Pest management advisory council – September 2023 meeting summary report

On September 18 and 19, 2023, Pest Management Advisory Council (PMAC) members joined the Pest Management Regulatory Agency (PMRA), virtually and in person for a hybrid meeting. The in-person portion of the meeting was held in Ottawa at the Brooke Claxton Building, Tunney's Pasture.

On this page

• Monday, September 18, 2023
• Tuesday, September 19, 2023
• Recommendations to the Minister of Health
• Participant list

Monday, September 18, 2023

The first part of the meeting was held in camera (closed discussion) for PMAC members. The meeting was then opened to external observers for the Opening Remarks.

Opening remarks

The PMAC Chair, Dr. Pierre Charest welcomed all participants.

All PMAC members introduced themselves and confirmed no changes to their affiliations and interests.

The Executive Director (ED) of the PMRA, Mr. Frédéric Bissonnette, welcomed the Chair and the PMAC members. The ED gave a brief update on the PMRA's work since the last annual PMAC meeting held in October 2022. The ED highlighted the Agency's completion of the re-evaluation of legacy pesticides registered before 1995 with the publication of the final re-evaluation decisions for these pesticides in March 2023.

Item 1: Report on action items and recommendations from 2022

Ruth Rancy, Director General, Policy and Operations Directorate

The presenter provided an overview of the PMRA's ongoing and upcoming work related to action items and recommendations from the October 2022 PMAC meeting.

Discussion
The PMRA's plan to engage with Indigenous Peoples and the importance of engagement with Indigenous Peoples were noted. It was suggested that since the PMRA has already begun developing an Indigenous engagement strategy, it should consider co-developing such a strategy with the Métis, Inuit and First Nations organizations as co-development would help optimize the engagement and encourage their participation.

Item 2: Update on the June 2023 ministerial announcement and next steps toward a sustainable approach to pesticides management

Lindsay Noad, Director General, Transformation

The presenter provided an overview of the Ministerial announcement from June 20, 2023 regarding a sustainable approach to pesticides management and PMRA's next steps. Topics included: the proposed amendments to the Pest Control Products Regulations, the lifting of the pause on Maximum Residue Limit (MRL) increases, and the amendment to the Government's Greening Government Strategy to eliminate the cosmetic use of pesticides on federal lands.

Discussion
In response to a question on how much of a reduction in pesticide use the ban on cosmetic pesticide use on federal lands was expected to achieve, the PMRA noted that reducing the risk related to pesticides is a key element to achieving the Government's goals under the Kunming-Montreal Global Biodiversity Framework. The ban of cosmetic use on federal lands demonstrates leadership in this area. The PMRA clarified that the Framework is led by Environment and Climate Change Canada and the Treasury Board of Canada Secretariat, and that discussions on the details are ongoing with other federal departments about pesticide use on federal lands (for example, national parks, experimental farms).

Item 3: Consultation on strengthening the regulation of pest control products in Canada

Ruth Rancy, Director General, Policy and Operations Directorate

The presenter provided an overview of the Notice of Intent (NOI 2023-01) and the proposed regulatory changes being considered by the PMRA. The presenter also provided PMAC an overview of what the PMRA heard from stakeholders on the proposed regulatory amendments and the next steps in the regulatory development process.

Discussion
On the topic of confidential test data (CTD), the PMRA noted that the current affidavit process requires the individual to confirm that they would not use the CTD for the purpose of applying to register a pest control product. Under the proposed new process, the PMRA would make it mandatory for registrants to identify CTD at the time of their initial registration submission.

Regarding assessing cumulative effects on the environment, there was support for processes to ensure protection of the environment. Some members suggested that understanding how to determine cumulative effects on the environment and better support for species at risk should happen prior to making regulatory changes. However, other members cautioned against delaying regulatory changes.

The PMRA stated that cumulative effects on the environment is an emerging science for regulators internationally. The Agency will be consulting its Science Advisory Committee on Pest Control Products (SAC-PCP) on this topic in the future.

When asked to explain the referenced “low cost” in relation to its proposed regulatory amendments, the PMRA clarified that a qualitative cost-benefit analysis is being conducted, but would also consider a quantitative analysis if there are data to support it.

On the topic of MRLs, it was noted that “consensus” was not reached based on information shared by other organizations who had attended the MRL Technical Working Group. It was drawn to the PMRA's attention that some environmental organizations had requested that the PMRA consider establishing separate MRLs for domestic and imported commodities. The PMRA was requested to reflect this divergent perspective in its future presentations. 

Item 4: Kunming-Montreal Global Biodiversity Framework (GBF): Overview and PMRA-relevant targets 6 and 7

Lindsay Noad, Director General, Transformation

The presenter provided an overview of the Kunming-Montreal Global Biodiversity Framework (GBF) and the PMRA-relevant targets 6 and 7.

Discussion
Extensive discussions took place, including on implementation challenges with the definition of risk, the indicators for measuring risk and reduction of use, and the conflicts between the two. The Council also discussed the need to involve provinces, as well as the importance of stakeholder engagement.

Diverging views were expressed on whether a use pattern indicator should be employed for measuring risk, and for monitoring GBF's objectives to reduce the overall risk from pesticides.

Members requested that the PMRA update PMAC on the outcome of its GBF consultations at a future meeting.

Item 5: Designing a National-Scale Water Monitoring Framework for Pesticides: How to include citizen-science

Janice Villeneuve, Manager, Environmental Assessment Directorate

The presenter provided an update on the National-Scale Water Monitoring Program for Pesticides, including the development of a national framework for water monitoring programs, the 2-year pilot monitoring program, the new water monitoring dashboard, and the consideration of the value of citizen-science involvement in a water monitoring program.

Discussion
The PMRA was commended on its collaboration with the Manitoba Métis Federation on its water monitoring pilot, which was noted as a step forward towards Truth and Reconciliation.

The definition of “citizen-science”, the selection criteria for recruiting sampling teams and need for quality data were discussed. It was suggested that a fully funded, in-house, PMRA-focused program should be developed from the start. Program components led by citizen-science could be added later to supplement the PMRA's program.

The group agreed that it is a complex process, and some shared their own experiences of similar work in their respective fields. It was suggested that the term “citizen-science” be replaced with “distributed-science” or “community-based science” since the latter two terms are more inclusive. Additionally, existing programs may include a network of local researchers who are trained in other science fields.

When asked about the quality and robustness of site selection and data collection, the importance of the correct site selection for the program was emphasized. The PMRA clarified that following the pilot work, a more comprehensive approach to site selection in Canada will be considered when scaling-up the program. The PMRA was asked to present a detailed plan on the National-Scale Framework for Pesticide Monitoring Programs at a future meeting and noted its potential for many applications, which could include monitoring biodiversity. The group noted that the PMRA will need additional funding support to continue expanding this program.

Item 6: Pesticide use information program

Roger Charland, Director General, Transformation - Special Projects
Regi Mathew, Director, Value Assessment and Re-Evaluation Management Directorate

The presenter outlined the PMRA's work to date on the Pesticide Use Information Program, and an overview of the draft Pesticide Use Information Framework.

Discussion
Clarification was sought on the existing Sales Reporting Program and how it relates to the new Pesticide Use Information Framework. The PMRA clarified that the Pesticide Use Information Program is intended to provide real-world pesticide use information and does not replace the existing sales data reporting required by registrants under the Pest Control Products Sales Information Reporting Regulations.

The PMRA was advised of the importance of engaging crop producers and the need to explain how the data would be collected and used. It was also suggested that the collected use data be synchronized with the sales data, and it was requested that seed treatment uses be included. The PMRA confirmed that the Agency would consider seed treatment uses. It was noted that the proposed frequency of collection of chemical-specific information was ambitious. The PMRA clarified that it would consider stakeholder comments to inform the ongoing development of the framework.

Item 7: Update on continuous oversight and proportional effort policies

Matthew Bown, Manager, Transformation - Modern Business Processes

The presenter provided an overview of Continuous Oversight (CO) and Proportional Effort (PE) policies as well as the PMRA's consultation plans, including expected timelines for implementation.

Discussion
PMAC questioned the PMRA as to why the CO and PE are separated into two different proposed policies with a plan to have public consultations on the CO policy in fall 2023, and on the PE policy in spring 2024. Some PMAC members also raised concerns about consulting on the CO policy in the absence of the PE policy and criteria. The PMRA noted that while there are linkages between the two policies, they operate separately. As well, consultation on the CO approach is not contingent on consulting publicly on the PE approach concurrently. The PMRA will continue to take an iterative approach to advance the adoption of modernized business approaches, including consulting the SAC-PCP in December 2023, to ensure the PE criteria are scientifically sound. 

PMAC members asked to be consulted on the criteria associated with the PE policy. PMAC members sought clarification on the criteria used to differentiate high risk and low risk products. It was requested that the final PE policy be presented at a future meeting once the criteria for the PE policy are clarified.

Item 8: PMRA Transformation: Transparency and data strategy

Lindsay Noad, Director General, Transformation
Roger Charland, Director General, Transformation - Special Projects

The presenters provided the PMRA's work to date on the development of new web pages and content for improving science communication and usability. The presenters also provided an overview of the outcomes of the PMRA's consultation and its next steps in relation to Document and Information Disclosure.

Discussion
The PMRA was commended by some members on the great work and improvements towards increasing transparency that it made on science communication.

The PMRA was asked to provide data analytics on web traffic for the improved web pages. Discussion was held on topics including prioritization of deliverables, allocation of resources, and the complexity of the different target audiences for science communication. The PMRA acknowledged the challenge in presenting audience-specific information, from plain language to technical, and noted that the Agency is prioritizing other pressing work (for example, inspection of CTD via the Reading Room process, and Access to Information requests).

Given resource constraints, it was suggested that the PMRA tighten the scope of the Transformation initiatives to maintain capacity to deliver its core mandate. The PMRA echoed the PMAC's note and informed PMAC members of its prioritization exercise in February 2023. Work is underway on a number of the priorities, which reflect the pressure that the Agency has been experiencing.

Lastly, it was suggested that the PMRA consider ways to measure the cost to the organization of initiatives associated with increased public participation.

Item 9: Maximum residue limits

Monique Thomas, Section Head, Health Evaluation Directorate

The presenter provided an overview of the work to date that led the PMRA to resume the publication of proposed decisions to increase MRLs.

Discussion
The PMRA clarified that there were about six MRLs remaining in the backlog at the time of the pause in 2021. All comments received to date on the published proposed MRLs that are proposing increases to MRLs are being considered to determine if any of the PMRLs in the queue need to be revised.

The PMRA clarified that some consumer testing of MRL-related web messages had been done which allowed adjustment of web content, but the consumer-tested content on imported MRLs has not yet been launched.

When asked about the rationale for bringing the glyphosate MRL question to the SAC-PCP, the PMRA responded that due to the volume of comments received, which included independent studies (rare during consultation), and the timing that coincided with the release of the EU report, the PMRA may seek scientific input from the SAC-PCP to help support public confidence.

Different perspectives were shared regarding the lifting of the pause on increased MRLs and the reporting of domestic and import MRLs as a single value.

While acknowledging some differences in opinion on whether separate MRLs should be established for domestic and imported commodities, the PMRA stated that the topic had been previously discussed by the MRL Technical Working Group and shared the highlights of what was heard.

The PMRA offered to update PMAC at a future meeting on the specific discussions of the MRL Technical Working Group in relation to MRLs for domestic and imported commodities.

The group was reminded of the importance of hearing these different views on MRLs, as it helps generate confidence in science-based communication.

Item 10: IT modernization

Joseph Mikhael, A/Director, IT Modernization, Transformation - Special Projects

The presenter outlined the PMRA's work to date on the modernization of its information technology infrastructure and next steps.

Discussion
PMAC members congratulated the PMRA on the great work in this area.

Recognizing that there were known industry initiatives to consolidate labels and standardize certain information (for example, identify harvest intervals), the PMRA was asked if this standardization could be pursued to help with improving data searches. The PMRA responded that the long-term vision is to standardize, but the Agency wanted to release a solution sooner to help resolve the re-evaluation backlog.

Some PMAC members suggested that the PMRA present an update on IT modernization tools at a future meeting. 

Item 11: Trends in Notices of Objection (NoO) to major registration decisions

Minoli Silva, A/Director General, Registration Directorate

As an action item arising from PMAC's meeting in 2022, the presenter updated PMAC on the Notices of Objection (NoO) received.

Discussion
The PMRA clarified that a review panel was used once in the past by the PMRA. The PMRA also explained that the SAC-PCP might advise on the initial screening of the NoOs in the future but indicated that a significant amount of initial work would be required before presenting NoOs to the SAC-PCP. The PMRA also provided an estimate on the number of objections in relation to the number of decisions. The PMRA further clarified that the numbers do not tell a complete story, since one decision can have multiple NoOs and their complexity is increasing. The PMRA shared that on the complexity of NoOs, there are more pre-market NoOs and the recent ones require follow-up on the scientific information provided to support their objection, whereas previously NoOs were quickly closed as they did not state the scientific basis of the objection.

It was suggested that the PMRA continue to provide updates on NoO statistics at a future meeting.

Tuesday, September 19, 2023

Item 12: Regulatory and policy updates

Ruth Rancy, Director General, Policy and Operations Directorate

The presenter updated PMAC on PMRA's recent ongoing regulatory and policy initiatives.

Discussion
Discussion focused on new guidance for registrants on implementation of changes. The PMRA clarified that once regulations are finalized, guidance on implementation would be updated or developed as required. The PMRA also informed PMAC that Health Canada's Regulatory, Operations and Enforcement Branch (ROEB) prepares an annual plan for compliance promotion, which often includes raising awareness about new or amended regulations and guidance. In addition, the PMRA is working on updating all its guidance documents.

It was noted that more antimicrobials were registered in the United States than Canada and asked whether the PMRA was working to address this “gap”. The PMRA responded noting that while the United States has many registered products, it is not clear how many of them are actually used, and that many products registered in Canada have zero sales and thus are never used. It was noted that the PMRA is looking into this issue.

Item 13: Post-market review program

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

The presenter updated PMAC on PMRA's post-market review program.

Discussion
PMAC congratulated the PMRA on the completion of the re-evaluation of all the legacy pesticides.

Regarding the planned consultation for the Policy on Cancellations and Amendments Following Re-evaluation and Special Review, the PMRA stated that the Agency would work with its engagement teams to avoid potential overlap with other consultations.

Extensive discussions took place on issues including performance standards, reasons for not meeting performance targets for categories 1 and 3, triggers for special reviews, as well as the long-term sustainability of the re-evaluation team given the increasing workload trend.

The PMRA noted that currently it takes an average five years to conduct cyclical re-evaluations instead of the target of 4.2 years. The PMRA stated that workload pressures are also impacted by the increasing trend in pre-market NoOs and three court challenges last year, which took a large amount of resources and time. The PMRA added that the scientists that must respond to pre-market NoOs and court challenges are the same individuals who conduct the cyclical re-evaluations.

While acknowledging the challenges, the PMRA noted the importance of initiatives, such as Continuous Oversight (CO) and Proportional Effort (PE) policies, as well as on IT improvements (structured labels – accessibility and readability). The tools and processes from these initiatives are anticipated to streamline processes and help the PMRA achieve the re-evaluation targets, including any surge requests.

In response to PMAC's question on the most common trigger for special reviews, the PMRA explained that previously the most common trigger was the prohibition of all uses of a product by an Organization for Economic Co-operation and Development (OECD) member country. However, more recently the most common trigger has been new scientific information (for example, information received via the Incident Reporting Program).

Item 14: PMRA budget overview

Glenna Somers, Director, Policy and Operations Directorate

The presenter provided an overview of the PMRA's budgets from fiscal years 2020-21 through 2023-24.

Discussion
In response to a request from the PMAC Chair, the PMRA provided a brief overview of the departmental budget process.

PMAC noted that some of the Transformation initiatives would not be completed by the end of the fiscal year and that many have significant delivery costs. Some PMAC members expressed concern that in the absence of renewed funding. The PMRA's capacity to deliver its core operations could be negatively impacted if the Transformation work were to continue. The PMRA indicated that seeking renewal of Transformation funding remains a top priority and provided examples of activities that would be scalable depending on funding level.

The Chair suggested that further discussion on funding would be warranted at the next meeting.
The Chair would also like to indicate that some PMAC members expressed the concern that recommendation number 1 and its explanatory paragraph are not reflective of the opinion they expressed during the meeting, and while not raising formal dissent, they requested that it be noted in this report. These members are of the view that the PMRA's capacity to deliver on its core operations will be negatively impacted if the Transformation activities were to continue without renewed funding. 

In camera session
The last portion of the meeting was held in camera for the following two agenda items:

Item 15: Health Canada's Pesticide regulatory program cost recovery modernization

Jason Proceviat, Director General, Transformation - Program Renewal
Lars Juergensen, Associate Director, Transformation - Program Renewal

The presenter provided an update on the PMRA's work to date and its stakeholder engagement this fall.

Item 16: Updates to PMAC's Terms of Reference (ToR)

Jordan Hancey, Director, Policy and Operations Directorate

The presenter updated PMAC on the proposed amendments to PMAC's ToR. 

Closing remarks

In closing, the PMRA thanked PMAC members for their inputs. The meeting was adjourned.

Recommendations to the Minister of Health

Members discussed potential recommendations for the Minister of Health, based on their deliberations during the meeting.

2023 Recommendations to the minister

1. PMAC acknowledges the significant progress that has been made by the PMRA on several fronts as illustrated by the presentations made on September 18 and 19, 2023. The PMRA has embarked on an ambitious Transformation Agenda that is complex in nature to ensure the protection of human health and the environment. PMAC is concerned that when the Transformation Agenda sunsets in March 2024, without additional funding for continuance of its initiatives, PMRA core operational activities could risk being negatively impacted. Additionally, the federal government is facing tremendous budget pressures that might impact the PMRA. Consequently, PMAC reiterates its recommendation of 2022:

   • That the Minister commits to increase core funding to the 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. An increase to the minimum core funding is required for the PMRA to continue to meet its overall legislative mandate.

   PMAC members recommend that the Minister seeks appropriate funding from central federal government agencies to ensure core funding and transformative agenda initiatives can be conducted over the next 3 years. PMAC members will also encourage their own organisations to make such representations in their submissions to central government agencies and appropriate government committees, such as the Finance committee.

2. PMAC recognizes the efforts by the PMRA to engage stakeholders who are diverse and often possess conflicting interests.

   PMAC recommends to the Minister that the PMRA maintains and enhances its efforts to engage stakeholders in a meaningful way, which would include early consultation on the development of new initiatives, on its Transformation Agenda, and on the continuity of its day-to-day operations. Special effort should be made for early engagement with Indigenous groups in the co-creation of novel consultation mechanisms. Also, engagement with partners in the provinces and territories should be strengthened to promote early communication – thus, ensuring support for PMRA initiatives. However, any consideration of community-based science initiatives should remain grounded in science-based decision making and based on a fully funded, in-house, PMRA-focused programs.

   Given the wide array of initiatives, there are numerous stakeholder consultations occurring simultaneously, which places a burden on stakeholders. PMAC recommends to the Minister that these consultations be coordinated within the PMRA and with the relevant federal departments where possible. The Minister should also consider how best to support stakeholders to participate in these various consultations while minimizing potential resource impact on the stakeholders.

3. Some pesticide-related initiatives that are of interdepartmental and intergovernmental nature would benefit from PMRA expertise and its network of stakeholders.

   PMAC recommends to the Minister that the PMRA remains engaged on a range of scientific issues related to environmental and health risk assessments. An example of this is the implementation of Targets 6 and 7 of the Kunming-Montreal Global Biodiversity Framework.

4. PMAC supports its current reporting directly to the Minister of Health, which was originally put in place to address multi-stakeholder concerns related to pesticides regulation in Canada. PMAC welcomes the additions of the chair and the co-chair of the Science Advisory Committee on Pest Control Products (SAC-PCP) as ex officio members to PMAC.

   However, PMAC members are concerned that the change of reporting of PMAC to the Deputy Minister could lower the visibility of PMAC recommendations to the Minister, and as such stakeholder perception that the PMRA issues are not considered as important as before.

   Consequently, PMAC recommends to the Minister to maintain the current reporting of PMAC directly to the Minister.

Participant list

Chair
Pierre Charest, PMAC Chair

Council members/alternates
Greg Bartley, Director, Crop Protection and Crop Quality, Pulse Canada
Shannon Coombs, President, Canadian Consumer Specialty Products Association
Ian Culbert, Executive Director, Canadian Public Health Association
Toni Grewal, Teacher and Labour Representative, member of British Columbia Teachers' Federation [via Zoom]
Lisa Gue, Manager, National Policy, David Suzuki Foundation
Brian Innes, Executive Director, Soy Canada
Jeremy Kerr, Chair, Department of Biology, University of Ottawa
Melanie Langille, Director, Program Development, New Brunswick Lung Association
Karsten Liber, Executive Director, School of Environment and Sustainability, University of Saskatchewan
Paleah Black Moher, Toxicologist and Principal Director, Ecotox Consulting
Terri Stewart, Executive Director, Chemistry, CropLife Canada (alternate for Pierre Petelle, President and CEO)
Geneviève Hamelin, Specialized Scientific Advisor, Public Health Institute of Quebec (alternate for Mathieu Valcke) [via Zoom]
Brodie Berrigan, Director, Government Relations and Farm Policy, Canadian Federation of Agriculture [via Zoom]

PMAC members from the Science Advisory Committee on pest control products
Eric Liberda, Professor and Associate Director, Toronto Metropolitan University [via Zoom]
Valérie Langlois, Doctorat, Professeure titulaire, Institut national de la recherche scientifique (INRS) [via Zoom]

PMAC members from the Federal/Provincial/Territorial Committee on Pest Management and Pesticides (FPT-CPMP)
Faye Dokken, FPT-CPM co-chair 2023, Director, Crops and Irrigation Branch, Ministry of Agriculture, Government of Saskatchewan
Eileen Beaton, FPT-CPM co-chair 2022, Agri-Environmental Specialist, Prince Edward Island Department of Agriculture

Regrets
Mathieu Valcke, Specialized Scientific Advisor and Institutional Researcher, Public Health Institute of Quebec, PHIQ
Pierre Petelle, President and CEO, CropLife Canada
Victor Odele, Senior Research and Policy Advisor, Environmental Health, Assembly of First Nations
Fruit and Vegetable Growers of Canada

Executive Secretary to PMAC
Frédéric Bissonnette, Executive Director, Pest Management Regulatory Agency (PMRA)

PMRA Secretariat
Ruth Rancy, Director General, Policy and Operations Directorate
Jordan Hancey, Director, Policy and Regulatory Affairs Division
Omar Ayad, Section Head, Stakeholder Relations and Outreach
Natalie Lamarche, Project Coordinator
Vicky Butz, A/Senior Scientific Projects Coordination Biologist
Diane Rhéaume, Outreach Communications Advisor
Kathleen Eng, Senior Scientific Project Coordination Biologist
Sophie Ziai, Scientific Projects Coordination Biologist

Health Canada – Pest Management Regulatory Agency representatives
Manon Bombardier, Assistant Deputy Minister of Transformation
Minoli Silva, A/Director General, Registration Directorate
Lindsay Noad, Director General, PMRA Transformation
Margherita Conti, Director General, Value Assessment and Re-evaluation Management Directorate
Regi Mathew, Director, Value Assessment and Re-evaluation Management Directorate
Janice Villeneuve, Section Head, Environmental Risk Directorate
Monique Thomas, Section Head, Health Evaluation Directorate
Lars Juergensen, Associate Director, Office of Program Renewal
Roger Charland, Director General, Special Projects, PMRA Transformation
Glenna Sommers, Director, Strategic Planning, Financial and Business Operations
Matthew Bown, Manager, Office of Program Renewal
Joseph Mikhail, A/Director, IT Modernization

Health Canada – Regional Operations and Enforcement Branch representatives
Denise MacGillivray, Director General
Rick O'Leary, Senior Advisor to the Director General

Deputy Minister's office
Eric Costen, Associate Deputy Minister of Health Canada