Madam Chair and honourable members of the committee, thank you for the opportunity to appear before you today on behalf of CropLife Canada.
My name is Pierre Petelle. I'm the president and CEO. I'm joined by my colleague, Émilie Bergeron, who is the vice-president of crop protection.
CropLife Canada represents the developers, manufacturers and distributors of crop protection products and plant biotechnology innovations. Our members invest heavily in research and innovation to provide Canadian farmers and others with the tools they need to manage pests, protect crops and improve productivity.
We're here today to speak specifically to division 13 of part 4 of Bill C-31, which proposes important changes to the postmarket regulatory framework for pest control products. CropLife Canada supports these amendments. As Émilie explained to the Senate agriculture and forestry committee last week, we see this as an important opportunity to modernize Canada's pesticide regulatory system by moving away from automatic, time-based re-evaluations and toward a more targeted science- and risk-based approach.
I want to begin by addressing an important point of clarification. Bill C-31 does not eliminate postmarket oversight. It simply changes how that oversight is triggered. Under the proposed amendments, the minister must initiate an assessment no later than 15 years after the relevant decision or previous assessment. That assessment must consider available information and determine whether the health or environmental risks associated with the product have increased significantly. Where there are reasonable grounds to believe they have, the minister must initiate the re-evaluation.
It is not accurate to characterize the bill as simply removing re-evaluations or ending continuous oversight. What changes is the relationship between the passage of time and the regulatory response.
Today, the statutory clock itself triggers a re-evaluation every 15 years, regardless of whether new evidence indicates that circumstances have materially changed. This approach has contributed to a growing backlog, longer review timelines and significant demands on regulatory resources.
Instead, Bill C‑31 would require the regulator to look at the available evidence and determine whether a significant increase in risk warrants a full re-evaluation.
This is not less science; it's a more targeted use of science.
Most importantly, the legislation does not create a regulatory vacuum between assessments. The Pest Control Products Act continues to provide the regulator with authorities to respond to new information and emerging risks.
Bill C‑31 also maintains transparency requirements by requiring publication of the minister's determination that there are reasonable grounds to believe risks have increased significantly, along with the reasons for that determination.
CropLife Canada has consistently called for clear, transparent and consistently applied criteria for determining when a significant increase in risk warrants a re-evaluation. We also believe Canada should make appropriate use of assessments and regulatory decisions from trusted peer jurisdictions. Where leading regulatory authorities have reviewed a product and continue to permit its use, that information should form part of Canada's assessment of whether circumstances have materially changed.
There is another important point. The objective of regulatory modernization should not be to conduct more reviews simply because a statutory clock has expired. The objective should be effective regulatory oversight that is proportionate to the evidence and the level of risk. That distinction matters to farmers, regulators, innovators and, ultimately, Canadians.
We also see value in the provisions that allow the pesticides regulatory directorate to better coordinate re-evaluations with special reviews. These provisions can reduce unnecessary duplication and allow regulatory resources to be focused where they are most needed. This is particularly important given the Government of Canada's broader objective of reducing regulatory backlogs and improving the timeliness of Canada's regulatory system.
Finally, the implementation of Bill C-31 should be considered alongside the important changes already made to the PRD's mandate through Bill C-30. As Parliament has recently recognized, protecting human health and the environment remains paramount, while Canada's pesticide regulatory framework also has an important role to play in supporting national and regional economic security and food security.
For CropLife Canada and our members, these objectives are complementary. Canadian farmers need access to effective crop protection tools. They need confidence that those tools are rigorously assessed, and they need a regulatory system that is timely, predictable and science-based.
We encourage the committee to support these amendments. Thank you very much for the opportunity.