Thank you, Madam Chair, and good morning, honourable committee members.
My name is Bronwyn Roe. I'm a lawyer and the director of the healthy communities program at Ecojustice, Canada's largest environmental law charity. I appreciate the opportunity to appear before you today to highlight Ecojustice's concerns about the proposed amendments to the Pest Control Products Act in Bill C-31. I would also refer you to our written brief, which was submitted jointly with 19 other Canadian health and environmental organizations.
The proposed amendments would eliminate mandatory 15-year cyclical re-evaluations of pesticides and replace them with weaker assessments, relying only on available information and applying an undefined standard. Removing the mandatory requirement for cyclical re-evaluations would weaken federal oversight of pesticides and undermine the primary purpose of the act, which is to prevent unacceptable risks to health, future generations and the environment from the use of pesticides.
Re-evaluations are the primary mechanism under the act for comprehensive postmarket review of pesticide risks. Scientific knowledge and methods evolve, patterns of use change and long-term or cumulative harms may become apparent only over time. Cyclical re-evaluations provide a mandatory checkpoint to ensure that the health and environmental risks of registered pesticides remain acceptable based on up-to-date scientific evidence and methods and according to the standards set out in the PCPA. Re-evaluations regularly identify health and environmental risks that were not recognized in earlier risk assessments, leading to restrictions on the use of the pesticide, additional risk mitigation measures and, in some cases, cancellations to protect human health and the environment.
There are several weaknesses in the proposed assessment scheme in comparison to mandatory re-evaluations. For one, an assessment is limited to available information, and there appears to be no requirement for Health Canada to request or gather information. Emerging science about health and environmental risks could be missed entirely. In contrast, on a re-evaluation, the minister is empowered to request up-to-date scientific information from the registrant of the pesticide and from other federal and provincial government departments and agencies.
It has been suggested that the pesticides regulatory directorate's continuous oversight policy may answer this concern at least in part, but it's important to note that the continuous oversight policy was designed to complement and improve, not replace, re-evaluations. Continuous oversight is far from being fully implemented. Health Canada has initiated continuous oversight monitoring for only nine pesticide active ingredients out of over 650 registered active ingredients.
On a re-evaluation, Health Canada is required by the act to follow a scientifically based approach, to make a determination about whether the risks of a pesticide are acceptable based on the legal standard in the act, to consider aggregate exposures and cumulative health risks, to engage in public consultation on a proposed decision, to publish final re-evaluation decisions with reasons and to respond to any notices of objection that may be made. The proposed assessments have none of these requirements. Where it is determined that a re-evaluation is required, the additional step of an assessment prior to initiating a re-evaluation will almost certainly result in further delays of necessary risk mitigation.
These proposed amendments come at a time when pesticide use in Canada is rapidly increasing. Over the 20 years for which annual pesticide sales data have been available, pesticide sales in Canada have increased a staggering 453%, from 26 million kilograms of active ingredients sold in 2005 to more than 144 million kilograms in 2024. They also follow amendments to the PCPA that were passed this spring in Bill C-30, further weakening Canada's pesticide oversight. Combined, these amendments may make it more difficult for Canada to meet our international obligations in the Kunming-Montreal global biodiversity framework to reduce the overall risk from pesticides by 50% by 2030.
Cyclical re-evaluations are not just bureaucratic exercises. They are vital mechanisms for public transparency, for accountability and for scientific scrutiny. They ensure that Canadians have a voice in decisions that affect their health, food and ecosystems. I urge this committee to reject the amendments to the Pest Control Products Act in Bill C-31 and reaffirm Canada's commitment to strong, science-based pesticide regulation that Canadians can have confidence in.
Thank you.