:
Thank you very much for the opportunity to appear before you today and to provide an update on the activities of Health Canada's Pest Management Regulatory Agency since we were here last June.
[Translation]
As requested by the Standing Committee, I have submitted a report that indicates the number of new pesticides approved, the number of older pesticides that were re-evaluated, the number of minor use pesticides that were approved, the number of temporary and emergency registrations, our cost-recovery figures and staffing requirements. I or my colleague Richard Aucoin, the Acting Chief Registrar, would be pleased to answer questions on this material. I would also like to take this opportunity to highlight some of our work and achievements that we believe will be of benefit to Canadian growers.
[English]
Shortly after our last appearance here, within the agency we established some priorities for ourselves. An important one for the agriculture sector is the commitment to improve relations with our stakeholders. I've tried to meet with grower groups from across the country to learn more about the concerns they have regarding pesticide regulation in Canada. I met separately with the grain and forestry industries in December, the Conseil québécois de l'horticulture in January, the Ontario Fruit and Vegetable Growers' Association last summer and again in January. We've had regular meetings with the Canadian Horticulture Council, and I've travelled to Alberta and B.C. and met with a variety of grower groups there.
These meetings have really been helpful in improving my understanding of their experiences and the challenges regarding the availability and use of pesticides. I've also provided them with information on our priorities, and received a great deal of helpful information on how we should proceed in achieving them.
In collaboration with growers, we are working on removing regulatory barriers, prioritizing the evaluation of products for minor crop uses, and looking for ways to improve access to new products already available to their U.S. competitors. Bill C-28, which received royal assent last fall, will make the Canadian process of setting pesticide maximum residue limits more efficient. This will allow pesticide maximum residue limits to be established directly under the new Pest Control Products Act, rather than having to go through a regulatory process under the Food and Drugs Act, which currently can take 12 to 24 months to come into effect.
With the new process, we could establish an MRL in as little as three months, allowing farmers likely to use products at least a growing season ahead of time.
We had a very productive session with growers during our first national crop protection meeting in March of this year, which we co-hosted with Agriculture and Agri-Food Canada and the Canadian Horticulture Council. During that meeting, we announced some initiatives we believe will be helpful in closing the technology gap that currently exists between Canada and the U.S. These initiatives are largely based on our ongoing regulatory cooperation with the U.S. Environmental Protection Agency, or EPA. We announced we are streamlining data requirements for residue trials.
In two locations we have amalgamated subzones, so we will no longer differentiate subzone 5 from subzone 5b or subzone 1 from subzone 1a. This provides more flexibility in deciding where required residue studies are located while continuing to maintain a high degree of protection against excessive residue limits for pesticide-crop combinations grown in those regions.
We are developing ways to register more minor crop uses in Canada in a shorter timeline. By making greater use of existing foreign reviews, which we can do more of in an internationally harmonized regulatory environment, we can significantly reduce the timelines for arriving at a regulatory decision.
For example, we are piloting the evaluation of some active ingredients of significant minor use interest based on the U.S. EPA reviews of these active ingredients, which are similar to program one under our re-evaluation program. These evaluations would be done by teams dedicated solely to these submissions.
We expect this innovative evaluation method will result in a regulatory decision in six months, rather than the standard eighteen months.
Additional incentives, such as extended data protection granted for minor use registrations, are also under consideration. Any revisions to the User Requested Minor Use Registration or URMUR program based on the outcomes of the pilot project will be made in consultation with the grower and industry communities.
As you see, we're continuing to seek ways to further harmonize with the U.S. EPA in order to keep closing the pesticide technology gap that can hinder our growers' global competitiveness. We're also continuing to increase our capacity to cooperate on the evaluation of new products and the reassessment of products already on the market, whether it's through joint review or sharing of the evaluation work.
This year, four out of twelve active ingredients, or 33% of new registrations, were joint reviews. When manufacturers take advantage of the joint review program and submit the application for registration to both countries, we can bring new products onto the market at the same time in both countries.
Under the NAFTA technical working group, we also have agreed to a 25% reduction in the number of field trials required for a joint review. I've heard estimates that this will save the industry up to $1 million per active ingredient under the joint review program. That's a very positive incentive for industry to use joint reviews.
It's not just with the U.S. We anticipate an expansion of the joint review work through the Organization for Economic Cooperation and Development over the coming years. Richard has been working with colleagues on the first global review, which I think is due for receipt this fall.
[Translation]
We are moving forward with the revocation of the default 0.1 ppm Maximum Residue Limit for pesticides, in favour of setting specific MRLs for each pesticide/crop combination registered in Canada. The US residue limits, or what they call tolerances, that have been established after the US Food Quality Protection Act went into effect will guide the establishment of these new specific MRLs for Canada, thus harmonizing with the US more closely. We'll be releasing another document on this topic for consultation with stakeholders in the very near future.
[English]
Using the U.S. tolerances and adopting them wherever possible both moves us forward in harmonization and favours farmers in having access to the same product.
As some of you are aware, the experience with the own-use import program since 2005 raised a number of divergent issues that we felt needed to be addressed. Growers want access to pesticides that are priced similarly to those in the U.S., while manufacturers want assurance that their investment in the data used to support the registration of their products is protected.
In the midst of that, there were also concerns about the potential impacts on human health and the environment from things such as improper container disposal. To resolve these and other issues, the PMRA formed a task force that represented a wide cross-section of stakeholders, including a number of growers, the pesticide industry, health and environmental organizations, and officials from federal and provincial governments, to identify the issues and to work through them.
The task force has met 13 times since November of last year, and I am pleased to say it is very close to consensus on a package that will provide growers with access to competitively priced products while simultaneously achieving data protection for manufacturers. The task force is looking at ways of ensuring ongoing access to own-use importation in a way that will address all of the key issues identified.
[Translation]
In the past year, one of our main priorities has been the coming into force of the new Pest Control Products Act. The new Act is based on three key principles: strengthening health and environmental protection, making the pesticide regulatory system more transparent and strengthening the post-registration control of pesticides that are already on the market.
[English]
The work related to bringing the new act into force has been very significant, and work on new regulations continues. For example, four sets of proposed regulations were published in the Canada Gazette. These included proposed regulations for safety information; adverse effects reporting, which we're now calling mandatory incident reporting; sales information reporting; and revised and updated pest control products regulations. Comments received after Part I publication in Canada Gazette have helped us to refine the proposals. The updated Pest Control Products Regulations we expect to be published in part II soon, and the act will soon be in force.
Perhaps the most significant changes in the new Pest Control Products Act are provisions for increased transparency and public participation in the pesticide regulatory system. Under the new act, growers themselves will also be able to access information on applications made for new products or new pesticide uses, as well as the estimated timeline for registration. This increased transparency in the regulatory system will be useful to growers when they go about planning. It will allow them to start considering at a much earlier timeframe the additional minor uses they might like to have related to any particular registration application.
A couple of weeks ago PMRA officials, Canadian growers, and industry representatives participated in a meeting with their counterparts in the U.S. At this meeting they committed to exploring a common label for pesticides sold on both sides of the border. A short list of candidate products was established, and Canadian and U.S. officials will work on the elements to make the common NAFTA label possible.
With a common label for pesticides sold in NAFTA countries, pesticides would be able to move across borders more easily, thereby evening the playing field among NAFTA partners and making them more globally competitive. This is an initiative growers have looked at with great anticipation, and the pesticide industry CropLife members are also doing a key part there.
[Translation]
Looking ahead, Health Canada's vision for pesticide regulation is to continue to work towards a more open and transparent regulatory system that is responsive to the needs of growers and more predictable. This will be more helpful to growers as they make their business decisions. In addition to that, we will continue to make credible, science-based regulatory decisions that are protective of human health and the environment. We will also strive to make better linkages with our stakeholders, provincial/territorial governments and international counterparts.
[English]
In closing, I would like to say that we hope our already productive dialogue with the agriculture sector and growers continues to be fruitful in the next year.
:
For clarification, I will say a few words about our work under NAFTA and then I will turn to Dr. Aucoin to discuss the pilot, which is referring to some minor uses and builds upon our NAFTA work.
We have made considerable progress under the NAFTA technical working group; that is, Canada, U.S., and Mexico. It isn't really an even threesome. Mexico is there. Mexico has recently developed its own law and regulation and is still sort of feeling its way as to how it can work in the NAFTA context. But it's involved very much in our discussions, and one of the big benefits of that NAFTA forum is it doesn't impede close work and progress between Canada and the United States.
The NAFTA work has evolved from first looking at things such as what the data requires and working to harmonize the data requirements, which is a big benefit for the industry, to considering how we evaluate the data, making sure criteria are consistent, all the way to this program of joint reviews.
A number of us think the program of joint reviews is a very solid point for the future. What's really happening is that the companies are bringing a submission to both the U.S. and Canada at the same time. We divvy up the submission and it's agreed that Canada will review certain aspects of the file and the U.S. will review other aspects of the file, then we come together and discuss our respective decisions.
In discussions, both within Canada and the U.S., we've been clear that not one of us can abrogate to the other the responsibility of making a decision. A very clear example for us in the Canadian context is that we have to look at things such as our Species at Risk Act, and in the United States they have to look at their Endangered Species Act. We know that at times there will be some differences, but the intent is to minimize any differences that are under our control and to maximum the harmonization across the two.
Going forward, we hope that will address the fact and reduce the increase in this technology gap. The problem is that the history shows that Canada didn't approve as many products, mostly because industry wasn't bringing them to us for those uses, and this is where we think this kind of pilot project will have some pay-offs.
I'd ask my colleague Richard to make some comments on that.
:
With respect to the technology gap, and I think that's of very much interest to you, we're really taking two approaches. We do have a bit of a retrospective approach. We do recognize that there's some significant catch-up to do in terms of the kinds of registration approvals available in the United States versus Canada, particularly in the area of minor uses, particularly for the horticultural uses. So this pilot program that we've been talking about is heavily focused on trying to encourage submission to Canada of those active ingredients that hold a huge minor use potential, a huge promise for additional minor uses for Canadian growers.
We've been trying to identify, with help from the Canadian Horticultural Council and others, what exactly the priority chemicals are that we need to encourage to come to Canada. We're going to, in a way that we've tried to do in the past, largely base our evaluations using the U.S. EPA data packages. All the data and information that was submitted to the EPA will be provided to Canada. We will base our decisions largely on that information when we can.
I and others have often described the situation of Canada with the United States in a way that says we're substantially harmonized when it comes to the agricultural chemical requirements for registration. I think I've occasionally got into trouble for using that adverb “substantially”, because then people want to know what I mean by “substantially”.
Over the last number of years we got to a point right now where the kind of information that we need to make our decisions in Canada is so close to the U.S. information package that this will be a real test of our ability to use those U.S. EPA packages, and what specifically, in addition, do we actually need for Canada? We've narrowed that down to a point where it really is hopefully just at that point where, as Karen says, there are certain areas, like endangered species, where we may have to have specific information, but we're really hopeful that we can move ahead with the U.S. EPA data package. So we're really putting a lot of our eggs in the basket of this pilot program over the next year.
Prospectively, looking ahead, we're also very active in promoting and encouraging joint reviews, not just Canada and the United States, but globally. As Karen mentioned, we have global reviews, in-house, coming into PMRA this summer that are going to be...Canada, the U.S., and Australia. We have one in-house now, and we have another one coming in June. In September we'll be working on a joint review with Canada, the United States, and Austria on behalf of the European Union. In January of next year, the first truly global review will come in, which is Canada, U.S., Europe, Australia, New Zealand, Hungary, Italy. It's very global, so we're really encouraging that as a way of moving ahead and trying to encourage those minor uses to come into Canada at the same time as those other countries.
:
Thank you, Mr. Chair and members of the committee.
We appreciate the opportunity to come before you today. We're the trade association that represents the developers, manufacturers, and distributors of plant science products--that is to say, pest control products, and plant biotechnology for use in agriculture, urban and public health settings. Our goal and mission is to support innovative and sustainable agriculture in Canada.
Today I would like to use my time with you just to raise six areas that we think are relevant to our industry and to you as a committee.
First, it's important that Canada achieve its goal of becoming a global leader in agriculture and agri-food innovation. The plant science industry and our partners believe that future technological innovation at the farm gate level has a pivotal role to play in addressing the challenges facing society and our farmers. We believe the future will be defined by what many call the “bio-economy”.
While crops will always be a source of food and feed, in this new agriculture of the future, plants will also serve as the platform for the production of biofuels, bio-materials, bio-plastics, industrial oils, vaccines, drugs, functional foods, and nutraceuticals, representing a true transformation of agriculture as we know it today.
By our calculation, this emerging bio-economy could have a value of roughly $700 billion by 2015. That compares, Mr. Chairman and members of the committee, to the current market of $55 billion for crop protection products and the plant biotech and seed market of today.
There is an increasing global demand for biofuels, both ethanol and biodiesel. From the plant science industry standpoint, we're working on genetically transforming wheat, corn, and canola to improve fuel yields or make them more amenable to biofuel production. These solutions for society are in addition to the work going on that is specific to the interest of our immediate customer, the farmer. If Canada's agriculture industry is to benefit from a bio-based economy, farmers will need new technologies and innovations from our industry.
Our industry's advancements and technologies are not the only answer to today's pressures on farm income, but I would submit that supporting innovation in agriculture and bio-economy is one meaningful response to the current situation.
The challenge for you and for us is to ensure that Canada attracts and sees commercialization of its fair share of this potential $700 billion bio-economy for the benefit of Canadian farmers as well as for the benefit of Canadian society.
The second area I would like to address is the technology gap that we heard about from Dr. Dodds this morning. It's accepted that pest control products are an important tool for Canadian farmers to produce abundant, affordable, high-quality crops. So that Canadian farmers are competitive, they should have access to the same array of leading-edge, competitively priced pest-control products as do farmers in other countries, especially in the U.S. Reduced-risk, minor-use, and, I would submit, micro-use products have increasing importance in the production of lower-volume, higher-value crops such as plant-made pharmaceuticals and industrial products.
The current gap in pest management technology between Canada and the U.S. is felt by many to be the result of two main issues: the size of the Canadian market, and the regulatory differences that still exist between the two countries. Canada, despite the size of our agricultural sector, is about 3% of the world market. It is recognized that only five crops drive product development in Canada: wheat, canola, barley, pulse crops, and corn. The remaining hundreds of crops are minor uses, or even micro uses.
A multi-stakeholder committee has been struck to address key areas of the technology gap between Canada and the U.S. Currently, farmers have identified the gaps, farmers have prioritized their needs, and now farmers, CropLife Canada members, and the government, Agriculture and Agri-Food Canada and PMRA, must work together to address these gaps. I can say to you, the members of the committee, we're committed to addressing this issue.
The third area I would like to speak to is harmonization. Given the global market for food crops, having common regulatory approaches with our NAFTA trading partners makes sense. Many regulatory differences exist between Canada and the U.S, which are impacting agriculture industry's access to new technologies. As Canadians we cannot afford to have regulatory policy create a lag behind our major trading partners in innovation and technology.
It must be noted that the PMRA has made significant progress in moving forward on harmonized data requirements and regulatory procedures for pest control products. However, more needs to be done, and there needs to be a commitment to immediate implementation. Harmonization can be interpreted in many ways, but on behalf of Canadian farmers we have one simple goal. The goal is one data package, one data evaluation, and synchronous registration decisions between Canada and the U.S. This will allow both a reduced time requirement for registration and unnecessary duplicate evaluations for the same products.
I have a few words on efficacy, a long-standing issue. I can say we're pleased to be working closely with the PMRA on the issue of efficacy data requirements. Value and efficacy assessment help ensure that only those products that make a positive contribution to pest management are registered. However, the issue of data requirements has been seen as an added cost in time to the regulatory process and ultimately to the pesticide product itself.
Both farmers and CropLife Canada have expressed this concern to further examine and deal with this issue. A working group with PMRA and CropLife has been struck, and we're encouraged by the progress to date through this working group, with a better understanding of what is needed, especially from the safety standpoint. After that, we believe farmers are in a very good position to make judgments about which products work and which do not work.
A fifth area, own-use import, was touched on by Dr. Dodds. I would just say the multi-stakeholder task force addressing this issue has been very diligent in its work. We're very close to consensus. As the final report has the finishing touches put to it, I think it will be a win, win, win for all the stakeholders at the table, in that there will continue to be an own-use import program, but as well, as part of that package, a modernization of the generic registration system in Canada and further headway—fast tracking, if you like—of the NAFTA harmonization. You put all this together and we look at this not just as an own-use import issue, but as part of a larger pesticide competitiveness package. Once that report is issued, we will be seeking the support of members of Parliament for those recommendations.
Finally, a few words to acknowledge progress by the PMRA on a number of other important fronts. CropLife Canada believes it's important to recognize the progress made over the last few years. It is clear the leadership of Dr. Dodds, executive director, has had a positive impact on the agency and its efforts. A key advancement is evident upon examination of the PMRA performance timelines. This year over 90% of the major submissions made to the PMRA met the applicable review performance timelines. This positive move forward, along with the continued improvement and commitment by PMRA, is essential in ensuring our companies are able to provide farmers timely access to a wide array of products.
I can say, Mr. Chairman, and to the others on the committee here, over the past years I think this is the first time I have appeared before the Standing Committee on Agriculture when we didn't have the issue of timelines in our brief.
The second area I would want to acknowledge improvement on is in the area of the PMRA being more proactive in its communications. We've heard Dr. Dodds' take about stakeholder relations, and we applaud that initiative as well. With the new act and these new regulations, we feel it's important not only for the industry, our immediate stakeholders, and our farmer customers to know about all these new, important safeguards for public health and the environment, but that it's important for all society to know about the first-class regulatory system we have here in Canada, especially given the changes represented by the new act and the new regulations. We encourage the PMRA to continue these communication efforts that will continue to build the public's confidence in their federal regulatory system.
Finally, Mr. Chairman, I would just close by saying we supported the new act. We are working with them diligently on putting together the regulations so this act can be brought fully into force, and we're committed to the speedy implementation of this new act.
Thank you, Mr. Chairman and members of the committee.
Good morning, members, and thank you for the opportunity to speak to you this morning on an issue that is critical to Canadian agriculture, and in particular to Canada's grain and oilseed producers.
My name is Bob Bartley. I am a director of the Grain Growers of Canada. I farm at Roland, Manitoba.
The Grain Growers is an umbrella organization that serves as the national voice of grains and oilseeds producers, devoted solely to representing grain producers' interests on policy issues, including domestic support, regulatory issues, market access, and trade policy, as well as on practical issues such as investment in the sector and transportation.
We have member associations in every region of Canada and represent 90,000 grains and oilseeds producers. As an organization, we have been very active on issues related to pesticide regulation and approvals, given the importance of having timely and affordable access to crop inputs.
I would like to state for the record that Canadian grain and oilseed producers recognize the utility of a sound, science-based regulatory system to protect Canadians, including farmers who use these products on their land and in close proximity to our families, from potential hazards associated with chemicals such as pesticides and herbicides. We will continue to support a science-based regulatory system as a means to manage potential environmental and human health risks and we would also go on record as promoting the responsible use of these products.
Canadian grain and oilseed farmers use these products in a responsible manner, recognizing that there are risks associated with them, and we actively take steps to reduce or to mitigate those risks. This is not only part of sound and sustainable agriculture practice but is also a sound business practice, for these products represent major costs in our operations.
I would like to speak for one moment about the types of business risk, as a means to describe the backdrop against which Canadian farmers are operating.
It is no secret that Canadian producers are facing difficult circumstances. This committee has heard in recent weeks about the income crisis in Canadian agriculture, where producers are facing rising costs and receiving declining prices for their products. Key reasons for the decline, and indeed the reasons for the rise in costs, are beyond the control of producers.
Grain Growers considers that one of the key factors in the decline in our reference margins is the use of subsidies by our trading partners and competitors. These have the effect of overstimulating production and depressing prices. We are pleased that the Prime Minister and the Minister of Agriculture recognize the income problem by honouring the commitment to the grains and oilseeds sector made by the last government and by committing new funding to agriculture, but we note that it is also important to turn to policy solutions to alleviate the problem too.
One of the practical problems facing grain and oilseed producers is the issue of timely access to affordable inputs such as pesticides. The Grain Growers of Canada is committed to eliminating disparities in access to pesticides between Canadian and American producers, as well as between producers in different parts of Canada.
Members of this committee may know that the Grain Growers was an active participant in the work on the own use import task force. Through access to own use Imports, producers were able to save $2 per litre for one particular product when it was imported from the United States through OUI. This may seem like a small amount, but when you consider an average use pattern of approximately 1.5 litres an acre of that product and calculate the savings per acre against an average farm, say one that would be just under 3,000 acres, a producer could save more than $9,000.
When you consider this in light of the crunch producers face from declining prices, you begin to understand the reason producers turned to such a program in record numbers in 2005. However, the Grain Growers recognize that this is a complex issue and that our producers need a reliable supply of product and access to new products.
We recognize there are problems with the own use import program, no matter how much cost saving there is on an individual farm basis. Among other things, from a producer's perspective the program is not easily accessed by individual producers. Obtaining an equivalency declaration can be a complicated, time-consuming, and costly endeavour.
As a solutions-based organization, the Grain Growers strive to find constructive policy solutions to challenges facing grains and oilseed producers. For this reason, we welcomed the smart regulation initiative and we are pleased that the government has decided to enhance cooperation with our American and Mexican neighbours under the security and prosperity partnership.
We see these as important and concrete steps to improve the situation for producers in the long term. In fact, regulatory cooperation with a view to working towards real harmonization and a single North American market for pesticide products is, as far as we can see, the real solution to some of the problems related to pesticides facing Canadian agriculture producers.
Regulatory harmonization through cooperation and mutual recognition is the key to closing the technological gap for many producers. It is puzzling that Canadian regulators would establish a maximum residue limit for chemicals on imported products that will be consumed by Canadians but not approve these same chemicals for use by Canadian farmers on the same Canadian-grown products.
This issue speaks to the increasingly globalized nature of our market. Canadians eat food from many parts of the world every day, just as Canadian food is consumed the world over. As such, Canadian producers are well aware of the perils of regulatory measures used as non-tariff barriers to trade. We take measures to ensure that our producers meet the requirements of our customers and we rely on Canadian rights under the WTO's agreement on sanitary and phytosanitary measures to defend Canadian products from unfair measures. The SPS agreement, along with requiring that measures be based on science, encourages harmonization between countries as a means to reduce non-tariff trade barriers. For this reason, we see the natural progression of the own-use import task force, which has examined the problem from a number of angles, should lead to regulatory harmonization in North America.
The PMRA has taken several steps towards this through the NAFTA working group on pesticide harmonization, but we would encourage the agency to move towards mutual recognition of regulatory decisions as a means to improve the business environment for agricultural producers, while ensuring the protection of Canadians and the environment. We considered that reducing the regulatory burden would ultimately improve access for Canadian producers by ensuring access to new products at the same time as our American counterparts, and this should ultimately reduce the cost to producers. Regulatory fees would be recuperated by passing them on to the users and consumers of the products, namely farmers.
I'm sorry that Mr. Easter has gone. I wanted to talk about Wayne's wild oats.
Prince Edward Island and Quebec are areas that lack wild oat herbicides in wheat. I'm a farmer from Manitoba. We have access to several wild oat herbicides that will take the wild oats out of the wheat; Quebec and Prince Edward Island lack that. So we need some harmonization between provinces and among the regions across Canada too.
In short, as we have stated before, grains and oilseed producers do not believe that the government owes farmers a living, though we do believe that government owes us the industry policies that will allow us to make a living. These policies are within our grasp. One of these policies is the improvement of the regulatory system for agricultural crop inputs.
Thank you, Mr. Chair.
As I said in my remarks, the pesticide manufacturers and developers, the process market base, typically look upon Canada as having big acres of wheat, oats, barley, and canola. Ergo, with the $200 million or $300 million that it takes to develop a molecule from the beginning to the end, you can economically advance into those marketplaces. However, other crops that are termed as minor use are very important. They have emerged over the last 10 to 15 years to the point where you and I might view them as major crops, yet they're still viewed as minor crops. I'm thinking of chick peas, lentils, the pulse sector, canary seeds, and all those crops that have become very important, especially in the prairie basin.
As we go forward with this new agriculture of the future, where you start to grow crops not only for food and feed but for some of these very specific uses, we see emerging low transfat canola, functional food crops, and nutraceuticals. Some of these very precise crops may be from very small acres but are of very high value.
Those that would fall into that category are what I would call a micro crop. The term by which they are identified in our industry is “micro crops of the future”. All the challenges that we have for minor use will be just as big or greater for the micro crop. We think that is very important for the future of agriculture.
On the term “synchronous registration”, I'm trying to come to the same point that I think Dr. Dodds was at. We recognize that Canada will probably never be in a position, and rightly so, to abrogate the final decision to another jurisdiction or another sovereign country. If we can take the same data, evaluate it in the same way, and ultimately come up with the same decision at the same time--i.e., synchronicity or whatever—that would be a pretty good end point for us.
That would be a simple way of describing our goals on harmonization. I don't know if my colleague, Peter MacLeod, has further comments on that.
:
I can start, and my colleague may be able to fill in more detail.
To start at the top, globally the approach of our industry today is very much, I would say, to research and develop for commercialization what are typically referred to as reduced-risk products, ones that have a much smaller environmental footprint, are safer to human health, and biodegrade much more quickly with little or no residue at any point.
As part of that, some of those products may qualify for organic demarcation by various organic bodies. At the end of the day, from a regulatory standpoint, all pesticides--whether they're synthetic chemicals, natural chemicals, biopestide, or even some mechanical-type approaches--have to meet the world-class standards at Health Canada for health and safety. After that, if some consumers and/or some farmers choose to pursue organic production, then obviously that is their choice.
Our members are best known for our synthetic chemistries, for example, and our biotechnologies--the interesting enigma for me always is bacillus thruingiensis, which is very much an organic product that's okay for organic certification but also very much a useful tool in biotechnology--but although we're best known for synthetic technologies, our members on a global basis pursue the new technologies, whether they're biological or otherwise, in the name of pursuing better, safer products.
Peter, do you have anything to add to that?
:
I can lay in on that one. The 2,4-D molecule is one that has been used by farmers for—I'm guessing—60 years, as a first point.
As a second point, it's probably the most exhaustively studied and restudied and tested and retested and evaluated and re-evaluated molecule in the pesticide industry. Although a final report on yet another re-evaluation of that molecule is pending here by PMRA in Canada, in their own words when they released their preliminary assessment a few months ago, 2,4-D when used only according to label directions can be safely used.
The EPA, Europe, virtually every international highly reliable regulatory community has weighed in on this one. So if we say it can be safely used if used according to directions, not only can we speak with confidence relative to the Canadian situation, but we have the advantage of all of these other very stringent regulatory agencies that have also weighed in on this molecule, because it is one that's used globally.
I could further go on to say that it doesn't matter whether it's this molecule or any other molecule, farmers and our industry have no interest in putting products in the marketplace that are unsafe to human health or that would propose an unacceptable risk to human health or the environment.
If international, peer-reviewed, legitimate science demonstrated that there is an unacceptable risk, the farmers, we as the industry, and for sure the regulators would want that risk managed, and if that meant eliminating the use or eliminating the product, that's the way it is. That's the commitment I think we've had and that's the track record of safety this industry enjoys.
I would make that comment relative to 2,4-D or any other of the 6,000 registered products we have here. It's to ensure this that we have re-evaluation, so that an old molecule, so to speak, meets the new tests of the new science. That's why we're willing go through these re-evaluations, so that the public can be assured, whether it's a homeowner or a farmer who's using it, or a public health authority that's using it.
:
As a trade association, the issue of pesticide prices or how our members market them, as you might suspect, is not an area we engage in, nor do we want to, but we must be seen to be making sure that we are not offside with any competition law.
That said, there are studies done on a regular basis by Agriculture and Agri-Food Canada. I think Ridgetown College, for example, collaborates with the USDA. In any given year, there are pricing studies out in the marketplace relative to pesticides as well as other inputs.
My experience over the years, reading those studies, is that in any given year you will find that there are some pesticides in the U.S. that are cheaper and some in Canada that are cheaper. Obviously, in that timeframe you will have fluctuations up and down.
The observation you made now I can't corroborate, because we ourselves don't track them, but others might make the reverse observation. When the Canadian dollar was really, really low and manufacturers were buying active ingredients with a really devalued dollar, many could make the observation, perhaps, that during that time there was no increase in pesticide prices.
What I'm trying to come to is that there are a number of factors, including the types of pesticides that our growers want to use in terms of the sophisticated approach they tend to take, and I think some of the studies have shown that for certain Manitoba growers versus their counterparts right across the border.
It's a complex issue, not one that trade associations typically engage themselves in, but it gets back to some of the comments that were made earlier by our colleagues and ourselves. At the end of the day, what we're talking about here is that with harmonization a lot of these issues go away.