No, I didn't say—
Evidence of meeting #49 for Health in the 41st Parliament, 2nd Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was pmra.
A recording is available from Parliament.
Evidence of meeting #49 for Health in the 41st Parliament, 2nd Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was pmra.
A recording is available from Parliament.
4:30 p.m.
Vice-President, Government Affairs, Chief Executive Officer, Farmers of North America Strategic Agriculture Institute, Farmers of North America
When I mentioned sustainability, that dealt specifically with the mandate of the act, which talks about sustainable pest management strategies. Let's remember one thing. I mentioned one product earlier. It's Folicur. Folicur is a crop protection product used to prevent a fungus in grain. The layman's term for that fungus is “vomitoxin”. If anybody eats that grain.... Or in fact, I've seen it impact on people in dust; just from using the straw from that wheat, the dust will also affect people adversely.
The question is, should we be using a pesticide on this product? Well, of course. I mean, part of the risk cup analysis on that should be, what's the impact on humans if that fungus is in the grain? What's the impact on humans if that crop protection product is being used? So by “sustainable crop protection strategy” or “sustainable pest-management strategies”... it includes all of that. You can't take one and not use the other.
This is about crop protection products that pose the least risk to human health and safety as possible, but then this is also about providing farmers with a lower-cost product, products that are already in the market—so again, it's not a health and safety issue—so that they can be economically sustainable as well when they produce foods.
4:30 p.m.
Conservative
The Chair Conservative Ben Lobb
Thank you very much.
Just so that everybody knows, there are blues that come up for each meeting, and so if anybody wants to correct the record, they have the opportunity to do it. I don't believe Mr. Bennett said that, but we'll give everybody the chance to go through the blues and make sure that what they said is in fact what they said.
We're going to suspend for a minute and come back with our next group and get right at it.
4:30 p.m.
Conservative
The Chair Conservative Ben Lobb
Welcome back. We're going to try to keep on track here as best we can.
Mr. Gage, we'll have you go first while our technology is in working order, and then we'll go to our guests who are here in person.
Go ahead, sir; you have 10 minutes.
4:30 p.m.
Andrew Gage Staff Counsel, West Coast Environmental Law Association
Thank you very much for having me and for the opportunity to speak to the review of the Pest Control Products Act.
Since I began working at West Coast Environmental Law in 2001, I've had the privilege, among other projects, of working with groups of farm workers and the organizations that work with them and speaking with them about their exposure to pesticides. It's been said that the measure of a society is how well we treat the most vulnerable among us. With that in mind, I'd like to focus my presentation on what the Pest Control Products Act says about farm workers and how we protect them.
I should emphasize that I think many aspects of the act in general are sound, but I will be touching on some specific concerns around how the act and the implementation of the act have perhaps not protected farm workers as well as they should. I'm going to make four points.
First of all, the Pest Management Regulatory Agency makes unrealistic assumptions that the pesticide labels are fully complied with when it evaluates the impact of pesticides on farm workers. Second, there are some cases where there's been undue delay in putting in place protective measures for farm workers during the review process. Third, the PMRA does not currently consider the combined exposure from occupational exposure and non-workplace exposures when it evaluates the risks of pesticides for farm workers. Fourth, farm workers and others would benefit from increased public disclosure of data related to pesticide use in Canada.
On the first point, the assumption of 100% compliance, the PMRA relies very heavily on pesticide labels as a means of controlling exposure to otherwise dangerous products. Subsection 2(2) of the act allows them to take into account the conditions or proposed conditions of registration, but as I understand it, the PMRA interprets that section as allowing it to assume that all the requirements of the pesticide label will be fully complied with, which is perhaps an unrealistic assumption, and certainly, we believe it is an unusual assumption.
The Pest Control Products Act was developed after extensive consultations by the Standing Committee on Environment and Sustainable Development, resulting in their “Pesticides: Making the Right Choice” report. At that time, the committee wrote:
The use of pesticides should be investigated to determine whether end-users comply with label instructions. This will enable the PMRA (and indeed the government in general) to determine whether they can continue to rely on product labels as a key risk management tool.
That research has not occurred. The PMRA still does not know what level of compliance actually occurs on the ground in terms of those labels, yet they rely on them very heavily, assuming full compliance with them in determining whether there is a risk to workers' health and to the environment. It's our view that likely there is non-compliance occurring. The conditions that appear on pesticide labels are often fairly complicated, even for Canadians who actually read French and English.
A 2008 report, “Health Literacy in Canada”, highlighted that about 48% of Canadians have trouble understanding complicated written instructions such as those that appear on pesticide labels. Given that the pesticide labels are available only in English and French, there's even less basis for assuming compliance when we're talking about farm worker communities that may be predominately Spanish, such as the Mexican workers, or who may be Punjabi-speaking, such as occurs in much of the Fraser Valley.
Second, we know from talking with farm workers that they believe they're being exposed to pesticides, and there is some evidence from those conversations that label conditions are not always being complied with. Our own research was done around 2005 and involved two focus groups—relatively small groups—and a survey of 73 Punjabi-speaking farm workers.
We didn't have a lot of information about which specific pesticides were being used, so it was not possible to say conclusively whether the labels were or weren't being followed. However, there were some very suggestive results. Of the workers who reported applying pesticides, 30% reported that their employers had never provided them with any type of safety gear, and 64% of all the farm workers we surveyed reported having experienced some type of symptoms that were consistent with some level of pesticide poisoning. We gave them the various symptoms and asked them to rank whether they associated them with their use of pesticides.
Even when farm workers were provided with safety gear, they reported that they often did not use it. A more recent academic report involving surveys and a series of interviews with farm workers in the Fraser Valley in 2010 found very similar results.
In general, the PMRA has no actual evidence about what level of compliance is occurring in these communities. Therefore, this type of anecdotal evidence I think needs to be given some weight. The PMRA can, of course, take into account what's on the pesticide labels, but they certainly should not be assuming that they will always be followed.
Second, with regard to re-evaluations and farm workers, we know that the re-evaluations that occur can be very slow and that they can fail to provide interim protections for farm workers during that long many-year process, even where health risks are identified. A startling example of that is the review that was done of endosulfan. The re-evaluation started in 2002, and it wasn't until eight years later, in 2010, that the PMRA recommended the phase-out of the pesticide because of identified health concerns to the environment and to human health. Their recommendation came roughly two months after the U.S. Environmental Protection Agency had announced that it would be phasing out the pesticide.
The important thing here is that in 2004, two years into the process, the Pest Management Regulatory Agency proposed interim measures that were specifically intended to protect farm workers, because they had already identified that there were some health issues in play, but those interim measures were not implemented until five years later, in November 2009. Obviously a five-year delay in implementing protection for farm workers is troubling, but it doesn't appear to be completely atypical, even though the PMRA emphasizes that the endosulfan review was unusually complex. We're told that of 15 reviews where they proposed this type of interim measure, it took on average three years from when the measures were proposed to when they were actually implemented. In one case it took as long as seven years.
In our submission, where there is a potential risk to the health of farm workers, the PMRA must act with all haste to either confirm the risk or to implement protective measures that will actually ensure farm worker health.
Third, in terms of the risk assessment, the PMRA does not currently consider the workplace exposure of workers in combination with the non-workplace exposure. They interpret this as being the result of sections of the Pest Control Products Act that require them to consider aggregate exposure from non-occupational sources. But if you don't consider the two together, you're not adequately modelling and assessing the risk to one farm worker who does of course experience these exposures in both the workplace and when they're home, and who usually lives in an area subject to higher non-occupational exposure through drift, through contamination of water, and through other measures that are associated with living near or on farms. So we recommend that the word “non-occupational” be removed from the relevant sections of the Pest Control Products Act.
Finally, since 2006 the pest control products sales and information reporting regulations have required their registrants to report how much of each pesticide they've sold by province. The PMRA generates some general reports about trends and aggregate amounts of pesticides used in Canada, but the data itself is not available to Canadians. By contrast, several U.S. states provide full disclosure of what pesticides are used where, and often down to the county level. This allows groups working with farm workers and other vulnerable groups to have better information to inform and better protect farm workers.
In conclusion, the Pest Control Products Act was meant to take a precautionary approach and adopt strong protection for the environment and human health. As for farm workers, it has not yet lived up to its potential.
Thank you.
4:45 p.m.
Conservative
The Chair Conservative Ben Lobb
Thank you very much, Mr. Gage.
Next up is Ecojustice Canada.
You have ten minutes. Thank you.
4:45 p.m.
Lara Tessaro Staff lawyer, Ecojustice Canada
Thank you, Mr. Chairman and committee members, for the opportunity to appear before you in your statutory review of the Pest Control Products Act.
My name is Lara Tessaro. I am a staff lawyer with Ecojustice Canada. With me is my colleague Tanya Nayler, also an Ecojustice staff lawyer. Not with us today is our senior staff scientist, Dr. Elaine MacDonald. She is our scientific expert on pesticides and environmental health.
I should give a few quick words about Ecojustice. We are Canada's largest public interest environmental law organization. We have offices in Vancouver, Calgary, Toronto, and also here in Ottawa at the University of Ottawa. We are dedicated to defending Canadians' right to a healthy environment, and we do that by regularly advocating in court. We also work outside the courtroom to promote stronger environmental laws that protect the environment. Tanya and I also have the privilege of working with some of Canada's leading environmental groups on pesticides. I should note that our clients on federal pesticides matters include the Western Canada Wilderness Committee, the David Suzuki Foundation, and Équiterre.
I will note a few of the things we worked on together. We brought successful litigation against the agency in Federal Court, which forced the agency to comply with its duties to initiate 23 special reviews of active ingredients that are banned in the European Union for health or environmental reasons but are allowed and registered here. Those reviews are under way. As a second example, we jointly submitted a notice of objection with the Canadian Environmental Law Association objecting to the continued registration of clothianidin products. Mr. Bennett of the Sierra Club is involved in that as well. As he's already referred to it, I'll try not to repeat his remarks.
Overall, in our view this act is sound and is valuable. If the act were actually implemented properly by the agency, if it were implemented in a precautionary manner, then we think the act could achieve its primary objective. As I'm sure you all know, there is just one primary objective in this act: preventing unacceptable risks to people and the environment from pesticide use.
The Sierra Club has put before you some recommendations for legislative amendments. Generally we don't disagree with them—we think they're generally good recommendations—but Ecojustice's basic position is that at the present juncture, no significant or major amendments are actually required to this law. That being said, I don't want to suggest that the act is working as it should be working. It is not working as well as it should be working. Therefore, to assist the committee, we've identified three areas where we think some minor amendments may improve implementation and better protect Canadians' health.
I'll just run through those three areas, which are, I should note, in our written brief. We did not have it translated in time. We have it here in English, so I assume the brief will be provided to you in English and in French in the coming day or two.
The three areas that we would propose for minor amendment are conditional registrations, which you've heard something about, public consultation, and transparency.
l would like to illustrate our concerns with an example, which is in our brief as well. As I noted, we have made an objection to the renewed conditional registration of clothianidin products due to concerns that these products may significantly harm bee populations. You might understand our surprise, then, when we learned that after receiving our objection, the agency has, in a non-public manner, continued to register entirely new uses of those same clothianidin products that are under objection. They did that with no public notice and with no opportunity for public comment. We only learned of those new uses because the agency indirectly referenced them in a document proposing new maximum residue limits for the newly registered uses of those products.
I want to be clear that clothianidin is perhaps the most controversial pesticide in Canada right now. So while it's under objection, wide objection, the agency, as you heard from Mr. Bennett, is delaying its response to those objections—it's a year and a half now—and yet it is nonetheless secretly, and quite widely, expanding the use of the pesticide under objection.
With that example in mind, I'll turn to our three recommendations.
The first issue we'd like you to consider is the agency's overreliance, as we'd characterize it, on conditional registration. As you know, section 12 of the act—quite appropriately, actually, in my submission—allows the agency, as a condition of a product's registration, to require registrants to produce more information. lt's a really common-sense provision, but it's been heavily overused. That was the finding in a 2008 audit by the Commissioner of the Environment and Sustainable Development, which found that the agency had made, and this is its term, “unsatisfactory” progress in remedying its heavy use of conditional registrations.
It's an especially overused practice for neonicotinoids. As of 2014, the majority of conditional registrations in Canada are for products containing three notorious neonic ingredients: clothianidin, imidacloprid, and thiamethoxam. For neonic products containing these three ingredients, the agency's widespread practice, as you've heard, is to allow them to be registered despite expressly acknowledging that there are critical data gaps on bee health. That is the definition of not precautionary.
The Environmental Protection Agency in the U.S. has also been audited over similar concerns with conditional registration. As a result, the EPA now publicly tracks conditional registrations online. The EPA reports conditional data requirements. It reports when the data that is missing is due, when it's been received, and whether conditions are being complied with. Canada, in contrast to the U.S., does not publicly track conditional registrations.
Our first, I'd say, quite modest recommendation is that section 42, regarding a public repository of information, should be amended to require that the electronic public registry include the same information about conditionally registered pesticides that is publicly accessible in the United States.
The second issue we hope the committee will consider is a need to improve and increase public notice and consultation, under section 28. In theory, section 28 is a good provision. In theory, it requires the public to be notified of and consulted on many pesticide registration decisions, but in practice the agency excludes the vast majority of registrations and the vast majority of amendments to registrations from any public notice or consultation. How does the agency justify this? The problem is not with the act. The problem is with sections 14, 15, and 16 of the pest control product regulations. In general, those three sections purport to exempt most conditional registrations and most amendments to conditional registrations from three things: public notice and consultation, the right of the public to file any objection, and certain transparency obligations.
The second reason for this practice of conditional registrations has to do with an agency policy. It's a submissions policy. The agency policy deems certain categories of registration applications to be minor, and you heard the executive director very carefully refer to how broadly they consult on major applications. The majority of applications are deemed by this policy to be minor applications, and the policy then purports to exempt from public consultation and notice all allegedly minor registration decisions. It does this without any regard for the particular pesticide at issue and how risky it might be.
Our second recommendation is simple: The committee should recommend repealing sections 14, 15, and 16 of the pest control products regulations.
The third issue we'd ask you to consider is one you've already heard a lot about this afternoon and that is the transparency and accessibility of the electronic public registry. Section 42 of the act requires the agency to include certain information in the electronic public registry. In practice, the information required to be there is not always there, and when it is there, it is extremely difficult, as Mr. Bennett noted, to search. It's a very difficult tool for the public to use. I would actually encourage—maybe it's better to say I'd dare—you members of this committee or your staff to try to use the electronic public registry. Try to use it to answer a question you have about a pesticide regulation or a general practice. I have a couple of examples of that, but in the interest of time, I'll leave them for any questions people may have.
Our third recommendation, which is a modest one, is that you add a provision to the act simply requiring the agency to audit the accessibility and completeness of its electronic public registry.
In closing, I will emphasize again that this act has strong potential to protect Canadians' health and to protect our environment. It needs to be implemented in a precautionary and transparent way, and we hope that message comes through in the committee's report.
Thank you, all, for your attention.
4:55 p.m.
Conservative
The Chair Conservative Ben Lobb
Thank you very much.
Next up is Environmental Defence Canada.
Ms. MacDonald, go ahead.
4:55 p.m.
Maggie MacDonald Toxic Program Manager, Environmental Defence Canada
Thank you for this opportunity to address the committee and appear before you in your statutory review process.
Environmental Defence has been conducting research and public education on the issue of toxic pollution in Canada for over 20 years. In addition to writing reports on substances of concern and their impacts on human health, we are active participants in the stakeholder advisory council of Canada’s chemicals management plan. We monitor emerging issues regarding potential threats to human health and environmental health. Our mission is to challenge and inspire change in government, business, and people to ensure a greener, healthier, and more prosperous life for all.
In order to assist members of the Standing Committee on Health with their review, we have prepared a short brief on the Pest Control Products Act. We were late as well in submitting our documents for translation. They will be provided to you once the translation has occurred. Please excuse us for that.
The primary purpose of the Pest Control Products Act is to “protect human health and safety and the environment by regulating products used for the control of pests”. Environmental Defence views the act as an important piece of legislation, and it is also our view that significant amendments to the act are not currently needed in order to achieve the stated purpose of the act. However, to that end, we have identified an area in which the implementation of the act may be improved by the Pest Management Regulatory Agency.
Environmental Defence has some concerns with the implementation of the act with regard to the process of conditional registration, a theme you're hearing a lot about today. In this process, regulators allow for the pesticide registration to proceed, conditional on missing data being submitted at a later date. It is important for the PMRA to have the ability to apply conditions to registration. The concern is not with conditional registration in general, but rather with the renewal of registration when the conditions originally applied are not met within the allotted time.
In the preamble to the act it states that “pest control products of acceptable risk be registered for use only if it is shown that their use would be efficacious and if conditions of registration can be established to prevent adverse health impact or pollution of the environment”. A lack of evidence of risk is not the same thing as evidence of no risk. Where data is lacking regarding the safety of a pest control product, there is the potential for pollution of the environment to be occurring. To prevent this from arising, research must be conducted to demonstrate the safety of a given product.
Conducting sound research does take time, and it is possible that in some cases requests for extensions may be made in light of challenges in gathering that data. But reasonable limits must be set in order to prevent pest control products from inflicting damage on the environment, and potentially the greater food web, and harming insect species on which we rely, all while we wait for more data to be provided.
This remains a central problem within the neonicotinoid pesticides—neonics for short—that are implicated in large-scale bee deaths. Controversy about bees has sometimes been described as a matter of opposing views, or as a communications issue, but public concern is merited when pesticide registrations are being approved based on incomplete science. The PMRA itself has referred to the lack of chronic toxicity studies in bees as a critical data gap, and yet, to the present, they have given conditional registrations repeatedly for neonics.
Regulators in other jurisdictions have made different judgments about the safety of neonics and have created prohibitions on these chemicals. Based on a review of currently available evidence, the Government of Ontario found sufficient cause for concern that restrictions on neonics are now being planned in this jurisdiction. A Government of Ontario document entitled “Pollinator Health: A Proposal for Enhancing Pollinator Health and Reducing the Use of Neonicotinoid Pesticides in Ontario” provides an overview of the issue, including references to studies that underline the risks posed by these pesticides and an overview of the provincial government's proposed plan.
The risks associated with neonics are well documented. In the Standing Committee on Health session dated January 27, 2015, Mr. Aucoin, executive director of the PMRA, stated, “In the context of neonics, first of all, globally there is a concern for pollinators and the troubles that pollinators like bees are having in terms of population declines....” Mr. Aucoin cites several factors as the basis for this concern, such as climate change, pests, and diseases. He also stated that, “Within Canada itself we have had some bee mortality incidents with neonics”, while specifying that they have been restricted to soybean-growing regions of Ontario and Quebec.
Health Canada’s PMRA investigation found that 70% of dead bees “had neonicotinoid residues present, while the majority of live bees did not have residues present. The weight of evidence indicated that exposure to neonicotinoids during the corn and soybean planting period contributed to bee mortalities in 2012 and 2013”. The Environmental Commissioner of Ontario, in the 2013-14 annual report, found that “there is now clear evidence that acute exposure to neonicotinoid-contaminated dust is linked to mass bee deaths” and the PMRA’s investigation into the 2012 and 2013 bee kills in Canada concluded that neonics were a contributing factor in many cases. Accordingly, in 2013, the PMRA declared that “current agricultural practices related to the use of neonicotinoid treated corn and soybean seed are not sustainable”.
While some stakeholders may assert that further investigation should be undertaken before decisions regarding the use of neonics in Canada are made, evidence of harm is mounting. In accordance with the precautionary principle, steps should be taken to prevent further harm.
The fact remains that over 10 years ago there were critical data gaps. They are still not addressed. These products are still in use despite registration having been granted on condition that these gaps would be addressed. The deadlines have come and gone, and yet these products remain.
We recommend that the requirements for renewal of conditional registration be re-examined in order to prevent products for which inadequate safety data—for example, chronic toxicity data—is available from polluting the environment and causing undue harm to pollinators and other species.
In the January 27 session of the Standing Committee on Health, Mr. Aucoin described the PMRA’s process as being based on “rigorous scientific risk assessment, both for human health and for the environment”. He said, “We take a completely science-based approach to our decision-making. It's based on a foundation of data and information requirements that spans literally 200 studies or more.”
Environmental Defence supports this rigorous, science-based approach. But where data is lacking, there ought to be a deadline imposed that is enforceable, in the spirit of the preceding statement by Mr. Aucoin, if it is to be upheld.
The Pest Control Products Act is a key piece of legislation for the protection of human health and the environment, and improvements to the management of pest control products and prevention of pollution have, no doubt, occurred as a result of the act. Environmental Defence submits this brief regarding the implementation of conditional registration in the spirit of seeing the purpose of this important act fulfilled thoroughly and effectively for the benefit of all Canadians.
Thank you for the opportunity to present. l welcome your questions.
5:05 p.m.
NDP
Murray Rankin NDP Victoria, BC
Thank you to all the witnesses for their very thoughtful presentations.
I'd like to start with Mr. Gage, not only because he's from my hometown but also because he's with an organization I chaired for many years and am very proud of. Thank you.
You made so many points in so little time. I just want to start with your risk assessment point.
You said the law doesn't consider both workplace exposure and non-workplace exposure. I think this was your third point. You thought the word “non-occupational” should be removed from the statute because it doesn't take into account people who have exposure both at home and in the workplace. Do I have that right?
5:05 p.m.
Staff Counsel, West Coast Environmental Law Association
That's it in essence.
I should have mentioned that I also did not get my full written submissions in on time for translation. They are with the committee now, so presumably you'll get them. I have a more detailed discussion there of the PMRA's approach.
As I understand the PMRA's position, there is a specific requirement for them to:
consider available information on aggregate exposure
—that's the exposure of all the different ways someone comes into contact with a pesticide—
to the pest control product, namely dietary exposure and exposure from other non-occupational sources.
They interpret that section as meaning the aggregate exposure assessment is focused on non-occupational sources of exposure.
When we asked them about this, they said that at the time the act was drafted, in 2006, methodologies actually didn't exist to combine workplace exposure with aggregate non-workplace exposure. The methodologies are in the process of being developed now.
From our point of view, if you can determine—thanks to your label conditions—that the workplace exposure of a worker is just below what you consider to be a safe level for the pesticide to be approved, and you then ignore a small amount of non-workplace exposure the person comes in contact with as well, you've really missed the opportunity for a more precautionary approach.
5:05 p.m.
NDP
Murray Rankin NDP Victoria, BC
Thank you.
I'll go to a point that was made by you and Ms. Tessaro of Ecojustice and is very upsetting.
You mentioned, if I'm understanding you properly, that the regulations are.... Data is simply not available to Canada, you said, but full reporting is available to the United States in helping farm workers, for example, have access.
Ms. Tessaro, you suggest that section 42 be amended to require, if I'm understanding you, the same information that's available in the United States.
Essentially, if this is true, this lack of consistency and access to information on this, if your testimony is correct, certainly should be very disturbing to us.
5:05 p.m.
Staff lawyer, Ecojustice Canada
I'll let Andrew respond in a moment, but I just want to be clear about section 42. It does have numerous paragraphs that require numerous types of information to be provided to the registry, so I wouldn't want to suggest or to be understood to suggest that there aren't transparency mechanisms in place.
The provision that I was referencing about the EPA is very specific to conditional registrations. That's the piece the U.S. has that we don't have. Effectively, they require reporting on whether conditional registrations are being complied with. That's as a result of something analogous to our federal Auditor General doing a report of the EPA—
5:05 p.m.
NDP
Murray Rankin NDP Victoria, BC
The fact remains that there's less information available in Canada in this context than there is in the United States.
5:05 p.m.
NDP
Murray Rankin NDP Victoria, BC
Mr. Gage, you were suggesting that regulations should be amended to a similar effect. Do I have that correct?
5:05 p.m.
Staff Counsel, West Coast Environmental Law Association
More or less. The examples I was speaking to were not U.S.-wide. It wasn't the U.S. EPA. It was particular states in the U.S. They have very detailed information on where and how pesticides are being used.
The PMRA already does collect data at a provincial level about what pesticides are being used and they do generate some general reports on that, but for anyone wanting to drill down to a more detailed level, the data isn't available.
5:05 p.m.
NDP
Murray Rankin NDP Victoria, BC
In the interests of time, Mr. Gage, I want to go back to Ms. Tessaro. I only have a tiny bit of time and so many points remain.
As I understand it, you said that you believe the public registry should have an audit by the agency of how it is going, because you dared us to actually try to find something on it, and I've heard that from many people.
Shouldn't such a review be at arm's-length to the agency? It's the agency that set this up. Why would you have the agency do its audit?
5:10 p.m.
Staff lawyer, Ecojustice Canada
That's a fair comment. Again, I don't want to suggest that the agency posts no information. I don't want to be unfair to the agency. They do post some kinds of information.
Of the kinds of information that are missing more systemically, as I alluded to in my oral comments, there are two kinds of information that are particularly concerning.
There's a requirement in the act for the agency to publish to its register and its electronic registry the information that registrants rely on in support of their applications, but you generally cannot find that unless you're one Canadian lucky enough to live in Ottawa who can go to the reading room.
The second kind of information that's most often missing, and Mr. Gage referred to this—
5:10 p.m.
Conservative
The Chair Conservative Ben Lobb
I'm sorry. We have a point of order.
You can continue your thought. It's just that we have a point of order.
5:10 p.m.
Conservative
Eve Adams Conservative Mississauga—Brampton South, ON
On a point of order—and Mr. Rankin, this is not to encumber your time, but just so you're aware—we're required by statute to conduct the statutory review of this legislation. This will come forward over and over again. That's not to say that we ought not to perhaps have an independent third party review, as you may be suggesting, but just so you're aware, that's why this is before us today at committee.
Thank you.