Pest Management Advisory Council - 2021 Meeting Summary Report

The Pest Management Advisory Council (PMAC) is a multi-stakeholder group that fosters communication and dialogue among stakeholders and with the Health Canada Pest Management Regulatory Agency, and provides advice directly to the Minister of Health on policies and issues relating to the federal pest management regulatory system.

On April 7-8, 2021, members of the Pest Management Advisory Council joined the Pest Management Regulatory Agency for the annual meeting of the Council.

The meeting was held online via Zoom because of the COVID-19 pandemic.

The Chair will provide the Council's recommendations to the Minister of Health.

Wednesday, April 7, 2021

Opening remarks and review of the agenda

The Executive Director of the Pest Management Regulatory Agency (PMRA), M. Peter Brander, opened the meeting by welcoming the Chair, members and invited guests. He noted this valuable opportunity for exchange of thoughts and opinions and expressed appreciation for the Council's advice on key initiatives to inform PMRA's approach to challenges and opportunities ahead.

The Chair of the Council, Mr. Tom Beaver, also welcomed everyone and proceeded with the review of the agenda.

Re-evaluation and special reviews

Ms. Margherita Conti, Director General, Value Assessment and Re-evaluation Management Directorate, provided an update on the Re-evaluation and Special Review Program. She also presented PMRA's strategy aimed at reducing post-market review backlog and improving timely decisions. Elements included risk-based prioritization, workload and resource planning, process improvements and stakeholder engagement to contribute information and data to inform risk assessments.

Issues discussed by the Council included criteria used to prioritize re-evaluations, the quality, quantity and sources of data available to inform re-evaluations, and the consideration of value in assessments.

PMAC members were supportive of the multifaceted workload management strategy, highlighting the need for adequate resources to address workload.

Implementing the integrated approach

Mr. Jason Proceviat, Director, Office of Program Renewal, provided an update on the implementation of the Integrated Approach to pesticide evaluation. He described consultations undertaken with stakeholders to inform the initiative to include continuous oversight supported by timely data receipt to prioritize and address issues where and when possible. He detailed the essential roles of stakeholders in contributing to the new approach, as well as changes within the Agency including new processes, information technology solutions, and staffing.

Issues discussed by the Council included considerations for how the new approach will be implemented, and opportunities for the various stakeholder groups (e.g., registrants, pesticide users) to inform the implementation process as it unfolds.

PMAC members indicated their support for the prompt implementation of the Integrated Approach, including water monitoring. They also indicated that they would like to be informed about implementation progress details. A few suggestions were put forth as how this could be done, for consideration by the PMRA.

Greetings from the Minister

Dr. Harpreet Kochhar, Associate Deputy Minister, joined the meeting to address the Council members on behalf of the Honourable Patti Hajdu, Minister of Health. Dr. Kochhar thanked the Council for last year's recommendations and noted the Council's support of PMRA's progress in reviewing the re-evaluation program and the principles of the Integrated Approach to regulatory lifecycle management of pest control products in Canada. He also mentioned the Minister's concurrence with the Council's confidence that the Pest Control Products Act provides a strong legislative basis, and should be retained with only minor amendments as outlined in the Agri-food and Aquaculture Roadmap. The Council's recommendations regarding initiatives on water monitoring and label improvement undertaken by the PMRA have also been noted by the Minister. In conclusion, in his name and in the name of the Minister, Dr. Kochhar thanked the Council for its valuable work and wished the members success with their deliberations.

2021-2026 PMRA strategic plan

Mr. Jason Flint, Director General, Policy and Operations Directorate, described the context considered in developing the new strategic plan, which included, among others, increasingly complex submissions and workload, the Minister's 2019 Mandate Letter and the profound impact of the pandemic on the way PMRA now works. He presented the proposed vision and mission for the Agency going forward, as well as strategic priorities to support timely science-based regulatory decisions protecting human health and the environment, to support and develop a capable and motivated workforce, and to develop and sustain partnerships domestically and internationally.

This was followed by comments and suggestions from members, which PMRA will consider.

Policy and regulatory updates

Mr. Jordan Hancey, Director, Policy and Regulatory Affairs Division, summarized current and upcoming regulatory and policy initiatives and consultations related to regulatory amendments, policy directions, and horizontal and international activities.

Council members' discussion considered PMRA's mandate with respect to support for trade in agricultural products. Members noted the importance of scientific/technical support to trade that is provided by participation of PMRA's scientific experts in international fora such as the Codex Alimentarius Commission.

Labelling initiatives

Ms. Stacie Stiege, Section Head, Review and Science Integration Division, provided an update on initiatives underway to improve the structure and clarity of pesticide labels. This includes development of an electronic platform to automate the generation of structured labels, work on label content (standardized label statements), and regulatory work to improve the readability of labels and allow the optional use of e-labels and the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

Issues raised by the Council addressed the importance for all affected parties, including provincial and territorial government officials, to be informed when label changes take effect as well as the specific changes made to the labels. Such information is of significant value for training, education and enforcement activities. Members also pointed out the potential impact of different levels of internet access in rural areas when accessing e-labels online.

The meeting was adjourned for the day.

Thursday, April 8, 2021

Reading room

Mr. Jordan Hancey, Director, Policy and Regulatory Affairs Division, described activities underway related to the Reading Room policy, including an overview of the public comments received on PMRA's proposal to expand access at the post–market proposed decision stage rather than only at the final decision as is currently the case. He also noted that PMRA is investigating alternative approaches that may allow inspection of such data through other means such as satellite reading rooms, or secure online portals. Changes would aim to provide access more equitably across the country, while maintaining a sufficient level of security of the data.

Issues discussed by the Council included the nature of data released to the Reading Room, as well as other information that could be made available to the public to improve understanding of PMRA decisions. Members expressed general support for an online option and other alternatives, provided the necessary safeguards are met.

National water monitoring

Ms. Heather Simmons, Director, Product Assessment, provided an update on PMRA's efforts to develop a national water monitoring program that would assure robust data to support PMRA's risk assessments, and provide accurate information to assess effectiveness of mitigation measures. She described practical feedback received from stakeholders and described steps going forward to implement the program over 2021 to 2026. She also provided context on PMRA's role in establishing and leading the national water monitoring program, and efforts by Environment and Climate Change Canada to establish the Canada Water Agency.

Issues discussed by the Council included collaboration with stakeholders and non-government organizations able to contribute their networks and expertise, engagement of First Nations, choice of platforms for data entry, data access and extraction for users, including external stakeholders, and the use of data to support PMRA's assessments and other studies.

PMAC members were appreciative of the development of the plan and continued collaboration with federal and provincial authorities to support the program, as well as plans to engage stakeholders more broadly. Members emphasized that PMRA should play a leadership role focussed on implementation of the plan.

In camera session

The PMAC members went over their input to the Minister of Health. The Council's recommendations will be provided by the Chair to the Minister of Health.

Closing remarks

In closing, Mr. Tom Beaver and Mr. Peter Brander thanked members for their input and advice to Health Canada.

Participant list

Chair

Tom Beaver, Management Consultant

Council members/alternates

Barb McKinnon, New Brunswick Lung Association
Frank Annau, Canadian Federation of Agriculture
Rebecca Lee, Canadian Horticulture Council
Karsten Liber, University of Saskatchewan
Kathleen Cooper, Canadian Environmental Law Association
Paleah Black, Ecotox Consulting Services
Terri Stewart, Croplife Canada (alternate)
Shannon Coombs, Canadian Consumer Specialty Products Association
Toni Grewal, Health and Safety Officer, British Columbia Teachers' Federation
Sherif Hegazy, Ontario Ministry of the Environment, Conservation and Parks, and Provincial Co-
chair of the FPT Committee on Pest Management and Pesticides

Regrets

Pierre Petelle, Croplife Canada

Executive Secretary

Peter Brander, Executive Director, Pest Management Regulatory Agency

PMRA Secretariat

Natalie Lamarche, Stakeholder Relations, Policy and Operations Directorate
Diane Rhéaume, Stakeholder Relations, Policy and Operations Directorate
Barbara Njie, Stakeholder Relations, Policy and Operations Directorate

PMRA representatives

Connie Moase, Director General, Health Evaluation Directorate
Ellen Birnbaum, Senior Policy Advisor, Executive Director's Office
Frédéric Bissonnette, Director General - Chief Registrar, Registration Directorate
Heather Simmons, Director, Product Assessment, Environmental Assessment Directorate
Janice Villeneuve, Section Head, Environmental Division II
Jason Flint, Director General, Policy and Operations Directorate
Jason Proceviat, Director, Program Transformation
Jordan Hancey, Director, Policy and Regulatory Affairs Division
Lars Juergensen, Associate Director, Office of Program Renewal
Margherita Conti, Director General, Value Assessment and Re-evaluation Management Directorate
Minoli Silva, Director, Review and Science Integration Division
Mireille Prud'homme, Stakeholder Relations, Policy and Operations Directorate
Regi Mathew, Director, Re-evaluation Management Program
Scott Kirby, Director General, Environmental Assessment Directorate
Stacie Stiege, Section Head, Review and Science Integration Division

2021 Recommendations to the Minister of Health

Preamble

For the past 15 years the Pest Management Advisory Council (PMAC) has recommended an increase in resourcing for the Pest Management Regulatory Agency (PMRA) to enable the Agency to meet its legislative mandate, including increased funding for impacts on human health and environmental research, environmental monitoring, and collection of pesticide use data.

Since 2013, PMAC has annually discussed capacity issues within PMRA and called for more resources, notably A-base funding. Further, since 2017, PMAC has engaged closely with the PMRA as the new Integrated Approach to pesticide evaluation was developed. Since 2016, PMAC has annually supported the need to fund a national pesticide water monitoring program to specifically support the Agency's legislative mandate.

The recent Budget 2021 recognizes the importance of food security, both food affordability, domestic production and regulatory changes required for pandemic relief (e.g., federally-approved disinfection products), but does not address the long-standing funding shortfalls in PMRA funding.

Canadian growers have responded well to the pandemic but continue to face challenges created by a delay in implementation of new approaches to pesticide evaluation by the PMRA. The challenges due to the lack of new approaches, particularly the Integrated Approach to pesticide evaluation, are exacerbated by climate change which will continue to impact the agriculture sector and food security, whether through flood risks, overflows to agricultural drains, increased pest pressures, or resistance to existing pesticides.

As stated in its recommendations following its 2020 meeting, PMAC is supportive of the direction of the PMRA's new Integrated Approach to pesticide evaluation. PMAC also recognizes the success of the new approach is predicated on data collection throughout, key elements of which include a national water monitoring program for pesticides and collection of pesticide use data—tasks that require the interdepartmental collaboration of Environment and Climate Change Canada and Agriculture and Agri-Food Canada, respectively.

Notably, the Minister's 2019 mandate letter states that the Minister is expected to:

• With the support of the Minister of Agriculture and Agri-Food and the Minister of Environment and Climate Change, work to ensure that the Pest Management Regulatory Agency makes timely science-based decisions to support the safe and sustainable use of effective pesticide products in Canada.

In 2019 and 2020, PMAC again specifically recommended to the Minister that the PMRA needs additional core funding to implement the new Integrated Approach and effectively deliver its legislative mandate. This request has been supported by a wide range of stakeholders, beyond PMAC, over the last three years.

As such, PMAC was expecting that Budget 2021 would have provided funding to the PMRA to fulfill its mandate and proceed with the new Integrated Approach.

PMAC members are acutely aware of the implications of the lack of progress in securing additional funding for the new initiatives and the impact it will have on needed operational and policy changes.

We feel that the Agency is now in the position of choosing between advancing the new Integrated Approach at the expense of meeting its overall legislative mandate.

An adequately resourced PMRA, and notably the new Integrated Approach to pesticide evaluation, should be considered part of delivering on solutions to climate change and pandemic recovery. This resourcing is also key to help all the sectors at the table continue to be sustained and valued contributors during this pandemic and into recovery.

Recommendations:

• PMAC requests that the Minister continue to work with her Cabinet colleagues to find stable, long-term funding to support the timely delivery of the PMRA's legislative mandate.
• Furthermore, it is recommended that options for interim funding be explored to allow PMRA to proceed immediately with implementing the full complement of activities (including water monitoring and pesticide use data) for the Integrated Approach to pesticide evaluation.