Agriculture committee  I'll let Paul answer that first.

Agriculture committee  On the broader question of data for this summer, trying to tease out some of the water monitoring obviously takes a season or more to do. It is here that we've asked for some flexibility on the timelines.

Agriculture committee  As an industry we advocate for working together or harmonization, so, like I said on the front end, we've achieved a lot. On the re-evaluation side, on the older chemistry, there's still a lot of work to do. Richard pointed out the timelines. Some of the timelines are statutory, so it's hard to play with those, but wherever possible, absolutely, aligning those re-evaluation decisions and coming up with approaches and proposals that are consistent for growers in Canada and the U.S. is something we always advocate for.

Agriculture committee  You'll note that even in his testimony, Dr. Aucoin mentioned possibly 100,000 submissions. For a typical PMRA re-evaluation, if you get 30 submissions, that's a lot of interest. It's the registrants and maybe a few academics. It's a very technical area. A possible 100,000 submissions means that 99,000 of those are activist-based “click and send”, as I said in my testimony.

Agriculture committee  Maybe I'll just touch on that alternatives question because we hear a lot about that, that as long as there are alternatives, the impact on growers will be minimal. It goes back to what I said earlier. If the regulatory environment is questionable or if the companies are at a fundamental disagreement on the science with the regulator, the ability for them to bring new innovations to Canada will be diminished over time, without question.

Agriculture committee  For this specific active...?

Agriculture committee  We're certainly entering into it with that belief. We've put a lot of human resources into the working groups, as have other agriculture stakeholders. We're taking it seriously, and we're putting in the time and effort with the belief that the outcome of that could affect the decision.

Agriculture committee  I can touch on that one. I think the process is novel. To my knowledge, it has not been done for any other consultation in my time with CropLife. Should it have been done before the publication of the proposed decision? Absolutely. I think there's a lot of good work being done there, except it's being done on a very tight timeline.

Agriculture committee  Thank you, Madam Chair and members of the committee. On behalf of CropLife Canada and its member companies, we are pleased to have the opportunity to contribute to your study of PMRA's recent proposed decision on imidacloprid. I'm joined today by my colleague, Dr. Maria Trainer.

International Trade committee  We've begun informal discussions with the department, and I think they're open to finding a way to limit what we call the “belongs to” wording, the language we find problematic. That's why at the beginning I said if it's not this specific amendment, if it's something else that comes back from the department, we would be open to a discussion because there are more ways to get to what we need.

International Trade committee  It should help facilitate products that are coming through. We don't want Canada to be seen as a barrier to.... For example, if a company wants to use the Port of Vancouver—and the benefits that come from that to Canada—and then ship their products to a U.S. destination, we wouldn't want Canada to miss out on that opportunity and have that shipment diverted to a southern port.

International Trade committee  Yes, that's a possibility.

International Trade committee  I think the provisions to enable the trade and the changing of the definition of “package” is a good thing. We can't quantify—and haven't—what that could mean to our members. Each of the companies operates a little differently, so we haven't quantified what it could mean. The narrowing of scope of the label definition would keep it, as Shannon said, a little tidier.

International Trade committee  This provision, as far as we know, from what we've been paying attention to on this one, is to allow in-transit.... If you want to move an ingredient for a pesticide within Canada, currently the definition would require that it fall under the labelling provisions of the Pest Control Products Act as if it were going to be used in Canada.

International Trade committee  From our perspective it goes back to that label and the clear understanding from the end user that when we talk about that label what we're talking about is instructional directions and not marketing information. That's where we see the link with the end user—making sure that what we're all talking about is clear when we talk about a label, whether it be electronic or paper.