Pest Control Products for Use on Cannabis
Under the Cannabis Regulations (CR), licence holders are only permitted to use pest control products (PCPs) that are approved for use on cannabis under the Pest Control Products Act (PCPA).
Health Canada would like to remind licence holders of their obligations when it comes to the use of PCPs in the production of cannabis. These regulatory obligations must be met before selling products. As per:
- Subsection 93(1) of the CR, “cannabis that is a cannabis product or that is contained in a cannabis accessory that is a cannabis product must not contain any substance other than the cannabis”.
- Subsection 93(2) of the CR, “despite subsection (1), the cannabis may contain residues of a pest control product, its components or derivatives, if they do not exceed any maximum residue limit, in relation to cannabis, specified for the pest control product, its components or derivatives under section 9 or 10 of the Pest Control Products Act”.
- Section 81 of the CR, “cannabis must not be treated with a pest control product unless the product is registered for use on cannabis under the Pest Control Products Act or is otherwise authorized for use under that Act”.
Section 79 of the CR prohibits a licence holder from selling, distributing or exporting cannabis unless the Good Production Practices requirements set out in sections 80 to 88 of the CR have been met. This includes the requirements related to the use of pest control products.
As such, licence holders must ensure that no other products, other than the approved PCPs, are used to treat their products or have contaminated their products as part of their production practices.
Licence holders are required to have adequate controls at their site to ensure that unauthorized PCPs are not used. These controls may include, but are not limited to, restricting access to pest control products, monitoring the application of products to cannabis, or testing for unauthorized PCP use. Licence holders are encouraged to review and implement an integrated pest management program as part of their Good Production Practices.
Registered pest control products
The Pest Management Regulatory Agency (PMRA) maintains an online pesticide label search tool that can be used to determine which PCPs are approved for use on cannabis. Information and labels for the PCPs approved by the PMRA are available in the Pesticides and Pest Management section of the PMRA website.
The following list of pest control products that are approved for use on cannabis does not replace the information available on the PMRA website and is not updated in real-time. PMRA remains the appropriate point of contact for information on pest control product legislation and registrations.
As of February 8, 2019, there are 23 registered PCPs approved by PMRA for use on cannabis:
- Agrotek Vaporized Sulphur
- Bio-Ceres G WP
- Bioprotec CAF
- Bioprotec Plus
- Botanigard 22 WP
- Botanigard ES
- BW240 WP Biological Fungicide
- Doktor Doom Formula 420 Professional Use 3-in-1
- Influence LC
- Kopa Insecticidal Soap
- MilStop Foliar Fungicide
- Neudosan Commercial
- Opal Insecticidal Soap
- Purespray green spray oil 13E
- Rootshield(R) WP Biological Fungicide
- Rootshield HC Biological Fungicide Wettable Powder
- Rootshield Plus WP - Biological Fungicide
- Vegol crop oil
- Zerotol Broad-Spectrum Algaecide/Fungicide
If licence holders have questions or concerns regarding PCPs, or would like approval on the use of particular PCP, they are encouraged to contact PMRA for information.
Unannounced testing by Health Canada
Health Canada conducts unannounced sampling and testing of cannabis products produced by licence holders to provide added assurance to Canadians that they are receiving quality-controlled product and to ensure that only registered PCPs are used during the production process.
Mandatory cannabis testing for pesticide active ingredients by licence holders
In May 2017, Health Canada announced that it would require mandatory testing for the presence of pesticide active ingredients in all cannabis products before products could be sold or provided to individuals as a result of some licence producers using unauthorized PCPs. The Mandatory Cannabis Testing for Pesticide Active Ingredients and the List and Limits came into effect on January 2, 2019.
In the event that an unauthorized PCP is used on cannabis intended for sale, Health Canada will take applicable enforcement actions. This includes, but is not limited to, the seizure and destruction of the product, recall of products if they are sold to client and suspension and/or revocation of the licence or the issuance of an administrative monetary penalty up to $1 million. Compliance action may also be taken under PCPA.
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