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[Recorded by Electronic Apparatus]

Tuesday, November 16, 1999

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The Chairman (Mr. Charles Caccia (Davenport, Lib.)): We'll start our proceedings of this illustrious committee, which today continues its adventurous exploration of the world of pesticides and the application of the PMRA, which, as we all know now, stands for the Pest Management Regulatory Agency.

Today we are very fortunate to have representatives of the Canadian Public Health Association, the Canadian Institute of Child Health, and the Learning Disabilities Association of Canada. We welcome Barbara McElgunn, representing the Learning Disabilities Association; Sandra Schwartz, of the Canadian Institute of Child Health; and Dr. Bruinsma, of the Canadian Public Health Association.

It is my understanding that you would like to speak in that order. Welcome to the committee. The floor is yours.

Ms. Barbara McElgunn (Health Liaison Officer, Learning Disabilities Association of Canada): Thank you, Mr. Chairman. I'm Barbara McElgunn, and I'm health policy officer for the Learning Disabilities Association of Canada. I have also served on the research committee of the Learning Disabilities Association in the United States for the past twenty years. I've been involved in both associations in urging action on pesticides by the U.S. Environmental Protection Agency—the EPA—and Health Canada to protect children's health and development. I've participated in two OECD expert work groups, preparing draft guidelines for neurotoxicity testing. And I'm also a member of the Pest Management Advisory Council, which first met in November 1998.

In general, I should say the PMAC has only met three times, but in general my impression of PMRA is quite favourable. I do respect the scientists and others working in the agency who are trying to do a great deal with too few resources, gaps in their statutory authority, and too many shared mandates.

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The new legislation amending the Pest Control Products Act contains a number of very necessary changes and additions that are long overdue and badly needed. At our last meeting, the council unanimously agreed that the amendments should go forward. Also, I believe the advisory council should have some positive effect on PMRA policy and its operation, but I will expand on some of these observations later in this presentation.

Because we're the Learning Disabilities Association, we are particularly concerned about pesticides because they are designed to be neurotoxic to pests. That's how they work. Yet until recently—actually, back in the eighties—our agency, our LDA and other organizations in the United States, petitioned the Environmental Protection Agency to require registrants to produce toxicity data on neurotoxicity, which had never been done before. More recently, EPA has taken some actions on this important health end point and on other regulatory issues around possible effects on the developing organ systems in children. In August of this year it published the data call-in, requiring registrants to provide developmental neurotoxicity test data for some classes of pesticides that are designed to be neurotoxic.

I was interested in reading the transcripts of testimony from previous people who have appeared before this committee, particularly Dr. Claire Franklin's testimony, in which she said all pesticides undergo an extensive pre-market assessment before they are allowed to be sold in Canada. This statement is often heard from PMRA, and may be comforting and soothing to the public, but in our view it is not entirely accurate. For example, there are important gaps in the toxicity database for most pesticides, the lack of developmental neurotoxicity test data being one of them.

It is of concern to us that developmental neurotoxicity testing is not mentioned in recent PMRA notices concerning a pending re-evaluation of organic phosphate pesticides that act via neurotoxic action, nor in the draft document pertaining to harmonization of rules with the EPA to protect children's health. In the U.S., however, this testing gap is a major issue that is being addressed.

I would like to draw your attention to two recent scientific reports that underline these concerns. There was a study done in Mexico recently by Dr. Elizabeth Gillette, who looked at children between the ages of four and five. One group was exposed to many pesticides because of farm and home use, and the others who lived in the foothills had virtually no pesticide exposure at all. There were very significant differences between the two groups in both mental and motor abilities. The children from the farm areas were scoring at a much lower level. They had an increase in aggressive behaviour as compared to the matched pesticide-free children living in the foothills. Their play was more likely to be very solitary, and it did not show much play-pretend and that type of thing. So this was kind of important.

Also this year, a team of American and Canadian scientists has found pesticides in the amniotic fluid of unborn babies, at levels that may affect hormones critical to their development, the reproductive system and sexual differentiation. So I think that this whole area should also be looked at by the PMRA.

I think the push for a transparent regulatory system is important, and I think the PMRA is moving in that direction quite quickly. But from my own experience, I find that responding to these opportunities for comment requires a great deal of time and expertise. Those are something many of the NGOs do not have. We might have one staff person who can do it, but this would require much more time than what just one person could afford.

I really feel that if we're going to have a transparent process in which the public is going to be asked to comment on these important proposals for regulation, NGOs need some assistance to be able to afford to have someone on staff who is dedicated to this important work. If they're not going to be responding, then the agency will only be hearing from industry, and it will feel that everything else is all right by everybody else when it probably isn't.

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We also think the PMRA should develop and publish guidelines for risk assessments, as the Environmental Protection Agency has in the United States. I think this helps their risk managers, their risk assessors, and the public to know that sound approaches to risk assessment are maintained by the agency. It could perhaps even adopt some of the EPA risk assessment guidelines, or else modify them. However, they should be there in black and white for everybody to be able to look at and to know what is going to happen in terms of their assessment.

Another area that we think is tremendously important is information on formulants. As you may know, these chemicals may comprise up to 90% of the product. They are used to make the pesticide more potent or easier to use, but they could also have additive or synergistic actions with the active ingredient. In other words, they could make the active ingredient even more potent or they could be toxic in their own right.

In the U.S., more than 26% of formulants have been classified as hazardous to the public and the environment, and they must be listed on the label as “This pesticide contains the toxic formulant XXX.” In Canada, we have no such requirement. If a child is poisoned by a pesticide from the home, one that is used on pets or whatever, a physician might have a lot difficulty finding out what the carrier was or the what so-called inert was.

Since the EPA started to require registrants to label inerts of toxicological concern, the use of inerts for which labelling is required fell 86%, from 57 chemicals in 1987 to 8 in 1997. This shows that this had a really good effect on the industry removing these formulants from their products, because consumers were then making choices as to whether or not they were going to buy a product with a toxic formulant or one with a non-toxic formulant.

In Canada these formulants are protected as CBI, or confidential business information. Under the new Pest Control Products Act, this will unfortunately still be CBI. We very much think this should not be the case. They should be removed from CBI, and the identity of the formulants should be available.

Another issue for us is exposure assessments and information gaps. For this, we would like to give the example of drinking water. A U.S. National Research Council study showed that infants and children consume up to seven times the water that adults consume on a milligram-per-kilogram, body-weight basis. It made a number of recommendations on exposure assessments that should take this fact into consideration.

Water is the major source of pesticide exposure for many children. Yet when Mr. Shantora appeared before your committee, he noted that nobody—no department, agency, or level of government—is really systematically evaluating or monitoring water in Canada. I think this is unacceptable. If we do not have these data, how can Dr. Franklin look at the aggregate total exposure as mandated under the U.S. Food Quality Protection Act, which mandated a number of policies to protect children?

A number of pesticides have been shown to be present in well water. There is a U.S. pesticides in groundwater database, and it reviews data from over 68,000 wells in 45 states. Pesticides were found in more than 16,000 of these wells in 42 states. Nearly 10,000 of these wells had concentrations greater than EPA drinking water standards. The only survey Mr. Shantora knew of—the Ontario well water survey in 1998—found atrazine in one sample to be at 210 parts per billion, which is 40 times the Canadian guideline of 5 parts per billion for atrazine. And atrazine is again being found in 30% of samples of rainwater in Europe.

There was a five-year study of the effects of pesticide groundwater mixture and groundwater levels on rodents at the University of Wisconsin. It found detrimental effects on the immune, endocrine hormonal systems, and the nervous systems of those animals. There were effects replicated many times on thyroid levels and on the immune system, and there was increased aggression in the mice. That is of concern because, if you'll remember, increased aggression was found in the children in the Mexican study.

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I think your committee has looked at the issues of shared mandates and shared responsibilities, and we also have some concerns about those. We feel shared mandates delay or dilute decision-making and responsibilities to the point of inaction. They mean that agencies cannot make a decision on their own in many cases, or cannot be totally responsible, especially when it comes to monitoring and enforcement. Therefore, nothing happens.

The serious gap in drinking water monitoring programs in Canada underscores the findings and recommendations of the Commissioner of the Environment and Sustainable Development. Bilateral agreements or MOUs must designate clear responsibilities and contain some provision for mandatory reporting on issues such as these. There should be a public right to know on drinking water quality in Canada.

My last issue is the budget and programs of the PMRA, and its research and development capability. The commissioner's report also noted that there was a growing gap between the demands placed on federal departments to provide scientific information on toxic substances and their ability to meet existing obligations and to respond to emerging issues. Major budget cuts to scientific programs at Health Canada and Environment Canada have taken place during the last two decades. In its response to the recommendations of the Pesticide Registration Review, the government recommended that the resource requirements of the PMRA would require at least $20 million more per year to implement all of the PRR recommendations. This additional money was more than the budget of the PMRA at the time—$14 million—and this extra funding has not materialized.

We feel the PMRA should receive the increased budget recommended in the government's response to the PRR, and it should develop a new research and development division that has the capacity to undertake independent research in order to fill information gaps such as those relevant to children, aggregate and cumulative exposure, and non-cancer end points such as immune system, endocrine and neuro-developmental effects.

I have a comment on pesticide residues. There was a report recently noted in the Globe and Mail. It was obtained under the Freedom of Information Act, and it said that pesticide residues on produce have more than doubled since 1994. A spokesperson for the Food Inspection Agency was quoted as saying that he had no idea why there was such a huge increase in the rate for identifying pesticide residues, from 10.3% of inspections in 1992-94 to 21.1% from 1994-98.

We really need to know why growers are using more pesticides. Is it because the bugs are becoming more resistant to those pesticides? And we need to know the cumulative effect of several pesticide residues with a similar mode of action on fruits and vegetables consumed in one meal. For example, in this report, twelve pesticide residues were found in shipments of domestic apples. Six of the pesticides that were found are organic phosphate pesticides that are designed specifically to act in a specific way on the nervous system. That would be an example of a cumulative effect. None of the pesticides individually would be above the tolerated level. If you put four together, though, the child is receiving much more than should be received in that particular case.

About half of the violations in residues that exceeded the MRL, the maximum residue level, involve pesticides such as chloropyrifos, for which there is no approved use on the product. Under harmonization agreements, some tolerances have been raised in Canada. As a result, chloropyrifos levels on approved-use products that would have been in violation when the MRL was 0.1 PPM are in compliance now that the MRL is one PPM. This is of real concern.

We think the public should have the right to know the results of residue sampling, via annual reporting from the responsible agency, and what actions are being taken on violations. The PMRA must have the ability to investigate the reasons why pesticide use is increasing.

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In conclusion, Mr. Chairman, we feel that pesticides may very well prove hazardous to the developing brain at exposure levels below those inducing overt effects.

Dr. Bernard Weiss of the University of Rochester has said:

    Despite this enormous store of information on pesticide toxicity, however, and the special concern of the public over the exposure of children, our knowledge of how these potent chemicals might modify the course of brain development is disturbingly sparse.

Dr. Warren Porter, who studied the effects of environmental levels of pesticides in drinking water on the behaviour of mice, was quoted in the Los Angeles Times this year as saying: “Data suggests that we may be raising a generation of children with learning disabilities and hyper-aggression.”

Canada needs a solid pest regulatory system that heeds the precautionary principle and has the resources and the authority it needs to protect the environment and the health and development of Canadians.

Thank you.

The Chairman: Thank you.

Ms. Sandra Schwartz (Director, Environmental Programs, Canadian Institute of Child Health): My name is Sandra Schwartz and I'm here representing the Canadian Institute of Child Health. I work there as their director of environmental programs.

First, let me thank you all for inviting CICH to address this important committee. In our presentation today, we would like to discuss the specific susceptibility of children to the effects of pesticide exposure, preventive action in light of scientific uncertainty, and recommend an approach to setting pesticide standards and registration that takes into account children's unique vulnerability.

Recommendations such as the need for child-specific toxicological testing requirements and risk assessment procedures and the need for further research into low-level multiple exposures and resultant health effects will be examined in depth.

Currently, the pesticide regulation system in Canada does not take explicit account of children's special vulnerabilities. Specific recommendations that recognize children's specific susceptibility to pesticide exposure will be emphasized.

I want to start by addressing the special vulnerability of children. Children are exposed to many chemical pesticides from a wide variety of sources. Barbara has mentioned a few of the studies already, and in our brief we've also outlined the weight of evidence that does exist from numerous studies that have been done to date.

From conception to adolescence, children are more sensitive and more exposed to pesticides than the average adult. On average, children receive greater exposures to pesticides because kilogram for kilogram they eat more food, drink more water, and breathe more air than adults, and their diets are somewhat different from those of adults, particularly at a young age.

Furthermore, depending on their age, children's ability to metabolize, detoxify, and excrete many toxicants is different from that of adults. Exposures at critical periods of development can result in irreversible damage to growing nervous systems and affect emerging behaviour patterns, cause immune dysfunction, and have serious reproductive effects.

In some cases, prolonged exposure may be necessary to induce adverse effects. In other cases, a single exposure at a vulnerable point in time may be sufficient. Thousands of pesticides and other pest control products are registered for use in Canada. A handful of older products, such as DDT, are banned in Canada, but they're still present because of their persistence in the atmosphere and continued use in other parts of the world.

Children can be exposed while pesticides are being sprayed or applied or after they've entered the environment. Pesticides enter the body in three main ways: by swallowing, by breathing, and through skin. An individual child's exposure to pesticides will depend on many different factors, including their place of residence, the types of activities, their age, the occupation of parents or their caregiver, and their eating patterns.

In the brief I've outlined numerous routes by which children are exposed—for example, food, water, air and soil. They're also exposed at the prenatal stage while they're in fetal development as well as through consumer products such as toys. Children's diets are typically higher in the kinds of foods that may carry pesticide residues. For example, a U.S. study indicated that 20 million children, ages five and under, eat an average of eight pesticides a day, every day, which totals more than 2,900 pesticide exposures per child each year from food alone.

Barbara also mentioned water and the significant source of exposure through water. Pesticides can also linger in the air in homes, schools, day cares, etc., because of the vaporizing strips, as well as sprays, baits, and fumigation that are often used for pests like cockroaches. A National Cancer Institute study indicated that children are as much as six times more likely to get childhood leukemia when pesticides are used in the home or garden.

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Through soil or dust, pesticide residues and contaminated dust can often settle on surfaces and products such as toys in the home, to which children can be exposed. Children transfer the contaminated dust and dirt from their hands and toys and then into their mouths because of their frequent hand-to-mouth activity.

Prenatal exposure I have also mentioned. Pesticides can be transferred from a mother's body to a developing fetus or embryo. For example, as Barbara mentioned, concentrations of Lindane and DDE have been found in amniotic fluid. Once again, with consumer products not only do we have to be concerned about the accidents with children ingesting pesticides if they're improperly stored, but children often handle their pets that have been treated for fleas or ticks with powders, shampoos, or collars. Also, the mosquito repellents and head lice shampoos that are often used are also directly applied to children, and these are pesticides as well.

Pesticides can cause a variety of long-term or acute effects, depending on the type of pesticide, the dose, the route of exposure, and the sensitivity of the exposed individual. Exposure to low levels of some pesticides over many months or years can cause cancer, nervous system impairment, immune suppression, infertility, and behavioural and developmental effects. Household use of pesticides has been identified as a risk factor in causing chronic health problems in children, mainly leukemia and brain tumors. Barbara has also mentioned the study done in Mexico, which showed other neuro-developmental effects as well.

Recent evidence indicates that some pesticides at extremely low levels and potentially after only a single exposure can disrupt the body's endocrine system. The developing embryo is particularly sensitive to the effects of these chemicals, as the brain, sexual organs, and other structural elements of the body are dependent on finely-tuned hormone signals for proper development.

There is an urgent need to make children a pesticide policy priority. Despite children's extensive and heightened vulnerability to environmental contaminants, there is currently no coherent risk assessment and management strategy that ensures children grow up safe from exposure to environmental contaminants, and in particular to pesticides. In Canada the pesticide regulation system, as I mentioned, does not take explicit account of children's special vulnerabilities, nor do toxicological testing requirements or risk assessment procedures consider children's susceptibility. Most toxicity testing for pesticides is done on adult animals; therefore, there is little direct information on implications for the young.

Most food sampling for pesticide residues focuses primarily on the diets of adults. Typically most regulations and policies are designed to protect adults and refer to the healthy 70-kilogram male, and not the 7-kilogram child. Thus, standards need to be set that are explicitly protective of children.

Of the following number of recommendations we make, both to this committee as well as in the report that ultimately will come out of this, the first is that exposure from all sources, not just those of dietary origin, should be considered in deriving risk estimates.

Secondly, risk estimation models should be time-sensitive, permitting the earlier, higher exposures to be explicitly considered. Estimating tolerances should explicitly take into account children's higher exposures to certain pesticides and should also take into account the fact that this exposure takes place at a more vulnerable stage than does adult exposure.

Thirdly, because children may be more susceptible to chemicals than adults, and children's exposures to pesticides are different from adults', an additional tenfold margin of safety should be used in setting pesticide tolerances to protect children's health. The provision of a margin of safety is central to preventing children from being exposed to unsafe and unnecessary levels of pesticide residues. The safety factor serves as a buffer against existing uncertainties regarding that exposure and the susceptibility of children to many, if not most, pesticides.

Fourth is development of toxicity testing requirements for pesticides, especially for particular health end points, and specific contaminants and contaminant types—and Barbara mentioned formulants or mixtures—including new tests to assess potential toxic effects of pesticides on the immune system, the nervous system, reproduction and development, and the visual system of children.

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As well, we recommend the creation of an assessment process that attempts to fully capture cumulative exposure. Exposure estimates should not be restricted to estimating the impact of a single pesticide. The cumulative effect of pesticides with a common toxic effect should be taken into account in setting these tolerances.

Future approaches to setting pesticide standards and registration will need to take into account children's unique dietary patterns, developmental stages, and behaviour patterns. In general, standard-setting that is intentionally protective of children must include all available information from clinical and epidemiological studies of health effects in humans, particularly children; apply accurate estimates of children's exposures from all sources and through multiple media; assess effects through the child-developmental lens; and include a broader range of health effects, including endocrine disruption.

Further research into the association between pesticides and child health is essential, especially that which will address long-term and developmental effects, both of which are not sufficiently clear.

There is a need to establish and maintain systems for monitoring the levels of key contaminants that are released into the environment and the levels at which they are found in the body, as well as their possible health effects on children. Monitoring health outcomes and environmental indicators will help build a better understanding of the relationship between exposure to pesticides and health.

Because of the current shortage of data, collecting environmental and pediatric health information should receive increased priority to overcome the information deficit surrounding contaminants and child health. These data, in combination with research findings, will be invaluable to ensure a sound scientific basis for policy initiatives to protect children.

The next two recommendations follow this monitoring system.

The first recommendation is for development of a national survey on children's exposure to pesticides through food, air, water, and dust in homes, schools, daycare facilities, and other areas. This survey would provide direct data on children's pesticide exposure and would also address toxic effects as a function of age, including response as a function of critical periods of neurological and immunological development.

The second recommendation is for development of a national database on pesticide residues and a food monitoring program to compile data on pesticide residues gathered from monitoring of food throughout Canada. This would include monitoring food that is particularly important in children's diets—for example, pears, apples, tomatoes, rice, and peas.

In conclusion, guidelines and objectives for pesticides have to date been based on protecting the health of the average Canadian and have not explicitly considered children's unique exposures and risks. Guidelines and objectives do include safety factors to allow for uncertainties in the scientific information, including effects on children, but there is now evidence that children's exposure and risks from pesticides are different from, and in many cases larger than, adults' because of their physiology and their behaviour.

This suggests that current guidelines and objectives for pesticides should be reviewed to consider the need to explicitly include children's exposures and risks when setting guidelines and objectives.

The Food Quality Protection Act, the 1996 U.S. pesticide reform law, was motivated in part by this particular book, entitled Pesticides in the Diets of Infants and Children, a 1993 National Academy of Sciences study. It found that the regulatory process in the U.S. did not account for children's special vulnerabilities. It recommended that the process be changed to better safeguard the health of infants and children. The law was adopted unanimously, based on the overwhelming evidence presented in that report.

In order to protect Canadian children from pesticide exposure, we need similar child-centred protection strategies within our own government structures. Recommending changes to the Pest Management Regulatory Agency when it conducts risk assessments, determines tolerances for pesticides, and develops risk-reduction policies to include children's environmental health would be one such strategy.

We urge you to include the recommendations made within this report in your review of the management and use of pesticides in Canada and in the development of new pesticide regulations addressing the protection of our most vulnerable population—namely, children.

I'd just like to add that most of the recommendations as well as the information I used to write the brief come from Pesticides in the Diets of Infants and Children as well as a report conducted by the Canadian Environmental Law Association.

Thank you.

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The Chairman: Thank you, Ms. Schwartz.

Ms. Schwartz has also brought to the attention of committee members this article, entitled “How Safe is our Produce?” It's from the March 1999 issue of Consumer Reports. Its subtitle is “Pesticide Report”. For those of you who are interested in a copy, please advise the clerk.

Ms. Schwartz has also written an article entitled “Children First: Environmental contaminant protection policy needs to be rewritten to reflect the needs of our most vulnerable citizens”. Again, you can contact our clerk for a copy.

We will now move swiftly to the last speaker. Dr. Bruinsma, please go ahead.

Dr. Nicole Bruinsma (Canadian Public Health Association): I'm pleased to be here today, on behalf of the Canadian Public Health Association, to provide a public health approach on the use of pesticides in Canada. In so doing I'll identify related public health implications of pesticide use.

Just to give you a bit of background about the Canadian Public Health Association—you can read it in the brief as well—the Canadian Public Health Association is a national, independent, not-for-profit, voluntary organization that represents public health in Canada, with links to the international public health community as well.

CPHA's members believe in universal and equitable access to the basic conditions necessary to achieve health for all Canadians—namely, clean air, clean water, and uncontaminated food.

Environmental health is at the core of public health. As outlined in “A Public Health Approach to Pesticide Use in Canada”, the CPHA has been involved in a wide range of activities in occupational and environmental health. CPHA's background knowledge and experience places it at the centre of discussion on human and ecosystem health.

Pesticides are a public health issue. Pesticides by definition are the only chemicals released into our environment that are specifically designed to kill life. They are used for a variety of reasons, and with a variety of applications.

The applications, as mentioned in the brief, include agricultural applications, which account for about 70% of all use of pesticides in Canada. They're used in buildings, schools, hotels, churches, public buildings, private buildings, and in lawn and golf course management. Depending on which surveys you look at, 30% to 70% of all landowners or lawn owners in Canada use pesticides.

They're used by governments in parks, on roadsides, and under power lines. They're used in industry—in paints, in glues, in fabrics—as preservatives and fungicides.

They're widely available over the counter. You can buy as much as you want of it. Aerosols, foggers, bombs, pest strips—you name it.

Research has shown us that North Americans and Europeans have residues of at least a half dozen persistent toxic chemicals in their bodies. Everywhere we have looked in the human body—in blood, in serum, in semen, in tears, in saliva, in hair, in teeth, in amniotic fluid, even in the fluid that surrounds the follicle of the eggs in the human ovary—we have found pesticide residues. This means that Canadians as well as people worldwide are being exposed to these chemicals that are designed to kill life from even preconception.

Recent studies published in scientific journals suggest strong associations between the use of chemical pesticides and serious health consequences, which we've heard about already this morning—brain cancer, childhood leukemia, and non-Hodgkin's lymphoma.

There are a few characteristics of pesticides I'd like to examine. We've already spoken about the persistence of many of these in our environment. We've spoken briefly about the biomagnification effect where pesticides in agricultural settings, sometimes 99% of them, can drift off target and land on waterways. They are concentrated by plankton in the water. That's eaten by zooplankton, which are eaten by smaller fish, which are eaten by bigger fish. Humans, being at the top of the food chain, can concentrate these toxic chemicals by orders of magnitude of ten to the ninth, which is billions of times.

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So when we find in the rivers of Quebec diazinon in the waters at levels 75 to 300 times the maximum allowable doses recommended by Environment Canada, that's already in the water and we're going to magnify it a billion times when we get to the top of the food chain.

The older pesticides, the organochlorines, were attracted to fats in the human body, so they're not fast-acting, but we do know that they have serious chronic effects in the human body as well as in wildlife, such as cancer, immune suppression, and disruption of hormone function.

The short-term acute effects relate to second-generation pesticides more than the first generation, which are the organophosphates of which you've heard this morning. Many of these side effects are not persistent, but they are acutely toxic and may well have long-term effects. Effects can range from disorientation to spasms, to death.

The World Commission on Health and the Environment estimates that there are 220,000 deaths a year directly attributable to pesticides. Canadian data on pesticide poisoning is a bit sparser, but the Quebec Ministry of the Environment and Wildlife published a report by the Quebec Poison Control Centre in 1997 that indicated that there were 1,650 known cases of pesticide poisoning in Quebec in that year alone.

But let me tell you, when you're working in the emergency room like I do and somebody comes in with non-specific symptoms like vomiting and headache, very many of those will be diagnosed as some sort of a viral illness or who knows what. They'll probably be okay in a few days, and they probably are, but they're not registered as pesticide poisonings. And this number is probably a gross underestimate.

There are also indirect effects from these pesticides. Pesticides place the ecological role of native plants, birds, fish, beneficial insects and other wildlife at risk. Bees, for example, pollinate one-third of all the food we eat.

We are actually destroying 23 billion tonnes of soil per year at a rate that's greater than the soil is being produced on this planet, and most of that is due to poor agricultural practices and poisoning of the soil. Pesticides are not specific to the organism they want to kill. They kill all the billions of micro-organisms in the soil as well, which are essential to provide the productivity of the soil, which is the thing that sustains the very food we eat, that sustains us.

Let me talk a little bit about the long-term chronic effects. According to the World Commission on Health and Environment, they cause cancer, birth defects, and hormone disruption and sterility in over 700,000 people a year. In the last 20 years human sperm counts have decreased by 50%. Hormone-related cancers such as breast cancer, ovarian cancer, prostate cancer and testicular cancer are on an alarming rise.

We used to think that things were toxic only if they caused gross fetal abnormalities, like thalidomide or cancer, but we now know that many of these pesticides, as we've heard this morning, can act as hormone disrupters.

What does that mean? Hormones are messengers that carry crucial messages from one part of our bodies to the other. From the moment of conception to the moment of death, hormones regulate just about every single physiological process within our bodies. Ask any woman who has gone through menopause and she'll tell you.

So if we're messing around with that process of hormones that act in the parts per billion levels, and even some studies have shown that parts per trillion of certain hormones can have measurable effects on the outcome of development, we have to be questioning what sorts of effects the cumulative effect of these thousands of different pesticides that have hormone-disrupting ability are having on us.

There are many at-risk and sensitive populations, as Sandra has pointed out. Although all of us are exposed to pesticides, and very often in ways in which we're unaware, current standards for pesticide testing are generally based on tests done in healthy adult males, as we've heard. It also ignores the concept of synergism, which our first speaker spoke about.

I won't go on again about the effects to children, but it is essential and crucial that we think about it. Breast milk now is the most contaminated food that humans can eat, because it presents a food that is at the very top of the food chain. It's more concentrated than anything we're exposed to because it's already been concentrated one more time in our bodies. And that's the first food we're putting into the mouths of our infants when they're coming out of the womb, at the moment of birth, at a moment when their vulnerabilities are maximal.

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Children's organ systems are not yet developed at birth. They have an inability to detoxify certain chemicals. Their kidneys are not well developed. They can't excrete certain chemicals. Their skin is not quantified yet. They absorb everything through their skin. They are little environmental concentrators, if you will.

We can still recommend to people on a public health basis that breast feeding is still superior to bottle feeding, because breast milk contains all sorts of wonderful things like immunological factors that we can't reproduce in any artificial way and that protect us against infectious diseases at an early age. But to have to weigh the risks of infectious diseases in the short term versus a possible cancer risk to a child later in childhood, or even as an adult—it is unthinkable that we should have to weigh those risks. At this point in time breast feeding still wins out in the balance, but I'm wondering when my daughters have their own babies whether it still will win out in the balance.

There are also multiple-chemical-sensitive people with less than perfect health, including those with asthma or allergies, as well as individuals with a chemical sensitivity, who suffer the effects of pesticide exposure more severely than those without. We have to wonder how those people became so sensitive to begin with too. Is it because of the multiple exposures they've received throughout their fetal and adult life? For such people day-to-day life can present challenges, since there is not often anywhere to hide from the widespread and persistent use of these toxins.

So even though we don't have one clear scientific study that shows us that these things are bad, we have mounting evidence, and many different lines of evidence, that these things are causing adverse health effects.

Let me give you an example for a non-Hodgkins lymphoma. One line of evidence is if you look at the incidence of non-Hodgkins lymphoma over time—it's one of the diseases we don't have a good screening test for, so we can't explain it away by better screening—non-Hodgkins lymphoma has been on the rise at a steady rate of increase in the last 15 years. If you look at the second level of incidence, if you do computer mapping of non-Hodgkins lymphoma in the map of North America—I'd like you to visualize the map of North America in your minds—the rates of non-Hodgkins lymphoma that are the highest are in the mid-west, and there'd be a big red line along the mid-west where pesticide use is the highest.

The third line of evidence is that we have animal model studies for non-Hodgkins lymphoma in dogs, canine sarcoma, which is very similar to non-Hodgkins lymphoma. We know that dogs whose owners use pesticides are five times more likely to die of sarcoma. We have that from veterinary records. So that's the third line of evidence.

The fourth line of evidence is if we look inside our own bodies. If you look at patients with non-Hodgkins lymphoma, they have a very peculiar gene mutation on one of their chromosomes. It's when one of the genes actually lifts out of the DNA amd turns itself around, which is called an inversion mutation. It's very rare. We find it in non-Hodgkins lymphoma. Where else do we find it? We find it in those people who have had the greatest exposure to pesticides. We find it in workers who handle concentrated technical formulations, in farmers and other agriculture workers, in exterminators, in pesticide applicators, in lawn and golf-course owners, and in Vietnam War veterans who have been exposed to large doses of 2,4-D or Agent Orange in the Vietnam War. And 2,4-D—

The Chairman: May I ask you to conclude please.

Dr. Nicole Bruinsma: —is found in one of the most common weed killers that we have in North America: Weed N' Feed.

So if you look at all those things independently they don't amount to much, but if you take all of the lines of evidence together it creates a convincing story.

There are alternatives. There are successful organic farms. Organic farming has become the one of the fastest-rising industries in Canada.

The risk to public health can be discussed within the context of current pesticide legislation. A recent report by the Commissioner of the Environment and Sustainable Development in 1999 focused on the lack of adequate monitoring, assessing, and managing of pesticides by the federal government. Risk assessments have taken five years to complete, and to date only 31 substances or groups of substances have been conclusively assessed for toxicity and risk under CEPA.

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The CPHA recommends the implementation of the precautionary principle when considering new registration or reregistration of pesticides.

I'm going to give you the example of cigarette smoke. In 1964 the Surgeon General of the U.S. stood up and said that cigarette smoke is related to lung cancer. He only had partial but good evidence on which to make that statement. We have a large weight of evidence now. We can wait for more and more evidence, but we need to take action now, using the precautionary principle. I think if you look at human breast milk, there's no better argument than that for the precautionary principle.

Second, the Canadian Public Health Association recommends that the federal government allocate funds to mount a public education program to inform the Canadian public about the risks of pesticides and other toxins as well as the benefits of alternatives. The rationale for this necessary public education and research is that increasing numbers of Canadians are exposed to pesticides on a daily basis either at work or in their homes. Consumer education would help, for example, to demystify the notion that a product is better tasting or more nutritional or that lawns need to be a monoculture of Kentucky bluegrass.

Third, the Canadian Public Health Association recommends that the federal government provide funds for research into alternatives to chemical pesticides as well as funds to promote the existing alternatives, such as integrated pest management and organic farming.

Fourth, the Canadian Public Health Association recommends that the federal government provide leadership at the national level that will assist all Canadians in a move toward a chemical-free environment, given that there are successful examples both municipally in Quebec and provincially of strategies to effectively regulate and reduce chemical pesticide use. In other words, if people are informed, they'll make the right choices.

The Canadian Public Health Association also believes that the following recommendations regarding pesticide regulation and registration as well as the review and re-evaluation of currently registered pesticides would improve the efficiency and accountability of the PMRA in protecting the health of Canadians.

Occupational exposure to pesticides must be regulated under federal guidelines. The Workplace Hazardous Materials Information System, WHMIS, should be extended to cover chemical pesticides.

The over-the-counter sale of chemical pesticides should be drastically reduced and controlled through a much stricter regulation process.

Those pesticides known to be hormone disrupting should be regulated for immediate phase out. There are approximately two dozen pesticides that are considered to be endocrine disrupters, most of which are registered for use on food crops. Those that haven't been tested for this property should be tested immediately.

The Canadian Public Health Association recommends that the maximum residue limits for food products set by Health Canada in order to protect human health, especially children's health, should be reassessed. The tenfold safety factor has already been put in place by the Food Quality Protection Act in the United States, and we need to follow quickly. The rationale is that most of our foods come into contact with pesticides, and the precautionary principle should be followed.

In conclusion, the weight of evidence from different lines of inquiry into the adverse effects of pesticides on human health is mounting rapidly. In light of this evidence it is the position of the Canadian Public Health Association that the precautionary principle should be practised and that all efforts should be made to reduce and eliminate where possible the use of chemical pesticides. The Canadian Public Health Association advises the implementation of alternatives to their use as soon as possible.

More research is needed in the area of pesticide alternatives, as well as in the area of policy and public education programs development. This important research will provide for a Canadian public that is informed about the risks, options, and alternatives to the chemical use of pesticides.

On behalf of the Canadian Public Health Association, I'd like to thank you for the opportunity to present this brief before you today.

The Chairman: Thank you, Dr. Bruinsma.

Against this cheerful background, we can start with Mr. Jaffer, followed by Madam Girard-Bujold, Mr. Lincoln, and Mr. Reed. Welcome, Mr. Jaffer.

Mr. Rahim Jaffer (Edmonton—Strathcona, Ref.): Thank you, Mr. Chairman.

I have one big question, and I think I'll direct it to our first speaker, Barbara McElgunn. Then if any of the other presenters want to make comments on that question, that's fine.

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I appreciate all of you taking the time to bring this information in front of the committee. I find it very useful, especially the information about the effect of pesticides on young people.

Some may argue that I was maybe affected by pesticides at a young age, since I entered politics at such a young age. But maybe that's neither here nor there.

One of the things you suggested, Barbara, which I think all of the presenters suggested, was strengthening the PMRA and focusing on research in that area when it comes to the effects of pesticides.

One of the things that was brought to my attention was that the companies producing many of these pesticides have an interest in not only selling their products but also in making sure they're safe to some extent. One of the fears I have is that if you focus strictly on strengthening government resources in order to put a check on industry, it can sometimes have negative effects.

What I would like to hear your comments on, because none of you mentioned it directly, is what sorts of cooperative approaches can be taken. Maybe they're already there and I'm not aware of them. Instead of just looking at increasing resources and money for PMRA, maybe there are some cooperative efforts that can be made by that particular organization in its current state with some of these companies that are already doing research on pesticides and looking to produce products that are less harmful to the public. Maybe there are some cost advantages in going about it in that way. I'd like to hear your comments on that. I didn't really hear anything about taking a cooperative approach, so to speak, with industry in dealing with this issue.

The Chairman: Because there are many questioners, I would invite short answers as well as short questions.

Mr. Rahim Jaffer: That is the only question I have, Mr. Chairman.

The Chairman: Ms McElgunn, please.

Ms. Barbara McElgunn: It's very difficult with a regulatory agency. The regulatory agency has to have authority. I think trying to achieve too much of a cooperative relationship or partnership with the industry is not in the public interest.

What I see in terms of PMRA is the opposite. If you look at what the EPA is doing and at the language of EPA rules, you'll see that PMRA uses the word “request” a lot, while the EPA uses the word “require” a lot. The EPA is looking at the reregistration of pesticides, while PMRA is looking at re-evaluation. Now, those words have different weights.

I think from some of our perspectives the relationship between PMRA and the industry has been far too collegial. I think a regulatory agency has to have authority. It also has to have the ability to do independent research. The industry is not going to look at new health end points unless they have to. It is not in their interest. In terms of the reporting of adverse effects, for instance, if they're not required to report adverse effects, they are not going to report them. This is something we really want to see in the new legislation, where there is a requirement.

In the U.S. there was one company that had 1,000 adverse effects reports that they didn't tell the EPA about. I think it was from a dog flea collar. The EPA turned around and fined them $1 million. This was a benefit to the EPA in terms of their finances, but it also gave the industry more than a slap on the wrist, which is all PMRA can do now in terms of their ability to fine people who are not acting well.

I'm not saying the industry is bad in all respects, but I think there has to be a watchdog approach to what the industry is producing and how they're using it.

With regard to cooperation in terms of alternatives, I think PMRA can give some faster-track evaluations for safer alternatives. This is being done by the EPA, and I think PMRA is looking at it. In other words, if you come along with a pesticide that's not as toxic, we will see if we can evaluate that more quickly and make it a little easier to get it onstream. I think that's one example where they can use a cooperative approach for everybody's benefit.

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Mr. Rahim Jaffer: That's the only question I had.

The Chairman: Second round, perhaps?

Mr. Rahim Jaffer: Sure.


The Chairman: Ms. Girard-Bujold, five minutes, please.

Ms. Jocelyne Girard-Bujold (Jonquière, BQ): The three of you have said in your presentation this morning that, when pesticides are certified in Canada, the process is not cautious enough, and inadequate precautions are taken. You also state that we currently have no statistics on pesticide regulation in Canada, including children's special vulnerability.

Ms. Bruinsma, you talked about the process in Quebec. You said that statistics exist in Quebec, while they are very difficult to find elsewhere in Canada.

Given what you have said to us this morning, what can Canada do to improve the process, to take into account the fact that these pesticides have extraordinarily serious impacts on children and women? You say that the government should take very specific measures. If today the government decided to make very stringent recommendations, what effect would that have on people's health? What should such studies be based on, and why should they be carried out? Thank you.


Dr. Nicole Bruinsma: I think Sandra already talked about developing a sound scientific basis for policy in terms of much more research being needed, but what we already know provides sufficient basis for some action. Even before we do any more studies, the public will take what we already know and will intuitively feel this is a bad thing.

The example you'll be hearing about next week involves some municipalities in Chelsea. After public discussion about the use of pesticides, they asked their municipal councils to pass a bylaw that bans the use of these things for cosmetic uses.

No rational person, no rational parent faced with the kind of data that Sandra talked about—you have a sixfold increased incidence of childhood leukemia if you use pesticides on your lawn—will use pesticides on their lawn if they're faced with that information. The problem is that they don't know that information. That's why we are recommending a massive public education campaign on the harmful effects of pesticides. When people are informed, they then won't think these are very strict regulations. They will be asking the government. Those who are in the know already are asking the federal government to pass that sort of legislation.

So, yes, we need more research, but we can't let that delay what we already know. As I said, when you're doing a cost-benefit analysis, when you're looking at the cosmetic use of pesticides in home and garden, we know there's a cost. We know there are health effects in the use of pesticides. What are the benefits? It's a cosmetic benefit. How can you balance those two things? You cannot in the cosmetic use of pesticides. No rational person would use them if faced with the evidence we have already.

In the agricultural setting it's a different story, because the cost is much higher. You can't stop all use of pesticides now, because it would be a disaster. But we can use things like integrated pest management as stepping stones to the phase-out of pesticides.

Ms. Sandra Schwartz: Just to give a couple ways of thinking about this, as Nicole was saying on the cosmetic use of pesticides, dandelions don't kill. If you give an example like that, communities are sort of beginning to understand that idea. We see it across Canada, and Chelsea is one example. I was up in Thunder Bay on Friday. That's another example of a community that really wants to get some movement from their own local community, but also by getting the government involved so that there are no pesticides being applied to playgrounds and school grounds, etc.

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Once there is the education of the consumers on these issues, they just stand up and ask what they can do to make changes. They want to know even at a federal level how to get changes made, not just at their own local level. They want to see it go beyond that.

I would agree with what Nicole is saying. No, you can't stop it completely, because it would be disastrous, but finding alternatives and certainly supporting the organic farmers across Canada is another way, as is integrated pest management. We recognize that, yes, organic food is very expensive now, but if more of us buy it, it's just simply supply and demand and the prices will go down. But we also need to start encouraging that from the federal government level.


The Chairman: Thank you. Ms. Girard-Bujold, you can come back during the second round.


Mr. Lincoln, Mr. Reed, and Mr. Jordan, and then the chair, unless there are others.

Mr. Clifford Lincoln (Lac-Saint-Louis, Lib.): I have a couple of questions about risk.

The Auditor General pointed out that an “acceptable risk” is not defined in the legislation, the regulations, or any formal document. I look at the proposals of the PMRA for the revised act, at the latest formulation they have, and again we are back to what is acceptable and not acceptable. The product must be registered “if risks and value are acceptable”, and the application must be denied “if any one of risks or value are not acceptable”. That is extremely subjective.

I wonder, if organizations such as your own don't agree that we need a formulation, a definition of what is acceptable and unacceptable based on the highest possible risk, which is children and babies, if you would be good enough at getting your brains and experience together, formulate some sort of a suggestion for a definition that we could perhaps pass on to the PMRA as something from an independent group that has really studied the issue much more than we do.

It seems to me that this is the key to everything. There are many references made to the fact that the minister must initiate a special review if there is reason to believe the risks or value may not be acceptable, and references to who decides all this. I would really appreciate it if by any chance you could produce something.

My second question has to do with the question of CBIs. From all I've read, we're sure that if information is public and in a form the public can understand, chemical pesticides are going to be in far less use than they are now. But again I look at the suggestions in the newly suggested act, the latest version that has come to us, and they don't give too much room for comfort, because there are so many exceptions for the CBIs. It says:

    Regulations would specify the definition of CBI, e.g.:

      —manufacturing or quality control processes relating to pest control products;

      —methods for determining the formulation of a pest control product, including the identity or concentration of its components;

      —the identify or concentration of components, other than active ingredients, of pest control products, unless disclosure is expressly required under this Act or any other Act.

It seems to me that we have left a huge door open for manufacturers to just invoke CBIs on formulation and on just about everything. When we think about the fact that there are 6,000 formulated products and something like 600 active ingredients, it seems to me.... Again, perhaps you could tell us if your advisory committee has had some hope in convincing the PMRA that this is just not good enough. It makes a farce of public disclosure.

Ms. Barbara McElgunn: Mr. Lincoln, I brought this forcefully to the PMAC meeting, when we looked at the proposed legislative proposals under the CBI. They referred me to the solicitor who helped to draft these. He was there in the room, and he wanted to assure me that just because it's CBI, that does not mean the PMRA could not pass a regulation that would require the registrant to label the toxic ones. I find this really hard to believe, and I would like to go back—

Mr. Clifford Lincoln: So do I.

Ms. Barbara McElgunn: —to look at it again. He seemed to feel that having this under CBI did not preclude the PMRA from requiring labelling. I really would like to have a second opinion on this, if I could find another environmental lawyer. Perhaps I could ask CELA what they think about this issue. I think it's an extremely important one to consumers because these are exactly the pesticides that are used in the home.

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Mr. Clifford Lincoln: It might be nice if there were fewer lawyers and more health practitioners deciding these things.

Ms. Barbara McElgunn: Yes.

The Chairman: Thank you.

Mr. Reed, followed by Mr. Jordan.

Mr. Julian Reed (Halton, Lib.): Thank you, Mr. Chairman.

A few years ago a neighbour of mine half a mile up the road from my farm had a bumper crop of pears. He took those pears to a flea market that is held weekly in a community not too far from where I live. The flea market sells produce. People go there, set up stands, and sell fruit and vegetables and so on. There's a produce inspector who looks at the products as they come in. When he discovered that those pears had not been sprayed he would not allow them on the premises for sale. I relate this little anecdote just to point out that education can't stop with the general public. It has to prevail with people who have some power to say yea or nay in situations like that.

I suppose the dilemma that we see in the general public is what pest level the public is prepared to tolerate. Will you buy an apple with a worm in it, or two? Or will you buy a dozen cobs of sweet corn with the off chance that there'll be a corn borer in the centre? I grow sweet corn at home, and I don't spray it for anything, so I always get some corn borers. I share the sweet corn with the borers. When we harvest that corn, we break off the cobs with the worms in it and put them back in the land. But what is the level of public tolerance for imperfection when the housewife goes to the supermarket and expects perfection?

A voice: Or the husband goes to the supermarket.

Mr. Julian Reed: Or the husband goes to the supermarket, yes, that's right.

A voice: I can tell you, Julian, I don't do the shopping very often.

Mr. Julian Reed: I do my own shopping.

This is a bit of a dilemma, and it has been for many years. We've come through a metamorphosis in terms of pest control over generations. When I was a little kid, we sprayed heavy metals on apples—arsenic, lead, and so on. When I got to agricultural college, we had found a solution, and it was mercury that we were spraying. Now we're into chlorines and organophosphates and so on. I just say that to demonstrate the kind of dilemma we face here.

I wonder if you have any comments about biodegradable pesticides or pesticides that come from plants. There are plant extracts—pyrethrins and so on—that are plant derivatives and presumably break down after they've done their work. Do you have any comments or feelings about that?

Ms. Barbara McElgunn: There are some concerns about some of the pyrethrins. Some of them have been found to increase seizure activity in animal models, so people buying pyrethrins in thinking that they're preferably innocuous are probably being misinformed to some extent. They may be somewhat safer, but not all of them are completely safe.

There are pheromones, hormones that trick bugs into not copulating or copulating at the wrong time, and they might have quite a lot of use in this regard. There needs to be a massive research focus on alternatives. It's not there right now, and I think it is urgently needed if we are going to get rid of these things.

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Dr. Nicole Bruinsma: I agree. Organic farming is very management- and knowledge-intensive. It takes a long time to learn about companion planting and crop rotation and what you should be planting next to what to prevent infestations of what. All of those things require a great deal of education. It's much easier to call up your local pest control person and say you have this problem, and the guy will be there the next day and solve your problem. We need not only to educate the public but also to educate farmers into alternative methods that are not as destructive.

Mr. Julian Reed: I suggest to you that many farmers are fairly up to speed on those options. It's then a matter of relating the input cost and what the public is prepared to pay for the end product and also the recognition that this end product is not necessarily 100% perfect. There may be a little green worm in the broccoli. We deal with it all the time at home. So what? We're used to it. But when the average person picks up a head of broccoli at the supermarket they don't expect to get one floating in the rinse water.

Dr. Nicole Bruinsma: That's where public education comes in.

Mr. Julian Reed: Thank you, Mr. Chairman.

The Chairman: Mr. Jordan.

Mr. Joe Jordan (Leeds—Grenville, Lib.): I want to thank my colleague for his Bore War stories. You learn something new every day.

Mr. Julian Reed: I'm older than you are.

Mr. Joe Jordan: There's no pension in it for you, though.

Dr. Bruinsma, I want to pick up on what Julian was talking about, and that is, eventually this argument ends up being an economic argument. You talk about the precautionary principle, but I draw your attention to the fact that the term “cost effective” is in there, so we can't get around that.

Clearly, the situation you're describing is extremely serious and we need to take action. But how do we take action, given the pressures of the economic market we're dealing in? You talk about this inversion mutation in DNA and the fact that it is higher in certain occupations. Is that a test that could be done on people?

Dr. Nicole Bruinsma: Yes, it's very costly. It wouldn't be used as a screening test.

Mr. Joe Jordan: What would be the cost of that? Do you have to extract DNA and then analyse it?

Dr. Nicole Bruinsma: Yes. It's like looking for BRCA1 and BRCA2 mutations in breast cancer. The average time before the laboratory can come up with an answer is eight to twelve months of searching your genome for that mutation. So this is used for research purposes only.

Mr. Joe Jordan: Do they have enough data on that to be able to extrapolate, with certainty, that farmers have a certain percentage higher incidence of this?

Dr. Nicole Bruinsma: Of that particular mutation, yes. Our understanding of cancer has changed over time. We used to think that if something caused a mutation, it must cause cancer. Now we know that you may not only need one mutation, you might need eight mutations before you actually get runaway cell growth. You may need one mutation plus some promoting factors like endocrine disrupters to cause cancer. So just because you have that mutation doesn't mean you're going to get cancer. It's just like having both BRCA1 and BRCA2 gene mutations doesn't mean with 100% certainty that you will develop breast cancer. It gives you an 85% lifetime chance of developing breast cancer.

Mr. Joe Jordan: But it does represent critical evidence of significant intervention in your DNA, doesn't it?

Dr. Nicole Bruinsma: Yes.

Mr. Joe Jordan: The reason I'm saying that is I think that sort of thing might get farmers' attention.

On the economics of it, though, Julian talked about the input cost. Organic farming is certainly knowledged-based; it's also labour-based. There is the potential to address some of the employment problems in rural areas through organic farming. But we have to make sure that farm security, income security, is taken care of so that it doesn't cost the producer any money to do it, so the economics of the situation would say it won't. I think we need to look in that direction.

The other argument that's used is that products imported from other countries with lower standards are better looking and selling cheaper in the supermarkets, so therefore that's putting pressure on the agricultural community as well. So we have to look at how we address the economics of making it happen.

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As Julian says, I don't think you would get much argument from farmers if their income security is taken care of. Given that we're hearing all about the farm crisis, there's a lot of pressure on these people.

I want to ask Barbara a question, because she has some experience in Canada and the United States.

One of the issues the industry groups have noted is that our regulations take too long and are too cumbersome. If we could set a good standard, is there any logic to harmonization with the EPA? Are we now duplicating...? Are we refusing to accept their research?

If industry's concern is really the timelines, and if we take them at their word that they're not interested in causing detrimental effects to people's health, should we be looking at North American harmonization—and if not, global harmonization? At least in terms of our largest trading partners, perhaps we could get some cooperation at that level.

Ms. Barbara McElgunn: Certainly PMRA and EPA are doing joint re-evaluations and PMRA is using the EPA data on re-evaluations. Nevertheless, they have to spend a bit of time looking at that to make sure everything is fine. And I think EPA is looking at using some of PMRA's evaluations and they're trying to harmonize the toxicity data set they will be using.

My concern is that EPA has published its core data regulations in 40 CFR, part 158. Health Canada or PMRA has not published its core data regulations, so it's not as clear to all of us that this might not be somewhat arbitrary. In other words, for one pesticide you'd perhaps forget this and that. EPA is saying we need this set for every pesticide; we may ask for more, but this is the baseline and this is where we think we need some baseline sets from PMRA, in writing, either in the new legislation or at least in the regulations, so that everybody knows what the playing field is comprised of in terms of toxicity data requirements.

I do think there's a lot of cooperation between EPA and PMRA. On tolerances and water, they're quite different right now, although the tolerances have been changed. PMRA had to change it, as I mentioned, for chloropyrifos, which was a concern to me. They changed it from 0.1 parts per million to 1.0 part per million to harmonize with the U.S.

I also understand, from listening to some of the crop producers in the west, that they couldn't sell canola because they used Lindane, and the U.S. does not allow Lindane on canola. So there are different things like this that vary from country to country.

I really don't think Lindane should be allowed on anything, because it's one of the chlorinated pesticides...especially in children's Quell shampoo.

There is a lot of cooperation going on, and I don't think the industry should really feel they are treated any better or any worse in Canada than in the United States.

The Chairman: Thank you, Mr. Jordan.

Before we start the second round, let me ask you a few questions briefly.

My first question has to do with your reference, Ms. McElgunn, to the proposed legislation on page 3 of your brief. When you speak of proposed legislation under the information on formulants, which legislation are you referring to?

Ms. Barbara McElgunn: I was talking about the amendments to the Pest Control Products Act, which are in the process now. We hope in this sitting or the next they will be brought forward by Mr. Rock, probably with some recommendations from your committee. We hope that will change the CBI on formulants and perhaps change some other things you've heard.

As I said before, the Pest Management Advisory Council did in general terms approve of the way it is now. It's light-years ahead of the old 1969 one. It does give PMAC more authority in various areas where they need it, more public right to know, etc.

The Chairman: Have you seen that proposed legislation?

Ms. Barbara McElgunn: No, we've just had the outline Mr. Lincoln referred to, which gives a broad scoping.

The Chairman: The outline consists of how many pages? And what date does it carry?

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Ms. Barbara McElgunn: I have it here. It's dated January 1999 and it is 27 pages long.

The Chairman: It was given to you in January of this year?

Ms. Barbara McElgunn: I believe we received it this year, yes, probably later than January, though. I think it was in the spring of this year. We had a very sketchy outline of the amendments to the Pest Control Products Act and we asked for more information. We said we couldn't make any decisions or any comments on something that was quite sketchy, so we were supplied with this, but it's not actually the wording of the legislation.

The Chairman: My next question is for Ms. Schwartz. You refer on page 8 of your brief to the fact that most regulations and policies are designed to protect adults and refer to the healthy 70-kilogram male and not the 7-kilogram child. You have this qualifier for most regulations.

Would you elaborate, when you say that most regulations you are referring to expand on the application of this sample male of 70 kilograms. Evidently what you are saying here is that the regulations are designed with an adult in mind. You are saying “most” regulations. Which regulations do not take into account the adult male, but possibly take into account the 7-kilogram child?

Ms. Sandra Schwartz: When it says “most” regulations, it would refer to most of the regulations that exist, like CEPA, for example, and several of the other acts, such as the Pest Control Products Act. The older acts certainly do not take into account children. The new acts, such as CEPA, still don't explicitly state anywhere that children are a more vulnerable population. There's no particular environmental regulation or act that specifically takes into account children.

The policies and the regulations are based on the risk assessments that are done. And the risk assessments themselves generally keep in mind the 70-kilogram, 25-year-old healthy adult male. They're not really doing any research necessarily on the young. Certainly, risk assessments are conducted on fetal exposures, but not on the young offspring of these animal studies.

The Chairman: Is it the same case in the United States? Is it the same in the EPA?

Ms. Sandra Schwartz: It was, but to my knowledge that has changed. It changed, particularly with the study that was conducted, which I referred to.

The Chairman: Thank you.

Finally, this is a question to anyone who wishes to answer it. If this policy were to be promulgated in the form of an invitation to the public at large and to the users to cut pesticides by half, as a first step toward an improvement on what we have now, what would be the net effect of it, in your opinion? It would be a policy addressing all the users of pesticides, not just in agriculture. In your opinion, what would be the net effect of an invitation to cut in half the current use?

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I'm asking this because it is a very simple message that everybody would understand. It may be accepted or it may not be accepted. I don't know. This is why I'm asking the question.

Dr. Nicole Bruinsma: I can start.

Such a measure with a lack of public education prior to such a measure would not make any sense, because it would be a bolt of lightning from the blue. Most people haven't ever given pesticides a second thought, so why suddenly would the government say we're going to cut all pesticide use in half?

Where we have to start is massive public education, just as we did for smoking. Smoking is a bad thing. Second-hand smoke is a bad thing. We got smoke out of all public places, out of airplanes, and out of people's homes long before we had actually identified the mutation P52 on B chromosome that links definitively cigarette smoke with lung cancer. We have that level of evidence now.

We don't have that for pesticides, but as I said before, we have lots of evidence that I think is sufficient to convince people, the public at large, that wide-scale changes should be made. As a government, we can't impose that on unknowing people. People have to be informed first. That would be my opinion.

The Chairman: Thank you.

Second round, Madame Girard-Bujold.


Ms. Jocelyne Girard-Bujold: Ms. Bruinsma, in your presentation you stated that 31 substances or groups of substances had been assessed to date, while there were over 500 pesticides on the market. That is a huge number. Many of them are obsolete, but have still been there for years. What must the federal government do to ensure that all these pesticides are analyzed as quickly as possible? And why must this be done quickly? And what must ARLA do for the federal government to provide the money to analyze those 500 pesticides?

You have told us exactly what is happening—how health and other factors are being affected. However, we note that there is no will to take action. Please tell the committee how the government can take action today, and not at a later date. Must the government allocate funding to this? Should it use studies carried out in other countries? What should it do to reverse its current position and ensure that these pesticides are finally analyzed? Thank you.


Dr. Nicole Bruinsma: The cost associated with all of the testing that was suggested by the Canadian Institute of Child Health is huge. And we all know government has no funds, or very little. The funds are with the industry.

Perhaps, as you were saying before, there needs to be some level of cooperation, in that perhaps the industry can bear certain costs of this sort of testing. But the government has to provide the framework in which that testing is done. We can no longer accept tests from industry that say, “This doesn't cause any gross fetal abnormalities and it doesn't cause cancer; therefore it's safe.”

We have to provide them with the animal models they need to use on their tests. Does it cause endocrine disruption in the development of frogs? Does it cause adverse effects on brain development in rats? Those are the types of requirements we need to give to industry. We need to say, “You've passed this test. Fine, it doesn't cause cancer in adult rats after one day of exposure and harvesting them six months later. But what about long-term studies? Have you done these studies; have you done these studies?” And there should be a list of studies that industry must complete before any of those things are even considered.

We do that for drugs all the time in the pharmacy industry. It's the pharmaceutical responsibility to show they've done adequate testing. As the government, we don't necessarily need to bear the costs of all that testing, but we need to require the industry to provide that sort of testing. That sort of testing is not being done.

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Ms. Sandra Schwartz: I'll add to what Nicole is saying. In fact I would like to see a system similar to what's set up in the U.S. through the Agency for Toxic Substances and Disease Registry, which do the superfund sites. Now, the superfund is specific to toxic site cleanups. The fund was created through industry money. The industry had to put in funds for the cleanup.

I still believe much of the research ought to be done by government, but perhaps industry needs to help pay for that. There needs to be a fund in order for that research to take place. If we have only industry doing that research, there's going to be a bias that goes along with that.

One thing that I think is really important, and something I got from reading the commissioner's report, is the question that remains in my mind: Who is the client? Is the client the pesticide manufacturer, or the Canadian public? The client ought to be the Canadian public.

When we're doing registration or some of the reregistration is going on or some of the re-evaluation is taking place, it ought to be the government that does some of that research. But it should not necessarily be paid for only by the Canadian public. Industry as well needs to take on some of that responsibility.

Ms. Barbara McElgunn: May I just say that right now industry does pay for the toxicological data. They have to provide it, and they pay for it.

In terms of re-evaluations in the United States, if they want to have their reregistration, they have to pay up front. I'm not sure what PMRA is doing in terms of reregistration.

As you say, there's a big backlog. There are a lot of chemicals out there that haven't been assessed properly. I think increasing PMRA's budget and giving them more evaluators and risk assessors might help quite a lot and also in terms of producing safer pesticides.

Ms. Sandra Schwartz: Just on the cooperation note, I think it's vital that when we talk about cooperation, we speak also about cooperation with the Canadian public. It's fine to have cooperation between government and industry, but the public also needs to be involved in that. What that means is that there needs to be a public right to know. We need to know what it is we're purchasing. Whether it means a label on a product or an education process, we need to be part of that as well.

The pesticide manufacturers put an awful lot of pressure on Canadian farmers to use their products. They also put a lot of pressure on the Canadian government to register those products. That system needs to change. We need to put more balance back into that power structure in order for this to really work well. That comes, I think, from making industry pay for some of that, over and above what they currently do. There perhaps needs to be a fund created.

The Chairman: Mr. Lincoln.

Mr. Clifford Lincoln: I would like to follow up on the issue of risk and registration.

You mentioned, Mrs. McElgunn, that provided the CBI was revised, this outline might be satisfactory. Maybe I misunderstood you. To start with, in the outline for a 1999 act or whenever, the definition of the precautionary principle is extremely worrying. It says:

    Diverse and conflicting interests in relation to pest management must be balanced within the regulatory system in a way that is consistent with the overall public well-being.

I find that to be pretty weak.

Then you go on to the health and environmental risks and value and say it would be defined in the act. But when I look at the definitions where they mention what is acceptable and not acceptable, they don't mention anything about multiple exposures or aggregate exposures, which are key to proper registration in the future.

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I'm really worried that we are back on the same track where we're going to say we're going to examine and assess one particular product without having a look at group exposure, multiple exposures, and aggregate exposures. I'm wondering if we are back to the same thing, especially in giving a weak definition of what is supposed to be the precautionary principle, whereas we should be reversing the onus onto the producer to show that there are now aggregate exposures, multiple exposures, or the possibility of endocrine-disrupting factions in the various formulants. I'm wondering whether you agree that this thing seems very weak the way it is.

Ms. Barbara McElgunn: I would agree, and we have pushed to have children mentioned in the preamble. I think that was part of our brief I didn't have time to go over today. We really think any action should be based on the most sensitive group in the population, and that is usually children. We think that should be in the preamble. I think that would go a long way toward looking at all these other things.

The other recommendation we made—and I didn't read the summary on the last page of our brief—is that PMRA should develop guidelines for risk assessment that are similar to those of the EPA. The EPA is now developing a guideline for cumulative exposures. They bring scientists together, and they decide how they're going to address it. All their risk managers and risk assessors have to follow the guidelines. They'll have them on cumulative, aggregates, neurotoxicity testing, cancer end points, and so on.

These are quite large documents. You can't get it all into the legislation, but it can come into the regulation and the guidelines. I think these would be very helpful, and they're absolutely necessary.

I agree with you that in looking at the legislation it's very unclear as to whether or not health protection is really there. It doesn't even say that the minister or PMRA can request or require new data. I think the words are very wishy-washy.

Mr. Clifford Lincoln: It says that they may.

Ms. Barbara McElgunn: I wish I could remember exactly how it was worded. I was looking at it the other day.

Mr. Clifford Lincoln: It says “could require registrant to submit provincial/territorial sales figures”.

Ms. Barbara McElgunn: Well, “require” is there, so that's good. That's a change in the right direction.

But I think the whole tone and culture have been to sort of make everyone happy, the registrants happy and the public happy. I think that's what they're trying to balance the need for these pesticides and also the need for health protection. I think the need for pesticides has sort of overruled the need for health protection in terms of the language of the act. I think the need for health protection should be number one in the preamble, and we made that comment as well.

Mr. Clifford Lincoln: If I may suggest, I think the reference to children shouldn't be in the preamble. It should be in the definition. If you have it in the preamble, it's not part of the operation of the bill. I think it should be in the main definition.

Also, I agree with you that you can't put everything in the definition, but if the definition refers to the guidelines you're going to set up, then at least there's a reference.

We questioned Dr. Franklin, and she told us that they were considering cumulative effects, aggregate effects, and multiple impacts, but I don't see anything in there.

Ms. Barbara McElgunn: No.

Mr. Clifford Lincoln: So where is she going to put it? Unless she has a reference in the definitions to—

Ms. Barbara McElgunn: There should be written guidelines—and this is what they're very short on—on risk assessments and exposure assessments that really describe and define cumulative exposures and aggregate exposures, how they're going to look at these, and what they need in order to look at these.

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I mentioned the example of the lack of information we have in Canada on pesticides in well water. We cannot disregard water as a source of exposure, especially to infants and children, because they consume seven times the amounts—as Sandra and I have said, and others—of adults in terms of water, making formulas and juices and so on.

So I think those kinds of things have to be in PMRA guidelines that everybody knows about.

Mr. Clifford Lincoln: Shouldn't they be more than guidelines? Shouldn't they be requirements rather than guidelines? Because guidelines by their very nature are just guidelines.

Ms. Barbara McElgunn: Yes. I'll go this far. I think that in the legislation some health end points should be mentioned in terms of toxicological data. We had a hard time to even get those two words into CEPA many years ago. All the way through it didn't mention toxicological data. Now the new one does.

I think that in the new Pest Control Products Act perhaps end points such as cancer, immune system effects, developmental effects for children, developmental neurotoxic effects, and reproductive effects should be mentioned in the legislation.

Mr. Clifford Lincoln: Could I make one suggestion? If all the NGOs got together, they have a very clear idea of what is wanted in this legislation and the WHO has produced a first-class booklet. This is what was done by many NGOs in regard to species at risk: they produced a draft bill of what they would want to see. We could then send it to the PMRA and there would be comparison between the optimum version and their version. And I'll tell you, the pressure would be great to look at your version.

Ms. Barbara McElgunn: Of course we haven't seen their version, but we could maybe look today.

Mr. Clifford Lincoln: No, but from what you can see there.

Ms. Barbara McElgunn: Yes, that's true. That's a very good idea. We will consider that, sir.

The Chairman: Thank you, Mr. Lincoln.

Julian Reed.

Mr. Julian Reed: Mr. Chairman, I have two brief comments and a question.

First of all, in terms of bearing the cost of this testing and research and so on, I would submit that I don't think we can make a pronouncement about it in isolation, understanding that we're in a global economy and we're exporting and importing and so on.

If all the load, for instance, goes on the manufacturer of the pesticide, then what it results in is a direct pass-through cost to the farmers. This stands to reason. And yet I'm glad I heard the comment, some of the responsibility, because the public at large is really hopefully the beneficiary of this testing, and it would seem to me that government itself, as representing the people, should bear a substantial amount of the cost of the kind of research you're suggesting.

There was a comment made about cutting the amount of pesticide in use. I would submit that farmers don't use an ounce more pesticide than they feel they need to do a particular job at a particular time. After all, it's a direct input cost, and they're not in the business of wasting money. Other countries, we believe, do use pesticides in excessive amounts, but we're still bringing in grapes from Chile.

The question I have for you is how do you feel about genetically engineered foods that wouldn't need pesticides?

Ms. Barbara McElgunn: Some of the genetically engineered foods, such as the canola, do need pesticides and they're engineered so that they do not die when they are sprayed with Roundup. So I think in terms of the concept that some genetically engineered foods would not need pesticides. Maybe the Bt type of genetically engineered might not, I don't know. I think the public has been sold this story that genetically engineered foods would not need pesticides, when the one we know of the most in Canada probably can be drowned in pesticide and still live to see the next day.

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Mr. Julian Reed: I'd submit to you that there's a potato on the market now that is not susceptible to the Colorado beetle. The Colorado potato beetle is the main reason for using the pesticide on potatoes. Believe me, I know all about it, from running up and down rows trying to squash Colorado larvae before they start to lay more eggs. I have found that in the end, I've had to go the rotenone route, because if you miss a day, it gets ahead of you. The thing is there's a potato on the market now that doesn't need that kind of treatment. Do you support that kind of work?

Dr. Nicole Bruinsma: This is a whole other can of worms here, and I'm not really sure we want to get into the whole GE issue at this point.

I agree with Barbara that a lot of the genetic engineering that has taken place thus far is in making plants resistant to pesticides so that more pesticides can be applied without that plant dying from the pesticide. That's the vast majority of the GE work that's been done to now.

The other thing is—very briefly, because as I say, this could be the topic of another six days of discussion—genetically modified organisms are a big black hole. We have absolutely no idea what the long-term implications of genetically modified organisms are going to be on our environment and on our health.

If we produce a potato that doesn't need any pesticides, that's some sort of super-potato that can survive in all circumstances, what we're doing in essence is we're compromising the very biodiversity that sustains life on this planet. These are huge issues, and we can discuss them maybe at another time. I don't think this is the right forum to do that.

I would be very hesitant to say we would support a potato that didn't need pesticides, because we don't know why it doesn't need pesticides, whether it has been bred to have some other toxic effect, why the insects won't want to eat it, and a whole host of other things.

It's a bit misleading to the public to let them think, “Don't worry about it. Technology will save us in the end. We'll manufacture food in a genetically modified way so that everything will be okay.” That's a very misleading type of thought to give to the public, because we don't have any idea.

You talk to the scientists who are working on genetically modified organisms and they will tell you they don't have any idea what the long-term effects on the environment and human health are going to be with genetically modified organisms—no idea.

Mr. Julian Reed: But modification has been going on for millions and millions of years.

Dr. Nicole Bruinsma: That's completely different. People get that very confused.

Mr. Julian Reed: Mutations have taken place in our lifetime.

Dr. Nicole Bruinsma: People get very confused when we talk about genetically modified organisms. “Haven't we been doing that for centuries?” they say. With Mendelian genetics, you take the strongest plants and breed them. But that is intergenerational transmission of genes.

We're not talking about intergenerational transmission of genes. We're talking about lateral transmission of genes, where you're actually cutting out a gene from one organism and placing it into another. There's been no research done on the lateral transmission of genes between species, which has never happened before in the history of the earth.

Mr. Julian Reed: It's happening all the time. It happens in nature.

Dr. Nicole Bruinsma: Not that genes are taken out of an organism—that a gene from a fish can be transplanted into the genome of a rat. That has never happened in the history of life on this earth, ever.

Mr. Julian Reed: You'll find that it has, and it's going on all the time.

Dr. Nicole Bruinsma: Not in the sense that we are doing genetic modification now, when people talk about genetic modifications.

But let's not get into that, because that's not even related to what we're talking about today. I'm happy to discuss it with you later if you like.

The Chairman: Thank you, Mr. Reed.

Very briefly, I have one last question before you go. We hear this term “risk management” quite frequently. Would you indicate to us how you interpret that term and how you would see the government implement risk management—in the way it is being done now or as an alternative to what is being implemented?

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Ms. Barbara McElgunn: I've been concerned for some time that in documents from PMRA and also in the amendments to the Pest Control Products Act, it is stated that the agency will use a risk management approach.

I have not seen a definition of that approach. It would be good to have a definition of that approach. If it's going to be in the legislation in those words, we need to know what they mean by those words.

I think what they mean is it's a weighing of values, of efficacies that are part of those values, and of risks to the population from the use of these pesticides. But I'm not absolutely certain or clear in my mind whether that is what PMRA has in mind as a risk management approach.

I'm really concerned that it might be that they're looking at the economics and the cost benefit of using or not using these products very heavily. I'm concerned that risk management might overshadow risk assessment, inasmuch as I feel risk assessment must be purely a scientific process that isn't always looking over its shoulder to see what it's going to cost down the road to the producers or to the registrant.

Risk management is what you do when you get these data, what you do with them, how you manage the risk. But it is and should be completely separate from risk assessment, in my opinion.

I would really like to see in the legislation a definition of the risk management approach by PMRA or by whoever is drafting the legislation.

The Chairman: Would you be willing to supply this committee with a definition of your own?

Ms. Barbara McElgunn: Of risk management?

The Chairman: Yes.

Ms. Barbara McElgunn: Surely.

Dr. Nicole Bruinsma: Along with acceptable risk and unacceptable risk?

The Chairman: Yes. Also, the clerk will supply you with some eleven questions prepared by our researchers, which we didn't have the time this morning to ask you. Would you mind doing that, perhaps by mail?

Ms. Barbara McElgunn: I'll do my best.

Dr. Nicole Bruinsma: Certainly.

The Chairman: All right.

On behalf of the members of the committee, thank you very much for your appearance and for your presentations.

Ms. Barbara McElgunn: Thank you.

Dr. Nicole Bruinsma: Thank you very much.

The Chairman: This meeting is adjourned.