Pest management advisory council - October 2022 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’s Pest Management Regulatory Agency (PMRA), and provides advice directly to the Minister of Health on policies and issues relating to the federal pest management regulatory system. The Council’s recommendations are provided by the Chair to the Minister of Health.

On October 3 and 4, 2022, PMAC held a virtual meeting.

Monday October 3, 2022

Opening remarks and review of the agenda

The PMAC Chair, Mr. Pierre Charest, opened the meeting by welcoming the members and participants. Mr. Charest proceeded with an overview of the agenda.

The Acting Executive Director of the PMRA, Mr. Frédéric Bissonnette, welcomed the Chair and members. He emphasized that the advice of the Council is of great value in the development of approaches to issues brought forward.

The Assistant Deputy Minister of Transformation, Dr. Manon Bombardier, welcomed the Chair and members. She expressed her gratitude to the Council for their input and support in PMRA Transformation initiatives.

The Associate Deputy Minister of Health, Mrs. Heather Jeffrey, welcomed the Chair and members, thanking members for their valuable contributions to the work of PMAC.

The Minister of Health, Jean-Yves Duclos, welcomed the Chair and members, thanking members for their valuable contributions to PMRA. PMAC members were invited to provide comments and raise questions to the Minister.

Discussion of PMAC members with the Health Minister:

Each PMAC member was given the opportunity to provide the Minister of Health with comments and questions.

Some PMAC members raised concerns regarding the need for long-term funding to support initiatives for obtaining real-world data to inform science-based decisions, and science communication to minimize confusion between facts and perception beyond the 2024 Transformation funding. Some PMAC members expressed the importance of timely, science-based decisions, including those related to Maximum Residue Limits (MRLs), as the current pause is negatively impacting Canada’s ability to ensure food security. In addition, some PMAC members encouraged the Minister to act on Canada’s commitment to reconciliation by prioritizing engagement with Indigenous populations to help inform PMRA’s decision-making.

The Minister acknowledged the overall objective for Health Canada’s pesticide regulatory system and current transformation underway, the role of the Council, and noted that all of the following support each other: protecting the health of Canadians, the environment (including wildlife), food safety, and a strong agricultural sector. The Minister also stated that he recognized the importance of timely and science-based decisions to instill confidence in Canadians to trust the PMRA. Regarding long-term funding, the Minister stated that there is a need to maintain PMRA’s ability to do what is required, while noting that this work is increasing in complexity. He indicated that while progress has been made on the Transformation Agenda, the upcoming What We Heard report would better inform the work to come.

The Minister thanked the Council for its work and members’ time, acknowledged PMAC’s important role, and encouraged members to make their views known through this forum.

PMRA’s Transformation agenda to further strengthen health and environmental protection and improve transparency

Manon Bombardier, Assistant Deputy Minister, Transformation

Context for the PMRA’s Transformation Agenda was provided, specifically the trigger and scope of the Transformation initiative.

Discussion

Some PMAC members were supportive of the approach to transformation. Some members expressed that the current Pest Control Product Act (PCPA) and regulations and supporting policy directives provide a strong legislative framework to implement elements of the ongoing transformation initiative. Others tabled the need to keep moving forward with the changes that do not require legislative changes as to not delay progress. The issue of Indigenous engagement and participation was raised throughout the meeting, including the need for proper outreach mechanisms and for capacity building within Indigenous communities.

Strategic objectives and priority areas – Transformation strategic objectives

Lindsay Noad, Director General, Transformation

An overview of the four pillars of PMRA’s Transformation Agenda was presented: Modernizing business processes, Improved transparency, Increased use of real-world data and independent advice, and the Targeted review of the PCPA.

Discussion

Some PMAC members raised concerns that PMRA may be prioritizing Transformation over PMRA’s core work and clarification was given on funding levels. Some members noted that long-term, core funding will be required for PMRA to continue to meet its overall legislative mandate and additional funding is also required to maintain the momentum of transformation initiatives and ensure PMRA is properly resourced for new activities.

Transformation pillar: Modernized business processes

Jason Proceviat, Director General, Program Renewal

An overview of the modernization of business processes was presented, which goal is to strengthen human health and environmental protection through a continuous oversight approach that reflects the level of risk, and supports efficiency, transparency and timely decisions.

Discussion

Some PMAC members were supportive of PMRA’s long term vision for program modernization. PMRA currently has the existing resources to implement the continuous oversight approach and some PMAC members encouraged continued consultations with Canadians, as needed.

Transformation pillar: Improved transparency

Gillian Dawson, Senior Director, Transparency

An overview was provided on transparency, which key objective is to enable a regulatory system for pesticides where all stakeholders have a clear understanding of the science, data and rationales that underpin PMRA’s decisions. The presentation spoke to PMRA’s ongoing focus on trying to understand what stakeholders and the public need to meaningfully participate in the regulatory process, and what communication, data, and information are needed on how pesticides are regulated and used.  Some of the topics that were covered during the presentation included: definitions of confidential business information and confidential test data (CTD); access to CTD; sharing of evaluation reports; sharing of real-world data; creating a more user-friendly online experience; and, improving science communication.

Discussion

In the general question period, provisions for the need to safeguarding data from unfair commercial use was raised. Members expressed their support and appreciation for PMRA’s recent focus on improved science communication and indicated that the PMRA’s approach in this regard makes sense.

Transformation Pillar: Improved use of real-world data and independent advice

Janine Murray, Director General, Environmental Assessment Directorate

Margherita Conti, Director General, Value Assessment and Re-evaluation Management Directorate

An overview of the increased use of real-world data initiatives under transformation was provided, as well as an overview of the integration of independent advice. Stakeholders and partners were consulted to identify issues PMRA should consider in terms of accessing, sharing and releasing comprehensive water monitoring and pesticide use data.

Discussion

Some PMAC members were supportive of providing the public access to data; however, they expressed the need for researchers to be able to contribute to and re-use this data to provide a more comprehensive understanding of the information. PMRA reiterated that while access to data is currently within the PCPA mandate, modernized business practices will need to be prioritized for real-world data and independent advice to be shared with the public more effectively. PMRA emphasized that consultations with stakeholders are valuable for gathering input and recommendations on how modernized business practices can be implemented. International models on the integration of real-world data are starting to be examined, and PMRA will explore further how these models may be appropriate to Canada.

Some PMAC members also discussed recent developments with regard to the Science Advisory Committee (SAC), specifically the update to the Terms of Reference to include its members’ abilities to pose its own questions.  Some PMAC members expressed concern that given the lack of SAC members with agricultural or regulatory knowledge, questions may not be balanced. PMRA stated that updates to the SAC Terms of Reference are discussed and agreed upon by the co-chairs of the committee.

Transformation pillar: Targeted review of the Pest Control Products Act

Manon Bombardier, Assistant Deputy Minister, Transformation

An overview of the feedback from stakeholders regarding the targeted review of the PCPA was presented. The PMRA conducted broad consultations with provinces, territories, key federal departments, non-governmental organizations, academia, consumer groups, industry associations, and user groups to inform a targeted review of the PCPA and potential changes to support program transformation.

Discussion

Some PMAC members were supportive of the engagement in the context of the review of the PCPA; however, others expressed concerns over its pace and volume of meetings. Some PMAC members expressed how targeted meetings with specific questions may be more effective moving forward.

Transformation agenda: Phases of implementation and progress to date

Melanie-Anne Way, Acting Senior Director, Engagement

An update was provided on the phased approach of the Transformation Agenda, the key accomplishments to date, and the next steps for implementation was provided. The next steps included a publication of a What We Heard Report on the PCPA targeted review consultations, the continuation of the implementation of the water monitoring sampling, and resumption of stakeholder and partner engagement on specific Transformation initiatives.

Discussion

Some PMAC members expressed an interest in reviewing the upcoming publication of the What We Heard Report. It was decided that PMAC would meet again to receive a technical briefing on the content report once it was available.

Challenges and opportunities

Manon Bombardier, Assistant Deputy Minister, Transformation

Potential challenges and opportunities related to PMRA Transformation were identified and discussed.

Discussion

Some PMAC members were appreciative of PMRA’s candor in the challenges being faced. PMAC would like the Minister to examine the role of PMRA within the broader context of domestic food security, and the availability of tools to adequately address pressures due to climate change including managing invasive species, increased pest pressures, resistance and the impacts on public health and farmers’ and ranchers’ livelihoods.

The meeting was adjourned for the day.

Tuesday, October 4, 2022

Mr. Pierre Charest, Chair of the Council, welcomed members to the second day of the meeting and reviewed the agenda for the day.

Reviewing PMAC Terms of Reference

Jordan Hancey, Director, Policy and Regulatory Affairs Division

A presentation on proposed updates to the PMAC Terms of Reference was provided.

Discussion

PMAC was supportive of the update of its Terms of Reference. Members of the Council also requested an increase in representation on the Council to include representatives from each of Canada’s Indigenous groups (i.e., First Nations, Metis, and Inuit).

Update and discussion on Maximum Residue Limits

Nicole McKenzie, Acting Section Head, Science Communication

A presentation was provided on improving maximum residue limit (MRL) transparency and science communication.

Discussion

Some members expressed concerns that the proposed communication product might not be easily understood or address the concerns of the general public, such as parents. There were also comments on the infographic, and in particular the importance of adding an Indigenous lens and the importance of international alignment.  There was discussion amongst some PMAC members about the importance of setting MRLs in Canada in support of imports of agri-food products for food security. The Council requested that the Minister should immediately lift the pause for increases to MRLs, given that there is no scientific reason or need for additional information to continue the pause.

Update on Notices of Objection

Minoli Silva, Director, Review and Science Integration Division

The considerations in the updated assessment process of Notices of Objection (NoO) were presented. Some PMAC members asked PMRA to provide statistics on whether there has been an increase in NoOs over the past five years at the following meeting. PMRA indicated that there has been a trend for increased NoOs and agreed to provide more specific details at the next meeting. PMRA clarified that when a review panel is established to address a NoO, evaluators different from the original review team of the final decision are assigned; however, PMRA does not have dedicated resources for reviewing NoOs. Employees who conduct NoO reviews also conduct other pre-market or post-market reviews.

Discussion

PMAC expressed concerns that there may not be enough funding and internal capacity within PMRA to conduct the review of the NoOs if the numbers have increased since there are no additional resources to support the added work.

PMAC also asked whether NoOs are flagged and assessed with the same rigour as other reviews. PMRA clarified that the same rigour is given to review NoOs; however, it is focused on the concern highlighted in the NoO.

Closing remarks

In closing, PMAC members were thanked for their input and advice to PMRA.

Next meeting

PMAC will receive a technical briefing following the publication of the What we Heard Report, or as needed. The next meeting will be scheduled for spring 2023, with the date and location to be determined.

Action items:

1. PMRA to provide at the next meeting additional financial information on the Transformation Agenda and core work
2. PMRA to provide at the next meeting statistics on trends for NoOs for the past five years
3. PMRA to inform PMAC when the What Was Heard Report on the Pest Control Products Act targeted review consultation is published.

Participant list

Chair

Pierre Charest, retired 2019 from Vice-President, Natural Sciences and Engineering Research Council of Canada

Council Members / Alternates

Frank Annau, Canadian Federation of Agriculture
Greg Bartley, Pulse Canada
Shannon Coombs, Canadian Consumer Specialty Products Association
Ian Culbert, Canadian Public Health Association
Toni Grewal, British Columbia Teachers’ Federation
Brian Innes, Soy Canada
Jeremy Kerr, University of Ottawa
Melanie Langille, New Brunswick Lung Association
Rebecca Lee, Fruit and Vegetable Growers of Canada
Paleah Black Moher, Ecotox Consulting
Victor Odele, Assembly of First Nations
Terri Stewart for Pierre Petelle, CropLife Canada (alternate)

Regrets

Lisa Gue, David Suzuki Foundation
Karsten Liber, University of Saskatchewan
Pierre Petelle, Croplife Canada
Mathieu Valcke, Institut nationale de santé publique du Québec

Executive Secretariat

Frédéric Bissonnette, A/Executive Director, Pest Management Regulatory Agency (PMRA)

PMRA Secretariat

Ruth Rancy, Director General, Policy and Operations Directorate (POD)
Jordan Hancey, Director, Policy and Regulatory Affairs Division (PRAD)
Shifawn O’Hara, A/Section Head, Stakeholder Relations and Outreach (SRO)
Elsa Gagnon, Senior Scientific Project Coordination Biologist, Stakeholder Relations and Outreach (SRO)
Natalie Lamarche, Project Coordinator, Stakeholder Relations and Outreach (SRO)
Diane Rhéaume, Outreach Communications Advisor, Stakeholder Relations and Outreach (SRO)
Kathleen Eng, A/Senior Scientific Project Coordination Biologist, Stakeholder Relations and Outreach (SRO)
Mireille Prud’homme, Previous Section Head, Stakeholder Relations and Outreach (SRO)

PMRA Representatives

Manon Bombardier, Assistant Deputy Minister of Transformation
Margherita Conti, Director General, Re-evaluation Directorate
Janine Murray, Director General, Environmental Assessment Directorate
Minoli Silva, Director, Review and Science Integration Division
Lindsay Noad, Director General, Transformation
Jason Proceviat, Director General, Program Renewal
Gillian Dawson, Senior Director, Transparency
Nicole McKenzie, Acting Section Head, Science Communication

Minister’s Office

Jean-Yves Duclos, Minister of Health of Canada
Heather Jeffrey, Associate Deputy Minister of Health Canada

2022 Recommendations to the Minister of Health

The Pest Management Advisory Council (PMAC) recognizes that the Pest Management Regulatory Agency (PMRA) has initiated a transformation with the Government’s additional funding provided in 2021 to modernize and strengthen the administration of the Pest Control Products Act (PCPA) over three years.

PMAC is supportive of the direction of the transformation agenda.  It notes however that, once the current funding sunsets in March 2024, ongoing additional funding will be necessary for the Agency to continue delivering on its core work while taking on new transformative obligations for transparency and communications.

PMAC recommends that the Government:

• Commit to increase core funding to PMRA beyond the 2024 transformation funding to keep the momentum of the transformation initiative, to support initiatives for obtaining real-world data to help inform science-based decisions, and to continue improving PMRA transparency and science communication to minimize confusion between facts and perception. A minimum core funding is required for PMRA to continue to meet its overall legislative mandate.
• Determine the elements of the transformation agenda that can move forward without legislative change. 
• Conduct a review of the pesticide regulatory activities in light of the needs of and risks to Indigenous populations and develop a plan on how to address data gaps.    
• Develop mechanisms for Indigenous engagement and foster capacity building in those communities.
• Lift the current maximum residue limit (MRL) pause and re-engage with international partners to align MRLs, where appropriate, given that the pause is having negative impacts on Canada’s ability to ensure food security through imports, and negative impacts on confidence amongst international regulators who provide additional science-based evidence in our decision-making process.
• Review the role of PMRA within a broader context of domestic food production and food safety, and the availability of tools to adequately address pressures due to climate change, including managing invasive species, increased pest pressures, pesticide resistance and the impacts on public health, and farmers’ and ranchers’ livelihoods, and also domestic food security.