Agriculture Committee on June 8th, 2006

[The Vice-Chair, Bloc, André Bellavance]

Thank you, Mr. Bartley.

Mrs. DeBellefeuille.

[Claude DeBellefeuille, Bloc, Beauharnois—Salaberry, QC]

Thank you very much for your presentation.

As you may know, Quebecers are very strong on environmental values. Many farmers in my riding are moving to organic farming for some of their production.

Someone explained to me a while ago that no Canadian industry is developing technologies to produce pesticides that could be classified as organic.

Mr. MacLeod, since Quebec consumers like to buy organic products -- products that are less damageable to the environment since their production standards are very high -- is your industry planning to encourage the development of new technologies that would allow for pesticides to be classified as organic?

The United States is far ahead of Canada on this.

[Lorne Hepworth]

I can start, and my colleague may be able to fill in more detail.

To start at the top, globally the approach of our industry today is very much, I would say, to research and develop for commercialization what are typically referred to as reduced-risk products, ones that have a much smaller environmental footprint, are safer to human health, and biodegrade much more quickly with little or no residue at any point.

As part of that, some of those products may qualify for organic demarcation by various organic bodies. At the end of the day, from a regulatory standpoint, all pesticides--whether they're synthetic chemicals, natural chemicals, biopestide, or even some mechanical-type approaches--have to meet the world-class standards at Health Canada for health and safety. After that, if some consumers and/or some farmers choose to pursue organic production, then obviously that is their choice.

Our members are best known for our synthetic chemistries, for example, and our biotechnologies--the interesting enigma for me always is bacillus thruingiensis, which is very much an organic product that's okay for organic certification but also very much a useful tool in biotechnology--but although we're best known for synthetic technologies, our members on a global basis pursue the new technologies, whether they're biological or otherwise, in the name of pursuing better, safer products.

Peter, do you have anything to add to that?

[Peter MacLeod]

A number of the biological pesticides or organic pesticides that growers are looking for are part of this list of 135 we were talking about. There are a lot of these micro-use pesticides, and that is a problem. The U.S. market for biological and organic pesticides is larger than Canada's. It's the same for the conventional pesticides. But the PMRA has specific programs for this type of product that include reduced cost for submission and streamlined data requirements so these products can come to Canada.

It is in its infancy. These products are being developed. They're very high-tech, although organic--to have very precise biological control is a very scientific thing. But I believe there are programs in place to deal with these products. The trick will be to reduce barriers by utilizing the U.S. data evaluations, and have similar data requirements in Canada as for the U.S.

[Claude DeBellefeuille, Bloc, Beauharnois—Salaberry, QC]

Thank you.

Mr. Bartley, you stated that one solution would be to reduce the regulatory burden for producers. Could you tell me if there is a tendency to lower our standards so that they be harmonized with those of the Americans? Would we want to eliminate our regulations which may be more demanding for producers but might also be more compatible with our Canadian values? My fear is that in order to harmonize we would lower our standards in order to close the gap with the US.

Could you put my concerns to rest and tell me what is the position of producers?

[Christine Moran, Executive Director, Grain Growers of Canada]

That is certainly a question that needs to be answered. We're looking to work with the PMRA to ensure that we are addressing those issues. Obviously there are a number of stakeholder concerns, and we're addressing them strictly from the producer perspective. We're looking at the issue of access to products. We're looking at the question of cost to our producers as well, especially considering the economic and fiscal backdrop against which we're operating.

So we recognize that there could be concerns and there are a number of questions to address. However, we do see that for a number of them the solution could be greater harmonization.

[The Vice-Chair, Bloc, André Bellavance]

Thank you, you only have fifteen seconds left.

[Claude DeBellefeuille, Bloc, Beauharnois—Salaberry, QC]

Thank you, that's all I had.

[The Vice-Chair, Bloc, André Bellavance]

Mr. Anderson.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

I would like to clear up one thing here today. In the past when the PMRA came, I understood that even as late as 2003 and 2004 we had a tremendous backlog of products. This morning we heard that wasn't true, apparently. Now you're telling me there are 30 critical products in the pipeline that haven't been approved. Do we have a backlog or not, from your experience?

I guess this would be aimed toward Mr. Hepworth.

[Peter MacLeod]

I will take that. That's a difficult question.

What was commonly referred to as the backlog occurred at a time in the pesticide regulatory experience when a submission was received by the government, and because of various reasons, resources being one, it was not a complete package and they couldn't finish their evaluation, so it sat.

One of the things the PMRA did in the late 1990s and into 2000 was take those submissions and find out if they had enough information to make decisions on the products. If they did, they made the decisions; if they didn't, they were taken out of the system.

So the backlog was dealt with in two ways. If they had enough information they went ahead and registered the product; if they didn't they took it out of the system.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Do you have any idea of the percentage that went either way? What percent was approved, and what percent was just removed from the application process?

[Peter MacLeod]

I don't have those numbers for you. I do know that some of the submissions that were removed from the system have since come back in. When enough information was generated they came back into the system, but I don't have those statistics. Perhaps the regulatory agency could provide them.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

This morning Ms. Dodds talked about the goal of setting minor-use registrations, getting them down to six months. Is that realistic? Is that a good timeframe for you folks?

[Peter MacLeod]

The process we talked about earlier, looking at one package of data, having it evaluated, and using foreign evaluations, is a key part of that. Most, if not all, of these minor-use crops in this technology gap have been registered in the U.S., so they've had sufficient information to have the registration granted by the U.S. EPA. So critical to the process to get that speed down to six months is utilizing those evaluations and only picking up Canadian parts where it's absolutely critical. We recognize that we don't want to lower the standards of safety in Canada, so it's very important to make sure that we have similar standards, but to make sure that there's no additional data that's not absolutely critical to make that safety determination.

[Lorne Hepworth]

If I could add on to your question about the backlog, you referenced the 30, and just to put that in perspective, I don't know that it's part of the backlog. Those are the critically identified priorities they'd like to see into the system, if I understand it correctly.

[Peter MacLeod]

Those haven't been submitted. Those 30 that I was talking about, going from the 130 down to these priority substances that are in the U.S., are ones that are not even in the submission process in Canada. They're yet to be applied to the PMRA.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Apparently we're told that there aren't any backlogged. The ones that have been applied for have basically been cleared out of the system. Is that your understanding?

[Peter MacLeod]

The timeline for a typical new product is a year and a half, and the recent statistics I've seen that were presented this morning are in fact true from our perspective. About 90% of the time for these major new products and new evaluations, they are meeting the standard that they've prescribed of 18 months. For joint reviews, they're meeting them 100% of the time.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Okay. That's a big change from the past.

[Peter MacLeod]

It sure is.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

I just have a couple of questions about maximum residue levels, and I'd like your opinion on this.

I had a chance to go to Japan around Christmas-time, and they were bringing in some new regulations that covered a whole pile of products with some fairly onerous regulations. Do you see an international movement towards this? Do you see that as being positive or negative for producers, as well as for your industry?

I have another concern: that those don't end up being used as trade barriers in a new age.

[Peter MacLeod]

There is a system of global maximum residue limits through the Codex, through the FAO. Unfortunately, not every country recognizes that global standard, and in fact that global standard is sometimes not appropriate for each individual country because the use pattern is different.

Maximum residue limits is largely not a health or scientific process. It's really how the product is used in that individual country. So we promote a synchronous MRL process between Canada and the U.S. and our major trading partners so there are not barriers to trade. It is an unfortunate area that can sometimes creep in where there is a maximum residue limit that would create a barrier. I believe we need to look at this from a global perspective to make sure it doesn't happen.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

One of the problems seems to be if you've got, as we talked about earlier, different residue goals in different areas, climatic or geographic, then you always end up picking the strictest one as a standard, and that means everybody has to apply it, and that can get to be a problem in the long run.

I was going to ask you, do you consider 2,4-D to be a safe herbicide?

[Lorne Hepworth]

I can lay in on that one. The 2,4-D molecule is one that has been used by farmers for—I'm guessing—60 years, as a first point.

As a second point, it's probably the most exhaustively studied and restudied and tested and retested and evaluated and re-evaluated molecule in the pesticide industry. Although a final report on yet another re-evaluation of that molecule is pending here by PMRA in Canada, in their own words when they released their preliminary assessment a few months ago, 2,4-D when used only according to label directions can be safely used.

The EPA, Europe, virtually every international highly reliable regulatory community has weighed in on this one. So if we say it can be safely used if used according to directions, not only can we speak with confidence relative to the Canadian situation, but we have the advantage of all of these other very stringent regulatory agencies that have also weighed in on this molecule, because it is one that's used globally.

I could further go on to say that it doesn't matter whether it's this molecule or any other molecule, farmers and our industry have no interest in putting products in the marketplace that are unsafe to human health or that would propose an unacceptable risk to human health or the environment.

If international, peer-reviewed, legitimate science demonstrated that there is an unacceptable risk, the farmers, we as the industry, and for sure the regulators would want that risk managed, and if that meant eliminating the use or eliminating the product, that's the way it is. That's the commitment I think we've had and that's the track record of safety this industry enjoys.

I would make that comment relative to 2,4-D or any other of the 6,000 registered products we have here. It's to ensure this that we have re-evaluation, so that an old molecule, so to speak, meets the new tests of the new science. That's why we're willing go through these re-evaluations, so that the public can be assured, whether it's a homeowner or a farmer who's using it, or a public health authority that's using it.