With regard to emergency registrations, the Association des producteurs maraîchers du Québec proposes a two-step process. There is the current emergency registration process, which is useful because it allows us to operate even when there are very long delays for normal registrations. In cases where a product that has not yet been registered is needed quickly, emergency registrations can be used. In fact, this is necessary.
For real emergencies that require very rapid action, we need an expedited emergency approval process. This process would allow a product to be used in a very specific geographical area for a period of 48 hours, for example. After that, this type of registration would no longer be valid. This type of registration would be used for a very specific period of time and geographical area, allowing for a rapid response when significant problems arise.
We are also asking for the regular emergency registration process to be improved. For example, one of the proposed changes would be to no longer have to go through the provincial environment ministries. This is one of the requests made by the PMRA. Currently, whenever there is an emergency registration request, a letter must be obtained from all the provincial environment departments concerned, which can take time. Usually, there is no problem: The departments always respond positively to our request because they rely on the Quebec Ministry of Agriculture, Fisheries and Food. In our opinion, this process adds no value and only lengthens the time frame. It would be useful to review the overall process. These are the most important elements we propose.
In terms of transparency, it is very difficult for us to know what is happening with minor-use registration applications. We do not know what stage of the process they are at, how far along they are, or how long they have been there. If we were able to track these applications and understand where they are in the process, it would help us better understand why the delays are sometimes so long. We are often told that it is for commercial reasons or because it takes time for the data to be transmitted from the manufacturer to the PMRA, for example. That is understandable, but, as far as possible, we could be told.