Sierra Club of/du Canada

The Sierra Club of Canada welcomes the Bill C-53, the new legislation governing pesticides in Canada

Key Considerations

The Sierra Club of Canada is pleased to see improvements to the current Pest Control Products Act, introduced March 21, 2002 by Health Minister Ann McLellan, including:
  • Priority on human health and environment in principle;

  • Increased margins of safety for pregnant women, infants, children, women and seniors;

  • An increased margin of safety of ten times greater for product to be used around homes or schools (though likely debate will occur over definition of "around";

  • Reverse onus on proof of safety of products;

  • Pesticides are now subject to the requirements of the Workplace Hazardous Materials Information System;

  • A requirement that all pesticides be reviewed every 15 years;

  • Requirement that a special review be made mandatory for any pesticide banned or restricted by an OECD country;

  • Increased public participation in registration and re-evaluation decisions; and

  • Increased transparency and access to information.

Necessary improvements to make the bill workable must include:
  • A fast-track approvals process for lower risk alternatives;

  • Adequate review of legislation: time period for debate too short – lack of public confidence in the committee process and its ability to reflect public concerns with C-53;

  • Entrenchment of the Precautionary Principle as both a guiding principle and operational force;

  • An evolution away from a focus on the registration of "products" and toward reduced reliance on pesticides and sustainable farming practices;

  • Cosmetic use ban: These ARE Minister's jurisdiction – label determines legal uses. Simply restrict use in homes and gardens on the label, unless for specific, exempted, non-ornamental uses;

  • Substitution principle: Need a fast-track deregistration process for toxic chemicals of concern when less toxic products are registered;

  • Time limits for reevaluations. If industry is unable to provide required information within 5 years of reevaluation's initiation, uses should be suspended;

  • Information on aggregate and cumulative exposures should be required for all registrations and reevaluations, not just when available;

  • A statutory mandate given to the Pest Management Regulatory Agency, not simply delegation of responsibilities/obligations to the Minister of Health;

  • A definition of acceptable/unacceptable risk; and

  • A clear definition of what constitutes confidential business information.