first option was that an applicant, such as a
company, could make a regular pesticide submission that would naturally include quite an extensive set of data requirements to cover
the health and environmental aspects of this particular strychnine product. The only other option was that if the situation warranted in
the future, the provinces could again put forward to sponsor an emergency registration for use of the 2 per cent liquid concentrate.
We also informed participants at that meeting that the strychnine itself would be re-evaluated sometime over the next five years.
The PMRA has a re-evaluation program to assess older pesticides against the most up-to-date standards to determine whether and
under what conditions the continued registration of a pesticide would be acceptable.
Strychnine was originally registered in Canada in 1939. Sometime over the next few years we will be re-evaluating all uses of
strychnine. That may entail companies that would want to register strychnine products and would support strychnine products with a
significant database that would be up to modern standards. We felt that it was important that we flagged that issue to the participants
at that meeting.
The PMRA officials at that meeting also encouraged provincial officials and users to carry out research comparing the
effectiveness of strychnine baits with alternative products for gopher control. In the U.S. the principal products currently being used
to control gophers appear to the zinc phosphide and anticoagulants such as diphacinone and
chlorophacinone. These are also
registered for gopher control in Canada. However, strychnine seems to be the active ingredient that farmers prefer.
In conclusion, it is important to understand that the mandate of the Pest Management Regulatory Agency places the need to
protect the health and safety of Canadians and their environment first and foremost. When pesticide regulatory decisions are made
considerations of economic competitiveness are secondary to the need to secure the health and environment of Canadians.
In 1992, the Minister of Agriculture was concerned about potential threats to Canadian safety and environment. As a result,
restrictions on the availability of liquid strychnine concentrate were put into place. The evidence of risk to harm was such that federal
and agricultural officials were united in their resolve that some action needed to be taken. The extreme toxicity of strychnine was
clearly known. There were cases of misuse being reported. There were prohibitions in place on
strychnineinternationally. We had replacement products that were registered at that time for gopher control. As well, we believed that the
ready-to-use product would be as effective.
One could ask the question: Why would we have allowed such a product to remain publicly available, given all the information
that we had in front of us?
Finally, I should like to indicate that the PMRA would continue to take a cautious approach to the possibility of bringing back the
liquid concentrate form of strychnine. We are, however, open to listening to farmers' concerns. We have had a number of meetings
with agriculture officials, growers and Senator Sparrow. We are happy to work in cooperation with the provinces and users to
investigate and find solutions to this problem. We will be glad to continue to do that until we find some resolution.
The Chairman: Thank you for that presentation. I wish to point out to the honourable senators that we have a Member of
Parliament with us. I have asked Leon Benoit to sit at the table and find out how things work in the Senate. He is the Member of
Parliament for the constituency of Lakeland.
For the advantage of members who are not from Saskatchewan, I would ask Senator Sparrow to give us some idea about the
severity of the problem. Senator Wiebe may want to comment on that as well before we go to direct questions.
Senator Sparrow: The problem in Saskatchewan is serious. The gopher infestation has been so bad that they have been known to
clear off quarter sections of land. If they do not clear the land entirely, they do enough damage to make it uneconomical to harvest
the crop when they have taken up to 50 per cent of it. It takes about 150 gophers to eat about as much as a cow. When you get up to
600 gophers on an acre, you can image what devastation they will do. That is what has been happening in Saskatchewan and, I am
sure, in Alberta as well.
I want to welcome Mr. Benoit who has been concerned about the problem in Alberta and has worked diligently to assist in solving
this problem. He has worked with me using information that we have gathered.
This is such a serious situation that the rural municipal governments have received literally hundreds of letters from municipalities
requesting that a change be made in the distribution system of strychnine.
Prior to 1992, a farmer could go into his rural municipal office and buy a 250-millilitre can of 2 per cent strychnine poisoning. He
would mix the strychnine with 4 litres of grain, and distribute this poison to gopher holes. The farmers were very satisfied with the
Mr. Aucoin will tell you that the ready-to-use product was just as effective as the freshly mixed product. They convinced all of us
that it was a good product and, yes, there would be no objections to its use. However, it did not work.
Since 1992, the gopher population has expanded and there has been talk of weather conditions and farming conditions as the
cause, but the expansion took place because there has not been an effective control in place. There are a number of products, as
Mr. Aucoin mentioned, but none of them have been successful for the agriculture community. The farmers have asked that the
strychnine poison be made available to them, once again, until such time as there is an effective product found to control the issue.
Mr. Aucoin has stated that studies have been done, but we cannot find any such studies. We have all the information they can give
us. As a senate committee, we asked for the scientific studies that were made inn order to determine why the changed the system.
The information came back yesterday, addressed to the Legislative Assistant to the Minister of Health that there are no studies. That
is to say, there is no information available.
The response going around is that representations were made over a number of years by concerned stakeholders: local police
departments, the RCMP, Canadian veterinary and medical associations, humane societies, Canadian Fur Bearers Association and
numerous media reports. However, there is nothing in the file that indicates that this representation was made. It appears that there
was not any scientific evidence given to take the product off the market because they thought there was a satisfactory replacement for
The rural municipal associations requested this fall that the previous method of distribution be made available to the farmer
because there are no scientific studies that indicate that this poison is a problem.
I have information from the PMRA stating that in Alberta, there are 10 to 15 cases of strychnine poisoning per year, according to
Dr. J. Kendall of the Provincial Agri-Food Surveillance Systems Lab in Edmonton.
In Saskatchewan, 20 to 25 strychnine poisoning and the occasional strychnine wildlife poisoning are confirmed each year,
according to Dr. Blakely at the Western College of Veterinary Medicine at the University of Saskatchewan. PDS figures indicate that
the number of strychnine dog poisonings have decreased only slightly since the 1980s or early 1990s when the farmer could pick up
As a matter of interest, if you buy the ready-to-use poison and you want to poison a dog, all you have to do is put a couple of cups
in a pound or two of hamburger and the dog will eat it. Eating a gopher will not kill a dog, because there is not a great enough
difference in body weight. If you want to poison a dog, obviously you can poison it with the ready-to-use strychnine.
There has been no indication of any human deaths attributed to strychnine poisoning. There was one letter from the RCMP
requesting information from the department about the possibility of a human death from strychnine poisoning. That was never
proven, and there have not been any similar indications. We cannot use that as an argument, but the argument is being used. The
report made in the House of Commons said that all these groups were in agreement. The only reference is that the Western Forum
and the Canadian Association of Pest Control officials decided that this change would be made in 1992.
We have evidence from Saskatchewan that is interesting and informative. The municipalities are asking for the reinstitution of the
use of 2 per cent strychnine that is mixed by a farmer with his own grain on his farm. Put that process back in place until such time
as we can find an alternate source of poisoning that is as effective. There is nothing available that is as effective and the farmers are
suffering as a result.
Farmers hire people to go out and shoot gophers. They shoot 600 gophers in a day, and it does not affect the damage that is being
done. We are faced with this serious problem. A decision was made, and no one will look at it. I hope that a change will be made so
that we can save the millions of dollars that it is costing the agricultural community.
You are aware of the request that the 2 per cent strychnine poisoning be put back into the hands of the municipalities, the
administrators or the municipalities to control the distribution of it to the farmers for pick-up so they can mix it on the farm.
Is that an alternative that you are considering? What are the possibilities of that happening?
Mr. Aucoin: As I indicated in my statement and at our meeting in Edmonton in November, there are only a couple of options
open to the minister. We can receive a pesticide submission or an application from a company to register this product again under
Those conditions would be specified and might propose various means of distribution of the liquid concentrate. That is one option.
That is the normal option for registering a new pesticide product.
The only other option is under an emergency registration scenario where the provinces would demonstrate to us that there is an
emergency situation and they need registration of a particular pesticide product, which the minister could then authorize for up to one
Senator Sparrow: Where are we at in this scenario?
Mr. Aucoin: We have only a ready-to-use strychnine product registered in Canada. We do not have an application made by a
company to register a 2 per cent liquid strychnine concentrate product.
Senator Sparrow: Strychnine is a permitted product for use. It is being used?
Mr. Aucoin: The active ingredient strychnine is currently a registered active ingredient in Canada. It is only for technical
manufacturers to formulate into a ready-to-use product.
Senator Sparrow: It is still a registered product and can be distributed without the proviso that it is mixed by some company at an
outside location. That is the only difference. It is still a registered product. By the stroke of a pen, your minister can make a statement
that it will be made available on a basis that is not a pre-mixed basis. Is that correct?
Mr. Aucoin: No, not by the stroke of a pen. We need an application from a company to do that, and if we get it we will consider
Senator Sparrow: The company is prepared to make any request that the farming community is interested in, is it not?
Mr. Aucoin: I cannot speculate what their interest is in this product.
Senator Sparrow: They were at the meetings.
Mr. Aucoin: They were at the meetings, yes, but I do not know whether they have any business interest in the long-term
registration of a liquid concentrate product for farmers to use themselves. There are liability considerations. For us to consider the
registration of that product again under those kinds of circumstances, we would need a submission that would almost certainly entail
a significant amount of information and data supplied by the company.
To register a new product today, we normally require a fairly modern database to do a modern risk assessment on that proposed
product. That would entail a significant commitment on the part of a company to put that information forward without a certain
outcome. As we pointed out in Edmonton as well, the whole strychnine story will come under re-evaluation by the agency sometime
in the next five years. The company needs to consider its business case, I presume.
Senator Sparrow: The strychnine product is available and registered in the 250-millilitre containers for use by farmers in
Saskatchewan if it is pre-mixed at a site.
Mr. Aucoin: The strychnine if pre-mixed into a ready-to-use product is registered. There is no product registered in 250-millilitres
Senator Sparrow: Let me make this clear: this past summer a farmer could go to a central location and have the grain mixed from
the 250-millilitre cans that I am talking about. The cans were there, and they were available. They were mixed, not by the farmer, but
by a technician, because they said that the farmers were not responsible for mixing their own product or for whatever reason. It is a
registered product. It was used this spring. It is only a matter of the use.
Mr. Aucoin: The registration for that particular product expired August 31, 2001. That was made available under an emergency
registration provision of the act. That registration does not exist today.
Senator Sparrow: Would it exist if we repeat the same program as last year?
Mr. Aucoin: If the provinces indicate to us that the situation is of an emergency nature next summer that will become an option
open to consideration.
The Chairman: It appears to me that timing is important, and we need this available before spring break-up so that farmers can
deal with the drought situation. The experience I have is that drought and gophers and grasshoppers all come at the same time. It is
important to have this in place before the spring break-up.
At the wish of the senators, I will ask our Member of Parliament from Alberta if he has a short comment on the situation.
Mr. Leon Benoit, MP: I appreciate this opportunity very much.
We know that removing the registration was a mistake because we had an emergency temporary registration in Alberta and parts
of Saskatchewan this spring. For the government to do that means that it must have known that the situation is extremely serious.
There is no doubt of that.
I cannot say for certain the amount of money that having this tool taken away from farmers has cost them, but the estimate that I
have been using is tens of millions of dollars. I estimate that it would be several tens of millions of dollars last year alone. The
gophers hit in a hard fashion last year and cost farmers a lot of money. On a half-section of one of my fields of canola, I lost
probably $10,000 just on the two fields; that was only a small section of the fields that were hit. It is extremely costly. I do not think
we will argue that, otherwise the emergency registration would not have been put in place.
In terms of the non-target species being hit, I received evidence from the department back in 1994 or 1995. I started dealing with
this back in 1994 with a letter to the department asking why this had happened. It has been a long process. I have taken it before the
House of Commons on three occasions in different forms to try to get this problem resolved.
In terms of secondary species being hit, the important thing to note is that if there were any, there were extremely few cases where
it was accidental targeting. In other words, where the non-target species were hit, in most cases it was intentional. We have the
Criminal Code. We have the law to deal with those situations; let the law deal with them.
We are looking to have this 2 per cent solution of strychnine available to farmers so that they can use it to help protect their crops.
All of you know the kinds of situations that grain and oilseeds farmers are in right now. It is extremely serious. It is a border-line
case. We will lose thousands or certainly hundreds of farmers again this year.
I recommend that the 2 per cent solution of strychnine be re-introduced and we allow farmers to mix it themselves. A key
consideration is that farmers must be able to use this bait very soon after they mix it; they do not want to leave the mixed bait around.
Whether this is an above-ground use or not is questionable, because the bait is normally placed in the gopher hole. You put it down
the gopher hole as far as you can, perhaps six inches or a foot.
The other option is to have bait stations, which can be very safe and which will limit the access to the Richardson ground squirrel,
the gophers themselves.
Bring the product back. Allow farmers to mix their own product so it can be fresh and so it can work. If the authorities deem it to
be necessary that farmers take a course so that they use this product safely, most farmers would agree to that. If it takes a Saturday
morning or a day to take a course to learn how to use this product safely, most farmers would agree to do that. I am not convinced
that would be necessary because most farmers have been using it safely now for many years. I do not think that is a serious concern.
From the information I received, and I believe I sent it to Senator Sparrow, there were few letters on this product to start with.
Again, most of them focused on intentional misuse of the product, which is covered under the law. If we can get this back, monitor it
and, perhaps, require the use of bait stations after five years it will give farmers a chance to phase into using bait stations only. I think
farmers would agree to those terms. The product can be used completely safely in that type of scenario. Let us explore this route.
If we do that, we can return this important product to farmers and ensure that there is no unintentional damage done. Again, let us
not remove a product from farmers because a few people choose to use it improperly or illegally. There were not many such cases of
intentional abuse of the substance. Senator Sparrow referred to the numbers. In those particular cases the people could have killed the
neighbours' dog in any way and would have done so with or without the strychnine. Let us not remove this important product
because of that illegal use of the product.
I thank you again for having me here today. This is an important issue you are working on today. If you are successful in getting
this product back to farmers, I will be first to write each one of you a thank-you letter. It has been working on this problem since
1994. Senator Sparrow has been working and so have the Prairie farmers for a long time. Let us make it happen.
I am sorry that I must leave the meeting. The issue is not so much about what has happened in the past but what we can do about
the future. Let us return this important tool to farmers by the end of March of this year. It must be in the farmers' hands by the end of
March so they can use it most effectively, which is before the grass starts growing this spring.
The Chairman: I will now go to Senator Wiebe, who is a Saskatchewan farmer. He has some experiences with gophers as well.
Senator Wiebe: The gopher problem exists along the Alberta-Saskatchewan border. It does not affect the entire Province of
Saskatchewan or the entire Province of Alberta. However we have had a serious problem with gophers along the
Alberta-Saskatchewan border for the last three years and area of infection is getting larger each and every year.
If the department needs any evidence that the poison is not working all it has to do is look at the evidence of the last three years of
experiences that the farmers have had. Had it worked, the gopher situation would be under control.
The risk we now face is having the gophers spread to other areas if we continue to have only this tool at our disposal. It is
imperative that the department take a serious look at the representation that is being made by the pest control officers in each of the
regional municipalities. They are the people who are charged with the responsibility of keeping pests in their RMs under control. I
put a lot of stock in their advice to me. Each and every pest control officer has made exactly the same representation to me, as he has
to other members of Parliament, about the fact that the product that the farmer is allowed to use is not doing the job. Three years of
experience in that regard should certainly demonstrate to the department that it is not working. If we allow this to go on for another
two or three years the infestation areas of Saskatchewan and Alberta will be much larger and we will not be able to bring the problem
The decision to take liquid strychnine concentrate off the market was a collective one with the provinces of Manitoba,
Saskatchewan, Alberta and British Columbia. For that reason it was implemented by Agriculture Canada. People seem to be
concentrating their efforts on Agriculture Canada to correct the situation, and that is where it must happen.
However, what kind of formal representation have you had from the Government of Alberta and the Government of Saskatchewan
in regard to the correction of this issue? Have they stepped up to the plate or are they passing the buck over to us?
Mr. Aucoin: No, not at all.
Senator Wiebe: Have you received representation from those two governments?
Mr. Aucoin: Yes.
Senator Wiebe: Why have we not acted, then?
Mr. Aucoin: We have a federal-provincial-territorial committee on pesticides and pesticide management. We are close partners
with the provinces and have had discussions with them concerning all pesticide regulatory issues, including this one. This same issue
was discussed at the annual meeting in Charlottetown both last year and this year. During those meetings all of the members
recognized the seriousness of the gopher control problem and recognized what had happened with removing the liquid strychnine
We have been well aware of this problem for a long time. The provinces are aware of the situation and have been working with us
on the matter. We have had many representations from the provincial regulatory officials about the seriousness of the problem and
what can do done collectively to correct the problem.
Senator Wiebe: How long does it take you to work on something to arrive at a solution? If you tell me that the Government of
Canada, the Government of Saskatchewan and the Government of Alberta have been working on reviewing this problem constantly
for two years, how many more years will they need to work?
Mr. Aucoin: First, we are a regulatory agency; we are supposed to assess a proposal. We need a sponsor. We need a company to
come forward with a solution that we can assess. We are happy to work with the provinces to see if we can build some kind of an
understanding that would allow for use of this kind of product under certain circumstances. We will still need a company to come
forward and say that they are interested in registering the product and in supplying us with the information that we need and to pay
any associated costs.
Senator Wiebe: If you have studied and talked about the problem, and you realize that there is a problem, then why has someone
not taken the bull by the horns and asked the company to make a submission? Why has the Province of Saskatchewan not done that?
Why has the Province of Alberta not done that? Why has the Government of Canada not done that? How long will you study until
you decide to ask the question? I think there would be lots of companies out there, had the question been asked, who would say,
"Look, this product is not working. Can you develop one that will?"
For example, if the Minister of Agriculture for the Province of Saskatchewan, the Minister of Agriculture for the Province of
Alberta and the Minister of Agriculture for Canada comes to your agency and says, "Look, we want to ask a company to do this
because we will have a problem in the West in 2002." If you did that tomorrow, how long would it take to have a product on the
Mr. Aucoin: A company must make a business case to come forward for a product of this nature. This is a highly toxic product
and I do not know the extent of the economic interest any one company would have in it. At our meetings in Edmonton, in
November, which included stakeholders and Senator Sparrow, there were two companies that listened to what we had to say about
strychnine. They are considering whether they might have a business case for it. If there is a business case there, and there is money
to be made, I am quite confident that one of these companies will come forward. We are a regulatory agency, however.
Senator Wiebe: Therefore, it is quite all right for the Government of Alberta, the Government of Saskatchewan and the
Government of Canada to sit back and admit that there is a problem with gophers but wait until some private company comes along
and makes a proposal so that the private company can make some money on this proposal.
Are you telling me that these three levels of government do not care about the amount of money that the farmers out there are
losing as a result of this problem?
Mr. Aucoin: No, I am not, senator.
Senator Wiebe: Why are we so concerned about whether a company makes money and we are not concerned about whether the
actual user makes money? I know that these are tough questions, but these are things that are certainly on the mind of the Western
Mr. Aucoin: We have been working with the provinces on the problem. I want to make that clear. It is not as if we have been
doing absolutely nothing for three years. We are a regulatory agency. Our fundamental mandate is to consider pesticides and to
ensure that they are safe for humans and the environment. We are not in the business of generating business income for anyone. We
want to ensure that growers have access to pest management tools, but we cannot do that by creating products. We do not create
products; we simply assess them.
Senator Wiebe: I want to thank you for your presentation. I want to thank you for your forwardness. The people we should hear
from are the Ministers of Agriculture for Saskatchewan, Alberta and Canada. We are asking you questions that you are not in a
position to answer, but I wish to thank you for your help.
The Chairman: I farm in Southern Saskatchewan. While we do not have a major problem now, we notice there have been more
gophers in the past three years than we have had for some time. I want to emphasize what Senator Wiebe said: the importance of
quick action. Farmers are hurting. As we have heard from Senator Sparrow, many are losing their farms. We need some urgent
Senator Tkachuk: I am somewhat confused. Is strychnine an approved product?
Mr. Aucoin: The active ingredient, the chemical substance strychnine is a registered, active ingredient.
Senator Tkachuk: Is it available to be purchased?
Mr. Aucoin: The current registration of strychnine only allows certain uses of it. It can be used as a technical manufacturing
concentrate. The only registered use for it at this time is that it be formulated into a ready-to-use product, mixed into grain bait and
sold like that.
Senator Tkachuk: Who actually mixes the product into the bait?
Mr. Aucoin: The company or registrant who owns or has the approval does that procedure. There are two or three companies that
actually have this registration.
Senator Tkachuk: What is the difference between the product that is mixed by the company and what the farmer would mix that
causes the regulatory bodies a problem?
Mr. Aucoin: It is the distribution system and the access system.
Senator Tkachuk: Explain it as you go, because I do not understand it. What is the distribution system?
Mr. Aucoin: The problem is primarily access. We have one, hopefully closed system formulating plant that takes this highly toxic
strychnine, mixes it into a grain bait and packages it and sells it in the marketplace.
The other option that has been proposed in terms of bringing back liquid concentrated strychnine is that that same company would
sell, in the marketplace, many little bottles of highly toxic strychnine. It is a question of access to those small bottles of strychnine
that could be used for purposes other than mixing with bait.
Senator Tkachuk: If strychnine is an approved product, why is the company concerned? I do not understand. If they already
make the product and they already have it, if there is a demand for it, they
will sell it. You must create the demand. Is it not the regulatory bodies that
must say: "This product can now be mixed by the farmer rather than be mixed
by the company"?
Mr. Aucoin: We do not create a demand.
Senator Tkachuk: Yes, you would, if you said that someone could buy this product in a particular form you would create a
demand because there is no question that the farmer needs it. He would be out there scouring the market to find it to use it.
Mr. Aucoin: It is the role of the company to do that.
Senator Tkachuk: Why do you care about the company? Why is the government concerned that the company will do these
things? Your job is to say that the farmer can purchase this product in this particular form.
Mr. Aucoin: We do not make those kinds of decisions in isolation in the absence of a submission from a company who takes
ownership of that product at the end of the day.
Senator Tkachuk: Boy, this is a difficult question.
Mr. Aucoin: It is like drugs.
Senator Tkachuk: It is easier to get drugs than to get strychnine, I tell you that. I wonder if gophers would take cocaine?
Senator Oliver: I have been trained as a lawyer and as such I been trained to ask questions and to defend the opposite side. I want
to ask a couple of questions that will help put on the table some of the apparently opposite arguments.
First, is there a natural predator to the gopher?
Senator Sparrow: The farmer.
Senator Oliver: You spoke about your concerns in regard to protecting the public and the environment. Most people who have
any understanding whatsoever of insecticides and pesticides are concerned about residue. In other words, if you kill a gopher and the
birds come along and eat the carcass, can they carry disease?
Second, if a gopher carcass is near a lake, river or well and it gets into the water, will it affect the water and if humans drink the
water will it have an affect on them?
Have you done any studies on these questions that arise from the death of a gopher that has been killed by the chemical?
Mr. Aucoin: One of the conditions of the emergency registration this past summer was that Saskatchewan Environment and
Resource Management do exactly that type of study. They were to look at the ecological impact of using strychnine to control
gophers and to study what the level of secondary target effects would be.
There have been incidents where bald eagles and other types of raptors have been exposed to dead gophers. I am sure senators
around the table with experience in agriculture realize that you cannot be expected to pick up every dead gopher.
Senator Oliver: In your paper today you said that strychnine has a high acute toxicity.
Mr. Aucoin: Yes.
Senator Oliver: As such, if birds eat a gopher carcass that has been poisoned, can they carry that?
Mr. Aucoin: Yes.
Senator Oliver: Will that affect other insects, birds and animals?
Mr. Aucoin: I am sorry I am not following you in terms of affecting other birds, insects and animals. If an eagle were to pick up a
dead or dying gopher and make off with it, and consume it, then it could kill the eagle.
Senator Oliver: If the dead gopher got at or near a well for drinking water, what effect would that have?
Mr. Aucoin: I do not know.
Senator Oliver: Have you done studies on this that you can lay before the committee so that we can review the information?
Mr. Aucoin: No, we do not have those kinds of studies.
Senator Oliver: Do you have any evidence of any deleterious affect to the environment or to people as a result of gophers being
killed by strychnine?
Mr. Aucoin: We have numerous reports that were discussed in the early 1990s with us.
I am sure there will be literature on the secondary affects of strychnine poisoning of gophers. The use of strychnine was prohibited
in the United States in 1988.
Senator Oliver: Have you done your own research? Do you have your own papers?
Mr. Aucoin: No, not that I am not aware of. There have been requests for very specific economic studies and yet, there have not
been any done. There were no scientific studies done at this particular time to make this decision. We based our decision on
representations made by a number of groups.
The primary case that was being made against liquid strychnine at that time, on which we based our decision, was misuse of the
strychnine liquid concentrate. It was recognized that there was potential for secondary, non-target effects on various animal species,
but the key at that time was that there was misuse. People were intentionally poisoning dogs, although perhaps for valid reasons.
Senator Oliver: The Criminal Code can look after that.
Mr. Aucoin: I appreciate that there is legislation in place to deal with those situations. Our information is that those situations
continue and that there are additional agricultural insecticides being used to poison dogs and coyotes and those products were not
meant for that purpose. This is the background against which we are being asked to bring back a 2 per cent liquid strychnine
Would it be responsible to potentially exacerbate the situation?
Senator Tkachuk: How many dogs have been poisoned?
Mr. Aucoin: There were 20 to 25 confirmed cases in Saskatchewan each year and 10 to 15 confirmed cases of strychnine
poisoning in Alberta each year. Use of additional agricultural insecticides for this purpose has been confirmed.
Senator Oliver: Is there any evidence that a large number of birds have been killed or poisoned?
Mr. Aucoin: There are reports of a large number of birds being killed by strychnine this year, although I am not sure whether they
are confirmed for strychnine.
Senator Oliver: What about private water wells, lakes and rivers? Is there any indication that strychnine has entered this water
and caused damage to either the environment or people?
Mr. Aucoin: No.
The Chairman: Senators, although I know there are many more questions for Mr.
Aucoin, we have witnesses waiting from the
Government of Saskatchewan and from the Association of Rural Municipalities. If we have time after hearing them, we will bring
back these witnesses from Health Canada.
We will now hear from Mr. Cameron Wilk and Mr. Scott Hartley of the Department of Agriculture of the Government of
Saskatchewan, and from Mr. Ken Engel and Mr. Robert Schultz of the Association of Rural Municipalities.
Mr. Cameron Wilk, Pesticide Management Specialist, Inspection and Regulatory Management, Saskatchewan Agriculture
and Food: This morning I will talk about some of the factors that contribute to our problems with ground squirrels; about our
emergency registration in the past year; our plans for 2002 and, if time allows, I will talk a bit about strychnine. Mr. Hartley headed
up the survey on the levels of ground squirrels and northern pocket gopher infestations in the province.
As Mr. Aucoin said, the mild winters and warm spring conditions we have experienced over the past three years have contributed
to increased ground squirrel populations. The registered strychnine ready-to-use baits have been ineffective.
Mr. Scott Hartley, Provincial Specialist, Insect and Pest Management, Saskatchewan Agriculture and Food: We were
getting a number of calls about this and we wanted to determine how extensive the problem is in the province. Therefore, I put
together what I call a gopher survey. In this survey we dealt with both Richardson ground squirrels and pocket gophers, but I will
restrict my comments to the Richardson ground squirrel because that is the major issue here today.
We set up our study even before the Pest Management Regulatory Agency requested more information on the problem. The
Western Forum is a group made up of the Western Committee for Insect Pests and the Western Committee for Plant Disease. The
forum used to deal with rodent issues, but has not done so for a number of years.
The PMRA addressed this issue a year ago, in Moose Jaw, and asked us for more information, which coincided with our survey. It
was quite an extensive survey and I have given it to Senator Sparrow. If more information is needed, we do have the publication.
We interviewed 1,724 producers in the province; that number is considered to be well above statistical significance. This survey
was done by phone survey during the winter of 2000-01. Approximately 67 per cent of the respondents reported increases in
Richardson ground squirrel problems in the last 10 years. This gives an indication of what happened during the time when strychnine
was not used. Approximately 56 per cent reported crop loss; 40 per cent reported equipment damage and 19 per cent reported
livestock injury as a result of gopher burrows in pastures and from predators such as badgers enlarging the gopher holes. Livestock
includes both cattle and horses.
Approximately 91 per cent of the respondents said they attempted to control ground squirrels in the province. About 69 per cent
indicated that poison was their control method of choice; 11 per cent utilized trapping and 80 per cent utilized shooting. There are
combinations of all of the above. Other methods include anhydrous, cultivation to break up burrows, and even drowning.
There was a section of the survey that allowed for additional comments from the producers. There was an abundance of these, as
you can imagine. The majority of the comments focused on the lack of effective poison controls, especially in the absence of
strychnine and the disappointment in the ready-to-use baits.
Mr. Wilk: This past summer we had reports of levels of infestations, in the northwest part of the province, as high as 8,000
burrows per quarter section, or 1,000 family units of ground squirrels per quarter section. A family unit of ground squirrels can range
from eight to 10 individuals. Losses ranged, as a minimum, anywhere from 15 per cent to 30 per cent of the crop. Crops impacted
included cereal crops, oilseeds, pulse crops, forage crops and pastures.
Accessing the 2 per cent concentrate by way of the emergency registration was a cooperative effort between our department,
Saskatchewan Environment Resource Management, the Saskatchewan Association of Rural Municipalities, and what we call here the
Provincial Council of Agricultural Development and Diversification Boards.
To give you some background on the ADD Board structure, the rural municipalities are organized into 38 districts, ranging in size
from 14, being the largest at Moose Jaw, to two municipalities in the Hudson Bay area of the province. These ADD Boards were
originally set up to facilitate green plan funding several years ago and the old Save our Soils program.
The boards are organized into six regions: two representatives from each of the regions in the province form the provincial council.
The provincial council acts as a mechanism where we can flow about $530,000 annually for pest control funding in this province.
In Saskatchewan we applied for our emergency registration on June 25. PMRA granted it on June 29. PMRA turns the
emergency applications around fairly quickly; they treat them as a priority. As Mr. Aucoin mentioned, the label expired August 31
of this summer.
The program was highly restrictive in this province because of limited supplies of strychnine. We limited the amount of grain any
one producer could purchase, to ensure that anyone who wanted the product could get some of it. They had to provide their names,
telephone numbers, mailing addresses, regional municipality numbers and locations where the bait was to be applied. They also had
to agree to complete an evaluation as to how well or effective the product was working on their agricultural operation.
Saskatchewan agriculture and food had several terms and conditions: We had to provide a list to
Nu-Gro, the company that
manufactured the strychnine concentrate, and a list of all the rural municipalities that requested access to the product, we had to
monitor the product for problems and we had to prepare a report on how effective the fresh mix bait was from the farmers who
bought the product.
Again, Mr. Aucoin referred to an impact study undertaken between Health Canada and our Department of Environment Resource
The liquid concentrate arrived in Saskatchewan on July 16. Once we had the registration in place in the early part of July, it took
a period of time to come up with the funding available to bankroll the program. It took Nu-Gro about 10 days to manufacture the
product and make it available to us.
We ordered 560 cases of the concentrate, expecting that would be enough to service up to 1,500 farmers. At the end of August, we
were able to get the product to 717 farmers. We went through 9,000 bottles of the concentrate; Alberta went through 69,000 bottles
The map I have in front of me indicates the rural municipalities that requested help with the problem. At that time the greatest
amount of pressure was coming out of the southwest part of the province. As we progressed to mid-July, just as we were getting
ready to get the program underway, these are the municipalities that indicated their interest in purchasing the product.
By the end of August, at the end of the program, it was clear that the problems were limited to the northwest and southwest parts
of the province. There is a block of concern coming along the Qu'Appelle River system on the eastern side of the province.
The ADD board system employs two regional pest control coordinators who supervise the mixing of the bait program. We only
have two in this province, so we had to schedule mixing days: they spend two days at each location. What you see is the schedule
that we had to work with once the strychnine concentrates began to arrive in Saskatchewan.
By the end of July, the drought was well underway in this province. Harvest was underway and interest in the program lessened.
In terms of distribution, North Battleford and Lloydminster accounted for by far, the greatest amount of strychnine access in this
province. We were anticipating that Swift Current's demand would be as high as
Lloydminster's. However, again, with the drought
conditions and the early harvest, that demand backed off considerably.
The problems concerning the emergency registration, from the evaluations completed by the producers who bought the product,
focused on the supervised mixing of the bait. There were problems and confusion around the use of oats in the mixture. The
coordinators experienced fatigue because there are only two of them in the province. There were concerns about the mixing rate; was
it being mixed too strong? There were considerable concerns about the cost of the product and a number of concerns about the
availability, access and distribution of the product.
Timing was a factor. Farmers wanted to take the product back to their own operations and mix it for their use. There were
concerns about the safety of the product. They wanted to see a coloured dye in the concentrate. They wanted to see larger bottles to
facilitate easier mixing of larger amounts of grain. Communication, given the tight timelines we had with this product, was a concern
With SERM and with PMRA we are progressing with an emergency application for this spring. Essentially, the ground squirrel
population remains high; the squirrels are in hibernation. It is somewhat analogous to the concerns we have with the snow goose
problem in the Northern part of the country, where these things are simply down south waiting to return in the spring.
The 2001 control program in this province was implemented too late to have any significant impact on the level of ground squirrel
population. Weather conditions to date remain the warmest on record, with little or no precipitation anticipated in the forecasts.
The precipitation map only confirms that observation. Significant parts of the province remain extremely dry, with little hope of
any improvement on that front.
Features of the application for the 2002 control program will involve farmer access, point of sale being the rural municipal offices.
There is some thinking about a wider mixing rate, a number of new carriers for the 2 per cent concentrate, a specific time frame
focusing on the spring, a large component around training pest control officers and having the pest control officers in position to train
farmers for the program this coming spring.
Any access to farmers would have to include a farmer training aspect.
We are looking at limits on the amount of strychnine that any one farmer can buy. The limit might be a case per person. The same
restrictions on information from the producer will apply as in past programs.
We are working on having the pest control officers and the municipalities work a collection system once the label expires, and we
are also addressing returns and disposal of unused product once the label expires.
Farmers will be required to complete a release form. Rural municipalities will be responsible for ensuring the compliance of the
farmers. That will be done through the pest control officers employed by our ADD board system or by the rural municipalities. Our
department will be responsible for ensuring compliance by the municipal offices. Empty containers and unused product will be
returned to the regional municipality offices for collection and disposal.
Farmer training will take the form of a PowerPoint presentation featuring specific information about strychnine, safety concerning
strychnine and how to properly apply the product. The presentation will also have a large component on ground squirrel management
and how to get effective control of these particular rodents.
With respect to the point of sale that I mentioned earlier, the strychnine will be sold out of rural municipal offices. SERM has
agreed to provide us with some expected demands based on the dose level out of the baits that are prepared.
With respect to the mixing rate, there are questions as to whether or not the 0.4 per cent solution is too strong. Research out of
Alberta clearly indicates that the fresh mixed 0.4 per cent product is 97 per cent effective, while off-the-shelf ready-to-use baits are
only 67 per cent effective. When you look at the pre-1992 labels, depending on the amount of bait added to the strychnine
concentrate, you ended up with a fresh mixed product that ranged from a 0.11 per cent to a 0.27 per cent product that was accurate.
What is missing here is data on whether or not those baits were effective at those ranges. This is how you arrive at a 0.4 per cent
The carriers will be expanded to include all cereals and canary seed. However, the effectiveness, and this is a major part of the
ready-to-use baits, is influenced by the enzymes, oils, dust and moisture content of each of the carriers that are used to prepare the
After discussions with the gentlemen from SERM and other farmers we agreed that the period between February 15 andJune 30 would be suitable for us. The Saskatchewan conditions are not quite the same as those of Alberta and we are looking at
March 15 to July 31 as a window for control. Timing is very critical. It is best to get these little guys when there is still snow around
and before any green material shows up. Once fresh vegetation appears ground squirrels are not interested in eating dried bait
Strychnine is a tree that grows to about 40 feet high and is native to India, Thailand and Vietnam. It has a thick trunk with
irregular branches covered with smooth, ash covered bark, similar to a poplar tree. The wood is white, hard, close- grained and quite
bitter. The flowers are white, and the leaves are opposed, fairly smooth on both sides. The fruit is about the size of an apple and it is
in the seeds of the fruit that one finds the strychnine. Manufacturing or getting the strychnine out of the seeds is a difficult process,
and it usually takes a great deal of effort to dry down, slice and grind up the seeds.
Strychnine is the most important alkaloid that comes out of the plant. Each seed contains up to 1.5 per cent strychnine. The other
product that comes out of the strychnine fruit is Brucine. Strychnine is 12 times more powerful than the Brucine product. Strychnine
is bitter and this bitterness has something to do with the palatability of mixed baits; one part can be detected in 750,000 parts of
water. It is fairly stable in air, insoluble in water and can be soluble in alcohol and chloroform.
Strychnine is extremely toxic. It has an LD-50 in rats of 1 to 30 micrograms. The ground squirrels we found in our environmental
impact study with Environment Resource Management were analyzed by the Prairie Diagnostic Services College of Veterinary
Medicine in Saskatoon. The stomach content contains strychnine at 18 nanomoles per gram, that is, 18 parts per billion was enough
to kill ground squirrels. It is highly toxic and there is no antidote for it.
This slide indicates the range of 1992 labels. These are PMRA slides that they shared with us in Edmonton during a meeting.
There are approximately six strychnine baits available for use in the province. The last slide shows some of the other options
available to agriculture producers in the province for the control of ground squirrels.
With that, I will end my presentation.
The Chairman: Thank you, Mr. Wilk. I want to clarify that the statistics you have given us are from a year ago, meaning that the
problem has persisted for another summer and another spring. Has the problem gotten worse?
Mr. Wilk: We are expecting the ground squirrel infestations to be as high, if not higher, this spring.
The Chairman: I will now go to the representatives from the Saskatchewan Association of Rural Municipalities, Mr. Ken Engel
and Mr. Robert Schultz.
Mr. Robert Schultz, Director, Saskatchewan Association of Rural Municipalities: I am the director of
Environment and Resource Management and I welcome the opportunity to speak to the committee this morning.
The Province of Saskatchewan has seen an invasion of gophers over the last 10 years, partly due to drought conditions, but mainly
due to the fact that the effective strychnine was removed from the marketplace 10 years ago and has been unavailable to the producer
since that time.
The lack of a suitable product to counteract the rodents is a problem. We have ready-to-use products on the shelves. It can be
argued that possibly through some chemical reaction, this product could be registered as the Viagra of the gopher world.
The cost to the farmers have been mentioned by both Senator Sparrow and Senator
Wiebe; I have experienced losses in crop due
to Richardson's Ground Squirrels and gophers.
The natural predators of the gophers are coyotes and badgers; the coyotes have never looked healthier. They are so fat right now
they could not catch gophers if they had to. The badger holes are so large that they are big enough to plant utility poles in. This
causes many problems as animals break legs and, consequently, having to be destroyed. The holes also take their toll on farm
machinery with resulting broken wheels, axles and so on.
The emergency registration of the 2 per cent strychnine in the late spring of last year, although it proved to be very effective, was
simply too late to be of significant help.
It proved to be very inconvenient for producers to gain access to the product. We heard stories of producers driving a 100 miles to
get a product mixed and then having to rush home and apply this product in the holes while still fresh.
The fact that the product was restricted in the amounts was not helpful. Many producers have hundreds or thousands of acres of
land. A five-gallon pail of bait does not go very far in treating that much land.
We also heard that the product is very expensive. We would certainly like to see something done about that. In future years the 2
per cent strychnine must be made available when required, so that a farmer can mix up a batch as needed. One producer may not
need a five-gallon mix to treat a small population while another producer will need more than that. Simply stated, we are asking that
strychnine be made available to the producer to mix when it serves him best.
Mr. Ken Engel, Executive Director, Saskatchewan Association of Rural Municipalities: Honourable senators, thank you for
this opportunity. I would like to thank Senator Sparrow for all the work he has done on this issue. He has been a great help to us.
I have copies of petitions signed by thousands of people from Saskatchewan. These petitions were signed in 2000-01 to express
the problems with gopher poison. Many of these petitions were tabled in Ottawa, however, just as many never made it to Ottawa or
were refused by Ottawa, because the right form was not used or people had not given complete addresses, et cetera.
I also have letters from municipalities all around the province indicating the ineffectiveness of this pre-mixed product. This has
been a standard complaint from many producers since it was withdrawn in 1992. Senator Wiebe made reference to the fact that it has
been a problem for a couple of years and nothing has been done.
We have had annual resolutions from our association since the product was removed in 1992. These resolutions have called for the
restoration of an effective product. This problem did not just happen; it has been here for 10 years. People are becoming extremely
How serious is this problem? Let me give you an indication. Mr. Schultz mentioned that some producers had to rive 100 miles to pick up a pail of pre-mix might cost as much as $150. For ranchers with heavy infestations a five-gallon pail may
be empty after treating 20 acres. In many cases the producer had such a bad infestation that he spent money just to see if the product
would work. They were pleased with the results. The fresh-mixed bait is desperately needed.
Senator Tunney: I have a question for Mr. Aucoin.Is the lack of applications due to the insecurity of a manufacturer with a
product that has only a 12-month life cycle? The emergency permit goes year by year. How will the manufacturers know whether an
emergency permit will be issued next year? They do not want to be left holding stock that cannot be sold.There may be no
opportunity for volume sales, nor any hope of a profitable return in the operation.
Mr. Aucoin: That is correct. They must estimate the demand in any particular time period. Under the emergency registration
scenario, a proposal is made for a specific time period. A registrar must be on side and willing to supply the product for that time
period. This summer they estimated a certain quantity that they could put forward. We do not yet have an expression of interest in the
long-term by a registrar for a normal registration of this kind of product that would go beyond this sort of emergency scenario.
Is there a long-term interest in a company supplying all the necessary data and studies necessary to support strychnine use in
Senator Tunney: No one can hope to solve the infestation problem in the next few years. I suggest that the manufacturer needs to
be assured of a longer-term permit. It is horrendous that farmers must travel so far to get the product and pay so much money to
apply it on land that, because of grain prices, will not return the cost of the fuel, seed and fertilizer. That is a big problem.
I am not trying to blame you for things that are bureaucratic and government-oriented. You do not have the authority to change
those things. We do have the authority to change things and yet, we do not seem to act responsibly or quickly enough to get these
I have another question. Do we have, in the Western provinces, any problem with animal rights people who want to protect the
gopher? In Eastern Canada, we have activists who would not want me to kill a rat if it were in my barn, let alone other animals,
birds, fish. Are there reactions to the proposed wipeout or control of gophers?
Mr. Aucoin: PRMA is not aware of any representations of that type. The provincial governments may be closer to that issue.
Mr. Wilk: To date, the environmental lobby has not materialized in this province. We caught them pretty much by surprise with
the emergency application last spring. We are anticipating that they will be prepared for us in the future. The biggest challenge I have
is keeping our urban environment resource management on side.
That will be influenced by the report that they are preparing on the environmental impact study.
Mr. Engel: We have been selling ready-to-use farm products out of the office since 1992. Before that, we were selling the full
strength product. We distributed the product in this test flask out of our office as well. I have not received any calls concerning this
issue from animal rights people.
Senator Tkachuk: It was mentioned that 25 dogs died due to strychnine poisoning. You mentioned earlier that none of those dogs
had died by accident. It was done with malicious intent. When did this happen?
Mr. Aucoin: These are annual statistics. In Alberta you may expect 10 to 15 dogs to be poisoned annually due to strychnine. In
Saskatchewan, there are 20 to 25 cases per year.
Senator Tkachuk: Has that number changed much from 1992?
Mr. Aucoin: I do not have that information.
Senator Tkachuk: That would be important information to have, would it not? The regulations changed in 1992 to disallow the
stronger form of strychnine to be sold in its pure form to the farmer. As a result, the number of strychnine caused deaths in dogs
should have decreased since that year.
Mr. Aucoin: It is worrisome that there are still that many cases of strychnine poisoning.
Senator Tkachuk:Is it possible that number may have increased?
Mr. Aucoin: I could not speculate on the answer to that question.
The Chairman: Was the poisoning of those dogs intentional, or was it the result of an accident? Had the dogs eaten the grain
Mr. Aucoin: No. Perhaps Senator Sparrow would have some insight on that. I would not expect dogs to consume ready-to-use bait
product. They would only consume some type of bait that had been laced with strychnine.
Senator Sparrow: I quoted earlier from PMRA that in Alberta there were 10 to 15 cases of strychnine poisonings per year. In
Saskatchewan, 20 to 25 strychnine dog poisonings per year have been reported. The PMRA indicates that the number of strychnine
dog poisonings have decreased only slightly since the early 1980s. Dog poisonings are still occurring and are probably intentional.
I did refer, Mr. Chairman, to the ready-to-use poison. You could mix two cups of the ready-to-use poison and two pounds of
hamburger, and it will kill the dog, if that strychnine is still available.
The scientific evidence indicates that most wild animals, such as coyotes, will not touch the poison because they are wary of
anything that they do not customarily eat. They avoid anything with a different smell. Thus, it is not off-target poisoning.
I am glad someone mentioned that earlier. The off-target problem of killing horses and cows is great because when a cow breaks a
leg in a hole, it has to be killed. Obviously, if a horse breaks its leg, the horse has to be shot. We are losing many more cows and
horses than we are dogs. That is for sure. As mentioned, if a person wants to kill a neighbour's dog, he can find another way to do it.
Senator Tkachuk: He can shoot the dog. It seems to me that there would be less use of this product if it were placed on a control
basis. Before, the farmer was well aware he could purchase the product, and as a result was always on the lookout for gophers. He
did this to manage his land. Therefore, he was always on the lookout for a small outbreak of gophers on his property and he would
kill them before they infested another farm. The gophers just continue populating, correct?
My view is that these emergency situations are creating a larger problem. First, you have the problem of the gophers. Second, you
have a massive use of poison to get rid of them. If the product were always available the farmer would be able to solve the problem.
In this way, there would be a lot less use of the product rather than a horrendous use of the product during an emergency.
The Chairman: Mr. Engel wants to respond. Mr. Engel, are you hearing us? We are having some technical difficulties.
Mr. Engel: We missed the last five minutes. Could you repeat the substance of the discussion?
Senator Tkachuk: I will repeat the last question. My view is that if this product were on the market on a regular basis, there
would be less use of it. Farmers would be constantly controlling the pest population rather than dealing with huge infestations in an
emergency situation. Mr Aucoin, could you comment on that first, which might assist to fill in the few minutes of communication
that were lost. I hope that they will comment on that, as well.
Mr. Aucoin: If it is okay with the committee, I would like to defer to Saskatchewan's expertise on that issue.
Mr. Wilk: The approach you have described makes sense to me. Having an effective control measure to keep the population under
control is the preferred route to follow. However, as Mr. Aucoin referred to earlier in his presentation, that would require a company
to come forward with an application for full reinstatement of the 2 per cent concentrate. We would be more than happy to lend some
support to that.
The Chairman: We were also discussing the problem of dogs. Have you any comments on that? There is no indication, according
to Mr. Aucoin, of dogs that were poisoned from the grain mix. There were dogs that were probably either shot or killed with
hamburger that was poison-laced. Do you have any comment or statistics on that?
Mr. Schultz: I do not have any statistics. I can tell you that if I wanted to poison my dog or your dog, I could go into a
pharmaceutical store that sells veterinary supplies, or to any vet, to buy off-the-shelf products that would poison a dog just as quickly,
with probably a similar reaction, as strychnine poisoning. If a person wants to poison a dog, they will poison a dog.
I am simply saying there are products available. You do not need prescriptions or any special orders to buy them. They are
Senator Hubley: My first question is about the product itself. I have heard several messages, which I would like you to comment
on: a 2 per cent fresh product delivered at an appropriate time would achieve the desired results. If the management technique is part
of the problem, we must look at that.
Does the product affect a younger animal? Is there a way of coming from behind the product and targeting the families that come
forward every spring? I would like you answer that first, please.
Mr. Hartley: That is why the management technique is best in the spring. Again, it is partly the idea that there is much more food
available as we move from spring into summer. The other idea is to try to control the mothers and young ones before the populations
really explode during the summer. That, in actual fact, is one the targets of that kind of spring management.
Senator Hubley: Is this happening? This problem has gone on for quite some time. Is that management technique being promoted
through education or other methods to inform the farmers? Are farmers able to obtain the product to apply it at the appropriate time?
Mr. Hartley: Springtime presents other problems, because it is one of the busiest times of the year for most producers. That
presents a bit of a problem. The education method has been used, and that is reflected in our survey. We have made a conscious effort
to emphasize to producers that springtime is the optimum time to manage the gopher problem.
Part of the reason is that people considered the ready-to-use baits to be ineffective. If they are to be effective, the best time to use
them is in the spring. The results in the survey indicate that everyone who was controlling, or attempting to manage, the populations
were doing so in the spring, as their first choice.
Mr. Wilk: One of the other problems was that the ready-to-use off-the-shelf strychnine baits available to the producers for the
spring control programs were ineffective. They were not delivering the intended results.
Senator Hubley: Was that the 2 per cent product?
Mr. Wilk: No, that was the 0.4 per cent, off-the-shelf, ready-to-use baits.
Senator Hubley: You mentioned possible targeting of the females and the young. Has there been any other scientific work in
respect of a sterility solution. Has that been studied?
Mr. Wilk: I do not know of any research being done on that aspect of control. We have been looking at other products that are
foam-based rodenticides; they are currently being evaluated by PMRA.
Senator Hubley: You have talked about other animals that might be targeted, and there always seems to be some residue from any
kind of an aggressive solution to a problem. I come from Prince Edward Island where we have done a great deal of work on
developing environmentally sound ways to apply pesticides; on the proper usage of pesticides; on education of pesticide users; and
on licensing farmers to use those products. Even with all of those steps, we still run into major environmental problems.
It is interesting that we are now finding that, even with careful use, it is affecting the honeybee industry. It seems to be that when
you take an aggressive step against any species, there are repercussions in another areas. We are trying to learn today just where
those might occur. Thank you.
Mr. Hartley: We did not catch the last part of the senator's comments.
Senator Hubley: I am not sure how far back.
The Chairman: Senator Hubley, would you repeat your question, please?
Senator Hubley: I stated that, with any aggressive approach to eradicating a problem, we often create other problems. That is
something that our committee is looking at today. I mentioned that I come from Prince Edward Island, where we have had major
environmental problems caused by the use of pesticides. We have made major improvements in that area, both through education and
research, but in spite of our best efforts, we are affecting the up-and-coming honey industry in Prince Edward Island. The pesticide,
even in very small amounts, is affecting the honeybees. It seems that to solve one problem you create another. We would like you to
be aware that there are inevitable repercussions to problem solving. Thank you.
Mr. Hartley: That is why our environment resource management is looking at this issue. We are trying to take a fairly holistic
approach to the problem. That is also why PMRA has to spend some time trying to address the entire issue. We would like to have a
balance. In my work with insects or vertebrates, I do not believe that complete eradication is a reality.
Rather, we want to achieve a good balance. Certainly, the Richardson's ground squirrel and other rodents are part of the food
chain, and we have had people voice concern over the effects on the food chain further along the line. The idea that there has not
been a large outcry from animal rights groups does not mean that there has not been comment made about the aggressive measures
taken against the gophers. We are attempting to address the problem with a well-balanced approach.
Senator Chalifoux: How long have you been working with Alberta? I am surprised there has not been more research done on
several of these issues.
What are you doing in respect of the research that is so badly needed? There is endangered specie in Southern Alberta, the small
prairie fox, which they are trying to reintroduce. The eradication of the ground squirrels will affect that specie. I would like
comments on the research and also about what you are doing with Alberta.
Mr. Hartley: My specialty is insects and much of this work has been trying to get caught up on vertebrate. I have relied a great
deal on the Alberta situation, and so I maintain close contact with Alberta agriculture in respect of this issue. Research is a main
factor, and we do not have a large component in our agricultural department that can be set aside for research.
As you know, I am both an insect and vertebrate pest specialist. Alberta has more resources for that research, and so we rely on
them. We have made use of government funding to try to improve trapping success for pocket gophers. We put money into this
survey to try to establish the severity of the problem.
One of the major concerns of SERM is endangered species. The Palliser Triangle is home to the swift fox and regardless of what is
happening with strychnine, SERM is looking at how strychnine use will be handled in the south-west part of our province.
Senator Wiebe: Let us look for a moment at some of the solutions. I should like to direct this question to both Mr. Schultz and
Mr. Aucoin. The proposal for the 2002-year that the province of Saskatchewan is asking for sounds like it is pretty much the same as
what we did last year, only we will start earlier.
Is the problem the product or is it the regulations surrounding the product? Let me expand on that a bit. We now have a mixing
rate of a 250-millimetre bottle to 1,000 parts of grain. What would happen if we put that same 250-millimetre bottle into 500 parts of
grain? I use that as an example. Will you have more effective control of the gopher that way or must we design a brand new product?
Mr. Schultz: I do not believe the product is the problem. The problem we see and we hear about is that the timing is wrong. We
have addressed that issue this morning. The other problem is that the product must be made more readily available. There were
certain test stations last year. Producers were travelling many miles to these test stations: For the benefit of our people, we feel that
the product should be made available closer to home so that they can access this and, if need be, mix their own product to serve their
Senator Wiebe: If I understand that properly, the solution is very simple: It is a matter of a change of regulations.
Mr. Schultz: It appears that way.
Senator Wiebe: Would thechange of regulations have to be supported by the four provinces that first agreed to it, and the federal
government? If it is a simple change of regulations, what process might be used to get those regulations changed?
Mr. Aucoin: That is probably quite accurate. However, change is neither necessary nor simple. The legislation is quite clear about
registering a pesticide in this country.
Senator Wiebe: I am not talking about registering; I am talking about changing regulations. We already have the pesticides. The
regulations are there to govern the rate.
Mr. Aucoin: To govern the rate? First, the product that you want to use is not registered. To register that product, the minister
must satisfy himself that the safety to health and the environment risks are acceptable.
Senator Wiebe: We are talking about the same product. We are talking about a 250-millimetre bottle of liquid poison.
Mr. Aucoin: Yes.
Senator Wiebe: Under the regulations now, you put that bottle with 1,000 parts of oats. We are saying to take that same bottle but,
instead of putting it in 1,000 parts of oats, you put it with 500 parts of oats.
Senator Oliver: There is no registration for that now.
Senator Wiebe: What is the process, then, to change that registration?
Mr. Aucoin: To clarify, there is no registration now for that 250-millimetre product. That is not a registered product approved for
use in Canada today. The only way to make that re-appear next year for use by growers is either through a regular pesticide
submission made by a company, or an emergency registration application made by the province with the support of the company.
Senator Wiebe: You hit the nail on the head right there. Let us go back to the simple solution. If the Provinces of Saskatchewan
and Alberta declare an emergency situation for gophers and ask for permission to mix a 250-millimetre bottle of this product with
500 parts of oats, then, it can happen very quickly.
Mr. Aucoin: They will make a submission for an emergency registration and we will consider the rate that they propose to use the
product. If there is evidence that the rate should go up or down, we are happy to consider that evidence.
Senator Wiebe: We have presented a considerable amount of evidence to you this morning as to the need for that emergency. The
next step is for the provinces to write to you requesting a doubling of the mixture.
Mr. Aucoin: I will leave that to the provinces to answer whether they would double or alter the rates available. From all the
information I have heard today, last year's emergency registration to allow use of the 2 per cent liquid concentrate to make up baits,
which resulted in a 0.4 per cent final concentration, was very effective in that form.
Senator Wiebe: We have accomplished that. In regards to how far the farmer must travel to pick up a 250-millimetre bottle, who
is there to oversee the mixing of it, and so on? Are those regulations that would be changed by the province or are those regulations
that would be changed by your department?
Mr. Aucoin: Those would have to be approved by our department. Last year's registration, for example, indicated on the label the
type of product, the type of restrictions and the type of people who were authorized to mix up the product for use by farmers. These
are logistical problems. These distribution problems were discussed in Edmonton. Some solutions were put forward to have
additional pest control operators, for example, who would be authorized to deal with that. We could consider all of these in the
context of a new emergency application. If there is a better way to distribute the product, it is open for consideration. We are happy
to consider it.
Senator Wiebe: How long would it take you to take something like this under consideration?
Mr. Aucoin: Saskatchewan's application for last year came in June 25 and on June 29 we granted their emergency registration
application. That was largely helped by our work with Alberta's emergency registration. We worked closely together with them to
work out some way of managing this problem that we were both comfortable with.
Senator Wiebe: Would the kind of approach that I have just outlined be acceptable to
SERM? That is to say, if the regulations
could be relaxed and the amount of liquid could be doubled to the grain, would that solution be acceptable to
Mr. Schultz: I am not so sure that the solution is the problem. The solution that we had available to us on the test basis last year
seemed to be satisfactory and adequate. The problem we are having involves accessibility and availability. It was made available in
restricted form. Producers could only get so much of the product and it was not available close to home.
Senator Wiebe: Do the changes that you have talked about fall within the responsibility of the federal government or the
provinces to initiate? It is my understanding that the solution would come from the provinces. The provinces' request to the
regulatory agency would allow them to set these different regulations concerning how far someone must go to pick up the product
and whether the pest officers will mix the product or someone else.
Should our efforts as a committee be to sit down with the Provinces of Alberta and Saskatchewan and say, "Look, we must ask for
changes to the regulations to allow the regulatory agency to have a look at it and make a ruling as they did last year. They accepted
the recommendation that was put forward by the provinces." Should the provinces now put in recommendations suggesting that they
are sympathetic to the concerns that have been expressed by SERM?
Mr. Wilk: Saskatchewan Agriculture and Food emergency application for 2002 will feature farmer access to the strychnine
concentrate. The point of sale will be at the rural municipal office, which has in the neighbourhood of 270 sites in the province
versus the dozen locations where we mixed bait last summer. We are working to that end. Essentially it will be up to PMRA to
approve the application or the process when that application arrives for their consideration.
The Chairman: It is important that we keep our questions and our answers confined to a solution. This committee is used to
getting solutions. We will keep our comments to that. Senator Wiebe you have one more question.
Senator Wiebe: In the application that you will be submitting on behalf of the Province of Saskatchewan for the 2002 program,
have you designed that request in consultation with SERM?
Mr. Wilk: That is indeed the case. SERM has been a part of this application development process for a good period of time. The
department also developed the application process when Senator Sparrow met with us in Edmonton last November. Over the course
of the months of October and just as recently as two weeks ago, I met with the farmers who make up the provincial agricultural
board system to discuss the proposal and the avenues we were advancing to PMRA. A great deal of consultation has gone forward.
This afternoon I am meeting with the SERM board of directors to add some fine details to our application.
Senator Wiebe: If the regulatory agency accepts your proposal for 2002, I know you cannot make everyone happy, but will the
majority of the producers and SERM be happy with that proposal?
Mr. Wilk: I hope so. I will let Mr. Schultz comment on that.
Mr. Schultz: That would be a landmark decision, if we could come up with it.
Mr. Engel: Mr. Aucoin spoke about two solutions: a company making application, and the emergency application being made by
the provinces. The only real solution that we have for next year is the emergency application. There is a third option that needs to be
looked at, and that is the federal government passing whatever regulations or legislation is needed to instruct PMRA to allow the sale
of the 2 per cent strychnine to our farmers just as they were able to purchase it from 1938 until 1992. This solution could be
implemented until such time as other biological controls or other proven methods are found.
Senator Sparrow: Strychnine has been registered in Canada for gopher control use since 1928. Strychnine was used effectively
up until 1990 when there was some representation made to have a ready-to-use product. In all of those years, the provinces kept
gophers under control. They did not eradicate them, but they kept them under control. No one can come up with the scientific
evidence that there was a problem. The change was made without scientific evidence.
Mr. Wilk from the department in Regina, and the Saskatchewan Association of Rural Municipalities are doing a good job. They
are doing what the farmers and Association of Rural Municipalities asked for: that the product be made available through our
regional municipality offices directly to the farmer with certain controls on it. Am I wrong on any of these statements I am making?
The indication is that somewhere along the line someone thought the farmer was irresponsible and could not handle the situation.
We must get rid of that notion.
In regard to the training of farmers to handle the product, I appreciate what we are talking about here. We are trying to make
excuses to have the product registered. We are grabbing at little straws to say it will be safe. We must train the farmers. Let me tell
you this: The farmer has been going in and buying a can of poison for years. He takes it to the farm, opens it and mixes it and puts in
four litres of grain and mixes it around puts a teaspoon down the gopher hole. Are you telling me that we are going to have extensive
training programs for that? We are not talking about herbicides that are sprayed all over the place. We are talking about that simple
If you insist that the farmers have a training program, he will go for it, but he will not be happy. Can you comment on that?
Senator Hubley asked about the 2 per cent and we keep hearing about 4 per cent concentrate. A 2 per cent concentrate, when it
is mixed with approximately 4 litres of grain brings the concentrate down to 0.4 per cent. That is the difference. It figure not 2 per
cent or 4 per cent, the concentration is brought down to the 0.4 per cent level.
The problem is that the poison must be available when the farmer needs it, not when some bureaucrat says he can use it. That may
be no good to the farmer; he may have other things to do on that day. The gophers may not be out. You must poison gophers four
different times a year. The farmer must decide when that will be done because every district is different.
The male gopher comes out first in the spring of the year. He comes out as soon as the snow starts to melt. He is the only one. If
you want to get him, you poison him. The female comes out a month later. She fools around a bit with the male gopher and then she
stays out for two-or-three weeks and goes in and gives birth. She is in for another three to four weeks giving birth. You must catch
her with that poison when she is out before she gives birth. There is that period of time. The farmer has known how to handle that
situation since 1928.
The females that were not poisoned give birth in June and it is in that month that you have to kill the young. The males go back
into hibernation in the middle of July and the females go very shortly after. It is only the young that are active in the fall.
Mr. Aucoin said that the company has to make application. They assured us at the Edmonton meeting that they are prepared to
make application. I believe it was Mr. Wilk who said they could supply the product within 10 days notice. If we need the product, the
companies can provide it.
The companies are prepared to request that the 2 per cent concentrate, in its mixed form, be made available to the rural
municipality. That is pretty simple. They will do that tomorrow if that is the direction they are going to take. However, they will not
take that direction unless they have some indication of what the provinces want. We got that indication this morning and I appreciate
it very much.
The application will be made on the basis that the rural municipalities and the farmers have been requesting: that that it is made
available in this solution for use by farmers themselves.
The three main points are, first, that supply is important; second, that application by the provinces be made on a timely basis and;
third, that the provinces request that the department bring out reasonable regulations for use.
Senator Tunney: In response to your admonition to come to a solution, I got part of my answer in the lesson in biology we got
from Senator Sparrow. I want to know how much material is dropped into each burrow. When you are on a quarter section of land
with thousands of burrows, how do you keep track of which burrows have been treated? Is the poison dropped into the burrow by
hand with a teaspoon, or is there a metering device that ensures that the exact amount is dispensed?
Senator Sparrow: You are correct that a teaspoon is the recommended amount of poison for each gopher hole. Farmers use
different methods for knowing where they have placed poison, such as little flags. They do that for their own safety and their own
Scientific studies show that gophers need eat only four or five poisoned kernels of grain to be killed. A coyote, as an example,
would have to eat 50 gophers in a sitting to ingest enough poison to die. A coyote could not possibly eat that many gophers. A hawk
would have to eat 10 gophers in a sitting to ingest enough poison to die. That is calculated on the basis of weight.
We are concerned about safety if the farmer does not act responsibly. Prior to 1992, farmers mixed a 250-millilitre can of poison
with four litres of grain. A ready-to-use liquid was introduced that reduced the solution from 2 per cent to 0.4 per cent, although
there is no scientific evidence to substantiate the reduction in strength.
Alberta and Saskatchewan introduced this special program this spring because of concerns about farmers being responsible.
However, the regulations permitted the use of strychnine two to three times as strong as farmers were used to using. There is no
scientific evidence for why that was done. The answer I received was that they thought they should make it stronger or farmers
The farmer wants to be responsible. However, now they buy a pre-mixed 20-litre pail. Instead of using five cans of the poison,
they use 15. That made the solution three times as strong and increased the cost by three times.
We heard evidence at a meeting in North Battleford from a farmer who has 15,000 acres of grassland, hay land and pasture land.
On the basis of $150 a pail, it will cost him $450,000 to control the gophers. Since the gophers got so far ahead during the years that
he was not able to control them, that will be his cost. I compared that to what other farmers have said, and found that he was not
inaccurate. We are talking about a lot of money.
Mr. Wilk: You are correct, in that the formula this summer was stronger than what existed in the pre-1992 labels. However, the
product we mixed this summer yielded a 0.4 per cent product, which is the same as the ready-to-use baits. We wanted to ensure that
the fresh mixed product was more effective than the off-the-shelf, ready-to-use products at the same active ingredient level.
The research from Alberta supports that the fresh mixed product is much more preferable. If this committee has some advice on
what the active ingredient level should be, we would be pleased to hear that.
Mr. Aucoin: Our concern was primarily with use and access to the 2 per cent concentrate and not so much with the end-use
product. Senator Sparrow is absolutely correct. Whether the end-use product is 0.2 per cent, 0.3 per cent or 0.4 per cent, you have a
The gopher problem last year created an emergency situation and we did have to respond quickly. We did not want to introduce
yet another variable into the mix. We had a ready-to-use 0.4 per cent product on the shelf and we did not want to suggest that we
decrease the strength of the product available to growers. If it is proven that we could drop the strength because palatability
outweighs the strength argument, we will be happy to consider that. We will wait for a recommendation on that.
The Chairman: I want to thank the witnesses for their excellent presentations this morning. We will be making recommendations
from what we have heard.
Perhaps before we go I could ask the witnesses from Saskatchewan to make a short comment on the drought. Although it is a bit
off the subject, gophers, grasshoppers and drought all go together.
What is the general condition of the drought?
Mr. Schultz: I cannot say much about the drought at this time. There is light snow cover throughout most of the province. Much
of the province was certainly affected by the drought last year. Some areas were not as badly off when it came time to take the crops
off, due to reserve moisture from a year ago. However, there was no moisture accumulated this past year. If we do not get an excess
amount of snow this winter and timely rains in the spring, we will have a serious situation with regard to drought in the province, and
it will cover a greater part of the province than last year.
The Chairman: Thank you for that comment. Again, thank you for appearing and for a very interesting morning.
In terms of where we go from now, I am going to suggest that the clerk, along with probably Senator Sparrow and
Senator Wiebe, write up the recommendations. We have a pretty good handle on where we have been this morning. I do not think it
is necessary to call another meeting; we can trust our two colleagues.
Senator Wiebe: If I may make a comment. I agree with the urgency and I agree with what has to be recommended.
The Chairman: It is pretty clear.
Senator Wiebe: There is no doubt in my mind whatsoever. As deputy chairman of this committee, I must also keep in mind that
our responsibility as a committee is to give the opportunity for all sides of the question to be heard. We have heard from only one
side of the issue. While I agree with the urgency, we, as a committee, should meet with Greenpeace or the RCMP or whoever it is
that might be opposed, otherwise we run the risk of criticism from those who may be opposed to it.
Senator Oliver: That is what my questions were directed at.
Senator Wiebe: We may not agree with their position. It bothers me when I hear comments like those from the chairman from
Saskatchewan, saying "We managed to do an end run around those who were opposed to it by getting those things in quickly. We
may not be that fortunate this year."
We have a responsibility to the process. If that is the route that the committee wants to take, I cannot support it. I must say it puts
me in an embarrassing situation. I am supportive of the problem that farmers have, but I also have in my mind a strong responsibility
to the fairness of this committee to hear from all sides.
Senator Tkachuk: I do not buy the deputy chairman's argument whatsoever. First, we had an emergency situation last year in
which the federal government approved the use of the product. It looks like we will have applications again. We can certainly call for
support and quick movement by the federal government on the short-term solution. We can certainly ask the senate to do that. That
would be helpful and it would show farmers that we support their issue.
Second, we should have perhaps one more day of hearings and have the gopher side come forward to make a presentation. We
could hear from a few environmentalists who want to save the gophers, and maybe there will be some long-term solutions they could
offer. Surely in the short-term, we can show some support for the farmers in a formal way. It is nice of us to say we support them, but
why do we not show it in a formal way and do what we are supposed to do?
Senator Sparrow: We have heard sufficient information now so that the committee may at least write a letter to the Minister of
Health indicating our concern about this issue and expressing our hope that serious consideration will be given to the suggestion
made by the Province of Saskatchewan's Department of Agriculture.
If the committee thought that would be feasible, then the committee might want to make a report to the senate in the same method.
The committee met and heard evidence and now shows concern about the existing problem and hopes that the government will take
action to alleviate the situation. We are indicating to the senate and to the Minister of Health that there is a problem to be solved. We
are not in a position in this short time to solve it.
To Senator Wiebe and to the rest of the committee, we are now beyond the problem of next year. To start calling witnesses at this
time would mean taking another six months. Obviously, there has not been the concern of those environmentalists, because there is
no evidence anywhere of their objections to the use of the pesticide. In one exception, someone brought this forward in 1988 or 1989,
but they can find no evidence of it.
The Saskatchewan Department of the Environment said to me that they have no file on the issue. They have nobody in the
department that is familiar with the gopher problem, or who was there when the decision was made in 1992. They have no file on the
issue. So, if we are to start exploring to find out more, it cannot be done in the time frame in which the problem can at least be
Let me pursue it a little further. In the province of Saskatchewan and Alberta, there is a problem of the swift fox.
Senator Chalifoux:And also with the little burrowing owl.
Senator Sparrow:Yes, and with the burrowing owl in the area. I sent out the names of the areas where municipalities have made
requests to the province. It covers most areas of the province. There are certain areas that are not a factor because of the soil
concentration. If you have a heavy clay soil, the gophers cannot burrow into it and they ignore that area. They moved right out of the
Rosetown area of Saskatchewan. In the areas where the soil is sandy there is a persistent problem.
I have the records showing the habitat of the burrowing owl and the swift fox. No municipality has brought forward its concerns
concerning these animals, and it becomes anecdotal evidence of some description. My answer to that problem is to treat the area
differently. You do not penalize the whole province because of an area where we want to protect the swift fox and the burrowing owl.
Let us make some type of different arrangement for gopher control in those particular areas.
We could cover that, but we cannot cover all of those issues by calling in
Greenpeace, et cetera. We could contact them, I suppose,
and we could have hearings later. However, we must do something now.
The Chairman: There are two things that come to my mind. First, there is no end of people that want to come before this
committee. We have been holding many meetings, probably more than we should have been holding. One group that SenatorLawson brought to my attention that is important in dealing with the environmental issue. Apparently, this group has a machine being
made for use in B.C. that will take manure, sludge and other things and process it into a very useful type of fertilizer and other uses
that are environmentally sound. Senator Tunney mentioned that as well. This information just crossed my desk yesterday, and they
would like to appear before this committee. That is item that is much in line with what we are talking about.
The second item is that the pest control people from Saskatchewan mentioned this morning that they are quite aware of the
importance of the issues that surround the gopher problem.
Senator Chalifoux: I have a couple of questions. I agree, but in the Palliser area in and in the Cypress Hills, there are big issues. I
have been watching documentaries on the swift fox and the burrowing owl. Work is being done on that in that area.
Senator Tkachuk: What is the problem with the swift fox and the burrowing owl?
Senator Chalifoux: They are endangered species.
Senator Oliver: Have they been poisoned off?
Senator Chalifoux: They do not want them to be poisoned off, but that could happen. We need to hear from someone who has the
environmental expertise to provide the appropriate information. Farmers are concerned and we are concerned. We are the keepers of
Yes, I totally understand the gopher problem, because I lived with it when I was a child. In those days, we got a nickel per tail; I
What interests me is that we are hearing one side of the story, and I think we should hear both sides. They are saying that we have
until March 15 before eradication must begin. We should be able to at least hear a couple of people before that time.
Senator Tkachuk: We do not come back until February.
Senator Wiebe: May I suggest that we meet with the Department of the Environment next Tuesday at our regular meeting time?
Senator Chalifoux: At least that would give us some comfort to know what they are doing. You are saying there is no information
and there are no records. Let us challenge them.
The Chairman: I am in the hands of the committee.
Senator Oliver: What would you like to see done?
The Chairman: I will not be here next Tuesday.
Senator Oliver: What is your direction in terms of the resolution to this problem?
The Chairman: It is important to put the recommendations out there. They are pretty straightforward and simple. The biggest
enemy we have is time. If the majority feels that it is absolutely necessary, I am in your hands.
Senator Wiebe: I do not think it makes much difference.
The Chairman: The department itself is very careful about these concerns of health for humans and other affected animals. They
will defend that well, from what I heard this morning from Mr. Aucoin.
Senator Tkachuk: I must not be in the same meeting. We did this last year, but it was too late. Now, we want to ensure that the
federal government cooperates with the provinces so that they get the applications processed quickly. Not to denigrate the owl and
the swift fox, but we can worry about those next year. Right now, we need to come up with a long-term solution, which is better for
the environment than the short-term solution.
Too many gophers are not good for the environment either. We cannot solve everyone's problem. Surely we can provide some
sustenance and support to the provinces. I cannot imagine why we would not.
Senator Chalifoux: Surely we can wait until next week.
Senator Wiebe: I cannot see what time difference it will make, whether our researcher drafts a letter on Monday or Wednesday
for us to send to the minister.
Senator Tkachuk: We should do it today. We must approve it before it is recommended in the senate.
Senator Sparrow: I am sorry but I am confused about Senator Wiebe's comments. He said earlier he was not prepared to support
this because he wanted witnesses called, and he listed a number of different organizations.
Senator Wiebe: I said "possibly."
Senator Sparrow: Obviously, we cannot do that between now and next Tuesday; we might possibly have one witness.
Senator Chalifoux: Yes, a witness from the Department of the Environment.
Senator Sparrow: That does not answer your problem.
Senator Wiebe: It does, because it gives me an idea why this law was changed in 1992. We need to know why that was done. I
believe that as a committee we must be fair. I do not want to be accused of being a committee of the Senate that is simply a lobby
group to the Government of Canada. By listening to just one group of witnesses, we run that risk.
Senator Hubley: I must start off by saying that I am not a Western farmer. I have great sympathy for the problems that you are
experiencing. We, as a Senate committee, must be able to answer the tough questions that other people will ask of us.
Questions concerning the environment will be some of the tough questions. I feel somewhat pressured now to make a decision on
a matter for which I do not have a balance of information. If we do have the time perhaps inviting some environmentalist to come
forward and give us their information would give us that balance that we are going to need to make this decision.
I do not know that we must be pressed by time. You have the experience that I do not have. I am not sure that this has to be done
in three days or four days.
Is it not our job perhaps to take a bit of time to look at all of the sides of the situation and then put forward our recommendations?
Senator Oliver: The questions that I asked today were designed to answer the very concerns you have. I did ask questions about
the environment and about water, lakes, rivers and wells and effects on humans. I asked that if they had done studies, they should lay
them before the committee.
The answer was that they have done no studies. Any evidence that exists, indicates that there has been no environmental harm or
damage as a result of what went on up until 1992. That is what I heard.
On the basis of that, I would like to hear that Senator Sparrow and Senator Wiebe should do a draft in conjunction with our
researcher and our clerk. They should circulate that draft to members of the committee so that we can look at it over the weekend.
Senator Chalifoux: I still do not think we are following the process. We have to appear to be fair. Doing this without hearing at
least from the Department of the Environment would not be viewed as being unbiased. We could hear witnesses on Tuesday and do
the letter on Wednesday. We could do a draft in the interim.
Senator Tkachuk: It would not get it into the senate until February.
Senator Chalifoux: What is the problem? They do not have to have this until March 15, 2002.
Senator Tkachuk: Let's have a vote, although I do not know on what to vote. We cannot come to agreement on a letter.
Senator Sparrow: I was at a different meeting this morning than some of the people here. The issue is not environmental. The
issue is how the strychnine poison is being distributed to the farmer. That is the issue.
There is no representation made by the environmentalists. I do have some evidence here quoting the environmental organizations
pertaining to the use of the poison. I cannot bore you with those now.
The issue is that the poison will be made available. It was made available last spring. They mixed it at site, at a separate location,
and the farmer had to come a 100 miles to get it. They are prepared to do that again if they have to.
The issue now is that it is too costly a way to do it. They want to make strychnine available, as it was prior, direct to the farmer for
use through the recognized municipal government. That is the only issue here.
The ready-to-use poison is still being used in the burrowing owl areas. I do not understand it is being used there. It is the same
product, only stronger, than the farmer mixing his own poison and putting it there. It is already mixed at another location.
The problem with the premixed product is that it becomes stagnant and stale in the can, and the gopher will not eat it. The strength
of the poison is the same. The strength of the strychnine is present, but it becomes stagnant and the gophers will not eat it. The only
issue is that it has to be mixed fresh.
The witnesses in my other meeting mentioned that it was mixed in certain locations in Alberta and Saskatchewan and the amount
was limited. If you set the limit at a 20-litre pail for a farmer who needs 100-litre pails, it is foolish. The issue is how it is going to be
distributed to farmers.
You say that the farmers do not need it until March 15, 2002. It must be in the hands of the farmer on March 15, 2002, not in the
hands of the government or the agency. They are going to make the decision now to get ready for March. They must make that
decision no later than January.
Senator Chalifoux: I am not disputing that at all; I support that. I am looking at the process of a committee of the senate. We have
to appear to be fair and unbiased. Unless we have somebody else coming here, such as the Department of the Environment, we are
going to look like we are a lobby group for the farmers. I do not want that.
I will support the letter. However, we must appear to be fair. That is the process. I totally support the farmers. I totally support the
letter. We must appear to be fair. That is my contention.
Senator Sparrow: Appear to be fair to whom?
Senator Chalifoux: We must appear to be fair to the Canadian public. We do not want to be viewed as a lobby group. We do not
want to be viewed as a very biased committee. That is my concern. We must at least appear to be unbiased.
By listening to the Department of the Environment, we can at least say that we heard them. We would then not appear to be
biased. That is my concern.
The Chairman: In the interests of time, we are at a log-jam. If someone wants to make a motion one way or another, we can vote
Senator Wiebe: I move that we ask the Department of the Environment to send a representative to appear before our committee
Senator Oliver: Could I ask that your motion say the Department of the Environment be asked to appear before the committee
Senator Wiebe: That is fine with me.
Senator Chalifoux: Tomorrow morning is fine.
Senator Wiebe: We would sit at nine o'clock in the morning.
Senator Oliver: We should ask the senate for leave to sit as a committee, even though the senate is still sitting.
Senator Wiebe: Let us do it on Tuesday at our regular time. We will be here next Tuesday anyway. I cannot see us leaving before
Thursday, and perhaps not until Friday next week. Many of us would like to have an opportunity not to have to get up at six o'clock
What is the rush? We will be here all of next week.
Senator Tkachuk: We would be happy to be out of here today.
The Chairman: We should move on this. I agree with Senator Sparrow. Our committee has been pretty open; we have heard all
kinds of people, and we have not won too many battles. If we are accused of being a lobby forum for the farmers, I do not know that
we have won that many battles.
From what I have heard this morning, the provincial people are ready to move. They have done their studies on pest control. That
is what we heard. We had the people that deal with these things. SERM was here making their presentation.
As Senator Sparrow said, our farmers are professionals when it comes to handling sprays and deadly chemicals. We spray
chemicals that kill grasshoppers like you would not believe. I am not too sure that we are making a mistake, but I feel that I should
make my representation known. If I were to vote on it, I would vote in favour of moving ahead.
Senator Tkachuk: You would vote to have a report to the senate?
The Chairman: Yes, having a report.
Senator Wiebe: Have you a motion before you?
The Chairman: Time is an issue that speaks to the question by Senator
Chalifoux. If you give some of these departments that are
slanted on the side of the issue of tying things up, they will do it.
Senator Wiebe: If you not going to recognize my motion, I move that this meeting now adjourn.
The Chairman: I recognize your motion.
Senator Wiebe: I move this meeting now adjourn.
Senator Chalifoux: That is not a debateable motion.
The Chairman: I will accept your question.
Mr. Daniel Charbonneau, Clerk of the Committee: There are two motions on the floor. The first is from Honourable
Senator Wiebe, who moved that Environment Canada be asked to appear before the committee on Tuesday, December 18, 2000 at
5:30. We should dispense with that motion or have Senator Wiebe withdraw it. We can then proceed with the motion to adjourn.
Senator Wiebe: If the chairman is prepared to call my motion, I am prepared to annul the adjournment motion.
The Chairman: I will call your motion. All those in favour of Senator Wiebe's motion?
Senator Oliver: Before you do that, I had asked whether you be prepared to change the date from Tuesday to Friday,
Senator Wiebe: No, let us do it on Tuesday.
The Chairman: All in favour of Senator Wiebe's motion? I see three hands. Opposed.
Senator Wiebe: Does Senator Sparrow have a vote?
Senator Sparrow: Yes.
Senator Wiebe: Motion is lost.
The Chairman: Before we adjourn, is it agreed that we proceed with writing a recommendation?I open the discussion on
recommendations of writing a recommendation.
Senator Oliver: Senator Wiebe, are you prepared to work with Senator Sparrow in writing a draft report?
Senator Wiebe: No, I would not be prepared to work with Senator Sparrow in drafting this because I believe very strongly that
our committee is making a mistake. I could not be part of drafting something that I was against doing.
Senator Tkachuk: Why not have the Chairman and Senator Sparrow do it?
Senator Wiebe: We have a researcher here. He can write out what our concerns were. I regret that the members of this committee
have decided to put me in this embarrassing position. That is the name of the game.
Senator Oliver: I am not putting you in any position. You happen to be knowledgeable. It had previously been suggested that you
and Senator Sparrow write the report.
Senator Wiebe: One has to be knowledgeable about both sides of the issues. If I am going to defend a report that this committee
makes in the chamber, I want to be abreast of all issues. I want to be able to say that I heard from the Department of the
Environment. I want to be able to say that even though I heard from the Department of the Environment, I still feel very strongly that
the direction that this committee will go is the right one.
There is no doubt in my mind that that is what will happen. I do not argue with what would be contained in the letter. I do not
argue with what would be contained in the report. I argue dramatically with the process.
To me, the process is far more important than the flack that I am going to get from SERM and from my own people in
Saskatchewan for me taking this position. I believe that this is an honoured institution. The committee structure is an honoured
institution. We must, as senators and members, do whatever we possibly can to maintain that institution. I know some senators do not
agree with me on that. That is fine.
Senator Tkachuk: I agree with all of it.
Senator Wiebe: I am giving you my reasons why I cannot go along with it.
Senator Tkachuk: We do not know what the report will be.
The Chairman: I accept your submissions, Senator Wiebe. All senators very consciously feel that whatever their decision, they
are taking that decision in light of the best interests of the country and the best interests of fairness of the committee.
Having said that, we understand what you are saying. I respect your view.
Senator Chalifoux: My position is the very same, which I am sure that you realize from my questions. I just cannot go along with
it for that reason. I do support everything else, but we should be able to say that we heard from the Department of the Environment.
Senator Wiebe: When does the committee meet to have a look at the draft?
Senator Sparrow: I will not draft anything up after this discussion. I could use whatever ammunition I gained here from the
evidence that was given. I can quote that evidence to the minister and to the department. It is on the record. If there is concern here
on the process, then I will not be involved in the process at all. I can handle that on my own, as you can as chairman or any
individual senator can.
Senator Wiebe: That is an excellent approach. I will do the same in a letter to the Minister of Agriculture because this is public
record. I have no objections. I will write to the Minister of Environment and the Minister of Agriculture, as I have done already, on
this very issue.
Senator Chalifoux: I am going to write to the Alberta witnesses.
Senator Wiebe: I will not put my name to a report that we will present to the senate on what we heard here.
Senator Sparrow: Just as a matter of interest, and it is not a lecture. I have been here a long time. I have never been at a
committee where we have heard all of the witnesses that wanted to appear, be it on legislation or be it on studies. There are always
far more people who want to appear than we allow to appear. At some point we cut off those hearings.
I am not suggesting that it is not a good idea to hear all those witnesses. We have made interim reports many times from
committees, interim reports on legislation, et cetera.
Senator Chalifoux: However, we have always heard both sides.
Senator Sparrow: No, we may not have. There are many more witnesses to be heard in all cases.
Senator Wiebe: Since my time here and in the committees of which I have been a member, we have alternated our hearings to
reflect the different views of different people. Yes, you are right, there is no way we are going to hear from everyone.
Senator Chalifoux: From everyone, no.
Senator Wiebe: There is no way we should. However, we should have some different perspectives on a certain view.
What is the problem? I am happy with using this material. Senator Sparrow is happy with using this material.
Senator Chalifoux: I am.
Senator Wiebe: I am only asking if are we will be writing a report? If we are writing an interim report, when will we see it?
Senator Tkachuk: You were not interested in even viewing it.
Senator Wiebe: I am interested in dealing with it. It would give me one more opportunity to express my point of view as to why
we should not be issuing the report.
Senator Tkachuk: Senator Sparrow does not want to do the draft report. It appears that we will not have one done.
The Chairman: I would suggest that we have had a very good morning of explaining the problem based on the testimony of our
witnesses. It is my view that the Saskatchewan people have looked into the safety side of it. There is no question that Mr. Aucoin has
indicated very clearly that they are very careful in how this thing is handled. The question is whether it has been too restrictive on the
side of caution.
I also have sat in committees for 23 years. I believe that we have heard both sides of the issue. In fact, we are battling the fact that
the department is overemphasizing and not allowing the farmers enough latitude on this. They indicate here that it was under special
recommendation from the provinces that they would be willing to do that. That is reasonable and fair. We could argue this for days.
Could we then come to the conclusion, as Senator Wiebe and Senator Sparrow have said, to let the meeting and the
representations made here today speak for themselves.
Senator Sparrow: May I just thank the committee for having this hearing. It was very crucial. I appreciate that they met on a
special basis. I want to thank all members of the committee for letting that happen. It was important evidence that came on to the
It is really valuable that the opinions of the Saskatchewan Department of Agriculture and the representatives of the farming
community are on the record. The statement of the PMRA is on the record. That is extremely important to us. We now have it all on
the record. We can use that in the interval if necessary.
The Chairman: That is a very important point.
I want to make another point. I was reading Paul Martin's report on the budget and the minister's report on agriculture this
morning. For the first time, I have heard the Minister of Finance mention grains and oilseeds and the fact that there must be some
special consideration given to these crops. I know that no numbers were mentioned, but I was encouraged that it was on the record
that both Minister of Agriculture and the Minister of Finance had made positive recommendations for grains and oilseeds.
I see that as very positive move that was on the record. We have the same thing here in this committee this morning.