Thank you, Mr. Chair.
My name is Paul Doyon. I am senior vice president general of Union des producteurs agricoles, or UPA. I am also a dairy and field crop producer in Saint-Joseph-des-Érables in the Chaudière-Appalaches region.
My remarks will mostly focus on the Pest Management Regulatory Agency, or PMRA, and Health Canada. Their job is to ensure that registered pesticides, when used in compliance with the user instructions on the label, pose no risk to health and the environment and are effective in crop protection.
UPA appreciates the fact the PMRA’s opinions are independent. We’d like to highlight the agency’s efforts for transparency over the past few years to strengthen its capacity to monitor environmental and human health risks linked to the use of pesticides.
Last winter, Health Canada held public consultations on the regulations amending the pest control products fees and charges regulations, which propose to increase the annual charge payable by registrants. We think it would be prudent to have the large majority, if not all, of the post-market regulatory costs continue to be funded from public funds. This would lend the process credibility and help strengthen public trust in the regulatory system.
The fact is that the many issues farmers have raised for years, particularly delays in processing registration and reviewing pest control products, have not been addressed. These issues were highlighted when we had extreme precipitation in 2023. Situations like these can have significant economic consequences for farming businesses.
A responsive system is crucial, particularly now as climate change intensifies pest pressures and pesticide resistance continues to rise. We believe that more human and financial resources are needed to ensure the registration process reflects the realities of agricultural businesses.
We have seen the Red Tape Reduction Progress Report tabled by Health Canada and would like to reiterate the importance of being fully transparent in the ongoing process to maintain continued public confidence.
The proposed measure to expand international joint reviews for pest control products seems self-evident. Many pesticide standards already have international consensus. This approach would make Canadian agricultural businesses more competitive by allowing the registration of pest control products in all participating countries.
The proposed measure to ensure continuous oversight could result in reduced wait times and better resource allocation to respond to user requirements, particularly in critical situations.
We can’t comment on the proportional effort policy referenced because the details are not fully known and there has been no public consultation in relation to that.
On the surface, the proposed measure to modernize labelling appears to address our demands, including providing standardized information. Farmers rely on labels during phytosanitary preparation and treatment and so at a minimum, the information should be easily identifiable.
Admittedly, the current economic climate calls for regulatory reform and careful management of public funds, but these should not in any way come at the expense of the oversight body that we know as the PMRA, which we trust. The resulting red tape reduction must serve as a lever to enhance competitiveness and provide agricultural businesses, which contribute to the vitality of Canada’s economy, incentive to innovate.
This is all a step in the right direction. However, it’s hard for us to see concrete gains in the everyday lives of agricultural producers. Thank you.
