Evidence of meeting #49 for Health in the 41st Parliament, 2nd session. (The original version is on Parliament’s site, as are the minutes.) The winning word was pmra.
A recording is available from Parliament.
Conservative
The Chair Conservative Ben Lobb
Good afternoon, ladies and gentlemen, and thank you to everybody for being here.
We have a very full afternoon from 3:30 p.m. to 5:30 p.m. I believe we have six guests, two panels, and we're going to get started right now.
From the Sierra Club Canada Foundation, we have Mr. John Bennett. You're up, first, sir, if you're ready.
Murray Rankin NDP Victoria, BC
On a point of order, Mr. Chairman.
I wonder if I might present a notice of motion at this point before the witnesses start. It has to do with the Pest Control Products Act review and it would be very short.
Conservative
The Chair Conservative Ben Lobb
That would be a lot easier.
We'll let them do their presentations and then during your time you can bring forward your motion.
Mr. Bennett, you have 10 minutes.
John Bennett National Program Director, Sierra Club Canada Foundation
Mr. Chair and members of the committee, I want to thank you for this opportunity to address you and talk about the Pest Control Products Act and more specifically, about the Pest Management Regulatory Agency that operates the act.
First, just a bit about the Sierra Club. The Sierra Club is a foundation. It is part of the oldest environmental organization in the world, dating back to 1892. We have been working in Canada to preserve and protect the natural environment for more than 50 years.
I'm the national program director, based here in Ottawa.
We believe that fundamental to all good environmental policy is transparency and public involvement in decisions that impact us all. To that end, I reviewed Mr. Aucoin's testimony before this committee last week. I wouldn't say he misled you, but I would certainly say that the reality is much different from the way he described it.
He made a point of telling you about the consultations that they do on their decisions about a whole bunch of things. What he didn't tell you was that they have 30 consultations a year. But their consultations don't come until after the decisions are made and you aren't allowed to see what kind of scientific basis those decisions were made from. When you're offered an opportunity to comment, you can't really comment effectively because you can't review the science that the PMRA reviewed in order to come to its decision.
It's not a real consultation in any sense of the word. It's a public relations exercise in order to put a check mark on the box at the end of the day that, well, we had comments.
He also told you that you could inspect all the scientific data that the PMRA uses to make its decisions. What he didn't say was that if you want to inspect the data, you have to go to Heron and Riverside, in person, to the library and look at the data on a very antique set of computers and a really hard database to read. It's there if you can go, that's true, but it's not in a format that is of any use to the researchers who might need that data or for us trying to determine whether or not decisions were made. Also, you're not allowed to see the most important documents, which are what they call data evaluation records. This is the record of the data and what process they used to come to the decisions that they came to.
They're approving pesticides and these are poisons and toxins, but you're not allowed to understand how that decision was arrived at and that's a really important point because you cannot effectively comment on a decision if you don't know how that decision was arrived at and you aren't allowed to see the same data as the government people.
Then he also mentioned that if there's a decision that any member of the public doesn't like, they can ask for a review. That's true. In September 2013, that's over 15 months ago, Sierra Club Canada and a number of other environmental organizations filed a notice of objection, asking for a review of the decision to re-licence clothianidin, which is one of the neonicotinoid pesticides. That's 15 months ago and we still haven't got a review. What we have got, after a press release and a press conference last March, was a letter from them saying we'll give you an answer in June. In June we got a letter saying we'll give you an answer in the fall and we haven't heard anything since.
That's 15 months and in that 15 months four more neonicotinoid pesticides have been registered. There's lots of time and staff to provide services to the pesticide industry to register pesticides, but there's no one and no time to actually give us that review that we have the right to. That's a really critical point.
That brings us back to the registry. He talked about the fact there's an online registry of all the pesticide information. Well, it's just a big list. It's not searchable. You cannot easily find any information unless you know exactly what to look for, exactly when it happened. You can't find it. I asked my staff last summer to look in the registry and determine how many neonicotinoid pesticides were on the market on a conditional licence. A conditional licence is yes, you can go ahead and sell it, but we'd like further scientific information, which is a whole other issue, but we'll get to that.
When we found it, we had to reprogram the database, download it all and reprogram it so that we could actually determine that information that should have been easily obtainable. What we found was that 55 of these pesticides have been on the market on conditional licences.
We wrote to the PMRA and asked them for a copy of the science that was a condition of the licence. Were those conditions met? When were they met? What we got back was a letter—and there's a copy of it in the presentation—telling us that everything is fine, that rigorous science is used by the PMRA, and we did not need to worry, but no mention of giving us any science or any indication of the dates when that science arrived.
Then, last week I was invited here. Last Thursday, I was invited here, and last Friday morning, I received another email from the PMRA. Now they're telling me that they're in fact going to provide that science. Do I have a right to it or don't I have a right to it? Do I have to appear before a parliamentary committee in order to see science from a government agency?
I think the last point I want to make before I go to our recommendations is that we're talking about licensing poisons and toxins. The decisions are of a critical importance, and we should be using the precautionary principle while we make those decisions. The precautionary principle says to us that if there's any possibility that something could go wrong if we allow this on the market, then we shouldn't do it. But that's not what happens with our Pest Management Regulatory Agency. It says we're not sure about a whole bunch of stuff, so we'll give you a conditional licence. You know, some of those conditional licences go back to 2004, so some products have been on the market for 10 years on a conditional licence waiting for more science. According to the latest communications from the PMRA, they've got all the science now, but they still haven't made it public. We should really have a system in place where the precaution and the onus is on the manufacturers to prove it absolutely isn't a problem—not on the public to prove that it is a problem after something bad has happened, like we've seen across the world in terms of neonicotinoid pesticides. There are studies from all around the world indicating that these pesticides need to have greater restrictions, yet we're not seeing any movement in that direction in Canada outside of the province of Ontario.
That brings me to our five simple recommendations.
The precautionary principle should be in the act. It should say that we don't do things unless we're absolutely sure, and if there's any question, we don't do them.
The act should be amended to ensure that not only do you have to prove that a pesticide is safe, but you should also have to prove that it's actually needed. There are 7,000 pesticide compounds registered in Canada. I think we've got most of it covered, and if we're going to put a new one on, shouldn't we be taking an old one off? Will we just keep adding them?
All qualified requests for a reconsideration of a PMRA decision should result in a mandatory review, to be held within a specified period. Now, a few years ago, Parliament saw fit to change the Environmental Assessment Act to limit the amount of time taken to assess a major project to two years. We're 15 months into a request for a hearing on one pesticide—15 months.
The public should be informed at the beginning of the process, not at the end. The only way we know when a pesticide is registered is if somebody is watching the PMRA website, or watching for the ads from the pesticide companies. We need to be informed at the beginning.
We should build into the act a citizen review committee with some experts to review PMRA decisions, policies, and practices, and advise the minister. Right now, the only advice about the workings of the PMRA to the minister is coming from the PMRA. We think that there should be some outside overview of that, so that the PMRA can be brought up to date. It insists that it has rigorous science. It has rigorous science but its rigorous science is 20 years old. There are much more effective means of studying the impacts of a pesticide in the environment than the system used presently by the PMRA. We need a systematic approach to determine the effects of a pesticide. We don't do that in Canada.
Thank you very much, and I'll be glad to answer questions later on.
Conservative
The Chair Conservative Ben Lobb
Thank you, Mr. Bennett. You get an A-plus for time. There's no doubt about that. You're right on the money.
Next up we have Mr. Friesen. Go ahead, sir. You're from the Farmers of North America.
Bob Friesen Vice-President, Government Affairs, Chief Executive Officer, Farmers of North America Strategic Agriculture Institute, Farmers of North America
Thank you very much, Mr. Chair and honourable members. It is a pleasure for me to be here.
I'm here for Farmers of North America. I used to be a farmer myself in Wawanesa, Manitoba, which I always considered to be the insurance capital of Canada. I was a turkey and a hog producer in Wawanesa.
Farmers of North America is a national farmers business alliance. It's made up of farmer members. We have about 10,000 members across Canada, and our members vary in size anywhere from 500 acres up. We have a member who has 60,000 acres which, just to put some perspective on it, is about twice the size of Vancouver. In total, our members are responsible for about 20 million acres. Our farmers business alliance is what we consider to be a private sector solution provider. We don't buy or sell anything; we simply create a crosswalk between our farmer members and our input supply partners. It was started in 1998 by a grain farmer from Swift Current, Saskatchewan, and it started out as a group of farmers getting group discounts. It moved from there very quickly to major fertilizer and crop protection programs. We've now reached the third phase—while we've still maintained the first two—where we create opportunities for farmers to invest in the value chain. A good example of that is ProjectN, our $2-billion, farmer-owned fertilizer manufacturing project. It is going along really well and we're very excited about it.
Our interest in the act is very specific. Our number one mission at Farmers of North America is to maximize farmer profitability. Our interest in the act is very specific to ensuring that it creates a framework within which we can have regulation that helps farmer profitability and farmer cost competitiveness. We have an extremely important—and in this case we're talking about crop protection products—crop industry, grains and oilseed industry, in Canada. It's worth anywhere between $30 billion and $35 billion. The crop protection input costs for farmers in aggregate in Canada is somewhere around $2.5 billion; that's the third largest input cost that farmers have, behind fuel and fertilizer.
We can't emphasize enough the importance of driving everything we can towards improving farmer cost competitiveness because they have to compete against, and within, very integrated industries with U.S. farmers. I can't help but think sometimes that whenever we negotiate a trade agreement with another country—and they're really important for our agricultural exports—we should always scrutinize to see how we can harmonize our regulation as well, so that our regulation doesn't make us less than competitive with players in industries in other countries. To that end, I want to congratulate and applaud this government for its initiatives in removing all the regulatory impediments to cost competitiveness that we possibly can. That's extremely helpful because we do have redundant regulation that impedes cost competitiveness, and this government has been zealous in doing that. I would like to implore you, however, to remind the departments and agencies, once in a while, that they share the same zeal that the government has in making sure that we are cost competitive.
Our interest in the act, as I said earlier, is that it creates a framework within which we can have effective regulation. It doesn't matter what your interests are in the act; the act itself is really only as good as the regulation within it. To that end, our interests are very specific. We want lower-cost generic crop protection products for farmers because they help cost competitiveness. That is what our interests are all about. This is not a health and safety issue. We are looking for lower cost alternatives to products that are already on the shelf. Also, this is not about undermining the exclusive period that basic or original registrants currently have. This is not about undermining that exclusive period nor is it about undermining their ability to recoup some of their costs with data compensation, and I should say fair data compensation for data that is relevant and legitimate.
Once the health and safety issues have been addressed and the exclusive period is done, it's about getting a lower-cost generic product in the market as quickly as possible for farmers so that they can avail themselves of the opportunity to be more competitive.
The current regulation within the act has resulted, unfortunately, in basic registrants delaying the process and in some cases preventing generic companies from registering lower-cost generics.
As I said earlier, a very important component of reducing farmers' costs is to make sure that we get lower-cost crop protection products in the market as quickly as possible. Currently, Canada is one of the most difficult countries in the world to register a generic product. As a result, some generic companies have pulled out their applications and in some cases have revisited their business plan for Canada.
Only about 15% of our crop protection products in Canada are generic. That compares to approximately 50% in the U.S. You may recall that I said earlier we have a very integrated grains and oilseeds industry with the U.S., and so that definitely puts us behind the eight ball.
Let me give you some price comparisons. I know these products are probably meaningless to you. They are to me too because I'm currently not a grain producer, but I'll specify the products anyway. These products are all registered on both sides of the border by the same company. It's the same product registered on both sides of the border by the same company. Banvel II is three times more expensive in Canada than in the U.S. Refine Extra is double the price in Canada than in the U.S. Folicur is six times more costly in Canada than in the U.S. Tilt is triple the price, and Select is more than triple the price. This is all because of the fact that we don't have a regulation within the act that facilitates the expedient registration of lower-cost generic products. Farmers are looking for more options when it comes to lower-cost generics. Don't let anybody tell you any differently. Farmers are always looking to reduce their input costs whenever they can.
I'll give you an example. Farmers of North America, together with their input supplier, a few years ago finally, after many delays, managed to register a generic for Horizon. We called it Aurora.
We negotiated a price with our input supply partner at half the price of the prevailing market price for Horizon. As a result, other related products fell in price as well. We calculated that, over a 30-day period, we took $60 million out of the market. In other words, $60 million more stayed in farmers' pockets because we were able to register that generic product.
If you look at the $2.5 billion crop protection industry in Canada, if you start doing the math on 10% reduction in costs or 20% reduction—20% reduction on $2.5 billion is $500 million—I can assure you that would result in much less reliance on the part of farmers on government programs. It is all about cost competitiveness.
Moving on to the act, you're very familiar with the mandate of the act. It says:
(b) seek to minimize health and environmental risks posed by pest control products and encourage the development and implementation of innovative, sustainable pest management strategies by facilitating access to pest control products....
And it goes on.
Innovation and sustainability apply to the generic products that farmers have access to as well. It's about cost-effectiveness. It's about creating regulation within a framework, the act framework, so that we can be cost-competitive, that we can be innovative, and especially within Growing Forward 2, in helping farmers be more competitive.
In reviewing the act, we need to ask the following questions. Does the framework of the act allow the minister to minimize health and environmental risks? That's absolutely important. Without compromising health and safety, does the act encourage implementation of innovative sustainable pest management strategies; in other words, cost-effective and sustainable products for farmers who are trying to improve their cost-competitiveness? In other words, does the framework allow for regulation that does the foregoing and encourages innovation and cost-competitiveness? In our case, beyond health safety and environmental concerns, it's all about giving farmers more access to lower-cost generics.
Is the framework effective? We believe it can do all of the above, except—and we're not suggesting that we reopen the act—there are a couple of challenges that we need to address and I'll quickly go over those.
One is section 66.(3) in the act, which calls for using the Canadian Commercial Arbitration Act when it comes to disputes in establishing compensable data when generics are registered. The Canadian Commercial Arbitration Act is binding and so in our case, if a generic applicant negotiates compensable data with an original registrant, they can't come to an agreement, they decide to take it to arbitration and the arbiter rules in favour of the innovator's number, the generic might say that in that case they can't afford to register the product and so they will not be moving ahead. Because the arbitration is binding, the generic would be required to pay it regardless of ability to afford to go ahead, pay the compensable data, and register the product. That needs to be fixed.
We've been told that there may be a fix without reopening the act and we're certainly looking forward to the PMRA addressing that. We implore this committee and the minister to continue to keep an eye on that to make sure that we can remove this impediment.
The other problem we have, and this again is about the fact that the act is only as good as the regulation within it, is that the regulation within the legislative framework has not achieved the PMRA policy for the protection of proprietary interest in pesticides. That policy objective is to provide favourable conditions for generic pesticide producers to enter the pesticide market and to increase the selection of products available to the user.
In conclusion, Mr. Chair, is the act effective? We believe it can be effective with effective regulation within it. The good news is that the PMRA is finally engaged in trying to come up with some solutions for the regulatory challenges we have within the framework. I would simply implore the minister and this committee to keep an eye on it to make sure that we don't lose momentum because it is imperative for farmers to have more access to lower-cost generics within the act and within the regulatory framework inside that act.
Mr. Chair, I will leave a document behind with the clerk that identifies the specific issue I talked about with regard to the Canadian Commercial Arbitration Act as well as some of the other recommendations we have regarding regulations within the act.
Thank you very much.
Conservative
The Chair Conservative Ben Lobb
Thank you very much.
Next up, from the Canadian Consumer Specialty Products Association, Ms. Coombs.
Shannon Coombs President, Canadian Consumer Specialty Products Association
Good afternoon, Mr. Chair, and honourable members of the committee.
It is a pleasure to be here today to provide CCSPA’s perspective on your review of the Pest Control Products Act.
My name is Shannon Coombs and I am the President of the Canadian Consumer Specialty Products Association. I have proudly represented this industry for 17 years and our many accomplishments as a proactive and responsible industry.
CCSPA is a national trade association that represents 35 member companies across Canada; collectively a $20-billion industry directly employing 12,000 Canadians in over 100 facilities. Our companies manufacture, process, package, and distribute consumer, industrial, and institutional specialty products, such as soaps and detergents, domestic pest control products, aerosols, hard surface disinfectants, deodorizers, and automotive chemicals, or as I call it, everything under the kitchen sink. I have provided the clerk with a copy of our one-pager that has a picture of our products. I am sure many of you have used them today.
Why are we here? CCSPA member companies that make domestic pest control products are regulated by the PCPA. Our final products are designed for consumers. We have personal insect repellents, ant traps, rodenticides, and wasp spray. The ingredients, end-use packaging, labels, advertising, and reporting are all regulated under this act. They meet the rigorous requirements of the Pest Control Products Act for safety, value, and merit. I brought a small sample of the products that some of our members make: bedbug spray, personal insect repellent, ant traps, and antibacterial cleaner. Products that are classified as sanitizers are also pest control products in Canada.
To put the domestic sales of pest control products in perspective—I know earlier this week you had the agriculture sector here—I would offer the following statistics. In the Pest Control Product Sales Report for 2011 it states that domestic pesticides account for 4.6% of all pesticide sales in Canada. Domestic products, are classified as antimicrobials, insecticides, and herbicides. Antimicrobials used primarily for swimming pools and spas account for almost 76% of all domestic pesticide sales. Insecticides account for 18% and herbicides 5%. It should be noted that the top 10 active ingredients account for 84% of the domestic sector of pesticides sold. Seven of the top 10 are pool chemicals.
In preparation for the presentation today I went back to the presentation that I made before this committee in April of 2002. I thought it would be helpful to reflect on where we were then and where we are now with eight years of experience with the legislation. Pesticides continue to make headline news and often for the wrong reasons. The message that the products are beneficial continues to get lost, which is unfortunate. That was the state of the issue then and it still is now.
The story is very different because of the modern legislation that this committee passed in 2002. The act put into place a rigorous, science-based system with checks and balances that serves Canadians well. They can be confident that the products they use in their homes to protect themselves from insects or weeds do the job. They are safe and they are effective.
Let’s evaluate the agency against the criticisms from 2002 and where we are today.
In regard to products under re-evaluation, there were 401 active ingredients that were identified in 1998 for re-evaluation. These re-evaluations are almost complete. The 15-year review cycle for re-evaluations commenced in 2006 when the act came into force. The approach for the 401 active ingredients was to conduct scientifically based reviews, to manage the workload effectively, and to work with industry to ensure that there were product changes, or label changes, or possibly even discontinuations of products. This is a very successful outcome of the work of the agency and the new act.
In regard to performance timelines, in 2002 the lack of the performance of the agency was at an all-time fever pitch when a 1998 report, the Nephin report, said that the agency was taking 40% longer than its counterparts to complete its reviews. This is no longer the case. The agency has worked very hard to develop performance standards and adhere to them. In the last three years it has met its performance targets for almost all submission types.
Since 2002 the PMRA has employed effective management tools, such as electronic submissions and pre-submission consultations, and addressed paper burden and unique Canadian data requirements to help our members bring innovative consumer products to market.
In 2002 sales reporting and the lack of transparency on how product registrations were conducted was an area that garnered a fair amount of criticism from stakeholders. Transparency is now a legislated requirement. There are registration decisions, products under review, the public registry, products being re-evaluated, comments solicited from the public on those actions, and annual sales reporting, plus a diligent process for collecting, evaluating, and reporting on incidents.
In our opinion, the PMRA raises the bar globally with all of these PCPA initiatives.
As an extension of the transparency initiatives, I would also like to mention the outreach conducted by the PMRA to various stakeholders through the work of the minister's pest management advisory council, an economic management advisory committee, and other work that it does with the federal, provincial and territorial committee on pest management and pesticides.
Those are just a few examples, but overall I believe we have a very modern piece of legislation that allows technology to come to Canada—products that are important to consumers—and allows industry to be competitive.
A predictable, science-based system exists and we all need a better way to communicate its successes to Canadians. There's been a great deal of improvement by the PMRA since 2002, when I appeared on the proposed legislation.
While CCSPA is not proposing any amendments to the PCPA, I would offer one observation of the PMRA, and it is its lack of self-promotion. In the summer of 2011, CCSPA conducted consumer polling in the province of British Columbia on the subject of pest control products. In that polling, 71% of respondents stated that they were aware of Health Canada's role in approving pesticides in Canada, and 69% of respondents trusted Health Canada's regulation and approval of pesticides. To me this demonstrates that when Canadians know about Health Canada's role in the regulatory process, they have confidence in the regulatory process. Health Canada should be doing more to communicate the work that it is doing to protect the health and the environment of Canadians as it relates to pest control products.
As the committee prepares its report, you may wish to also comment on the PMRA's need to increase its communications and offer a recommendation, if you are of the same opinion.
Mr. Chair, I thank you for the opportunity to present today. I will be willing to take any questions the members may have.
Conservative
The Chair Conservative Ben Lobb
Thank you very much.
We've had our first three presentations. Now we're going to enter into our question and answer portion. Unlike last meeting when I was very generous on time, we're going to have to keep very tight on time so that we give everybody a fair shot. If I cut you off, don't be offended. That's just the way it's going to be today.
Mr. Rankin, you're up first. You have seven minutes, sir.
NDP
Murray Rankin NDP Victoria, BC
Thank you.
At the risk of eating into my time, I'd just like to make a housekeeping motion if I could, Mr. Chair. I've talked to you and the clerk informally about this idea. The suggestion is that the committee extend the statutory review of the Pest Control Products Act by two days in order to hear from additional witnesses.
My fear is that this statutory review just isn't going to give us enough time. There are a number of people on the Internet with a pent-up demand for this review—
Conservative
Eve Adams Conservative Mississauga—Brampton South, ON
Mr. Chair, perhaps I may begin by welcoming our new committee member to our committee. I'm very much looking forward to working with him.
If I might very respectfully suggest that we move these discussions into our normal business meeting, I also have another item to raise, on behalf of a pregnant colleague of his. But perhaps we might shunt these discussions over to our business meeting?
NDP
Murray Rankin NDP Victoria, BC
I'm happy to do that. I just wanted to have it on the record that we believe there's not enough time for this review. I can move on and do that in a business meeting, as you put it. Frankly, I'd be happy to because I don't want to eat into my time for questions, so thank you.
With that, I'd like to turn to Mr. Bennett, if I could.
I'm a long-time member and supporter of the Sierra Club. I welcome you here. I'm a huge fan of your work.
I'm very troubled by the material you've brought to the committee today. It's consistent, frankly, with material I've heard from the Canadian Environmental Law Association. I guess I'd start with your concerns about transparency, which you've indicated today are serious.
As I read from your brief, you indicate that you are not able to know what science has been used or not used as the basis of a regulatory decision. The PMRA does an evaluation in secret and posts it for comment. Then you talk about lack of access to the key documents, which are the data evaluation reports.
I just want to understand, then, what the recommendation is that you would make specifically to amend the act.
National Program Director, Sierra Club Canada Foundation
That all the data is public.... The problem is that under the present act, the data is public. The PMRA has interpreted that it's the data. But how it handles the data...that document, they don't consider that data.
It's the road map that tells us what science they consulted, how they weighted it, what they discounted, what they included, and how they came to a decision. You can't see that when you're wandering through a library with antique computers on a day pass on Riverside Drive.
NDP
Murray Rankin NDP Victoria, BC
It's not merely a regulation that you need to amend. You believe the statute itself needs to reflect that requirement of transparency.
National Program Director, Sierra Club Canada Foundation
The statute should be clear that it means all the documents related to a regulatory decision.
NDP
Murray Rankin NDP Victoria, BC
The next point I wanted to raise involves your reference to the precautionary principle. Section 20 does refer to the precautionary principle.
Conservative
James Lunney Conservative Nanaimo—Alberni, BC
I'm sorry to interrupt you, Mr. Rankin.
On a point of order, has a copy of Mr. Bennett's presentation been circulated? I certainly didn't receive it. Does the clerk have copies he can distribute to us? We're furiously making notes.
Conservative
The Chair Conservative Ben Lobb
I can speak to that briefly, and then if you want further clarification, the clerk can as well.
The document was about 50 pages in length in one language. In order to be fair, we need it to be translated, and doing takes an exceptional amount of time. It is in the course of being translated, I believe.
I'll turn it over to the clerk and he can provide you more information, but that's my understanding.
Conservative
James Lunney Conservative Nanaimo—Alberni, BC
Mr. Rankin seems to be quoting from a document that the rest of us don't seem to have access to.
The Clerk of the Committee Mr. Andrew Bartholomew Chaplin
Shortly after noon or 1:00 p.m., I sent a partial piece of the submission, including the letter from the PMRA and the letters that the Sierra Club Canada Foundation referred to in that. It was sent electronically just a couple of hours ago.
Conservative
James Lunney Conservative Nanaimo—Alberni, BC
Apparently I didn't receive it, or at least it didn't show up in my book.
Conservative
The Chair Conservative Ben Lobb
In the letter they do reference a few letters, so the clerk had those translated. They are available right now, and the rest of them are being translated.