The Chairman (Mr. Charles Caccia (Davenport, Lib.)): Bonjour, mesdames et messieurs. Conformément au paragraphe 108(2) du Règlement, nous étudions la gestion et l'utilisation des produits de lutte antiparasitaire au Canada.
We have this morning three witnesses, and we welcome you all: Mr. Sankey, Ms. McDonald, and Ms. Land. Perhaps we'll start with the Working Group on the Health Dangers of the Urban Use of Pesticides. I suppose it's Ms. McDonald.
Welcome to the committee. Perhaps you would like to start by introducing your delegation. You have 10 minutes for your presentation.
Ms. Melissa McDonald (Member, Working Group on the Health Dangers of the Urban Use of Pesticides): Certainly. Thank you, Mr. Chair and honourable members, for inviting us here today. My name is Melissa McDonald. I'm here today with John Sankey. We are representing the Working Group on the Health Dangers of the Urban Use of Pesticides. I realize it's a bit of a mouthful, so we call ourselves HDUUP (aitch-dup) for short, just to keep it clear.
By way of introduction, I recently finished my LL.B, and I'm an articling student at a downtown law firm in Ottawa. John is a field naturalist, a retired scientist, and a person who has been involved in the pesticide issue in the Ottawa area for over 30 years.
Our group, HDUUP, is made up of volunteers, including retired scientists, health practitioners, articling students, and other interested citizens. What we're concerned about is the effect of pesticides on the urban population.
Je vais vous faire ma présentation en anglais aujourd'hui, mais je pourrai par la suite répondre à vos questions en français s'il y a lieu.
Just to give you an idea of what HDUUP is and what we do, our mandate is twofold: the first is to educate the public on the effects of pesticides in the urban environment and to promote non-toxic alternatives. Our second mandate is to lobby for the implementation of a municipal bylaw that will allow a municipality to control the use of pesticides on private property. This is something you'll be hearing a lot of in the near future, hopefully, because quite a number of groups across Canada are aiming for this same goal.
We wanted to present to you today because we really think it's important you hear from people who are concerned about this issue at the urban level. What I want to emphasize is that what you're doing up here at the federal level has a direct link to what we're doing down in the urban setting. We're going to present to you some recommendations we would like to see included in the federal legislative scheme.
But before we do that, I just want to paint a picture of why there's a problem with the urban use of pesticides. I want to distinguish that from, say, the agricultural use of pesticides or pesticides used to protect forestry resources.
The first thing to consider is that a lot of pesticide is used in the urban environment. One statistic I have shows that in pounds per acre more pesticide is used in the urban environment than in rural areas for agricultural purposes. That's a lot of pesticide.
The thing to bear in mind about this pesticide use is that most of it is for what we call cosmetic purposes, that is, to achieve one definition of a pretty lawn. These pesticides are not being used to protect food crops or to prevent a disease outbreak in the urban setting. The goal is this particular definition of a pretty lawn.
With regard to urban population density, I read a statistic from Statistics Canada saying that in southern Ontario it's 1,203 people per square kilometre. That's a lot of people who are being unnecessarily exposed to a lot of pesticides.
If you consider lawn spraying, and that's one of our main focuses, no matter how diligent an applicator is in applying pesticides, there will be drift spray, there will be winds, there will be weather. People who do not want to be exposed to pesticides will be exposed.
Another problem to consider in the urban area is that pesticide residues are found in groundwater. This is groundwater that will eventually lead into drinking water sources. One particular study I read showed that groundwater that had been studied in Canada and the U.S. had the residue of 39 pesticides in the water, and as I said, this eventually ends up in water we're drinking.
Let's take the case of children. Again, our focus is mainly on lawn spraying. Children play on lawns, they roll on lawns, they put their hands in it, and they put their hands in their mouth. So there's a pretty direct exposure route going on there, again for unnecessary purposes, to achieve the pretty lawn.
Industry may tell you that these pesticides dissipate fairly quickly outdoors, but what they won't tell you is that these pesticides are tracked indoors. Several studies have shown that indoor air contained pesticide concentrations quite a bit higher, 5 to 10 times higher, than the concentrations of pesticides in outside air. When pesticides are outside, some of the things that will contribute to their dissipation are sunshine and bacteria. That doesn't exist indoors, obviously. A few studies I read, one in particular, showed that pesticides can last in carpets for a very long time. What this contributes to is a longer exposure to pesticides.
Another issue we're involved with at the urban level is the indoor spraying of apartments or houses for cockroaches. This is particularly vile because the primary pesticide used for this purpose is an organophosphate called chlorpyrifos. Organophosphates have been shown to be neurotoxins that cause mutagenic effects and reproductive and immune system problems. Because it's indoor spraying, the exposure will be long term.
What I've set out for you, really, is that the urban population is exposed to significant amounts of pesticide. We should keep in mind why that's happening. I want to emphasize that it's mainly to achieve this cosmetic ideal of the perfect lawn.
I'm not going to go into detail about the link between pesticides and harmful health effects. I appended to my submission this particular newsletter from the environmental health committee of the Ontario College of Family Physicians. This came out about two years ago. It outlines in quite a bit of detail, with fully referenced scientific studies, what some of those health links are. So I leave that for you to read.
I also want to point out to you that there are studies coming out continuously that show links between health effects and pesticides. As well, I think Dr. Nicole Bruinsma is going to be presenting to you in the near future. She's a physician from Chelsea, Quebec, who will be dealing with that particular issue.
Now I come to the recommendations. First of all, we would like to say that we support fully the recommendations that Julia Langer put before this committee in the spring of this year. There are a few recommendations we would like to emphasize.
The first one is to include a provision in the Pest Control Products Act stating that legislation at the provincial or municipal level that further restricts the use of pesticides will not be ultra vires or unconstitutional. That's particularly significant for Quebec. Some of you may be aware that in Quebec, at the municipal level, 35 municipalities have been able to implement bylaws that restrict the use of pesticides on private property.
Hudson, Quebec, was the first municipality to implement such a bylaw. This bylaw was challenged at both the trial level and the court of appeal level by chemical lawn spray companies, and the bylaw was upheld. The chemical lawn spray companies have asked for leave to appeal to the Supreme Court of Canada, and they were granted leave to appeal. I think that's something really important for us to keep an eye on, because these bylaws that were supported by the municipalities are in place and they've been challenged at yet a higher court level. It will be really interesting to see what happens.
One of their arguments is undoubtedly going to be how is it that a product that is legally approved at the federal level can be banned or deemed to be illegally used at the municipal level? So that is why I point that particular request out to you.
The second recommendation that I put forward is to implement what is called "the substitution principle." This was something that appeared in Swedish legislation. The gist of that is to deregister a toxic product if a less toxic product is found to do the same thing. Another way to look at it is that approval is not given to a pesticide for which a less toxic product is found to do the same thing. To me, that just makes common sense. Why introduce yet another toxin into the environment when we already have something that has a desired effect and is less toxic?
In particular, an example for that actually comes with reference to the cockroach issue. Borax, a common product you'll find in your grocery store, has been found to be quite effective in controlling cockroaches, in addition to physical plugging of holes where cockroaches may enter. So here is something that has been proven, that is non-toxic, that is available, yet chlorpyrifos, which is quite toxic, tends to be used.
On another issue, we would like to see included in the product testing scheme the consideration of children and other sensitive populations. As it stands, as we understand it, data from animal testing is extrapolated and applied to the average adult male. I've already pointed out to you the direct exposure routes for children and how they may be more susceptible or have these more direct exposure routes happening.
When you consider children, they have a smaller body mass, a higher absorptive area, and a different metabolic rate. So they're going to be more susceptible to the effects of pesticides, and if that is happening during critical developmental periods, the effects could be much more detrimental.
Our next request or recommendation is that the inert ingredients in pesticides be revealed for product registration. Inerts are the products in a pesticide that make application easier.
One study I read indicated that over 610 chemicals that have been identified as hazardous are found in pesticides. As it stands, inerts are not revealed in the product registration; they are protected as a trade secret.
The difficulty with that is we have people dealing with these chemicals every day, physicians who may have to deal with patients who have ingested a particular product, and knowledge of what is in that product is not readily available because it's protected as a trade secret. My difficulty is, why does the bottom line of a corporation come before the consideration of human health?
My next recommendation is to incorporate the precautionary principle into the PCPA. I'm sure you've heard the precautionary principle before, but I'll repeat it. It states that where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as an excuse to forge ahead. There are so many things we don't know about pesticides, such as the long-term effects, the mutagenic effects, the synergistic effects, the effects on children, the effects on the fetus, but we do know that these toxins have an effect on organic matter, and we are made up of organic matter.
The Canadian Chemical Producers' Association has asked the federal government not to restrict a product unless there is definite scientific evidence. To me, this is certainly not logical, because once we have definite scientific evidence, if that can ever be achieved in science, it's going to be too late. We're waiting for the statistics saying, yes, this causes breast cancer; now it's time to take it out. At that point it's too late. That's why we think this would be a suitable addition to the pesticide legislative scheme.
Finally, I would like to address the issue of alternatives. We understand there is the alternatives strategies division in the PMRA. Our experience as a committee with the alternative strategies division unfortunately hasn't been all that productive.
About a year ago we wanted to know what they were doing in the area of lawn care and alternatives. At that time we were told that a brochure would be coming out addressing this issue. A year later we contacted them again, and unfortunately we were told the same thing, that a brochure would soon be forthcoming, but we haven't seen the results yet. So we would like to know if it's a question of financial resources. Can more financial resources be put to them? If it's something else, please have a look at it, because alternatives are essential to reduce toxins in the environment.
In concluding, I would like to say that when you're listening to industry representatives I want you to bear in mind who has what as a vested interest here. If it can be said that I have an agenda, then my only agenda is the protection of human health and the environment. I'm not being paid to be here. I do this on a volunteer basis because it's something I deeply care about and we deeply care about on our committee, and I certainly hope the Canadian government shares this particular agenda of health protection and the environment.
I would like to thank you for listening to us today. Both John Sankey and I are open to questions. Thank you very much.
The Chairman: Thank you, Ms. McDonald. Mr. Sankey, would you like to add any comments?
Mr. John Sankey (Former Co-Chair, Working Group on Health Dangers of the Urban Use of Pesticides): I would like to add that although my specialty is not medicine, I have a doctor and two nurses in the family, so I've been exposed to the health issues question all my professional life, and my involvement here in the urban region has been entirely with the direct health effects of incidental exposure to pesticides - that is, from people who did not choose to use them.
I have many friends who have been badly affected. I myself had severe asthma in my thirties and only realized after a while that I had never had it before and I didn't have it after being off on holiday for two weeks. I eventually had my house tested. There was a very high formaldehyde level. I moved out and I have never had a touch of asthma since. Formaldehyde is a very well-known promoter of asthma.
The primary producer of asthmatic attacks in the urban area today is the residue from insect skeletons, specifically cockroaches. Over half of asthma attacks are attributed to this by medical researchers, yet the treatment that is approved by the federal government for cockroach control makes the cockroaches sick with a nerve poison. They crawl into the walls, die there, and are still there to cause asthma attacks as long as their bodies survive.
If you use borax, the insect feels thirsty and crawls out and dies next to the kitchen sink, where it can be scooped up and dropped in the toilet. Then it is really gone, for the people who are most affected by cockroaches.
So if I have one suggestion for you, the first chemicals that you ought to apply the substitution principle to, in my experience, should be those used against insects indoors, specifically cockroaches. There are lots of approved products containing borax to cover all required needs, yet diazinon and chlorpyrifos are still registered because they have not been removed, even though there are less toxic alternatives.
That is the one thing I would like to add, from my personal experience. There are so many people being made really sick by these things, and it's not necessary. There are products that are known to do the job perfectly well; it's just that the registration of others has not been withdrawn.
The Chairman: Thank you, Mr. Sankey. Ms. Land, would you like to proceed?
Ms. Peggy Land (Co-Chair, Campaign for Pesticide Reduction): Thank you, Mr. Chair and honourable members.
Much of what I have to say is in total agreement with what you've already heard from Melissa and Julia Langer. I don't think it's any coincidence. There are some serious concerns about the health and environmental dangers of pesticides, which we all need to be aware of.
There are some basic points from my brief that I would like to emphasize, but first of all I'll just tell you that the Campaign for Pesticide Reduction is a network of activists across the country - volunteers doing grassroots work. It's guided by a steering committee with representation from the Sierra Club of Canada, the World Wildlife Fund of Canada, the Toronto Environmental Alliance, the Canadian Labour Congress and the Citizens for Alternatives to Pesticides.
I will just give you my view from where I sat as the coordinator of this campaign. I want to make the following points.
First, there are now over 70 communities across Canada that have bylaws and policies in place to protect people against unnecessary exposure to domestic-use pesticides. This is largely due to the efforts of ordinary people who are really distressed. The more they find out about pesticides, the more distressed they become. There's a real problem getting credible, reliable information out to people. They turn to us and we try to provide that.
Second, I really think Health Canada's role in the regulation of pesticides is sorely lacking. People who still use pesticides tend to say to us, "The government wouldn't let us use these products if they didn't think they were safe."
On the other hand, the Minister of Health and the director of the PMRA often say they are evaluating pesticides when in fact they're really just looking at the information provided to them from the manufacturers. Health Canada, to my understanding, has had no labs to test pesticides since 1993. So how credible can Health Canada be when they give the impression they are evaluating pesticides? There is no independent testing going on at this point to give people the confidence that these products should be legal in Canada.
Third, information from the PMRA is not accessible to ordinary people. I happened to finally get hold of the pamphlet Melissa referred to. I think it's something quite new from the PMRA and gives a 1-800 number people can call to ask for information. However, the 1-800 number is not even in the phone book and it's certainly not widely advertised. If you do call, you have to know exactly what to ask for.
It's even worse trying to get information from the pesticide companies that put up those little signs that have phone numbers you can call. For instance, a doctor called me from Goderich to ask what Par 3 was. I didn't have a file on Par 3, so I called Weed Man and various other companies and was given not only contradictory information but utterly useless information. One girl told me she had to look it up and said it was the name of the lawn care product. I asked her what it was exactly, and she told me it was the name of it, like baking soda is baking soda. So was I any wiser? Hardly.
Where are ordinary people to go after they get such information? It's really quite a concern.
Fourth, pesticides are more toxic than any of us are allowed to know about. Melissa has referred to a concern about inerts. I have a list here that was leaked to the Sierra Club from within the PMRA. It's very extensive. There are thousands of chemicals that are allowed in various products, including pesticides.
They include such really nasty carcinogens as solvents, pesticides, toluenes, xylenes, lead, naphthalene, diesel oil, you name it. These things are in pesticides. The pesticide itself could exist as only 1% of the so-called active ingredient, yet all these other ingredients enjoy the protection of secrecy, as confidential business information. This list should be made known, and I'd be happy to share it with you if you would like to see it.
The Chairman: Ms Land, have you supplied the clerk with the list already?
Ms Peggy Land: Yes. I had it analysed by a biochemist and she wrote some notations on it as to which ones were not of concern, and I must say they're in a very small minority. I only have one copy, so if I could get it back I'd really appreciate it.
Fifth, lawn care applicators are at great risk of overexposure. This is a photo I took of a typical lawn care sprayer. I think we've all seen these fellows. They are wearing no visible protection. This fellow is wearing a cotton overall with the sleeves rolled up. I think he has boots on, but he certainly has no gloves and no face protection. He's spraying Par 3. The information on the label, which would be the only thing he would have access to, says he should avoid inhaling the vapours - it's rather vague - and wear protective clothing.
A great concern to many of us - and I think it should be to everyone - is that under WHMIS, the workplace hazardous materials information system, information on pesticides is exempt. This means a person working for ChemLawn doesn't have to be told the real details on the kind of protection they should have and the signs and symptoms of overexposure. I think it is really evil that these people are set up to be exposed and not know what they need to protect themselves with, or the signs and symptoms of overexposure.
I'll just read you some of the signs and symptoms of Par 3 overexposure, for instance. This is on the material safety data sheet. The MSDS are perhaps not commonly known. They are supplied by industry, and I happened to get this through the PMRA because I knew what to ask for. Probably most of us have never heard of MSDS, so how would we even know to ask? The symptoms of overexposure are loss of appetite, nausea, vomiting, general tenseness, muscular weakness, breathing difficulties, marked eye irritation and corneal injury, but they're not associated by ordinary people or their doctors with pesticides.
The symptoms and signs for commonly used insecticides such as malathion and Dursban - Dursban is the other name for chlorpyrifos - these are commonly used insecticides. These particular insecticides are neurotoxins; they slow down the conduction of nerve impulses in our bodies. These signs and symptoms are dizziness, headache, uncoordination, weakness, vomiting, diarrhea, muscular twitching, convulsions, pulmonary edema, cardiac arrest, and death.
But who is making the connections when houses have been sprayed for termites or lawns sprayed for dandelions? How are doctors supposed to know? How are they supposed to make these connections?
These are just some of the concerns that I have and that have been expressed to me by people across Canada who want to know how to avoid being exposed and what to do about it when they are, and how to find out.
Another concern is that there is no legislation requiring pre-notification on private property, and the post-notification regulations are largely inadequate. I think this information should be common knowledge. My concern is that it's not.
I welcome any questions you may have. Thank you.
The Chairman: Would you like to start, Mr. Chatters?
Mr. David Chatters (Athabasca, Ref.): Thank you, Mr. Chairman.
Thank you for coming before the committee to inform us of your concerns. Certainly some of your testimony is shocking, to say the least. I think most Canadians want to have confidence that Health Canada is working for them and is protecting them from the dangers of pesticides and other toxins that are in our environment. And it concerns me that you say Health Canada in fact is not doing the job and that the protection of human health and the environment is not their number one priority.
I guess my question would simply be, if that's your opinion, then what needs to be changed in Health Canada and the PMRA to make it work for Canadians, to give Canadians the confidence that Health Canada in fact is protecting them and there are not other agendas going on?
Certainly when you get into the discussion about lawn care people and the protection they use, and all the rest of it, I'm not sure I totally accept your analysis of that. I don't think anybody can ever protect everybody from themselves. I worked for years in the agricultural industry. Today, at least in my province in the agriculture industry, you can't purchase pesticides to spray or to combat pests without an applicator's licence. That involves a considerable amount of classroom time where you learn about the symptoms of exposure to pesticides and herbicides and how you get the information you referred to about the contents of the product and how you protect yourself and others from exposure to the drift and vapours of those products.
So I'm quite skeptical of some of your claims and some of your accusations. My primary concern is how we can change Health Canada to give Canadians, including you, the confidence that Health Canada is doing the job that everybody expects them to do.
Ms. Peggy Land: In regard to your comments on my claims, I am reading what is provided by the manufacturers on the material safety data sheets. It's true that it's up to farmers and homeowners and everyone to apply as directed, but I know from experience you cannot avoid breathing in vapours.
I was walking on the other side of the street, a four-lane street, two weeks ago, where a fellow was spraying what must have been Dursban. It smelled a lot like paint thinner, as the fellow explained on television, spraying Nepean for chafer beetles not too long ago. I was more than a hundred feet away, and there was no wind. Those vapours travel. So even if he had been wearing a face mask or respirator, as is required clearly on the MSDS sheet - We're all exposed to these things.
Mr. David Chatters: No question. I don't argue that. I live in a rural area, and in June and early July almost every morning, early in the morning, you can go out and you can smell the vapours of pesticides.
Ms. Peggy Land: Yes, we know those smells. We're inhaling them, then, aren't we?
Mr. David Chatters: I assume that smell isn't doing me great harm, because Health Canada has licensed that product to be sprayed by air and I'm not being harmed by that.
Ms. Peggy Land: I'm sorry to say I think you're a little bit naive.
Mr. David Chatters: Okay.
Ms. Peggy Land: I'm a health care professional. I'm a practising physiotherapist, so I do have a health care background, and I know just logically that with repeated exposures from multiple sources - The last thing we need is to be breathing and inhaling and exposed to more of these.
So I would suggest all lawn care chemicals be discontinued. We don't need them. My lawn is beautiful, and I don't use lawn care chemicals. There is no such thing as an absolutely essential toxic chemical for a lawn, and I'm not just talking perception, so that something looks beautiful. We did fine without chemicals for our lawns for years.
Mr. David Chatters: But there again, whether it be lawn care chemicals, or whether it be borax for cockroaches, if these harmless and inert substances work as well as the toxic products, why wouldn't everybody use them? Quite frankly, I don't think they do work as well as the toxic products, or I couldn't understand why anybody would use a highly toxic, poisonous substance when borax would do the same job.
Ms. Peggy Land: Okay. I think John might like to speak to that. There are other beneficial organisms, nematodes, which can attack insects very, very well. But John, I think, could perhaps answer you as well.
Mr. John Sankey: I'd like to make three points, two of them strictly as a lifelong scientist.
The field of evaluation of toxic substances is called toxicology, and it deals solely with reproducible organisms, and that means healthy organisms.
When you have a laboratory rat population and you are testing any toxic substance, not just pesticides, you reject from that test population any rat that shows any sign of illness. They wouldn't be allowed to be on immune-suppressive drugs. They wouldn't be allowed to be on painkillers. They wouldn't be allowed to have arthritis or asthma or allergies, or anything of this sort. So the first scientific problem is that the testing of pesticide safety and all toxin exposure safety is only done on a subset of the population, the subset that are deemed to be in perfect health.
Now, my best estimate is that within the region of the Ottawa-Carleton health department at any given time, approximately 15% of the urban population does not meet the standard toxicological definition of a suitable test subject. These are people that have an identifiable condition that would be rejected in a laboratory test populace, and this does not include, by the way, pregnant women; pregnant women are assumed to be healthy. It does not include children; they are assumed to be healthy. I am talking about people who are on medication or who have medical conditions that make them substantially different in their response to toxins from the average populace.
I hope I haven't been too long, but this is my first point. When something is deemed to be of acceptable safety, it is only deemed to be of acceptable safety to a subset of humans, and there are many thousands of people for whom that evaluation is not appropriate and not accurate.
Mr. David Chatters: I don't want to interrupt, but my time will run out very quickly and I do want somebody to answer my question: how can we change Health Canada to make it worthy of the trust of Canadians and to make it do the job that we all expect it to be doing? Is there any way to do that short of totally banning the use of any toxic substance in pesticides or in whatever?
Mr. John Sankey: You're dealing here with a bureaucratic question, really, and since I spent my life in the bureaucracy - I don't know how Health Canada could regain trust. It must be more open.
I've been at several conferences that are supposedly held to get the information from people such as me who have other views. I have read the summaries that have been made of the testimony given, and in every case they have been meticulously modified - just a little word here and there - so that they end up saying that everything is safe. I don't trust any of the summaries of any of the testimony I've given to Health Canada that I've seen - and I know my opinion is shared by others. I don't know how you, as legislators, can change that.
The Chairman: Thank you, Mr. Chatters ... Mr. Lincoln, please.
Mr. Clifford Lincoln (Lac-Saint-Louis, Lib.): Would you say that access to all information, including inerts and pre-notification, so that the public would have total access to the inputs of final pesticides and their registration, would be the key element or one of the very important elements in any amendment?
Ms. Peggy Land: I would certainly support that. The more information, the better. I don't think we can call ourselves informed consumers, by any means. Even if we try to avoid using pesticides, we're still exposed to them. So yes, the more knowledge and the more openness, the better.
Mr. Clifford Lincoln: I would like to ask Ms. McDonald a question.
I've been following the cases of the municipalities in Quebec, starting with Hudson and my own and the municipality in my riding that adjoins the area, actually. Many of them have passed the same types of pesticide bylaws, Hudson having gone the furthest and having been tested, as you say, in superior court and appeals court. Do you know if the same trend is happening cross Canada? Does your organization or any such environmental organization know how many municipalities have adopted bylaws to ban chemical pesticides for lawn care?
Ms. Melissa McDonald: I think Peggy could probably give you a more up-to-date number, but as I understand it, at last count there were 70 municipalities across Canada that had implemented a similar bylaw. Quebec has the most numerous, with, I think, 35 municipalities. As well, Nova Scotia has recently come on board, with the province giving the power to municipalities to be able to implement such a bylaw. Peggy might be able to update you on that.
Ms. Peggy Land: Just to clarify that, a bylaw is not necessary in provinces where it has been deemed that you cannot legislate on private property. I would just call them policies that have been adopted by school boards or town councils, so on my list of 70, I believe that the bylaws would all be in Quebec so far; there are about 35 communities with bylaws in place, if that clarifies things. The rest are in nine provinces across Canada, though.
Mr. Clifford Lincoln: Here's what I was leading up to. I know that in Quebec when the Pesticides Act was passed, the first intention was to have a provincial regulation that would regulate the whole province. But the regulation is still pending, as you know, since 1987. It has never been published, unfortunately. So this is why the municipalities had to act on their own - and it's a very tiny number compared to 1,500-odd municipalities in Quebec.
I was wondering if, with your recommendation, we should make the test ultra vires; in other words, we declare that any challenge would be ultra vires. But admitting that the Supreme Court backs the Hudson bylaw, which I think it probably will, would you say that one good move for your organizations would be to go to the Federation of Canadian Municipalities, where the provincial law doesn't ban lawn pesticides and it's left to the municipalities - which in a great number of cases, it is - to get them to put pressure on for some sort of resolution that would carry to all the municipalities?
Ms. Melissa McDonald: Certainly. That would definitely be a good way to proceed. My concern with bringing it up at the federal level is that in the court of appeal the argument was made that because this is a law at the municipal level and it's a legally approved product at the federal level, this bylaw should be basically deemed ultra vires. That's why I bring it up at this level - to address that particular argument, which is undoubtedly going to come up in the Supreme Court challenge.
But the municipal level is certainly where we want to concentrate our efforts, and that would certainly be one route.
Ms. Peggy Land: As I understand it, the problem in Ontario, which Melissa actually knows a lot more about than I do, is that the Municipal Act is superseded by the Pesticides Act. So no matter how you may try to protect the health of your own citizens - and your own citizens may ask you to ban chemicals on private property - the Pesticides Act will take precedence. This comes back to the fact that as long as it's a legal product, a ban is not on.
Mr. Clifford Lincoln: But I really think that if the Federation of Canadian Municipalities were to carry some kind of a resolution, it would bring tremendous pressure to bear on the provinces. The municipalities have such big clout.
Ms. Peggy Land: Oh, it would help. That's really what we're trying to do. We're trying to get more municipalities on board, and as for whatever organization is thinking along those lines, the more, the better.
Mr. Clifford Lincoln: But at the federation you now have people who are strongly environmentally friendly, such as Louise Comeau -
Ms. Peggy Land: Yes.
Mr. Clifford Lincoln: - and I suggest that maybe that would be one place to go.
Ms. Peggy Land: Absolutely.
Ms. Melissa McDonald: We'll add it to our list.
The Chairman: Thank you, Mr. Lincoln ... Mr. Herron, please.
Mr. John Herron (Fundy - Royal, PC): ... I'd like to pick up on the comment Mr. Lincoln made in terms of the Federation of the Canadian Municipalities, because I think that's a huge tool you guys can use to leverage pesticide management within the country.
In my riding of Fundy - Royal, the largest municipality is Quispamsis. Mayor Leslie Hamilton-Brown has been very proactive on this particular initiative. Her regard has been driven largely from the human health perspective. There are a number of citizens living in my riding who are susceptible to environmental sensitivities, which can be very much triggered by pesticides and other chemicals in our environment - and I know there are citizens like this in every single riding of the 301 ridings in the country ...
This is what we do know: pesticides likely will have a role within our economy from a commercial perspective, but we also know that not using pesticides will have a role in our economy from a commercial perspective, because there's consumer demand in terms of buying products that are organically grown and pesticide free, and there's not necessarily an economic Armageddon from an agricultural perspective in not using pesticides.
The facts are that the pesticides act we have in place right now is 30 years old; it was written was I was five. We've learned some things in the last number of years; we would have done things in a very different way. We're the only country of the OECD that doesn't even track the amount of pesticides actually sold within our society. Actually, the Slovak Republic doesn't either, so we're in good company in that regard.
Minimizing our environmental footprint in terms of lawn care - those are the things we need to educate the consumer on in terms of the effect lawn care pesticides can have. There may be individuals, such as neighbours, for whom exposure to certain pesticides can actually be life threatening. It seems as though that would be an overstatement, but it's a fact in that regard.
Pesticides are probably one of the very few chemicals we actually license when we know they're designed to kill. That's what they're there for. I was actually floored by your comment just a few minutes ago, when you said that pesticides do not have to be included under WHMIS. We don't have to have a full material safety data sheet for any pesticide we have in the country.
Who governs WHMIS? Who legislates the rules and regulations of WHMIS? Is it the feds, the provinces, or ...?
Ms. Peggy Land: I'm not sure.
Mr. John Sankey: It's Health Canada.
Mr. John Herron: In terms of raising the confidence of Canadian consumers, perhaps one thing to mandate under WHMIS is that not just the active ingredients but all ingredients would actually be in the pesticide licence. Would that be a good step in the right direction?
Ms. Peggy Land: I think it was agreed to in the Rio Agenda 21 agreement that Canada would get on board and that the standards would be harmonized around the world, but this isn't going to happen for several years. Meanwhile, these guys are out there every day, maybe six months, day after day, spraying away. That has to qualify as overexposure for them, not to mention the people who are exceptionally sensitive to even small amounts. So I agree.
Mr. John Herron: How can we push the international community if our own hands aren't clean in that regard, if we can't say that at least we're doing it in our own domestic regime? So I think that would be a step in the right direction. That's what we did in terms of acid rain, when we delivered the acid rain protocol in 1987. We cleaned up our act to a large degree before we took the Americans on to be able to deliver that type of thing. So I think that's something we should do.
I would comment here that I think the Federation of Canadian Municipalities would be something to put in your toolbox, as well as demanding that Health Canada include any kinds of rules or regulations if we decide to maybe get a more up-to-date bill ... So we have a bill that's written to update the pesticides act but we just haven't tabled it. Would you think that one way to restore some confidence in pesticides management in the country might be to actually write a bill that was written actually in this century as opposed to thirty years ago?
Ms. Peggy Land: Yes.
The Chairman: Any comments?
Ms. Peggy Land: Again, you mentioned that the Federation of Canadian Municipalities suffers from lack of funds, as do the organizations I've been helping with the Campaign for Pesticide Reduction. It really does come down to funds. I know the PMRA is mandated to educate on alternatives and on pesticides in general, but I think funding has been a very major problem here. That's why it's been put on the back burner. As well, I think it's fair to say that it's been dominated by industry.
So there are many problems there.
The Chairman: Thank you. Madam Catterall, please.
Ms. Marlene Catterall: As I listen to you, what strikes me is that it does seem to be a mishmash, even for consumers who want to protect themselves, with regard to how to do that. The manufacturer provides certain information. PMRA, as you tell me now, has a brochure out, but who does that get to? If I call and I do want information, I have to know specifically what to ask for.
Let me give you a very concrete example and ask you how you think the system should work.
Half the lawns in the west end are being devastated by white grubs. I for one would like to know what I can do about that problem without using chemicals, which I haven't done until now. I'd like know that everybody has the information if there is another way of dealing with this problem.
Who should do it? When people know there's a problem like this, which is fairly widespread - and it's probably going to get more widespread within the next year - who should be letting people know what the choices are?
Mr. John Sankey: Health Canada, I would submit, should play a major role in that, because these white grubs do not exist just here in Ottawa-Carleton. They exist across the country. Health Canada should take a more proactive role in ensuring the optimal health of all Canadians.
Incidentally, that phrase is the mission of the Ottawa-Carleton health department, with which I do volunteer work. I do not ever see such a phrase, "promoting the optimal health of all Canadians", from Health Canada. So that would be an excellent start.
Ms. Marlene Catterall: As a homeowner who wants to avoid chemicals, I want to know who I can call and ask what I can do about white grubs. Do you think it should be PMRA and not my local municipality, for instance?
Mr. John Sankey: In Ottawa-Carleton, you can in fact phone your region and you will indeed get such information. I know, because I drafted a good chunk of it. But how many people know that?
I have known of the PMRA's 1-800 number for at least 20 years. I have never seen it listed. Most people don't know it exists.
There really is no single place where one can call to get information on things of this type. Heaven knows, if you try the Internet, you'll find everything from one end of the kitchen sink to the other.
This is an area of extremes. Most of the information is provided by chemical manufacturers and by people who are so frustrated from dealing with the chemical manufacturers that they go equally overboard in the other direction. It is very difficult for an ordinary homeowner to get sensible information. I feel that Health Canada should be mandated to be the clearing house, the ultimate source, for all information that applies to the health of all Canadians from coast to coast.
Ms. Marlene Catterall: I am worried about the information you provided about the health of workers in this industry. Again, what's the best way to deal with that?
Ms. Melissa McDonald: I think it comes down to this: if we can't get legislative changes to allow municipalities to control the use of pesticides on private property, which would obviously mean there'd be a lot fewer people applying these types of products, then it comes down to education. That's where we've shown that there's definitely a lack of information available. It keeps coming back to that aspect as well. The information is just not available.
Perhaps I could address your question with respect to availability of information on grubs. You want to be able to get information first-hand. Well, we have the alternative strategies division. They should be funding research, or they should be driving the force that will be finding out what alternatives are available so that information can trickle down and be disseminated.
So it's the lack of information available, but we also don't know necessarily what all the alternatives could be, because the drive isn't there to find out. I just wanted to make that point.
Ms. Marlene Catterall: I know Agriculture Canada is doing a lot of work on biological solutions to many of these problems, but I don't know who Agriculture Canada would provide that information for. I don't know that it's being funnelled through PMRA, for example, so that they could even make that information available, if it exists.
Mr. John Sankey: But Agriculture Canada deals with agriculture. This is a question of urban health. The two have always been very separate.
Ms. Marlene Catterall: A grub is a grub, whether it's in rural Saskatchewan or downtown Ottawa.
Mr. John Sankey: Not really. It is if it's in an urban area in both cases. What I'm saying is that you won't get the same kind of infestations in crops as you do on private lawns, because crops do not receive the incredible amount of tight monoculture.
Talk to any farmer who seeds timothy and then tell him how much you put on a lawn with bluegrass, the guy will faint. The practices are very different. The culture is very different. You don't walk all over your timothy field.
Ms. Marlene Catterall: My only point, Mr. Sankey, is that if Agriculture Canada is doing research on biological solutions to pests, then it's of as much interest to urban people as it is to rural people, and that research should be somehow funded through the PMRA. And I don't know that right now there is any mechanism for doing that.
I think I've used my time, Mr. Caccia.
The Chairman: Thank you. Mr. Reed, please.
Mr. Julian Reed (Halton, Lib.): Thank you, Mr. Chair.
I happen to be one of those who agrees wholeheartedly that you should never use a pesticide for cosmetic purposes. My agricultural training teaches me that it's not just the immediate response that you get when you apply the pesticide, there are all sorts of other reactions that take place. And I do understand that in an urban setting, with not only the intensity of people but the intensity of the way these chemicals are applied, it certainly is cause for great concern.
I'm surprised to hear that this information is not properly getting out and available to everybody. I come from an agricultural background so I'm in a different spot. When I want to find out about chemicals, I go to the Ontario Agricultural College and I get my information there.
Over the years, if I could go back a bit, there have been mechanisms for getting rid of products that prove to be unacceptable. I don't know whether you're aware of it, but we did eliminate the use of DDT in this country because of its secondary effects. It was great for killing apple maggots and flies, but it also killed the bees and it also produced thin-shelled eggs that decimated the predatory birds and so on.
But over the years we've done other things. When I was a kid spraying a commercial orchard, I was spraying lead arsenate, arsenic and lead, and I swallowed some one day, as a matter of fact, when the head of the sprayer came off. Then we decided that heavy metals were not a good idea to leave as a residue in the soil, so by the time I got to Guelph, to agricultural college, we had found the solution. It was mercury, and we sprayed mercurial...but we don't do that any more either.
What I'm trying to say is that as we learn and as we progress - There have been positive responses down the line, and there may have to be another response here as we move in and as we gain knowledge and so on about what things do and what they don't do. I'm very impressed with the potential for the alternative strategies area, if it can be beefed up, if it can be made stronger and so on, to be able to convey to people just what they are dealing with.
I live on private property, on 80 acres, and two watercourses go through my farm, so I personally take extra care about what I do. I wonder if there is a problem of legislating on private property, because I'm legislated on all the time. It's called zoning. It means I can do certain things on my property and I can't do other things on my property. I'm wondering why there's this concern about legislating on private property.
Ms. Melissa McDonald: The problem in Ontario specifically, and I can really only speak specific to Ontario, is the legislative scheme. The Pesticides Act in Ontario controls the use of the products, and it has as a provision that if anything conflicts with this act and we think there is a potential that a municipal bylaw would in fact conflict with it because it's dealing with the use of the product, then it's of no force and effect. So this is the principal problem in Ontario.
What we need is a municipality that is actually willing to be a test cast. I think there are some legal arguments around that, but again it's going to take a municipality that's willing to fork up the money to take on a challenge of that sort of bylaw at this point, because undoubtedly it would be taken to court, as is the case in Quebec.
Mr. Julian Reed: If something like this is legislated, is there a question that if a satisfactory alternative is found it might not be able to be used because of the application of the same legislation?
Ms. Melissa McDonald: At the municipal level or at the provincial level?
Mr. Julian Reed: Municipal level.
Ms. Melissa McDonald: Again, if it's conflicting with the Pesticides Act, which is what the province could say, then that's where the problem comes, because you're dealing with the use of the product and that's what provincial legislation is supposed to deal with.
Mr. Julian Reed: For instance, I try to use biodegradable product. If I have to use a pesticide I'll use a product like rotenone or pyrethrum, which come from plant sources and disappear in nature over time. I don't use them on my lawn but I use them on my potatoes and so on.
If that kind of municipal legislation were enacted, I'm wondering how it would affect the application of those alternatives.
Ms. Melissa McDonald: That would depend on how the municipal bylaw is drafted, what it's restricting, if it's allowing, for instance, the use of pesticides on noxious weeds or emergency situations. It's going to come down to a question of definitions within that particular municipal bylaw, I would say.
Mr. Julian Reed: That's very interesting, because I'm very sympathetic with the fact that all the information is not getting out.
The Chairman: Thank you, Mr. Reed ... Madam Torsney.
Ms. Paddy Torsney (Burlington, Lib.): Thank you.
I certainly support people getting information and making decisions on the best information available or all the information that should be available. I was a bit concerned when I was listening to your presentation, Ms. McDonald, and I clarified it in the actual written text, but you seemed to suggest that borax wasn't a chemical and in your presentation it actually says it's the less toxic method. But obviously if borax is killing cockroaches, it is toxic.
Ms. Melissa McDonald: Probably both John and I can address this.
I'll tell you what borax is. It's a mineral. Sodium borate is mined. There's no easy answer. It's mined in open-pit mines for the most part in southwest U.S. and South America. I know there are different approaches or different theories on what the mechanism of killing the cockroach is. One is that it slices through the chitin.
An hon. member: Who?
Ms. Melissa McDonald: That would be the outer casing or the shell of the cockroach. That's one theory, and John may be able to tell you of other theories of what actually causes death by the borax.
Mr. John Sankey: The first question is the causal mechanism: why is it toxic?
Organophosphates are toxic to us and to insects because they operate on a mechanism, our nerve system, that we have in common with them. Borax is almost totally non-toxic to us but very toxic to cockroaches because it operates on a system present in cockroaches that is not present at all, even in the slightest degree, in mammals.
Borax is very effective against all insects that have an exoskeleton. In effect, their skeleton and their skin are the same thing. It's made of a material called chitin, which can be pronounced differently depending whether you talk Latin or Greek. Borax makes it so that water vapour goes through it, and the cockroach dehydrates. It gets thirsty and it dies from dehydration.
That mechanism does not exist in the slightest degree outside of insects with exoskeletons. Borax is therefore an example of something that can be extremely toxic to cockroaches, yet almost totally non-toxic to human beings. This is why borax is legally registered as a pesticide. It is required to be, because it has an effect on pests.
Ms. Paddy Torsney: I haven't read too many borax labels lately - thankfully, I don't have cockroaches - but there's no bony hand symbol and there are no indications that children shouldn't swallow it. It's fine and safe for humans to be around and with borax, is it?
Mr. John Sankey: Borax is a major component of a lot of laundry soaps. There is therefore no skull-and-crossbones. A child would have to eat a sufficient amount that would - Of course, any kid will eat a bit of something, but let's face it, not too many children eat soap. It's pretty unpleasant stuff.
Ms. Paddy Torsney: It used to be a threat, right?
Mr. John Sankey: You would have to eat a fair amount of it before it would cause problems, and it would not cause the problem that kills the cockroach in any case.
Ms. Paddy Torsney: The record should note that several researchers obviously have been threatened with soap.
I am pleased to see that you've said it's less toxic, because clearly anything out of whack in our ecosystem can become toxic - too much vinegar or acids or whatever - when you're dealing with household cleaners and things. Anything out of whack is not necessarily good, so I'm glad you've clarified that in the written text. That was my main question.
The Chairman: Thank you. Now I have a couple of questions too.
Through our clerk, the PMRA has supplied the members of this committee, by way of a memo or appendix by Dr. Franklin that is dated August 24, 1999, several pages consisting of questions and answers. It would be interesting to have your comments on this memo in due course. I would like to explore with you today a couple of questions, and then two other brief ones beyond the scope of this memorandum.
Would you be able to comment on the PMRA's dietary assessment? Are you familiar with the procedure they follow in assessing the age-specific diet of humans? They take into account different eating habits of the population. Of course they deal with the calculation of the dietary intake of a particular food residue. Are you familiar with that terminology, and can you give us some comments?
Mr. John Sankey: It's completely separate from what we're talking about. The assessment of the danger of parts-per-million residues in food is not what we are talking about here at all. We are talking about people being exposed to 10% sprays. It's a totally different area. As a scientist, I have no quarrel with the general tenor of those dietary assessments. It is in the area of direct exposure to sprays that I have my major questions with the PMRA's methods.
The Chairman: All right, thank you.
The next question has to do with the famous MSDS, the material safety data sheets. Ms. Land, could you explain to this committee why, according to your brief, workers are not allowed to see these sheets? I'm referring to the second page of your brief.
Ms. Peggy Land: I don't know how that happened, but I know it's true and I think it's wrong.
The Chairman: But is that a general practice, or is this a particular case that you're referring to?
Ms. Peggy Land: No, it's a general practice that pesticides have been exempt under WHMIS. I'm really sorry that I don't know the history of it, but I know it's a fact.
The Chairman: Do you know when pesticides were exempted from WHMIS?
Mr. John Sankey: They were exempted right from the beginning of the WHMIS system in the first place. This was an initial restriction, and it has never been lifted.
Perhaps I should mention that MSDS, as a code word in the bureaucracy, applies to documents that are under WHMIS. Since pesticides are not under WHMIS, these things that are called MSDS are not subject to the same rules as apply to other MSDS. In effect, they are voluntary contributions by the manufacturers and are not controlled by the requirements of WHMIS in any way. Although they may be called MSDS, although they may be made available on a voluntary basis, they are not required to be, as the WHMIS legislation provides for.
The Chairman: Would you care to guess why pesticides were exempted from WHMIS?
Mr. John Sankey: Bureaucracy, sir. It was the nature of the game back then that Agriculture controlled pesticides and nothing else was to interfere with that turf. WHMIS was always Health Canada. I think that is the simplest, most genuine explanation for what happened.
The Chairman: Finally, are you in a position to comment on the website information that is available to the public when they look up Health Canada in search of products that they can use for the purposes of eliminating certain insects?
Ms. Melissa McDonald: I know I've certainly looked up the alternative strategies division, and I was quite disappointed in the information that was available at the time. The last time I would have looked at it was probably in the summer, so I don't know if it's been updated since then. It didn't provide me with any information, though.
The Chairman: Could you provide to this committee in writing, by way of a letter, your comments on the latest Health Canada website?
Ms. Melissa McDonald: On the way it stands today? You'd like me to go back and look at it?
The Chairman: Yes.
Ms. Melissa McDonald: Certainly.
The Chairman: And please provide any suggestions that you may want to make.
Ms. Melissa McDonald: Yes, certainly.
The Chairman: Madame Catterall.
Ms. Marlene Catterall: The MSDS is done purely by the manufacturers. As far as you know, does anybody verify that the information is appropriate to the product?
Mr. John Sankey: There are such procedures under WHMIS. I am not aware that there are any under pesticides.
Ms. Marlene Catterall: So nobody is checking that the information provided by the manufacturer is in fact appropriate worker safety information or user safety information.
Mr. John Sankey: Their lawyers will be, but I do not believe the PMRA does - at least, not to the best of my knowledge.
Ms. Marlene Catterall: Would it be a good idea if approval of pesticides included the provision that the equivalent of an MSDS had to be provided to every consumer?
Mr. John Sankey: Yes. I don't see why we should not require that pesticides be subject to WHMIS. There is no longer the bureaucratic impediment that there used to be.
Ms. Marlene Catterall: But quite aside from WHMIS, if an individual consumer wanted to purchase a product to use on the lawn, it just seems to me it would make sense that that person knows, as completely as possible, what it is that is being used and how to protect against negative effects of that product.
Mr. John Sankey: That's right.
Ms. Marlene Catterall: It also seems to me that any company that's using a product like this should be required by law to provide that information to the employees using it. I don't know if we can do that under federal jurisdiction, or if that's strictly provincial. I would suspect it's strictly provincial.
Mr. John Sankey: I believe you can do a great deal under the present WHMIS provisions. If pesticides were made subject to WHMIS - I believe it is entirely under federal jurisdiction - it would be of tremendous assistance.
The Chairman: Mr. Reed.
Mr. Julian Reed: Are any of the chemicals that are used in the urban setting the kinds of chemicals that have to be applied by a licensed applicator in the rural area? There's a fairly stringent requirement for the application of certain pesticides on farms. In order to run a commercial orchard, for instance, the applicator has to be licensed. They have to take a course and be fully aware of exactly what they're doing. Does that same thing not apply in the urban setting?
Mr. John Sankey: There are two situations here. First, the pesticides registered for agricultural use normally have completely different formulations and names from the ones used in the urban context, even when they rely on the same basic chemical. And that difference in concentration is held to call for a difference in licensing requirements at the provincial level.
There are a number of pesticides used in the urban context that are required to be applied by licensed applicators for reasons that are not really properly related to human health. For example, you need a licence if you are to do it for money. But if you buy it to put on your own property, you don't, even though it's exactly the same product. In other words, in the urban area it is much more of a mishmash than it is in the agricultural sector.
I've been in this business for 30 years, and I grew up in the country too. I have very little issue with the management of the agricultural or forestry pesticides as currently done. My problems are completely with the urban area, with the direct incidental exposure to sprays that in my feeling: They are not feeding hungry people. They are not protecting forests to build our homes. They're not even protecting human health, the way pesticides in drinking water are. And that is what my concentration is entirely. It's to deal with the direct exposure to pesticides in urban areas, and this was never addressed by Agriculture Canada because it just wasn't their turf. It should have been dealt with by Health Canada when pesticides were moved there, and Health Canada has let us down. They are doing less useful regulation to protect human health from direct exposure to pesticides than Agriculture Canada did when they had the portfolio.
Mr. Julian Reed: Thank you, Mr. Chairman.
The Chairman: Mr. Herron.
Mr. John Herron: One thing we set out to make quite clear is that the reason the information isn't getting out is because the information doesn't exist. There's no requirement that actually makes it exist.
I have a simple question. If you wanted to have some information on, say, a lawn pesticide, would you go to Health Canada, to the province, or to an environmental NGO like Sierra Club to get an analysis?
Ms. Peggy Land: A chemical analysis?
Mr. John Herron: Yes. Who would likely have the best information available quickly on a particular line of pesticide? Would you go the province? Would you go the federal government - Health Canada? Would you go to an environmental NGO like Sierra Club?
Ms. Peggy Land: Well, I was getting several calls a day from people across Canada wanting just basic information from people, for example, this doctor from Goderich asking just what is Par 3. It's a huge area, and it's very hard to know where to go. So we try to get out this information. I faxed him the MSDS sheets. I did the best I could, but it was a very difficult and huge job, and the better job I did, the more questions I got. I could hardly keep up with it.
Mr. John Herron: The reason I asked that is we've gone through this situation in my own office. There's a woman in my riding, in Quispamsis, whose name is Patty Donovan. Patty will get more information from environmental NGOs on the effects of pesticides on human health than we can even access through our own governmental institutions.
Ms. Peggy Land: Yes, Patty is one of our campaigners.
Mr. John Herron: The application of pesticides is administered by the provinces, so those rules and regulations have been established there. When some spraying is taking effect in different environments across the country, if they try to challenge the province and say they don't want this pesticide used, the province's immediate knee-jerk reaction is, "Well, it's been licensed and approved by Health Canada." Would this be a clear example of where Health Canada has really hampered the capacity of the provincial governments to act to ensure pesticides are administered in a safe way with respect to human health?
Ms. Melissa McDonald: At some point you have to look at the product testing scheme. That's where there are a lot of downfalls at the federal level. If people are saying they don't want this applied to them, and the provincial level is saying it's okay, well, it's only okay as far as the product testing scheme goes.
As it stands, it's industry that submits to Health Canada whatever they've done to meet the registration standards. Then Health Canada reads it and says yes or no. But I pointed out to you a lot of the shortcomings in the testing scheme. There are so many things that aren't tested for long-term effects, such as the effects of one chemical combining with another or how those chemicals change as they go up the food chain.
I just heard of a recent study that was talked about on CBC this week. They said pesticides that are tested in the lab are one thing, but once they're out in the environment, the molecular arrangement actually changes. In a reputable science journal of nature, they talked about a molecule being right-handed or left-handed, and depending on whether it was flipped one way or the other, it had a profoundly different effect. These things just are not tested. These are tested in the lab; they're not tested in the environment. We just don't know enough information at that point.
And of course we have to be able to trust industry with their testing scheme as well. I know there have been some incidents, well-documented incidents, where information has been falsified. So this is one of the major shortcomings.
Mr. John Herron: I have two more quick questions ... Are you aware of any pesticides in use currently that have active ingredients or other ingredients that, because they haven't been reviewed, say, for three decades, would actually be schedule 1 toxins under CEPA now?
Mr. John Sankey: That's a legal question, not a scientific one. I'm sorry; I don't know the classification you referred to.
Ms. Melissa McDonald: And I'm not sure I can answer that.
Ms. Peggy Land: I can tell you that 2,4-D has some unavoidable dioxin contaminants in it. They may not be the most toxic of the dioxins, but I believe 2,4-D would have been grandfathered under CEPA and would still be allowed. The amine formulation is used in agriculture, and the ester in domestic - or the other way around; I can't remember which.
Mr. John Sankey: It's the other way around.
Ms. Peggy Land: Okay. So it depends which dioxins are in which. That's a concern.
I'd like to add that some recent research shows that the effect of some pesticides, unexpectedly, is actually magnified by the nitrates in chemical fertilizers. This is a whole area that hasn't been looked at. But some very good research has been done on that. So it's not just the questionable way it's being researched. It's the whole inadequate way it's being researched, not to mention the lack of real life exposure. So it's very difficult to calculate how much we're really getting.
Mr. John Herron: My last question, Mr. Chair, is that when it comes to an analysis that would determine the effect a pesticide will have with respect to human health, there would be a bare minimum for those individuals who are more vulnerable in our society, such as children, pregnant women -
Ms. Peggy Land: The elderly.
Mr. John Herron: - and there has to be a component of that.
But also in terms of the science, why the lawn care side of it in particular has to be pushed is because pesticides are bioaccumulative in that regard. Is there a way to ensure that the bioaccumulative effect of a pesticide can be incorporated under any kind of pesticide regime of Health Canada?
Mr. John Sankey: I believe it already is. The problem is one of complexity. For example, when chlorpyrifos is administered to a laboratory rat that is in perfect health in isolation from everything else, it does not appear to be bioaccumulative, but when mixed with something else, it could be. We've had one very well-established case, the so-called Gulf war syndrome, which has turned out to be a most unfortunate combination of three apparently unrelated chemicals. The three interacted in such a way as to cause a devastating health problem to perhaps as many as 50,000 troops that were over there. This is the problem. Simple bioaccumulation is looked for in the current testing regime, but bioaccumulation caused by a combination with other substances is not.
Mr. John Herron: Thanks, Mr. Chairman.
The Chairman: The chair would also like to ask a couple of questions before adjourning, but is there anyone else? Madam Torsney.
Ms. Paddy Torsney: On the issue of the inerts, I wonder if this is a problem for poison control centres and such. Perhaps we could get some feedback from them as to whether getting that information would alter the care doctors are using when someone has ingested. Perhaps we could get some further research on that.
The Chairman: Thank you. Mr. Reed, briefly.
Mr. Julian Reed: I'll be very brief, Mr. Chairman.
Ms. Land, you talked about the impact of nitrates on the application of certain pesticides. Did you mean to tell us that increases their effectiveness? What does it appear to do, according to your knowledge?
Ms. Peggy Land: I don't have the study in front of me, but I can get it for you. My understanding is that it magnifies the effects, including the dangers, obviously.
Mr. Julian Reed: That would mean that in an agricultural application you could use less of it.
Ms. Peggy Land: Yes, I guess.
Mr. Julian Reed: Thanks.
The Chairman: That leads nicely perhaps to one of the two questions I wanted to ask Ms. Land. In your drive for pesticide reduction, what is your aim? Can you express it in percentages? Could we, for instance, achieve the same results by cutting pesticides by 50%?
Ms. Peggy Land: The aim is to basically eliminate unnecessary use of pesticides in the urban setting. I'm speaking for the Campaign for Pesticide Reduction, which is focused on domestic use. To our knowledge, there is always a biological and safer control for most pests. So yes, we're looking for elimination of cosmetic use of all pesticides used in the urban setting.
The Chairman: So you limit your complaint to the urban setting.
Ms. Peggy Land: This campaign does. But some pesticides, such as Roundup, are used in the urban setting and on farms a lot. It's difficult to draw a line when they're the same.
The Chairman: The other question has to do with the calculation of the toxicity of pesticides. An examination of that calculation seems to become necessary. Do I take it you don't have any comments to make on that calculation of the toxicity, and if you don't, can you indicate any names outside PMRA that are competent in that field?
Mr. John Sankey: I'm sorry, I can't help you at all there. The area of pesticides is so large; I have stayed completely away from the trace residues of food. I don't know. I haven't any advice to offer you at all.
The Chairman: Do you attribute any importance to the calculation of toxicity?
Mr. John Sankey: There are two completely different issues involved here. The first is the calculation that is appropriate to trace residues of many pesticides in foods. It is that calculation with which I have no personal quarrel.
The second question, though, is the question of toxicity of direct exposure, not via tiny residues but direct exposure to human beings, and it is there that I consider that the calculations of potential exposure and of relative sensitivity are greatly inadequate.
The Chairman: On what did you base that conclusion?
Mr. John Sankey: First of all, perhaps I should mention that at the National Research Council I worked in the physical measurements area, and my job was to spot things that were wrong with measurements, so we wouldn't mistakenly certify, say, a measuring device to be more accurate than it was.
It is with this in mind that I say you first of all have to determine what your subject population is. Is it all of the people of Canada? Is it 99%, or is it, as it is de facto right now, only about 85%? This is a political question. But if the politics say that 99% of Canadians are defined to be within the norms as far as all measures of Health Canada are concerned, then we would see a very large change in the evaluation of many of our pesticides.
The Chairman: So can we conclude from what you say that one of the key issues here is the definition of the subject population?
Mr. John Sankey: Correct.
The Chairman: And you would define it differently from the way it is defined now?
Mr. John Sankey: That is correct, yes, very differently.
The Chairman: You would expand it to include the totality of the population, by way of a sample, rather than excluding certain sectors?
Mr. John Sankey: Yes, I would include essentially all the populace, and at present that is not the case.
The Chairman: There are no further questions. We will adjourn. We thank you very much for your assistance.
Written questions and answers:
The optimal health of all Canadians should be the primary goal of pesticide regulation in Canada. A healthy economy and inexpensive food and dwellings improve human health, and will not be excluded by such a goal.
More work is needed, and our members of Parliament are responding. Since the PMRA answer, fifteen petitions were formally presented by MP's demanding an end to purely-cosmetic use of pesticides. One of these was presented by Joe Clark, a former prime minister, and currently leader of the Progressive Conservative party. Another was presented by Alexa McDonough, leader of the New Democratic Party.
Then, just before parliament rose for the summer recess, Minister Rock responded to oral questions from James Lunney and John Herron concerning toxic pesticide formulants. He stated that "formulants should be either taken out of the products or listed on the packages. We will introduce legislation in due course that will do just that." However, a spokesperson for Mr. Rock later 'clarified' the minister's statement: Catherine Lappe said, "the legislation will require companies to list all toxic ingredients, plus those that may cause allergies or other health problems."
We'll keep you posted.