Health Committee on May 28th, 2007

[Richard Aucoin]

There's no proposal to do that.

[Bonnie Brown, Liberal, Oakville, ON]

Okay.

If you're talking risk assessment on each and every pesticide on the market, it would seem to me that the 0.1 parts per million could be interpreted as using the precautionary principle, because it's a pretty stringent standard, is it not?

[Richard Aucoin]

The 0.1 parts per million was originally or historically established, I believe, based on the kinds of detection limits analytical equipment was capable of. So it would basically be able to detect any pesticide residues at all.

[Bonnie Brown, Liberal, Oakville, ON]

When you're talking about risk assessment, does this mean we're not using the precautionary principle, we're using risk assessment on everything?

[Richard Aucoin]

Our risk assessment approach essentially is the precautionary approach. It's inherent in everything we do. We do an extensive risk assessment—

[Bonnie Brown, Liberal, Oakville, ON]

I thought risk assessment and precautionary principle were sort of two different modes of operation.

[Richard Aucoin]

The risk assessment approach we take is essentially the precautionary approach. It's inherent in how we assess a pesticide, pre-market, before it's allowed for use or sale in Canada. It takes into account all the potential hazards that pesticide might pose, the kind of exposure that people might have, the environment, etc.

[The Chair, Conservative, Rob Merrifield]

Thank you.

Madame Gagnon, five minutes.

[Christiane Gagnon, Bloc, Québec, QC]

I would like to follow up on the issue of tolerance with respect to pesticide regulation.

On May 9 last, I directed two questions to the minister. According to his response, his government had not had any discussions of this nature and no change had occurred. I have here the minister's response to the effect that no agreement had been reached either with the US or with other countries and that the health of Canadians would be protected.

The minister's response threw us off a little. We were not too clear about what he was trying to say. You claim that some discussions did in fact take place further to NAFTA and that these talks are continuing. Some groups in Quebec and in Canada are very concerned, most notably the Coalition for Alternatives to Pesticides.

People ingest pesticides on fruits and vegetables. Apparently some residues pose a health risk. People often wonder what causes certain cancers, but what we ingest could also be responsible for the rapid rise in cancer rates.

Why consider allowing higher pesticide residue limits on certain fruits and vegetables? You are opening a door by saying that you plan to do a risk assessment. Canada and the US have a different climate. Why not close the door immediately? Otherwise, we will have to say yes to the US because of trade considerations. Since we already know that people's health could be at risk, why not adopt a zero tolerance policy?

[Richard Aucoin]

Thank you.

On your first point, with respect to what we've been saying about discussions within NAFTA, what we were saying is very consistent with what the minister has said. These things are under discussion. There have been no decisions reached yet, and there is in fact an international discussion, not just a discussion with the Americans. There are OECD countries and countries around the world that are discussing the potential trade issues caused by differences in pesticide maximum residue limits between countries and whether there is a possibility of harmonizing those pesticide residue limits or not.

We will absolutely not propose to do that if there is any chance of compromising human health on that issue, and we've been very clear on that. We're simply indicating that it is an international discussion; there are significant trade issues that are being discussed because of these residue limits. And we are asking if there is an opportunity or possibility to harmonize residue limits without compromising human health.

The goal, as you've said, should be to not increase pesticide residues on food. I absolutely support that. Health Canada supports that, and in everything we do we've been very clear that we actually support reduced pesticide use where possible. What we're discussing here are the actual residue limits on food and not the amount of pesticides that farmers are using. I think it's clear that there is a trend for farmers across the country and around the world to use less pesticide rather than more.

[Christiane Gagnon, Bloc, Québec, QC]

You maintain that for economic reasons, you are looking at ways of harmonizing maximum pesticide residue limits. We would like to see these limits lowered. Judging from what you are saying, harmonization will occur provided that limits are similar to ours or to the levels that we would like to see, that is the lowest possible. If you fail to come to an agreement because of the potential risk to human health, how would this decision affect the economy? Realistically, how would this affect exports of certain products?

[Richard Aucoin]

First of all, these discussions are still in pretty early stages. We started them a while ago, but there's still a lot of information we need in terms of the extent of those trade issues caused by differences in residue limits. At the end of the day, the health of Canadians is what is paramount to us, and we won't be changing our human health standards to accommodate changes in maximum residue limits of other countries. We do need to talk with these other countries, though, to understand the issue, and we'll certainly not be making any changes without the benefit of good science and without the benefit of consulting with Canadians first.

[The Chair, Conservative, Rob Merrifield]

Thank you very much.

Mrs. Davidson.

[Patricia Davidson, Conservative, Sarnia—Lambton, ON]

My first question is to Ms. Watts.

In your presentation to us you talked about the commission's requiring a claimant to submit full documentation in support of the claim. You outlined three instances: when the affected party makes a submission to the commission; when the claimant's declaration has been selected for verification as part of the commission's verification process; or, thirdly, when the screening officer has reason to believe that the information may not be accurate. Could you elaborate a little more on that last instance, please, when you're talking about information that may not be accurate? What would lead the screening officer to believe there may be reason to think it wasn't accurate, and what process would lead up to this?

[Sharon Watts]

Thank you for the question.

We can go back to the elements within the act that allow for verification. We spoke about the need to verify this declaration approach. We have to remember that the declaration approach is not just declaring that what they have in front of the commission is in fact a trade secret or confidential business information; they are also declaring that they have the substantiating information to back up the claim that it is confidential business information.

Whether it's an affected party, as you mentioned, or whether it's part of our random sampling scheme to verify, or whether it's the third element that you're specifically questioning, there is the need for a screening officer when they make a decision. The screening officer is the person within the commission who makes that quasi-judicial decision that, yes, this is a valid trade secret, and the screening officers need to know that they have the information before them on which to make an informed decision.

In some cases they may look at the declaration that a claimant has brought forward, and just by virtue of the number--the value that is being suggested as the economic loss they would suffer, the economic consequences they would suffer by virtue of this having to be fully disclosed rather being protected--they will know through their experience, either with that industry sector or with that particular company, since most of the companies we have as claimants are the large multinational global companies, that the number can't possibly be accurate on the face of it, so they'll need to go behind the number. They'll say they need to have that substantiating information--your economic analysis--to tell me how you arrived at that number.

It's only in doing so that a screening officer can make an informed decision and then be able to say whether this claim is valid or not.

[Patricia Davidson, Conservative, Sarnia—Lambton, ON]

Thank you.

Ms. Bryanton, on the second page in your statement you talk about the maximum residue limits as triggers; if they have a residue level significantly higher than the limit, you notify Health Canada, and then they would conduct a dietary risk assessment.

Can you tell me a little bit more about this dietary risk assessment? What's involved with it? Is it a lengthy process? Is it something that's going to be determined quickly, or are we looking at a long, drawn-out process before something is done?

[Debra Bryanton]

Thank you.

It may be that my colleague would like to elaborate on the health risk assessment process; I can talk a little bit about our monitoring programs, if you wouldn't mind, Mr. Chair.

The Canadian Food Inspection Agency has in place a monitoring program to determine the general levels in the food supply. It's not targeted at the level in a specific shipment of food, but it provides us with a picture of what levels are in the overall food supply. That's called our monitoring program. We publish our plan and its results every year. It's our national chemical residue monitoring program.

When we find a positive as a result of that program, we will first look at it to determine if it is in any way likely to pose a health risk. “Significantly” is probably the wrong word here; when we say significantly higher, anything that looks like it's higher than the MRL we will refer to Health Canada.

When a risk assessment is done and determines that it's not a health concern, it is still nonetheless a regulatory violation, so we institute follow-up action so that subsequent shipments from that particular supplier are tested and must be demonstrated to be within the residue limit. When something looks as though it may be a health concern, we submit information on that to Health Canada; in this case it would be PMRA.

[Peter Chan]

Thank you for the question. This gives me the opportunity to try to explain something in a more condensed manner. It is a very complicated issue, so I will try to explain that quickly.

In doing a dietary risk assessment, as I mentioned in my presentation, there are usually two main areas we look at. One is the exposure. In this case we are talking about the residue that remains on the food. When we do the exposure assessment, we include all the populations--including children, seniors, pregnant women--according to their dietary intake: what their dietary behaviour will be, what types of foods they will be taking, and so on and so forth, in doing the exposure assessment for the rarest age group. So that's one part of the risk assessment.

The other part of the risk assessment, as I mentioned, is to look at the potential toxicity studies to identify if there is any potential health concern of somebody being exposed to that particular pesticide product. Once we identify from the toxicology database, we will look at what is considered to be an acceptable daily intake, which in layman's language is that when somebody is ingesting or consuming certain products that contain that residue for the whole duration of their lifetime, it is considered to be acceptable or doesn't pose any health concern. So in that sense, we're looking at the hazard associated or the potential health concern, if any, for somebody exposed to that chemical versus the exposure from the residues that are from the food or from the crops, whatever the people are ingesting.

So when we compare the two, we look at what are the differences, what are the comfort levels, if that's the right word. If we determine that at a certain level there's no health concern, and then the exposure scenario is well below that, then we would say that is an acceptable residue in the food consumption.

So tying it back to the questions that PMRA would identify if there is any health concern or not, when they refer that to us, we immediately look at doing the dietary assessment of that particular reference. Depending on how much data we have on hand, it could be a process that's very quick, because we already have all the information and we can do the assessment and so on, or it could be a longer process. If we don't have all the data, we'll have to gather all the data information to look at comparing the exposure from this particular residue versus what we consider the acceptable daily intake for that chemical or pesticide.

So when we compare the two, if it's considered acceptable, there will be no health concern for that.

[Patricia Davidson, Conservative, Sarnia—Lambton, ON]

Thank you.

[The Chair, Conservative, Rob Merrifield]

Thank you very much.

We'll now go on to Mrs. Priddy. The floor is yours.

[Penny Priddy, NDP, Surrey North, BC]

Thank you, Mr. Chair.

So I can focus my question in the right direction, let me try to be clear on my understanding of this. You're stating that this is an initiative that came about because of Health Canada's work with countries around the world, including the U.K., the EU, etc. I assume then, according to the Minister of Health, that this has absolutely nothing whatsoever to do with SPP.

Anybody? A short answer, like yes or no, will help me, because then I can focus my other questions.

[Richard Aucoin]

Our discussions are part of a broader international regulatory cooperation with major OECD countries.

[Penny Priddy, NDP, Surrey North, BC]

Okay. Does it have anything to do with SPP? Is this going to have an impact on SPP?

[The Chair, Conservative, Rob Merrifield]

I don't see anyone jumping to answer that, so we will—

[Penny Priddy, NDP, Surrey North, BC]

I'll bet.