AGRI Committee Meeting

37th PARLIAMENT, 2nd SESSION

Standing Committee on Agriculture and Agri-Food

EVIDENCE

CONTENTS

Tuesday, June 3, 2003

Á

1105

The Chair (Mr. Paul Steckle (Huron—Bruce, Lib.))

Mr. Rick Borotsik (Brandon—Souris, PC)

The Chair

Mr. Rick Borotsik

The Chair

Mrs. Rose-Marie Ur (Lambton—Kent—Middlesex, Lib.)

The Chair

Mrs. Rose-Marie Ur

The Chair

The Chair

Mr. Howard Hilstrom (Selkirk—Interlake, Canadian Alliance)

The Chair

Á

1110

Mrs. Mary Komarynsky (Director General, Adaptation and Financial Guarantee Programs, Department of Agriculture and Agri-Food)

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1115

The Chair

Ms. Janice Hopkins (Director, Alternative Strategies and Regulatory Affairs Division, Pest Management Regulatory Agency)

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1120

Á

1125

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1130

Á

1135

The Chair

Mr. Howard Hilstrom

Ms. Janice Hopkins

Mr. Howard Hilstrom

Ms. Janice Hopkins

Mr. Howard Hilstrom

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1140

Ms. Janice Hopkins

Mr. Howard Hilstrom

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1145

Ms. Janice Hopkins

Mr. Howard Hilstrom

Ms. Imme Gerke (Minor Use Advisor, Pest Management Regulatory Agency)

Mr. Howard Hilstrom

Ms. Imme Gerke

Mr. Howard Hilstrom

The Chair

Mr. Bernard Bigras (Rosemont—Petite-Patrie, BQ)

Ms. Janice Hopkins

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1150

The Chair

Mr. Bernard Bigras

The Chair

Mr. Howard Hilstrom

The Chair

Mr. Bernard Bigras

Ms. Janice Hopkins

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1155

The Chair

Mr. Bernard Bigras

Mrs. Mary Komarynsky

The Chair

Mr. Mark Eyking (Sydney—Victoria, Lib.)

Ms. Janice Hopkins

Â

1200

Mr. Mark Eyking

Ms. Janice Hopkins

Mrs. Mary Komarynsky

Ms. Janice Hopkins

Mr. Mark Eyking

Ms. Janice Hopkins

Mr. Mark Eyking

Ms. Janice Hopkins

Mr. Mark Eyking

Ms. Janice Hopkins

Mr. Mark Eyking

Ms. Janice Hopkins

Â

1205

Mr. Mark Eyking

Ms. Janice Hopkins

The Chair

Mr. Rick Borotsik

The Chair

Mr. Rick Borotsik

Mrs. Mary Komarynsky

Mr. Rick Borotsik

Â

1210

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

The Chair

Mr. Howard Hilstrom

Â

1215

Ms. Janice Hopkins

Mr. Howard Hilstrom

Ms. Janice Hopkins

Mr. Howard Hilstrom

Â

1220

Ms. Janice Hopkins

Mr. Howard Hilstrom

Ms. Janice Hopkins

The Chair

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Â

1225

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Ms. Imme Gerke

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

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1230

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

The Chair

Mr. Bernard Bigras

Ms. Janice Hopkins

Â

1235

Mr. Bernard Bigras

Ms. Janice Hopkins

Mr. Bernard Bigras

Ms. Janice Hopkins

Mr. Bernard Bigras

Ms. Janice Hopkins

Mr. Bernard Bigras

Ms. Janice Hopkins

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1240

Mr. Bernard Bigras

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Janice Hopkins

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Janice Hopkins

Mr. Rick Borotsik

Ms. Imme Gerke

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1245

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

Mr. Rick Borotsik

Ms. Imme Gerke

The Chair

Mrs. Rose-Marie Ur

Ms. Imme Gerke

Mrs. Rose-Marie Ur

Ms. Imme Gerke

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

Mrs. Rose-Marie Ur

Mrs. Mary Komarynsky

Mrs. Rose-Marie Ur

Mrs. Mary Komarynsky

Mrs. Rose-Marie Ur

Ms. Janice Hopkins

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1250

Mrs. Rose-Marie Ur

The Chair

Mr. Howard Hilstrom

Ms. Janice Hopkins

The Chair

Ms. Imme Gerke

The Chair

Ms. Imme Gerke

The Chair

Ms. Imme Gerke

The Chair

Ms. Imme Gerke

The Chair

Ms. Imme Gerke

The Chair

Ms. Janice Hopkins

The Chair

Ms. Janice Hopkins

The Chair

Ms. Janice Hopkins

The Chair

Mrs. Mary Komarynsky

The Chair

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CANADA

Standing Committee on Agriculture and Agri-Food

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NUMBER 034

l

2nd SESSION

l

37th PARLIAMENT

---

EVIDENCE

Tuesday, June 3, 2003

[Recorded by Electronic Apparatus]

Á  (1105)  

[English]

    The Chair (Mr. Paul Steckle (Huron—Bruce, Lib.)): I'm going to call this meeting to order.

    Before we get into the business at hand, I want to consult with the committee as to whether or not you feel the need of a conference call. We believe there is information in the system regarding BSE that should be discussed, and the earlier the better. I'm referring to a time around 3:30 today, if that would be possible.

    Mr. Rick Borotsik (Brandon—Souris, PC): We have a vote at three.

    The Chair: So 3:30 or thereabouts.

    An hon. member: Would 4 o'clock work?

    The Chair: Four o'clock would work for me.

    Mr. Rick Borotsik: The earlier the better. I have electoral boundaries, which I have to be at.

    The Chair: Would that work?

    Mrs. Rose-Marie Ur (Lambton—Kent—Middlesex, Lib.): I have to apologize. I wasn't listening.

    The Chair: I'm sorry. We'd like to have a conference call.

    Mr. Bigras, I asked whether we could consider doing a conference call this afternoon again.

    Seeing that there's consensus, then, I'll look at 3:30. Your offices will be forwarded the number.

    I'm trying my best, Mr. Bigras, to communicate. We're going to have our office give the number so that your office will have the appropriate time. Your office will be notified of a conference call this afternoon at 3:30.

    Mr. Eyking, at 3:30 this afternoon, a conference call.

    Ms. Ur.

    Mrs. Rose-Marie Ur: There are votes in the house at 3 o'clock and there's going to be more than one.

    The Chair: Okay, so 3:30 should get us back to our offices, but given the circumstances of the vote, we may have to delay that by five or ten minutes, whatever the need might be. If we could do that, there will be other people connecting as well, so it won't be just the committee.

    An hon. member: Do you have the number, Mr. Chair?

    The Chair: We don't have that yet. That has to be set up.

    I would ask the Agriculture Canada people in the audience if they would proceed.

    Do you have a question, Mr. Hilstrom? Sorry.

    Mr. Howard Hilstrom (Selkirk—Interlake, Canadian Alliance): Yes, I do have a question of the committee and yourself as chair. In view of the fact that this BSE situation is not going to be over immediately, I would like to see the steering committee get together on Monday of next week to discuss the possibility of having a couple of special sessions in the summertime, or as many as are required, in order to deal with regulatory changes being proposed by various groups in the country, and in order to guarantee that our meat will be marketed around the world and be accepted, to guarantee that our systems are so strong that we're 100% better than anybody else. We don't need to discuss it here, but I'd like to ask whether the members would be willing to have a steering committee meeting to talk in camera on these issues.

    The Chair: Okay. Is there a consensus on that? It would have to be at about four o'clock on Monday. Will everybody be here at four o'clock?

    Mr. Bigras, that would work for you or your associates?

    Mr. Eyking, that isn't a problem?

    Okay. We'll take that under advisement and try to establish that as part of the agenda for next week.

    We will move on to the business we came together for this morning, which is to deal with the issue that we want a response to the third report of the committee on the registration of pesticides and competitiveness of Canadian farmers. This has to do with PMRA and it is what we're here for this morning.

    We have with us this morning Dr. Janice Hopkins, director for the alternative strategies and regulatory affairs division of PMRA. We also have with us Dr. Imme Gerke, who's lost her voice, so I'm not expecting her to respond--I think she was at a different convention than Mr. Borotsik was--and her partner, Ms. Mary Komarynsky, director general, adaptation and financial guarantee programs, Agriculture Canada, who is going to speak for Dr. Gerke, who is minor use adviser for PMRA.

    Ms. Mary Komarynsky, you're going to be leading off. You may begin, and then we will follow with questions.

Á  (1110)  

    Mrs. Mary Komarynsky (Director General, Adaptation and Financial Guarantee Programs, Department of Agriculture and Agri-Food): Thank you.

    Good morning, Mr. Chair and members of the committee. At the committee's invitation, I am here to talk about the work that Agriculture and Agri-Food Canada has done over the last five months to establish the pesticide risk reduction and minor use programs.

    Since December, our main focus at Agriculture has been on preparing for the 2003 growing season by identifying and equipping field sites, training staff, developing a plan for minor use field trials, and making contact with the private sector companies to undertake field trials to maximize our capacity.

    Our target was to conduct as many field trials as possible this summer to generate the data required to double the number of submissions for registering new pesticides with the Pest Management Regulatory Agency. We continue to work with U.S. officials from Interregional Research Project No. 4, also known as IR-4. We've been sharing information and consulting with them on program content, essentially drawing on their forty years of experience, in using their minor use program as a model for our new program here in Canada. Our staff attended their priority-setting meeting last September and they in turn participated in our national priority-setting workshop this March. We will continue to share priority setting between our two countries.

    Our roles and responsibilities at Agriculture and Agri-Food Canada have become more clearly defined as we move forward with the implementation of the pesticide risk reduction and minor use programs. Significant progress has been achieved.

    As I mentioned earlier, one of Agriculture's main roles will be to develop a minor use pesticide program that will accelerate the registration of minor use pesticides and improve access to more efficient and environmentally friendly pest control products.

    We have consulted and will continue to consult with stakeholders on pest management priorities for the sector. We have worked and will continue to work with pesticide manufacturers to get their support for new pesticide registrations and to conduct field trials, and we will use the resulting data to prepare submissions to PMRA.

    In addition, we are working with PMRA and our provincial and industry partners to develop alternative pest management solutions. We will identify pest management gaps by developing crop profiles for a wide range of horticultural, field, and specialty crops. This information will be used to determine the priority pest control needs for the sector and will lead to the implementation of practices and products that will reduce the risk of pesticides to human health and the environment.

    Since December, in our continuation of getting our program up and running, forty staff at our ten field sites have received training in good laboratory practices, or GLP, and four facilities are now GLP compliant. The remaining six sites are expected to receive GLP certification later this year once they have completed the necessary field trial work required for certification.

    We have prepared and submitted to PMRA close to 100 pre-submission documents. Sixty of these were new pre-submission consultation documents. The remaining were historical documents that we had to review and discuss with PMRA to ensure that they were still current.

    The 2003 field trial plan is being implemented, with 80 projects being undertaken at agriculture sites and through contracted private consultants, including 24 projects where Agriculture is doing field trials on joint projects with the American IR-4 program. This is almost twice the annual number of projects Agriculture has conducted or funded in the past through the Canadian adaptation rural development fund.

    Moreover, work is already under way for next year. In March, Agriculture held its first national meeting to determine priority pest management projects for 2004. The event officially marked the launch of the minor use program and brought together close to 150 stakeholders from across the country for a three-day workshop. Participants included growers, pesticide manufacturers, crop specialists, representatives from the IR-4 program in the United States and the United States Environmental Protection Agency, and provincial and federal governments. The result was a very successful, productive session with national consensus on 35 priority pest projects.

Á  (1115)  

    In addition to these 35 new projects, there will be some trials carried over from projects this year where Agriculture or private contractors were unable to complete the required field trials. As well, in consultation with the provinces, Agriculture will review project proposals submitted to PMRA in previous years to determine if field data generation is still required.

    We've also been in contact with a variety of stakeholder organizations to establish a 12-member advisory committee that will include representation from farm and commodity groups, the pest control industry, environmental groups, and consumers. This committee will provide agriculture with broad, strategic-level advice to support the program's goals and will advise on a variety of issues ranging from policies and program criteria to approaches to reducing risk. The advisory committee will also be used to track and report on how program funds are being utilized. So far we have received confirmation from 10 groups and expect we will have all members in place for an initial meeting set for June 25 and 26 of this month.

    In closing, I would like to reiterate that we have come a long way in the past year. However, a lot of work still remains to be done. To that end, we will continue to consult with our provincial and industry partners to help shape the program and provide pest control solutions now and in the future.

    Mr. Chair, thank you very much.

    The Chair: I will now move to Dr. Hopkins, sitting in for Dr. Gerke. We'll let her do the presentation.

    Ms. Janice Hopkins (Director, Alternative Strategies and Regulatory Affairs Division, Pest Management Regulatory Agency): Good morning, Mr. Chair. Thank you to you and members of the committee for the opportunity to update you on the progress that Health Canada has made since Dr. Franklin appeared before you in December 2002.

    We will focus our remarks on reduced risk and minor use pesticides. I will do double duty for the committee this morning. I'm here on behalf of Dr. Franklin, who is with the minister's Pest Management Advisory Council. That council is meeting now, today, to advise on the implementation of the new Pest Control Products Act. Because of Dr. Gerke's laryngitis, I will give her statement so she can save her voice to respond to questions from the members.

    With respect to the new Pest Control Products Act, on December 12, just two days after we appeared before you last year, that act received royal assent. Since that time, a number of stakeholders have commented on how important the legislation is in improving pesticide regulation and enhancing sustainability in agriculture.

    We feel it is a very important piece of legislation that will help to retain public confidence. We feel that in order for this to happen, it's important that the evaluations we carry out at PMRA continue to focus on whether health and environmental risks posed by a pesticide when used as directed will be acceptable and whether the product offers a worthwhile contribution to pest management.

    We are working to develop essential regulations so that the act can be brought into force at the earliest opportunity. We're focusing on those sections of the act that require that regulations be developed so that the act can be applied and are targeting to have those regulations in place in the spring of 2004.

Á  (1120)  

[Translation]

    During her December appearance, Dr. Franklin indicated that PMRA will use the new funds that were announced last spring to augment staff to meet the demand for timely registrations resulting from the increased number of submissions that we are expecting, and to expedite the review of reduced risk pesticides.

[English]

    I would like to update the committee on two issues: PMRA's accomplishments in reviewing reduced risk submissions, including minor use submissions, and our accomplishments in hiring staff to meet the increased workload.

    We do have three programs in PMRA that are there to contribute to greater availability for minor uses. We do recognize for these programs the importance of Agriculture's efforts in putting in place the studies necessary to support minor use label expansions and to coordinate the data for submission to PMRA for registration. As Mary has already mentioned, this parallels the very successful IR-4 program in the U.S.

    Our first program is intended for those products that have registered active ingredients and end-use products already registered in Canada. That's known as the user requested minor use label expansion program, or URMULE. Through this program those agriculture end users can encourage pesticide registrants to support the approval of an additional minor use of an already registered product. That would be a use on a crop or a pest that is not covered by existing registrations.

    Users, or user groups or organizations representing them, are responsible for initiating minor use requests by identifying the need for proposed new uses and contributing to the development of information that may be required for registrations. We also look to ensure that these requests are supported by a provincial or a forestry minor use coordinator prior to the submission to PMRA.

    This program incorporates two sequential steps: an initial pre-submission consultation during which PMRA identifies any additional requirements to the sponsor, and a corresponding submission by the sponsor in response to the consultation. Then, if after the review of the data in the submission the use is considered to be acceptable, the registrant is responsible for submitting an application to PMRA to add that use to the product label.

    The second program applies to products that are not already registered in Canada but are registered in the United States or in another OECD country. This program is known as the user requested minor use registration program, or URMUR.

    If the pesticide is registered in an OECD country within the last five years and if the registration of that pesticide has not been denied, suspended, cancelled, or withdrawn because of health and environmental concerns, and if the registrant provides foreign data reviews from OECD countries and identifies the proposed area and volume of use, that would make the product eligible for consideration as a URMUR submission. The registrant is the one who makes URMUR submissions to PMRA and works with sponsor and user groups.

    There is a third way that a number of minor uses are increasingly becoming available. We are encouraging and continuing to encourage registrants to participate in joint reviews so that a registrant can obtain registration at the same time in Canada and in the U.S.

    We've found that this process leads to pesticide submissions that seek approval for many more uses of the pesticide in Canada, and many of these uses are minor uses. We are also encouraging registrants who seek registration only in Canada to include as many uses, including minor uses, as possible in their initial submission, thereby facilitating earlier availability of products for minor uses.

    If these products are considered to be reduced risk products, they are then eligible for our initiative for reduced risk pesticides, which was introduced last May. Under this initiative, we accept the EPA designation and criteria of reduced risk, and the review of submissions that meet the reduced risk definition are expedited.

    As of May this year, some 46 registrations have been granted under the joint review program, consisting of 20 traditional chemicals, 20 reduced risk chemicals, four microbials, and two pheromones. This total includes both active ingredients and end-use products.

Á  (1125)  

    There are currently 15 submissions undergoing either joint review or work share: six are traditional chemicals, five are reduced risk, and four are microbials. In addition, we are pleased to report that there has been one minor use label expansion as well as one import MRL completed through the joint review program.

    During Dr. Franklin's appearance, she indicated that there would be a significant increase in the registrations for minor uses. In total, the three programs I mentioned have led to the registration of a total of 743 minor uses, 320 of which are specifically for agricultural crops during fiscal year 2002-03. The remaining minor use registrations for those who were doing the arithmetic were mainly for ornamental plants.

    Just to give you some statistics for a comparison in U.S. fiscal year 2002, IR-4 reported a total of 870 uses, of which 388 were agricultural minor uses.

    I have a few other quick points, Mr. Chair, to update the committee on what we have been involved with.

    We have held a successful three-day course for registrants and for those involved in the new reduced risk and minor use initiative. A specific module on minor use was organized for provincial minor use coordinators, who are our representatives, and AAFC officials. This session provided information about the requirements for high-quality minor use submissions.

    We have provided to AAFC officials 136 lists of data requirements that had been previously prepared for minor uses. These had been identified by provincial minor use coordinators as priorities but no submissions had been received, and Agriculture has since been reviewing those lists, as Mary mentioned.

    We responded in a very short time period, from January to March, to 60 pre-submission consultation requests from Agriculture. These requests resulted from a meeting in August 2002 that led to a consolidated list of minor use priorities. This has enabled AAFC to begin field trials this spring.

    We have also prepared templates for use by Agriculture to facilitate the submission of good-quality pre-submission consultation requests, and we have also prepared a number of templates, again for use by Agriculture, in gathering data for minor use submissions. These include templates for residue trials, efficacy trials, crop tolerance trials, raw data, GLP-compliant field notebooks, and study reports.

Á  (1130)  

[Translation]

    Mr. Chairman, I also indicated that I would update the committee on our progress in hiring staff.

[English]

    PMRA received $800,000 through the agricultural policy framework for this purpose in 2002-03. This, along with additional funds from PMRA's budget, was allocated to hire 12 additional staff to undertake pre-market submission, consultation and review, and to evaluate submissions for reduced risk products, including minor uses.

    In the current fiscal year we are receiving an additional $3.2 million for a total of $4 million in the current fiscal year. We will use this additional $3.2 million to hire additional staff, for an additional 30 staff, making a total of 42 staff to undertake reduced risk and minor use activities.

    This staff will be carrying out the following activities. They will do pre-submission consultation and review with those seeking registration to ensure that they fully understand the data requirements to support registration. In this case nine additional staff are distributed among the three main evaluation divisions within PMRA. Those are the divisions that handle health, environment, and efficacy assessments. Twenty-nine additional staff are being employed to screen and review submissions, again in the review divisions as well as in submission coordination, the chief registrar's office, and the executive directors office.

    Finally, on harmonization and the promulgation of maximum residue limits, four additional staff are being hired by the alternative strategies and regulatory affairs division, the division of which I am director, and the chief registrar's office to coordinate harmonization activities and to undertake the regulatory activities leading to the promulgation of maximum residue limit regulations under the food and drug regulations. Most of these staff have already been hired, and the remaining small number will be hired over the next few months.

    Mr. Chair, that completes my remarks. I would now like to make a few remarks on behalf of Dr. Gerke. I will speak as if I were Dr. Gerke so that I don't confuse the notes that I have here. So when I say “I”, I really do mean Imme.

    Since we met last time in December 2002, the minor use initiative has taken big steps forward. All stakeholder groups, growers, the provincial minor youth coordinators who select the projects, AAFC, which coordinates activities and generates data, PMRA, which reviews and registers new uses, and the industry that makes products available to the growers for these new uses have been very active in following up on their responsibilities. Everyone is still aching a bit from the strenuous efforts it takes to get such an initiative off the ground, but the progress has been considerable.

    From the first week of November until the last week of March, I have travelled to all 10 provinces, some of them several times. I accepted grower invitations to their annual meetings and to their farms. The goal of these visits was to present myself to the growers and to explain to them the process of the minor use initiative and the role they had in it, to make sure they felt comfortable to contact me at any time, and to give them the chance to express their frustrations with the old system and on the other hand explain to me the different growing and harvesting methods, their grading and marketing systems, and last but not least, their problems with pest management.

    Some of these meetings took place in large conference rooms, some in regular working groups, some on farms, in barns and on fields, and finally in my hotels over breakfast, lunch, and dinner. I have come to four conclusions from these travels: there was an urgent need for the minor use initiative; growers are very eager to make things work and to be actively involved in the process; there is an enormous amount of misinformation out there; and growers are looking far into the future and not just at today.

    There are now over 1,800 needs for registration on the national need list that growers have collected from the west coast to the east coast. Mary has described the meeting that took place in March at which some 80 of these growers came from all provinces for the priority-setting process that took place there.

    PMRA has put enormous effort into accommodating the new initiative by achieving timelines for setting data requirements and revisiting old submissions for which no sponsor had generated any data. The industry has made all efforts possible to assist agriculture in their new program by providing existing data and letters of support, shipping out product samples for the upcoming growing season, and advising on the application methods of these products for any given crop.

Á  (1135)  

    By now, the minor use office has assumed the following responsibilities: receives complaints and requests for information from growers, processors, provinces, industry, and scientists, and resolves these by either finding the information within PMRA or identifying new sources of information that shed a different light on a given issue and allow the development of a solution; clarifies misunderstandings of procedures and responsibilities concerning the registration of minor uses; shows small companies and the pesticide industry, in particular American companies, the path into PMRA; elaborates proposed timelines for PMRA, Agriculture, industry, and provinces to minimize the delay between the identification of a project and the registration of its new use; produces templates, to which I previously referred, to facilitate the production of submissions of acceptable quality so that delays caused by the need for clarification can be avoided; produces templates for study protocols, field notebooks, and study reports to assist agriculture and other sponsors in the production of high-quality data packages that will conform to OECD norms for good laboratory practice and that will be acceptable to PMRA and IR-4 and the Environmental Protection Agency in the U.S.; prepares a training plan about the registration process for study directors from Agriculture and Forestry; supports growers and provinces in the identification of potential pest control products; establishes tracking systems that allow us to follow the advance of any given project through the different parts of the process, from the identification of a need to the availability of the product on the shelf; and advises PMRA on different ways to adjust to the expected changes in the number of submissions that will come in through the minor use initiative.

    Thank you, Mr. Chair, for your indulgence in allowing me to speak on behalf of Dr. Gerke.

    The Chair: Thank you, Dr. Hopkins, for your presentation, and Mrs. Komarynsky for your presentation.

    We will now move to questions. Mr. Hilstrom, for seven minutes.

    Mr. Howard Hilstrom: Thank you.

    Ms. Hopkins, are you still receiving complaints from chemical companies and from farmers and grower associations--the department generally, not you personally?

    Ms. Janice Hopkins: Mr. Hilstrom, the answer is, very simply, yes. Everyone would like their products to be addressed as quickly as possible. We continue to try to handle that in the fairest way possible.

    Also, as Dr. Gerke has indicated, she receives a number of such questions, and I will let her answer your question as well if you wish.

    Mr. Howard Hilstrom: No. You've answered that question.

    On new active ingredients, it's still taking over five years to get a process through. I want to mention to you a couple of things here. I'm referring to an access to information request with a reply from Minister Anne McLellan, Q-198, for which Mr. Chatters from Athabasca submitted and got a reply back. Are you familiar with this document?

    Ms. Janice Hopkins: I believe so. If you go on I'll be sure.

    Mr. Howard Hilstrom: I'm going to refer to a specific thing in there, and that was one of the figures used. That five years, which is 1,912 days, seems like kind of a long time. I would like to deal today maybe with the minor use and just deal with one thing.

    I'm referring to another document I have from the Ontario Fruit and Vegetable Growers' Association. This is dated April 1. This is dated May 22, 2003. What I'm referring to is the fact that this system is still not working. Here are some of the issues. Under this access to information request it says:

One of the goals of the joint review process and other work sharing initiatives with the EPA has been to make the new products available to users in both countries at the same time.

    Of course, you've mentioned the funding.

    Here's what the Ontario Fruit and Vegetable Growers' Association had to say about the funding and personnel announcements:

Funding and personnel announcements made with respect to PMRA last year have had little impact upon the manner in which PMRA operates. In fact, PMRA's requirements appear to change constantly and have little basis in science. An example is PMRA's recent decision not to accept data from Michigan, even though it is in the same zone (5) as Ontario. As you no doubt imagine, this is extremely frustrating given Michigan's proximity to Ontario and the similarities with respect to climate and crops grown here.

    The second example is:

Lorsban is a widely used insecticide, with many horticultural crop uses both here in Canada and in the U.S. As a vegetable seed treatment or planting time treatment, past data has shown that residues are not an issue.

    Okay. That has been scientifically shown already.

Nevertheless this did not stop PMRA from requiring residue data in order to continue the use. The cost of generating the residue data; $25,000.

    Why isn't your system working? Why are these complaints still there? Although I haven't personally gone there, I believe this letter to be accurate. It's signed. What comments do you have in regard to these kinds of complaints?

Á  (1140)  

    Ms. Janice Hopkins: I'll make a couple of comments and then I'll ask Dr. Gerke to make a couple of comments.

    I will, first of all, investigate a couple of specific issues that were raised in the letter. Without, for example, knowing some of the specifics, I would have a hard time addressing them specifically today.

    I appreciate that there are times when the requirements we request are difficult for especially grower organizations to understand, and that's certainly part of the role Dr. Gerke fulfills in explaining some of these requirements.

    With respect to accepting data, we are moving increasingly toward accepting data across zones, and at present there is a NAFTA document that is out for comment among the three countries to move closer together in accepting residue data that is generated in the three North American countries.

    Yes, there are times when it seems difficult, as I say, for an organization to understand why specific data are requested, but that is what we are attempting to do to improve the situation.

    In some cases as well--and I don't know if this is specifically true for Lorsban--where pesticides have been on the market for some period of time, we are involved in a re-evaluation process, and that does at times require that data be generated because they were not there in registering the pesticide a number of years ago.

    I recognize that those are very general comments. Unfortunately, I would have difficulty with the two specific examples.

    Mr. Howard Hilstrom: No, I appreciate that, but we are trying to get down to the fact that there is a lot of money being spent and more people being hired and everything, and we need to see results and we need to see them quickly. We can't go on for another year.

    Another example here is this new ombudsman. Now I remember when that came up here. I think it was even a committee recommendation. Here's what I got back from Minister McLellan:

The new ombudsman person has facilitated increased communication between growers, the PMRA, and Agriculture and Agri-Food Canada to ensure the data requirements for approvals are met and has helped streamline the processing of submissions.

    And here's what the growers say:

...the Ombudsman person position the industry had requested has been filled with a Minor Use Advisor, reporting to Claire Franklin, the head of PMRA. At best, this position is merely a buffer between PMRA and grower groups.

    What has gone wrong with this ombudsman person? Why is it hampering the process and communication instead of helping? What these growers are saying, which is what I read out to you, that's verbatim. What about that ombudsman?

Á  (1145)  

    Ms. Janice Hopkins: I'll make one comment and I'll let Dr. Gerke answer as the adviser.

    Frankly, it has not been our experience that Dr. Gerke has been, and I think the quote was, “a buffer”. We have heard from her very directly about the issues she has heard about, and we are certainly taking action to be able to help her respond to those issues. But rather than having me speak about that, why don't I ask her to speak herself?

    Mr. Howard Hilstrom: Are you the ombudsman or this adviser?

    Ms. Imme Gerke (Minor Use Advisor, Pest Management Regulatory Agency): Yes, I am.

    Mr. Howard Hilstrom: Oh, okay. Well, great then. Give us the story.

    Ms. Imme Gerke: I must say, I'm a little bit astonished about that remark because most of my time is spent talking with growers. Growers call up and ask for information and usually growers are very happy with the answers they get. I can provide these answers in writing if that would help you.

    Obviously, I neither have the goal nor the power to turn around the system. However, from my view, the system does work, but it is not clear how it works. Most of the time I either hunt information that growers need to have or I clarify issues.

    I would like to give an example. We are all aware of the 1-MCP issue, where at the beginning of September of last year the growers contacted me and complained about PMRA being slow in dealing with 1-MCP at a time when PMRA didn't have the submission yet. So ever since then I have been talking with the company on a regular basis, asking them when would we get the submission. We finally received it on March 18.

    So there was a lot of communication that took place between the growers and my office and the company, meaning that the growers and my office phoned the company regularly, asked how we could help and what we could do, and so on and so on, with the result that finally the submission came in on March 18. But that was five and a half months later than the growers thought the product had been in the system.

    Mr. Howard Hilstrom: Are you suggesting you have success but that there are still lots of problems?

    The Chair: Your time has expired--grossly expired. We will now move to Mr. Bigras.

    You can probably pick that up later. I have to emphasize “grossly”.

[Translation]

    Mr. Bernard Bigras (Rosemont—Petite-Patrie, BQ): Thank you, Mr. Chairman.

    I would first like to thank you for coming before the committee.

    The delay in registering certain products has been mentioned several times today. I am concerned about this, but what I am more concerned about is the protection of public health and the environment.

    Whether products are registered or not is one thing, but that there be a delay in re-evaluating products is of much greater concern to me. We know that out of 6,000 products on the market and 500 active ingredients in registered pesticides, there are 300 that were approved before 1989 and more than 150 that were approved before 1960, and the standards today are very different from what they were then.

    When the Department of Agriculture gave you its re-evaluation priorities in 1986, three groups were established. Your mandate, in 1995, was to establish a re-evaluation program for pesticides.

    How can you explain today, and correct me if I am wrong, that there are still pesticides that were considered a priority in 1986? Re-evaluations have been ongoing for 20 years and none of these re-evaluations have been completed, except perhaps for a few. How can you explain that re-evaluations for products on the market have been ongoing for all these years in order to ensure that the public's health and the environment is protected and that practically none of these re-evaluations have been completed?

[English]

    Ms. Janice Hopkins: Thank you for the question on re-evaluation. A number or re-evaluations have actually been completed. We do frankly face some challenges in communicating our work on re-evaluation because there are a number of decisions that are taken along the way. Given that many products have quite a wide variety of uses, we have, in a number of cases, made decisions on some of those uses and then moved on to look at additional uses as well.

    However, we are using, to the maximum extent that we can, the work that is under way in the U.S. The U.S. Environmental Protection Agency has for some time allocated a large number of resources to this activity. We have participated with them in the policy formulation, and we also use the results of the reviews they do.

    The progress in both countries, quite frankly, has not been as fast as many people would like to have seen. We have collectively targeted the most difficult products first, and those are the organophosphates. Those are close to completion. A number of others are under way, and we have a target for completion by 2006.

Á  (1150)  

    The Chair: If I may interject for just a moment to clarify the reason for the bells--there is a 30-minute bell--the motion before the House is that the House do now adjourn. I'm asking the members here if we could continue this meeting through the vote rather than leave to vote. I don't think there is an advantage for any of us to leave, unless you feel otherwise. If we leave here we're going to put these people at a disadvantage. There's another meeting that I need to be at, at one o'clock, in terms of getting money for this committee. It seriously puts this committee in a bit of jeopardy. Do I have consensus for that? I am committing on behalf of the government side because I think this is important.

    Mr. Bigras?

    Mr. Bernard Bigras: Sure.

    The Chair: Thank you very much for your cooperation. This way we can continue on and disregard the vote. I haven't taken any of your time.

    Mr. Bigras.

    Mr. Howard Hilstrom: Mr. Chair, would you explain to my constituents why I didn't vote today? I have a very good voting record.

    The Chair: We'll forgive each other.

    Mr. Bigras, please carry on.

[Translation]

    Mr. Bernard Bigras: Thank you, Mr. Chairman.

    You say that re-evaluations are making good progress. Out of 6,000 products on the market, how many have undergone a complete re-evaluation?

    Second, you mentioned the Americans and you are right, everything is not bad. An international study led by the PMRA a few years ago showed that Canada was behind the United States, the United Kingdom and Australia in terms of money spent on re-evaluating current pesticides, compared to money spent on registration. Apparently the Americans invest 25% more money on re-evaluation than on registration.

    We know that the PMRA receives its funding in two ways, through votes and through cost recovery. Is the fundamental problem of the re-evaluation program not the fact that contrary to the United States, the United Kingdom and Australia, you do not allocate sufficient funds to re-evaluation? Americans allocate 25% more to re-evaluation than to the registration of new products.

[English]

    Ms. Janice Hopkins: Thank you for the honorary doctorate, but indeed it is Ms.

    With respect to the spending on re-evaluation, yes, we have not spent the amount of money that the U.S. or the U.K. have spent. That's certainly one of the reasons we work very closely with the U.S., to take advantage of the work done there.

    Recently, the government allocated additional resources to PMRA to fulfill the new legislative responsibilities. That did include some additional resources for re-evaluation.

    With respect to your first question about how many products out of 6,000, I don't have that number. But with respect to the active ingredients, out of the 400 ready to be evaluated, we have completed, I believe, approximately 60. As I mentioned, we have a target of completing all by 2006. I would be happy to provide the exact number to you following the meeting, but as I recall, it is about 60.

Á  (1155)  

    The Chair: Mr. Bigras, you have time for one more question.

[Translation]

    Mr. Bernard Bigras: My other question is for the officials from the Department of Agriculture and Agri-Food. I would like to know if you have in the works a draft policy to fund organic agriculture, as Europe does, where there are financial incentive programs, technical support programs and assistance for producers to encourage them to change their production methods. Does your department have a draft policy to support organic agriculture in Canada?

[English]

    Mrs. Mary Komarynsky: Thank you very much for the question.

    In terms of minor use pesticides and organic, there are two things. First, I mentioned that at the March meeting we set national priorities for next year, and there we looked at biopesticides. That is a beginning to move away from chemical pesticides. There was one priority identified. I know that's not a lot, but it's a beginning in terms of what the growers want.

    Second, in terms of organic agriculture, do we have a policy within our department? The department does spend money on organic farming. We do not at this point have a policy that links to pesticides and the reduction of pesticides. However, we have spent money over the last number of years to establish an Organic Agriculture Centre of Canada. We provided $3 million to this centre. This centre is essentially trying to encourage organic farming within Canada.

    So there is work within our department on the research side of organic agriculture. The department has also funded organic research in Canada.

    The Chair: Thank you, Mr. Bigras.

    Mr. Eyking, for seven minutes.

    Mr. Mark Eyking (Sydney—Victoria, Lib.): Thank you, Mr. Chair. It is good to see we are making progress, but it is debatable if we are going fast enough.

    Concerning the many products you just approved, are there many of them that are more environmentally safe? That was a big concern. Often the public thinks that farmers are getting more products so that they can pollute the environment, but it's not always the case.

    My second question is this. Are many of the products in the so-called backlog a big concern to a lot of growers? Are they waiting and holding their breath for some of them?

    My third question is, how different is our system when compared to the American system? Is there much difference? So often we talk as being more connected with the United States in the future in dealing with food safety issues. We see what happened in the last few weeks. Are we on the same page as the Americans or are they far off in the distance?

    Ms. Janice Hopkins: Thank you for the questions, and I'll try to ensure I cover them all.

    With respect to the questions about products that we have approved that are more beneficial from an environmental perspective, I referred to the joint reviews that we carry out with the U.S. and mentioned that of the number of products we have jointly reviewed, 20 of those products were considered reduced risk chemicals, four microbials and two pheromones. Generally, the pheromones and microbials are considered as more environmentally sustainable.

    With respect to the 20 reduced risk chemicals, they do present a reduced risk, but one of the things we try to ensure that people are aware of is that the risk is reduced. However, it is not zero, and it is very important as a result that the label directions are followed.

    However, those are examples of newer chemistries that are now available in Canada. We are also, as I mentioned, open to consider submissions for products that are reduced risk in the U.S. but for whatever reason the manufacturer has chosen not to bring them in to both countries at the same time.

  (1200)  

    Mr. Mark Eyking: I would like to follow up on that question. Is the industry and government getting the word out on what we are doing? Often you see these commercials by Health Canada, or whatnot, telling the public how we're making people healthier and whatever. Shouldn't we be informing the consumer out there what we are doing to make the environment and the products safer? Is there something going on with the industry? Do you see a void there, or is there something happening?

    Ms. Janice Hopkins: Perhaps I could ask Mary to comment from the APF perspective about what's happening on that front,

    Mrs. Mary Komarynsky: Under the ag policy framework--and committee members heard questions and answers and the minister in the last couple of weeks--there is a major communications strategy to communicate on the environment. Minor use pesticides and risk reduction is a key component, and we are currently developing a website for minor use pesticides, where we will be putting on the website not only what work we're doing on minor use, but what we're trying to do on risk reduction.

    Risk reduction strategies are really to take a look at, by crop, what's out there, what current pesticides are being used, what are some of the challenges facing producers with regard to those crops in terms of pests, whether that's insects, bugs, diseases, etc., and are there alternative methods that could be employed by farmers to reduce the use of pesticides and to have more environmentally sustainable agriculture?

    We've just begun that work with the announcement last May and June of the Government of Canada for minor use and risk reduction. We're just starting now on some of that work to get out that message and find alternatives for farmers to implement.

    Ms. Janice Hopkins: Would you like me to continue with your remaining questions?

    Mr. Mark Eyking: Yes.

    Ms. Janice Hopkins: With respect to your question regarding products and backlog, we actually operate on assigning timelines to products as they come in the door. Depending on the complexity of a submission, we will assign a timeline to review that submission. We work very hard to meet those timelines, and we're not always successful, but we continue to try and improve there.

    That obviously is only part of the issue, though, and in order for a product to get onto the market, it means we have to meet our timelines and we have to have the data in the submission from the manufacturer that allows us to make the decisions. Part of the reason it does take a long period of time is that in a number of cases we do have to go back to the registrant and seek more data.

    Finally, as I see you have other commitments, with respect to the situation--

    Mr. Mark Eyking: I understand that point, but I'll just make a point. Sometimes if growers have a certain product delisted--not that you have to push this thing through, a new product, but do you see that as a way of maybe prioritizing another product, or have you got a kind of due diligence with everything?

    Ms. Janice Hopkins: We do due diligence. There are some cases in which we can allocate reduced timeframes, though. It depends on the alternative that's proposed. If there is an alternative that's reduced risk, we can therefore offer the registrant a reduced timeframe--not reduced data requirements but a reduced timeframe.

    Mr. Mark Eyking: Just on the last one--

    Ms. Janice Hopkins: The EPA?

    Mr. Mark Eyking: What's the big difference? I know you can talk the whole day on it, but--

    Ms. Janice Hopkins: No. I'll tell you what the big difference is.

    As I just mentioned, we take submissions as they come in the door and assign them a timeframe. The EPA operates on a priority system, so they only accept the number of submissions per year that they feel they can review.

    So you have to get on the list in the U.S. to have your submission considered. That's the big difference. The reviews are very similar, and that's been worked out through both working out our procedures as well as through the joint review process.

  (1205)  

    Mr. Mark Eyking: Does that make lobbyists more involved in the process down in the States? Would lobby groups try to get somebody's product on that list? Is that how they work a bit, or is it not really like that?

    Ms. Janice Hopkins: I will answer you from my limited knowledge of how the U.S. sets their priorities.

    About 15 months in advance of their decision-making, they send out a letter to a wide variety of individuals and groups. They ask for their priorities. Then they go through a very long process of deciding. I believe companies are given choices among their products as to which ones they have to have on the list. It's quite a process.

    The Chair: Thank you very much, Mr. Eyking.

    You're not leaving; you're staying here. You can't go over to vote. I've given my honour to my opposition. Nobody's leaving here.

    Mr. Borotsik.

    Mr. Rick Borotsik: Thank you, Mr. Chair.

    The Chair: By the way, I'm your boss at this point in time.

    Mr. Rick Borotsik: I know.

    I can commiserate with you in your misery with your throat. Please bear with me as well, as it's a little bit hoarse.

    I have a couple of questions, and the first is for Ms. Komarynsky.

    It's an unusual relationship, obviously, with Ag Canada and having PMRA reporting to Health. It has always been...I won't say a difficult relationship, but certainly from the ag side of it, we always have these difficulties with PMRA because of the reporting back to the health side. We believe our priorities are certainly the highest priorities, and perhaps it's not the same as with PMRA.

    This is a judgment call, and I don't want to put you on the spot, but have you seen more openness and a better working relationship develop in the last year between the PMRA and the Department of Agriculture as such? We knew that was part of the problem going into this whole review. Have you seen that openness? Is it better?

    Mrs. Mary Komarynsky: I'll say two things. One, I refer to the remarks that were made in Dr. Gerke's opening remarks where PMRA has been working very closely with Agriculture and Agri-Food Canada to establish, as you heard, these templates. That is pretty important, because the bottom line is that both of us, Agriculture and Health Canada, want to get into PMRA as many submissions as we possibly can for farmers.

    While it may come across, “Why would we need a template?”, the templates are critical. They allow us to be more efficient and standardize the type of information that PMRA will require for registration. Agriculture Canada has been reviewing the templates.

    On the openness, I think we have provided comments to PMRA and will continue to do so, if we agree or do not agree. Essentially we are the ones that will have to work with the industry and the provinces to get that information into PMRA for registration.

    We have had regular meetings with Dr. Gerke where we argue back and forth, and I mean that in a positive way, in terms of what are the requirements, what are our roles, and what's the continuum of the role that Agriculture plays in PMRA.

    From what I've seen personally, I find the relationship open in that I think both organizations want to succeed. Our ministers have made commitments in terms of doubling the number of submissions and being more timely. That does not mean Agriculture will not have some challenges with PMRA, as will PMRA with ourselves. Our key goal is that from Agriculture Canada we want to ensure that our growers get the products they need.

    Mr. Rick Borotsik: As I understand the numbers, there were some 743 approvals last year and 370 were Agriculture. Is that an improvement from years past, or is that a similar type of ratio that we have had in the past?

  (1210)  

    Ms. Janice Hopkins: It's higher than in previous years.

    Mr. Rick Borotsik: So this is positive.

    Ms. Janice Hopkins: This is positive. One of the reasons it is higher is because of the number of uses that have been proposed in a number of our new product submissions. That's definitely contributed to a significantly increased number.

    Mr. Rick Borotsik: Dr. Hopkins, I'm going to ask you briefly to summarize the three programs you talked about before. There is a whole bunch of acronyms, but I want you to briefly summarize all three. I understand that these are new programs that have been implemented in the past year.

    Ms. Janice Hopkins: These are not new programs. They have been implemented over the past number of years or described better and made more widely known.

    Mr. Rick Borotsik: Are these three programs specifically agriculture-related?

    Ms. Janice Hopkins: No. They are available for forestry as well. I was quickly thinking as you asked me the question.

    In some cases there will also be some domestic uses that will come out of them. The focus and generally the sizable numbers have been agricultural numbers.

    Mr. Rick Borotsik: I have another question before you use the rest of my time on the programs.

    The other one is about the staffing levels you have. I'm not an expert, by any stretch of the imagination, but I've always been a fan of harmonization. I believe that if the work is going to be done in another jurisdiction, we should have the ability to harmonize some of those registrations. I see in your staffing that four people have been identified as harmonization, if you will. There are four staff members for that, where 38 have gone into different directions. Are all of these 42 staff again related to agriculture, or is it the big picture of PMRA?

    Also, do you not feel that perhaps more of a focus on harmonization would in fact reduce the level of staffing from the other sides?

    Ms. Janice Hopkins: I'll answer that quickly and then I'll run through the program quickly. I would be happy to send you the specific descriptions of the programs subsequently.

    On the staffing side, the four people I identified look at harmonization and the establishment of maximum residue limits. The harmonization activity is really to make sure that the joint review process and the work we do especially with the Environmental Protection Agency happens. The other 38 may well be involved in some joint review activities.

    Mr. Rick Borotsik: Implementation?

    Ms. Janice Hopkins: Implementation, yes. Think of those four as more on the policy side and the other 38 on the implementation side.

    With respect to the programs, very quickly, if there is a product in Canada for which a new use is being sought, that would be considered a label expansion. If there is a product that is not available in Canada but is of interest and has been available in another OECD country or in the U.S. and is being sought for minor use, that is the user requested minor use registration, URMUR.

    Mr. Rick Borotsik: URMUR.

    Ms. Janice Hopkins: URMUR, yes. I had to practise.

    Mr. Rick Borotsik: Come up with better acronyms, would you please?

    Ms. Janice Hopkins: I would like to.

    The final one is the work we've been doing on an ongoing basis with registrants who make regular submissions. In the past they have made their submissions often to Canada for grains and oilseed uses. Through joint review and through our work with them, we're asking them to bring the minor uses from Canada's perspective into those submissions when they make them to us the first time. Instead of having a small number of crops, although major use, we will have 50, 60 or 70 uses that come in when the submission first arrives. That's the third program I referred to.

    Mr. Rick Borotsik: Does it have an acronym?

    Ms. Janice Hopkins: No.

    The Chair: Mr. Hilstrom.

    Mr. Howard Hilstrom: Mr. Chair, I'll try to stay within my timeframe.

    We're trying to get across to you that there are still problems. You acknowledge that, and that's fine and dandy. It's a government regulation, and we need to have that government regulation and the legislation and everything. Just like the agricultural policy framework, when Minister Vanclief was trying to sell this to farmers and farm organizations, he said “They just don't understand. It's a great program, but they just don't understand, so I'm going to go out and sell it to them.”

    Ms. Hopkins, you said words to the effect that once again the applicants just don't understand. Hansard will show that, and farm organizations too, I suppose. These are large international chemical companies. The farm organizations, such as the Ontario Fruit and Vegetable Growers' Association, are professional organizations. To say that they just don't understand, I find that hard to believe. We are getting at the essence of the problem that you guys are all communicating, but you're not accomplishing the final goal.

    In the access to information from Minister McLellan, she refers to publication 96-01, “Management of Submissions Policy”. What does the 96-01 refer to? It's a date, I assume. What's the date?

  (1215)  

    Ms. Janice Hopkins: Yes, 1996.

    Mr. Howard Hilstrom: It is 1996, okay.

    So that comes out and it gets onto the infamous website and it goes through this timeline. It says here on one line, and I'll read it verbatim, that only 6% of the category A submissions registered over the period from 1997 to 2002 have been ideal submissions. Only 6% of the submissions are ideal submissions. These are for active new ingredients. A couple of lines further down it states that 94% of the category A submissions registered in this period have had quality problems requiring the use of at least one of the seven delays.

    How are we to believe that things are going to get any better in the future when we've still got all these problems arising after the 1996 changes? We've made more changes; we're spending more money and using more people.

    I've tried to make the point that they are not stupid people in the farm groups or the international chemical companies. What's the problem? There has to be a better answer than “We're changing, we're spending more money, we're working”. How come there isn't any communication? Why are these problems still on the go? Is it so complex? Is that the problem?

    Ms. Janice Hopkins: It is complex. It truly is. I would be remiss if I didn't recognize that.

    We're looking at substances for which we have to collectively consider their environmental effects, their health effects, and their value. These are pretty major activities on new ingredients. I admit to the complexity.

    Second, there are large companies, and those companies do have regulatory affairs departments that are devoted full time to putting submissions together for the various regulatory agencies internationally. There are also quite a number of smaller registrants who don't have those kinds of resources available to them.

    Third, you asked what we were doing about trying to improve the communication. I made reference to the three-day course we held last fall. We are going to continue to do that so that we can bring registrants together and talk about the areas in which things can be done better so that we improve our timelines.

    We're improving our communication with the companies themselves. We are meeting with them to talk about the kinds of problems that have arisen in their submissions in the past and how those could be addressed in future submissions. We try to continue to communicate and offer, for example, the pre-submission consultation process. We can sit down with a registrant in the very early stages of their submission to describe to them the kind of data that would be required. We reduce, we hope, through that process the cases in which submissions arrive without the data that's necessary. It's an ongoing process.

    Mr. Howard Hilstrom: What are the registrants saying back to you? Are they saying they can't hire smart enough people to meet your requirements and to understand your forms, or are they saying they just don't care and they will just put in any sloppy thing? There's a big problem here and I'm trying to get at what that is. You can communicate until the cows come home, but if things don't change for the better, then that doesn't seem to do any good. I don't know that we've really got right at the problem.

    I'll deal with one last little issue while I've got the floor here. I don't think we're going to be able to answer that.

  (1220)  

    Ms. Janice Hopkins: I wish we could resolve that one today.

    Mr. Howard Hilstrom: I know I'm on borrowed time, but we've got a little bit of extra time today.

    Getting back to the minor use thing, the reason for all this is food safety. That's what we're talking about, and we acknowledge that.

    Here's a farmer's perspective, as represented by Chairman De Brabandere of the Ontario Processing Vegetable Growers:

From a grower perspective, government talk about competitiveness is viewed as hypocritical when governments won't give growers the tools needed to compete, the very same tools our competitors use.

    Of course, every farmer has to make a dollar. They have to be competitive. He makes the point: “Nor is this a food safety issue, as the very same crop protection products not permitted for use here” in Canada are used on foods in other countries, the United States, “both fresh and processed, that are then legally imported into Canada and consumed by Canadians”.

    Why does your process stop the registration of these products for use in Canada when you allow in the same foods that have had these sprayed on them?

    Ms. Janice Hopkins: I will try to make a very short comment in response to that.

    Obviously, we can't allow a product into Canada unless we have a submission for it. That's the reality we face and that's one of the challenges. The second thing with respect to products being used in other countries is that we recognize that that is true.

    I need to get a little technical for a moment. One of the things we have been doing is there has been in place in the food and drug regulations something called a default provision. If you produced a food and expected that the residue limit on that food would be below 0.1 parts per million, you could bring that food into Canada without having a specific residue limit established for that pesticide.

    We have a proposal that has been under consultation that will revoke that exemption. In the future, those who want to import a food into Canada containing residues of a product that is not allowed in Canada will have to apply for the establishment of a specific MRL. We feel that will address at least part of the situation to which you're referring.

    The Chair: Thank you, Dr. Hopkins.

    Now, Mrs. Ur, unlimited time.

    Mrs. Rose-Marie Ur: Yes, I've been very patient.

    Just to finish off Mr. Hilstrom's letter, I have a copy and I'd be more than happy to give it to you, Ms. Hopkins. I've worked very diligently, as he has, to highlight everything he has said, but he omitted the last phrase, and I'd like it to get on record as well, because you indicated that you felt things were improving in the farming sector.

    It went on to say that “The pesticide registration process in Canada needs to start over with a clean slate. The status quo is not acceptable.” That pretty much says it all, I would think.

    You made the statement that with the joint review with the U.S. we have had 20 approvals in that process. What was the grand total out of it?

    You went on to say, and maybe I heard wrong.... Is it true that manufacturers decide whether they want to bring it into the country or they want to issue it in the United States and Canada at the same time? You don't make that decision, but they make that decision then, and PMRA can't be blamed for that.

    Ms. Janice Hopkins: No. We ask, though, that grower organizations encourage the chemical industry to apply in both countries at the same time. We encourage the chemical industry, the pesticide industry, but we do also ask that grower organizations make that same case to the pesticide industry.

    Mrs. Rose-Marie Ur: I think that was the committee's recommendation. That's why we wanted an ombudsman as well as an advisor, because we have heard the same story from day one, since this organization started, that this was a problem. Every time you came here it was the poor person, the farmers, not doing their submissions right to the chemical companies and the chemical companies weren't submitting to you right. That was why we wanted the ombudsperson and advisor, to say the least. It didn't happen.

    Out of those 20 registrations, what was the total sum?

    Ms. Janice Hopkins: There were 46 under joint review.

  (1225)  

    Mrs. Rose-Marie Ur: And we had 20.

    Ms. Janice Hopkins: Sorry, no. There were 46 Canada-U.S. jointly. Of those 46, 20 were reduced risk chemicals.

    Could I ask Dr. Gerke to speak? She gave you an example of one of her discussion--

    Mrs. Rose-Marie Ur: I have a lot of questions.

    Ms. Janice Hopkins: Fair enough. We'll try to be brief.

    Mrs. Rose-Marie Ur: Okay.

    Ms. Janice Hopkins: Would you like to speak about the discussions you have had with the pesticide industry?

    Ms. Imme Gerke: Again, this is something that is in development. There are many companies right now, for example, from the United States, especially the smaller companies, that have first registered in the United States and they are now invited by the growers to come north. The growers identify--the growers call me and ask me how to have access to the product. I put them in contact with the company. The companies call me back and then we are in the process of putting the submissions together for PMRA.

    That is something that is on the way. It's something that is happening. There are several submissions in preparation and there are also some that already came in for review.

    Mrs. Rose-Marie Ur: You also stated that the new staffing dedicated to the new minor use initiative...what are the numbers in there? Was the number four or five given out in that?

    Ms. Janice Hopkins: The number this year is $4 million and 42 staff. There were four that I identified who are working on policy-related issues, and that is the promulgation and maximum residue limits and liaison with the U.S.

    Mrs. Rose-Marie Ur: I was given some information that there were two young people working with Ms. Gerke and three with Daryl Kindack. They aren't reviewers. And these people were complaining about whether this $4 million was well spent on these five people.

    Ms. Janice Hopkins: As I mentioned, of the 42 staff, there are 38 who are involved either in pre-submission consultation or submission review and four who are involved with harmonization and MRL promulgation.

    Mrs. Rose-Marie Ur: You mentioned that you were going through due process and that you hoped the review would be done by 2006 for some of the products.

    Ms. Janice Hopkins: For the evaluation, yes.

    Mrs. Rose-Marie Ur: Yes. Do you not have a timetable of 18 months that you deal with--

    Ms. Janice Hopkins: On new products, yes, but not on the old products.

    Mrs. Rose-Marie Ur: Why is it different?

    Ms. Janice Hopkins: Why the difference? In part because we are working so closely with the U.S. on the re-evaluation of the old products, so we follow their review process. And frankly, their review process does not have specific completion dates. Part of the reason is that at times additional data has to be generated. So it depends on how long it takes to generate the data.

    Mrs. Rose-Marie Ur: I have some more questions I'd like to put forth.

    Is it true that several projects due for final approval were put on hold this past winter and spring? It was said that the staff were not paid nor the new money assigned to you to get these completed in time for the season. Did that happen within the department?

    Ms. Janice Hopkins: Those were several minor use projects. There were some projects that were not completed. We set them aside to work on the 60 pre-submission consultation projects that were received from Agriculture. If you have specific ones you'd like to inquire about, I could certainly find specific details, but that generally is my understanding of what happened.

    Mrs. Rose-Marie Ur: Another question that was posed to me was, is it true that staff developed policies to prevent expediting of key registrations that growers have lobbied for simply because a first in, first out policy applies? I heard you make mention of that here today.

  (1230)  

    Ms. Janice Hopkins: We do follow a first in, first out policy. We follow that for all submissions. It was the only way we could figure out how to deal with the 3,000 submissions we face annually.

    With respect to allocating priority, for those products that are reduced risk, we have reduced timelines. We also have relatively short timelines on the label expansion projects. The way we give priority is based on the nature of the submission and trying to reduce the timelines.

    Mrs. Rose-Marie Ur: If I have the time, I'll go on to round two or three, or whatever it is.

    There is a new Bt pesticide. This is a time-sensitive question. The new Bt pesticide with superior features for control of mosquitoes, the vector for the West Nile disease, has not received registration, despite the impending issue this year in that it's here and despite its registration status in the United States. Why are we not working more quickly on this? This is a really serious situation.

    Ms. Janice Hopkins: We understand that there is such a product available in the U.S. One of the realities is that we have not had a submission for that product here in Canada. We also understand that it is not necessarily more effective than some of the Bt products that are already available. However, as soon as we have a submission, we would be quite prepared to begin work on it.

    Mrs. Rose-Marie Ur: The information I was given is that this product works really well because it can be used in muddy water, where other products get bogged down. This particular pesticide can work much more efficiently. I question why we can't move a little more quickly on this.

    Ms. Janice Hopkins: As soon as we get a submission we can certainly take a look at it.

    The Chair: Thank you, Ms. Ur.

    Mr. Bigras.

[Translation]

    Mr. Bernard Bigras: Thank you, Mr. Chairman.

    I would like to come back to the issue of re-evaluation of active ingredients. You mentioned earlier that there were 400 active ingredients. I thought that there were approximately 500, but nevermind. You also said that 60 active ingredients out of the 400 had been re-evaluated.

    Out of those 60 active ingredients that have been re-evaluated, how many comply with the new standards for health and the environment? Furthermore, out of those 60 ingredients, how many have passed the new tests, that are very different from those that were used in 1960? How many passed the test? Did the active ingredients that were re-evaluated and that were included in registered pesticides pass the test? How many passed the test and how many failed it?

[English]

    Ms. Janice Hopkins: The re-evaluations have been carried out according to the new health and safety standards. Those standards include such concepts as the aggregate risk, that is, the risk of exposure to that pesticide from all sources: food, water, occupational exposure, and so on.

    One of the reasons this re-evaluation, especially on the organophosphates side, has taken some time is that we, with the EPA, are working on assessing the risk from all organophosphates. This is known as cumulative risk, and we are trying to look at the risk associated with products that have a common mechanism of toxicity.

    That's why that particular group has taken such a long time, and it has been the most complicated. They also have a large number of uses. All 60--and I will verify that number for you--of the re-evaluations that have been carried out have been done according to current health and safety standards.

    If we do not have data in some cases, we have asked the registrants to generate that data. Generally, there's some residue data available, in part because of monitoring done by the Canadian Food Inspection Agency. It tells us the levels of residue on crops.

    With respect to the number of active ingredients that remain registered, I would have to get that number for you. Of course, the 60 active ingredients are a large number of products. Some of those products have remained registered. Some of them the manufacturers have decided to discontinue.

    I'm sorry if I seem to be avoiding the question. I am truly trying to answer it for you.

  (1235)  

[Translation]

    Mr. Bernard Bigras: Mr. Chairman, I do not understand. I believe my question was clear.

    There are 500 active ingredients. You have just told us that 60 of those active ingredients have been re-evaluated according to the new health and environment standards.

    How many active ingredients passed the test? It's not complicated. How many active ingredients passed the test and can be used in products being sold? How many?

[English]

    Ms. Janice Hopkins: As I say, I regret I don't have that number here right now. I will get it for you because I do want to be precise.

[Translation]

    Mr. Bernard Bigras: Mr. Chairman, I would like the official to send us that number if possible. This information is very important because it is quite possible that some of the active ingredients that failed the new tests were registered in 1960 according to old standards and have been on the market for more than 40 years. We know perfectly well that your agency has taken more than 20 years to re-evaluate certain products and certain active ingredients.

    The Auditor General, the Commissioner of the Environment and Sustainable Development, as well as of many others, agree in saying that re-evaluation is necessary, whether one supports chemical products or not. Are you aware that if active ingredients have not passed the test, that means that they have been on the market and that people have been in direct contact with them?

    I will not ask you what the exact number is. Can you simply tell us if some products did not pass the test? I'm not asking you if there were three, four or five active ingredients that did not pass the test. Can you assure the committee today that all of the active products that were re-evaluated passed the test? I'm not asking you for a number.

[English]

    Ms. Janice Hopkins: I can't tell you that all 60 passed the test. I can tell you that 60 have been re-evaluated. In a number of cases some uses have ended, and I will find out for you--of the number that were re-evaluated--which ones did not pass the test.

[Translation]

    Mr. Bernard Bigras: Were all the active ingredients that were re-evaluated part of program number 1 of the Re-evaluation Program of the Pest Management Regulatory Agency? Were they a high priority?

[English]

    Ms. Janice Hopkins: Yes. They were high-priority, active ingredients. In a number of cases,as I mentioned, they were being re-evaluated in the U.S. In a couple of cases there have been some that we have been re-evaluating specifically because of Canadian interests. Those are products for lawn and turf use. We have moved more quickly on the evaluation of those than the U.S. has done. In those particular cases there are some uses that have ended. The evaluation of those products for other uses continues.

[Translation]

    Mr. Bernard Bigras: I would like to ask one last question, Mr. Chairman. It will be very brief, but important.

    Can the officials from the Pest Management Regulatory Agency tell us what high priority means? What is the risk level?

[English]

    Ms. Janice Hopkins: High priority from the PMRA's perspective in re-evaluation means that the products have been on the market for some period of time. There are some questions about the databases that support those products and therefore we give them priority for re-evaluation.

  (1240)  

[Translation]

    Mr. Bernard Bigras: They therefore represent a danger to health and the environment.

[English]

    Ms. Janice Hopkins: Health and the environment.

    Mr. Bernard Bigras:Merci.

    The Chair: Mr. Borotsik.

    Mr. Rick Borotsik: I'm going to go back to something Mrs. Ur put on the table. As I understand it, the PMRA policy is that you cannot react to any kind of a product unless a company makes an active submission or application. That is PMRA policy. PMRA policy is not to be proactive but to be reactive.

    Her example was an excellent one. If, for example, there is a product that can deal with mosquitoes and the West Nile virus, which we have difficult problems with, and if you go to the company and it doesn't wish to make an application on that product in Canada, you simply back off and say that's too bad. Is there any incentive? Is there any proactivity that you as a department would put in place to assist that company to put forward that kind of an application?

    Ms. Janice Hopkins: I'm going to answer quickly and then I'm going to ask Imme to comment because she has been pretty active in encouraging companies to make a submission.

    We do try to encourage them. We cannot force them to make a submission. As far as the incentives are concerned, as I mentioned, if the products are suitable, we do try to offer reduced timeframes for review.

    Let me ask Imme to talk about her experience.

    Ms. Imme Gerke: First of all, it's the companies who are the owners of the product. Nobody has access to any data if the company doesn't give it to PMRA, so there is no point and nobody can go and get it. That's one thing.

    The other thing is that for a company to decide to put in for a submission is not a decision that comes from the regulatory side. It's marketing who makes the decision and it's finance who makes that decision. They need an incentive.

    Mr. Rick Borotsik: [Inaudible—Editor]

    Ms. Imme Gerke: That's right, but that incentive comes from the market. It really has nothing to do with the registration process.

    Mr. Rick Borotsik: There is also a financial component with the registration process.

    Ms. Imme Gerke: Yes.

    Mr. Rick Borotsik: In talking about incentives, is there any kind of an incentive available to the corporations through PMRA?

    Ms. Imme Gerke: Yes, there is.

    Mr. Rick Borotsik: Have you ever made any of those incentives available to any of those corporations?

    Ms. Imme Gerke: Oh, yes. They're available all the time.

    Coming back to the acronyms, URMULEs cost $154.

    Mr. Rick Borotsik: That's pretty reasonable.

    Ms. Imme Gerke: I think so, yes. Whenever I told growers that, they got their wallets out. I don't think that is a blockage.

    Mr. Rick Borotsik: Let me go back to another question.

    I was rather intrigued with the 0.1 parts per million tolerance for residue coming into the country. I knew there was a 0.1 PPM tolerance. I heard you say that may be reduced and the corporations are going to have to apply for an MRL in order to do that.

    Is that going to be seen as a non-tariff trade barrier, by any chance, with respect to trade? We have a lot of the product coming in that we have already set at a 0.1 PPM tolerance. Have you considered that at all, and is there any action that could be taken against Canadian products going into the U.S. market, for example, based on that change in tolerance?

    Ms. Janice Hopkins: One of the ways we tried to make sure that didn't happen was before we put the proposal out to consult with Foreign Affairs and International Trade...after the proposal was released, we tried to encourage as many organizations as possible to respond to the proposal.

    It is our understanding that it should not be a trade issue. This particular approach is used in a very limited number of countries. Most countries establish specific MRLs. That's our understanding.

    Mr. Rick Borotsik: What does it take to apply for an MRL? What is the cost and what is the timeline?

    Ms. Imme Gerke: I'm not sure about the timeline. I would guess that it is around six months, but that is a guess. When I see the process, that's what I think it is.

    As far as I know, it costs $5,000 to get an MRL. The reason Canada is getting rid of the default MRL is that slowly all countries in the world are getting rid of it. It cannot be a trade barrier or a trade issue because the WTO would only be dealing with that.

  (1245)  

    Mr. Rick Borotsik: I have one last question, very quickly.

    The U.S. efficacy reports, residual reports, environmental reports--is PMRA using those now to assist in the approval process?

    Ms. Imme Gerke: Yes.

    Mr. Rick Borotsik: Then I go back to what Mr. Hilstrom said. Why was the Michigan efficacy, I think it was--

    Ms. Imme Gerke: No, it was residue. It was proved residue.

    Mr. Rick Borotsik: It was residue. I'm sorry. Why wouldn't Michigan residues be allowed in a similar zone?

    Ms. Imme Gerke: The U.S., Canada, and Mexico have been zoned out now in so-called residue zones. For Canada that part has been established by Statistics Canada. On that map, which overlaps with the United States, Michigan does have a different zone from Ontario.

    Mr. Rick Borotsik: You're saying the reason you couldn't use the residuals is because of the zone differential?

    Ms. Imme Gerke: That's right. It's a different zone, but there's a development on the way, again an international development, to look at the usefulness of zones. As long as they are in place--

    Mr. Rick Borotsik: Do you think I will see in my lifetime harmonization with the U.S. approval system? In my lifetime, will that ever happen?

    Ms. Imme Gerke: Yes, I think so.

    The Chair: Mrs. Ur, very quickly.

    Mrs. Rose-Marie Ur: Yes, I'll do this quickly.

    What is the zone number in Michigan?

    Ms. Imme Gerke: There is 5A, 5B, and 5. I'm never sure which one is which. I just know that Michigan is not the right one.

    Mrs. Rose-Marie Ur: Right. I think we're splitting hairs here. Ontario is deemed zone 5, and when we get into As, Bs, and all the rest, I think we're playing with a little bit of the zone factor. Can you respond to that?

    Ms. Imme Gerke: I don't think you will find any objection. It is just that this is the map that is in place right now. There's work being done on it. Maybe it's just a correction, but there is work being done on that map. As long as that map is the official map, it is what has to be used. There's lots of activity. I shouldn't say it is changing the map and I shouldn't say it is correcting the map. I'm not really sure what to call it. The map is being modified to incorporate it better between Canada and the United States.

    Mrs. Rose-Marie Ur: We have to realize that Ontario and Michigan are very close and the air doesn't stop in the middle of the river. Residues do go back and forth. I don't think a lot of people have passed either way on either side of the border with products.

    That being stated, I have another couple of quick questions before the chairman cuts me off.

    How often has the Pest Management Advisory Committee met over the last three years?

    Ms. Janice Hopkins: It met in November, I believe three or four times.

    Mrs. Rose-Marie Ur: November of what year?

    Ms. Janice Hopkins: November 2002. It's meeting right now. Before that there was a bit of a hiatus.

    Mrs. Rose-Marie Ur: Is the mandate not to meet twice a year?

    Ms. Janice Hopkins: The mandate is indeed to meet twice a year. However, at one point the chair determined that members were extremely interested in the new legislation and determined that the council wouldn't meet until the new legislation was tabled.

    Mrs. Rose-Marie Ur: Okay. This is my final question. Is there a formal liaison committee set up with AAFC to deal with the new minor use programs, and does it meet regularly?

    Mrs. Mary Komarynsky: A liaison committee with PMRA?

    Mrs. Rose-Marie Ur: Yes.

    Mrs. Mary Komarynsky: We have two committees, two working groups, I would call them, and one is on minor use pesticides.

    Do we meet regularly? We have not established formal meetings. We meet on an informal basis, not daily, but we have interaction quite regularly with PMRA. We will be establishing a formal committee for both minor use and risk reduction because of the requirements in our MOU to share work plans and report to a management committee and deputies on our progress.

    Mrs. Rose-Marie Ur: It was brought to my attention that this was discussed in the year 2001. Whether it's a surprise or not that I have this information, I received the information that a liaison committee on the minor use program has been put in place, scheduled to meet for the first time on June 3. I find that interesting.

    Ms. Janice Hopkins: We had to cancel the meeting, obviously.

  (1250)  

    Mrs. Rose-Marie Ur: Yes.

    The Chair: Okay. Let me go to Mr. Hilstrom for one question, and then we will conclude the questioning.

    Mr. Howard Hilstrom: I'd like to send a message to the ministers through the bureaucrats who come on their behalf. The message I'm sending to Minister Vanclief and Minister McLellan is simply that when we quit receiving complaints and concerns from the industry and from farmers, we'll quit calling you before the committee.

    My question is in regard to harmonization. That seems tremendously important. Can you provide the committee with the written agreement, or possibly a memorandum of understanding with the United States, of the precise goal of harmonization, the steps required to achieve that harmonization, and exactly what harmonization means?

    There must be an agreement if you're trying to do it. I think we would study that, and our clerk would....

    You can comment now, but....

    Ms. Janice Hopkins: We'd be happy to do so. There are a number of documents that are published by both EPA and PMRA that describe that. We would be happy to send them to the clerk.

    The Chair: I had a list of questions, but because we have to be in another room very quickly, let me just ask a question in closing. If you were to do a self-analysis of the reporting system, the way the work is going, the progress you've made--I know, Dr. Hopkins, you're here as a replacement, and I must tell you, you're a worthy replacement. We appreciated your presentation and your forthrightness this morning.

    In fact, to all the panellists this morning, could you tell me, out of 10, where are we?

    First of all, to you, Dr. Gerke, you are the reporting person. Obviously the reporting system doesn't go through the system the way we had intended it to and which we recommended, but where do you find yourself in terms of one to ten, ten being the highest?

    Ms. Imme Gerke: Myself?

    The Chair: Yes. How do you feel about the reporting? How well has it been received and how well is it being received by not only the director, to whom you're responsible, Dr. Franklin, but to the farm community itself, or your constituency, which is that broader constituency out there?

    Ms. Imme Gerke: I'm still not sure. Do you mean within the minor use initiative? Do you mean the reporting system toward you? What am I talking about?

    The Chair: I'm asking you how you feel about the reporting and the reception.

    Ms. Imme Gerke: This reporting?

    The Chair: No, the reporting as you're receiving information from your constituency, whether it's farmers or other use groups. How do you feel it's working? Is it working as well as you had hoped, or are you still in expectation of something even better than that?

    Ms. Imme Gerke: I think it is working very well, actually better than I thought, but there are still tools to be put in place.

    The Chair: You had hoped for a 10. Where are you at?

    Ms. Imme Gerke: At seven, seven point five.

    The Chair: Okay, Dr. Hopkins.

    It's an unfair question. It wasn't on the agenda, but I'm putting it to you.

    Ms. Janice Hopkins: I will buy you a coffee after the meeting is over.

    With respect to the minor use initiative, Mr. Chair, I believe we're making progress. I think we still have some distance to go. Where are we at on your scale? Wow. That's not a question that public servants often feel comfortable answering, I'll tell you.

    The Chair: I'm asking you to report here.

    Ms. Janice Hopkins: From my point of view?

    The Chair: Yes, your point of view.

    Ms. Janice Hopkins: All right. I think we're about halfway.

    The Chair: Okay, five.

    What about you coming from Agriculture Canada? Give us your sense.

    Mrs. Mary Komarynsky: I would say that in terms of the last 11 months, the industry would say that up to now we'd probably get very high ratings based on our priority meeting that we had in March and the fact that we will have 540 field trials this summer. That's more than double. So I think at this point they would give us a 10. I think the proof is in the pudding as to how many registrations that will result in, but we haven't finished our cycle.

    The Chair: Thank you very much. I haven't done a score on this, but we are averaging somewhere around eight across the board. That's my number.

    Thank you very much for being so forthright with us this morning. I think you've given us what we have asked for. There is still some information outstanding, which we are asking for. We'd ask that you provide it to the committee.

    Thank you, members, for staying with the table this morning. I think it's important that we get this issue resolved. At this point in time I will adjourn the meeting.