OFA provided comments on the Pest Management Regulatory Agency’s (PMRA) proposed policy on continuous oversight of pesticides, the latest piece in the ongoing Transformation Agenda being implemented by PMRA.
OFA welcomes the efforts of the PMRA to modernize their business processes through the transformation agenda. We understand that continuous oversight represents improved processes that will allow PMRA to implement a more continuous and proactive approach to identify and consider new scientific information, resulting in enhanced confidence and efficiency in addressing risk and enhanced protection of human health and the environment.
While OFA is generally supportive of the proposed policy on continuous oversight of pesticides, we are concerned that implementing this policy will increase regulatory effort and workload, affecting the timeliness of evaluations, decisions and PMRA’s efforts in addressing the backlog of products to review. Further and continuing delays lead to less products available to farmers in the marketplace while timely access to these products is essential to farmers producing crops to feed our growing population.
OFA understands that concerns exist about delays in adding a minor use crop to a product label, a relatively simple label amendment, because of continuous assessment leading to pending or ongoing reviews of new information. Minor use label expansions regularly involve older active ingredients that have been registered for long periods of time and may have larger bodies of new information available. Additional delays due to pending review of new data identified under continuous oversight would have significant impact on fruit and vegetable growers who already have limited access to pest control options compared to major field crops.
OFA encourages PMRA to explore options to engage with stakeholders to enhance working knowledge of the agriculture sector and improve awareness and understanding of the impact of regulatory decisions, systems, and policies.
OFA also encourages the harmonization between the Canadian and US system for evaluation and registration of pesticide products, ensuring that Canadian farmers remain competitive on the global stage. With the current system, many products approved for use in the US are not available in Canada or have different label instructions, creating a competitive disadvantage for Canadian producers.
Previous related OFA submissions:
September 8, 2023 – OFA submission on strengthening the regulation of pest control products in Canada
July 5, 2022 – OFA submission to the Pest Management Regulatory Agency regarding the Pest Control Products Act (DIS2022-01)
November 28, 2019 – OFA submission regarding the amendments to the Pesticides Act (ERO # 019-0481)