Pest Management Advisory Council – November 2024 meeting summary report
The Pest Management Advisory Council (PMAC) is a multi-stakeholder group that fosters communication and dialogue among stakeholders and with Health Canada's Pest Management Regulatory Agency (PMRA) and provides advice 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 November 13 and 14, 2024, PMAC held a virtual meeting with parts of the meeting open to the registered external observers while parts of the meeting were held in camera (closed discussion) for PMAC members.
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Meeting objectives
The PMRA updated the PMAC on the Agency's financial situation, as well as the ongoing work and next steps to advance key priority initiatives to improve protection of human health and the environment, increase transparency, modernize regulations, and ultimately increase public trust.
Meeting summary
Wednesday, November 13, 2024, summary
Item 1.0 Opening remarks and review of the agenda
The PMAC Chair, Dr. Pierre Charest welcomed all participants and provided an overview of the agenda. All PMAC members introduced themselves and confirmed no changes to their affiliations and interests.
The Assistant Deputy Minister (ADM) of the PMRA, Dr. Manon Bombardier welcomed the Chair and the PMAC members. On behalf of the Deputy Minister (DM) of Health, Greg Orencsak, the ADM conveyed Health Canada's appreciation of the critical role of the Council and thanked the Council for their contributions. The ADM gave a brief update on the PMRA's work and highlighted the meeting objectives.
Item 2.0 PMRA's journey: Sustaining progress on our priorities and strategic initiatives
Dr. Manon Bombardier, Assistant Deputy Minister (ADM), PMRA
The PMRA presented the PMRA's achievements since the last PMAC meeting in Fall 2023 and outlined the vision for 2029-2030.
The PMRA indicated that the PMRA's vision and mandate are to protect human health and the environment through rigorous science and building public trust in the process. The PMRA also highlighted the substantial progress the PMRA made in relation to strategic initiatives, which includes advances in the PMRA's core work, process modernization, transparency, and real-world data programs.
More specifically, the PMRA completed a two-year Water Monitoring Pilot Program for pesticides from April 2022 to March 2024. This pilot provided insights towards implementing a long-term Canadian water monitoring program for pesticides. The Agency is working on finalizing the framework in order to launch a Canadian program next year.
In the area of real-world pesticide use information, the PMRA completed two pilots, one on apples, and the other on select fruit and ornamental crops. A Proposed Pesticide Use Information Framework is being developed and consultation is planned for early 2025.
The PMRA also highlighted advances in transparency with the continued publication of science communication infographics and plain language summaries of regulatory decisions. Progress is also being made on improving access to information, such as disclosing the list of relevant studies used in assessments with a rationale for any exclusion, and facilitating access to confidential test data.
Lastly, the PMRA stated that stakeholder and partner engagement is key to the PMRA's success, and the PMRA is seeking broader, balanced perspectives to ensure efficient, transparent, and meaningful engagement. The PMRA is expanding its Transparency Policy across PMRA activities to publicly disclose meetings with stakeholders on a web calendar to increase transparency.
Discussion
The PMRA made reference to the ongoing media and public scrutiny facing the PMRA's scientists and how this is affecting the morale at the PMRA. In parallel to addressing media requests, the Department is reassuring the staff of their quality work in protecting Canadians and the environment of applying the best available science with high integrity. The PMRA is also working with the communications team at Health Canada to correct the misinformation.
Extensive discussions took place on the importance of having performance metrics to track progress and effectiveness on work related to transparency and building public trust. The PMRA responded that transparency is a journey. More time is required for the sum of efforts to fully materialize on the following transparency initiatives: plain language in regulatory documents, the PMRA's Reading Room service, and a new self-serve public portal. Currently, the PMRA obtains feedback through public opinion research and its various public consultations on policies. It was noted that the Agency is open to looking into this and considering improvements going forward.
Some PMAC members expressed concerns around the slippage in review timelines and asked if the PMRA would have data to illustrate year-to-year performance. It was also noted that increased workloads relating to Transformation might be putting pressure on resources and affecting performance. The PMRA responded that numerous factors are implicated, and the presentation shared secretarially contained pre-market performance data between 2021 and 2024. Regarding Category A submissions, the PMRA clarified that two years is the timeline to process a complete application. Any deficiencies or unaddressed risks would put a submission on-hold while awaiting additional data from the applicant; in turn, this lengthens the total timeline.
One member requested that the PMRA clarify how the Agency accounts for the additional work associated with the increasing demand for addressing responses to Notice of Objections, consultation comments and Access to Information requests. The member also inquired if the PMRA could compare the projections of the current workload with that from previous years. While appreciating the Agency's work to improve transparency, one member noted the importance and need for directional predictability in the PMRA's decision-making.
Some PMAC members raised concern about delays in processing NoOs and the need for a better system to manage these in a timely manner. The PMRA responded that these are becoming increasingly complex, and the Agency is taking steps to improve the process.
On the topic of plain language products the PMRA has produced, one PMAC member raised a concern with the tone and the goal of publishing these products. It was suggested that the PMRA focus on improving public awareness and knowledge of pesticide risks and regulation and not directing plain language efforts towards acceptance of pesticides.
It was suggested that alternate foods (for example, certified organic produce) should be proposed in the maximum residue limits (MRL) infographic. The PMRA responded that the mandate is not to suggest that the public consume certain products, but rather to improve communications so consumers can make the best choice for themselves. Some members expressed support for the plain language products.
Some PMAC members expressed concern that the water monitoring program and gathering of pesticide use data might be in jeopardy if transformation funding is not renewed and emphasized that re-evaluations should be prioritized. The PMRA responded that it would continue to seek funding for water monitoring and pesticide use program initiatives. The PMRA also indicated that re-evaluation is a core activity that is prioritized, and the Continuous Oversight and Proportional Effort policies that are being developed will provide tools needed to increase efficiency and timeliness.
During opening remarks, the PMRA referenced that the misinformation made in recent media articles had a negative impact on PMRA staff's morale. The claims called into question the Agency's reputation and its scientific staff. The Council expressed concern and asked whether staff morale is being undermined in a way that leads to animosity or lack of confidence in management, in the public media, or in the science community or some combination thereof. The PMRA responded that it is a combination of factors, and the media is one of them.
The PMRA stated that staff morale is a critical element of the PMRA's success and organizational health and that the management team is committed to creating a work environment that supports employees and where they can feel valued and proud of their work. Initiatives are underway to address morale, which stems not only from media attention but also from heavy workloads, including administrative work like responding to Access to Information requests.
Item 3.0 Regulatory and policy updates
Jordan Hancey, Director, Policy and Operations Directorate
The Regulations Amending the Pest Control Products Regulations (Exclusive Rights and Compensable Data): SOR/2023-104 came into force in December 2023. Three guidance documents for registrants and applicants were finalized, and two additional documents will be finalized following consideration of comments received during the recent consultation that closed in November 2024.
The List of Pest Control Product Formulants and Contaminants of Health or Environmental Concern was updated to include molluscs (an allergen) as a formulant, and a broader review of the List was initiated.
The presenter provided an overview of ongoing regulatory projects (Regulations Amending the Pest Control Products Regulations related to sodium hypochlorite and calcium hypochlorite, strengthening the regulation of pest control products in Canada, product exemptions and pest control product devices, research, and labelling; and Regulations Amending the Pest Control Products Fees and Charges Regulations – Annual Charge).
The presenter provided a status update on elements of the Treasury Board Secretariat-led Agri-food and aquaculture: Targeted Regulatory Review – Regulatory Roadmap, published in June 2019.
On the topic of policy, the presenter highlighted PMRA's involvement in the Kunming-Montreal Global Biodiversity Framework, the Greening Government Strategy (GGS) led by Environment and Climate Change Canada, and PMRA's updated Transparency Policy that will be published in early 2025.
Discussion
PMAC members asked for clarification on how comments received during the Consultation on Strengthening the regulation of pest control products in Canada (Notice of Intent NOI2023-01) were considered when developing the Canada Gazette Part I (CGI) pre-publication proposal. They expressed concern that there were not enough changes between the NOI and the CGI pre-publication to address the input they provided. The PMRA responded that all comments were taken into account, and they collectively informed the proposal that was published in CGI, which was more specific than the NOI.
Some PMAC members expressed concern with the resources directed toward the regulatory amendment on strengthening the regulation of pest control products in Canada, when the Minister of Health already has the authority to move forward with many of the proposed changes. The PMRA responded that making these authorities explicit will signal the importance of these types of data and help ensure that applicants and registrants are aware that they may be required to submit such data.
Some PMAC members expressed concern about the lack of a scientific methodology and requirements for evaluating cumulative environmental effects (CEE) while one member supported finalizing the amendment with respect to CEE while addressing the gap in requirements. The PMRA noted that this amendment helps align the PCPA with the recent Canadian Environmental Protection Act (CEPA) amendment, which added CEE, and will encourage the development of standards for assessing CEE.
In response to a comment on the long list of regulatory files, the PMRA responded that the team works on a certain number of initiatives at a time. Currently, the Agency is actively working on three regulatory projects pertaining to: cost recovery (CGI), and Regulations Amending the Pest Control Products Regulations - Product Exemptions and Pest Control Product Devices (CGI) and Strengthening the regulation of pest control products in Canada (CGII).
Action item
In relation to the reference on page 11 to Regulations Amending the Pest Control Products Regulations (Research), the PMRA was requested to correct the French translation to clarify that the term "benefit" is a qualifying adjective, referring to "research" and not to "the product".
In camera session
The remainder of the meeting was held in camera on November 13 and 14, 2024 for the agenda items listed below. The outcome of the in camera discussions are captured below and as part of PMAC's Recommendations to the Minister of Health.
PMAC discussion and deliberation of recommendations
The Council discussed and agreed on the five recommendations to the Minister included in this report.
Closing remarks
In closing, the PMRA and the PMAC Chair thanked Council members for their valuable contributions. The PMRA, the Secretariat and PMAC members thanked the PMAC Chair for his past three years of dedicated service to the Council. The meeting was adjourned.
2024 Recommendations to the Minister of Health
- PMAC recommends that the Government of Canada ensure sufficient resources for the PMRA to fulfill its core scientific mandate and legislative obligations. Activities related to pre-market applications, re-evaluations/special reviews, minor use registrations, addressing the re-evaluation backlog and the water monitoring program are critical activities to support the efficacy and credibility of PMRA decision-making on an ongoing basis.
- In light of significant budget uncertainty, PMAC further recommends that the PMRA launch a comprehensive review of its programming to identify any activities, initiatives, policies, among others, that does not fall within its core mandate and to evaluate whether they should be re-prioritized, streamlined, or eliminated. This comprehensive review should be undertaken in consultation with stakeholders, provinces and other relevant federal departments.
- Recognizing the importance of the issue of public trust and transparency, a special focus of the comprehensive review should be on how the desired outcome is measured, and how investments make progress towards this outcome. This is especially important for transparency and public trust, though is also relevant when reviewing activities in other areas. PMAC recommends that the PMRA report in subsequent meetings on the measurable goal for public trust and transparency, and how progress is being made.
- PMAC recognizes the annual cost recovery charge structure requires updating; however, PMAC recommends further consultation on the new user fee proposal. Transparency on the new proposal prior to publication would assist with understanding how this important initiative will support the Agency. As well, PMAC recommends that the Agency ensure that all cost recovery funds be returned to the PMRA.
- PMAC recommends that the Minister direct PMRA senior management to seek the fullest understanding of the origins and challenges regarding staff morale, and to take all appropriate follow-up actions to improve staff morale.
PMAC participants
Chair
Dr. Pierre Charest, retired 2019 from Vice-President, Natural Sciences and Engineering Research Council of Canada
Regular members
- Greg Bartley, Director, Crop Protection & Crop Quality, Pulse Canada
- Dr. Paleah Black Moher, Toxicologist and Principal Director, Ecotox Consulting
- Brodie Berrigan, Director of Government Relations and Farm Policy, Canadian Federation of Agriculture (CFA)
- Shannon Coombs, President, Canadian Consumer Specialty Products Association (CCSPA)
- Toni Grewal, Teacher, British Columbia Teachers' Federation
- Lisa Gue, National Policy Manager, David Suzuki Foundation
- Brian Innes, Executive Director, Soy Canada
- Dr. Jeremy Kerr, Chair, Department of Biology, University of Ottawa
- Dr. Karsten Liber, Executive Director, School of Environment and Sustainability (SENS), University of Saskatchewan
- Dr. Tracy Shinners-Carnelley, Vice President, Research, Quality & Sustainability, Peak of the Market Ltd., Vice Chairperson of the Fruit and Vegetable Growers of Canada (FVGC) Crop Protection Advisory Group, representing FVGC
- Dr. Mathieu Valcke, Specialized Scientific Advisor and Institutional Researcher, Public Health Institute of Quebec
Ex officio members
- Mark Langford, Provincial/Territorial co-chair from Federal/Provincial/Territorial Committee on Pest Management and Pesticides (FPT-CPMP)
- Dr. Eric Liberda, Professor, School of Occupational and Public Health, Toronto Metropolitan University, SAC-PCP co-chair
Alternate members in attendance
- Terri Stewart (for Pierre Petelle), Executive Director, Chemistry, CropLife Canada
Observer in attendance
- Chris Duyvelshoff, Crop Protection Advisor, Ontario Fruit & Vegetable Growers Association, Fruit and Vegetable Growers of Canada
Pest Management Regulatory Agency (PMRA) Executives
- Manon Bombardier, Assistant Deputy Minister
- Frédéric Bissonnette, Senior Director General, Regulatory Science and Operations
- Ruth Rancy, Director General, Policy and Operations Directorate
- Minoli Silva, Acting Director General, Health Evaluation Directorate
- Heather Simmons, Acting Director General, Environmental Assessment Directorate
- Lars Juergensen, Acting Director General, Office of Continuous Improvement
- Jason Flint, Director General, Registration Directorate
- Margherita Conti, Director General, Value Assessment and Re-evaluation Management Directorate
PMRA PMAC Secretariat from the Policy and Operations Directorate
- Michelle Kivi, Section Head
- Natalie Lamarche, Project Coordinator
- Shannon Seguin, Senior Project Coordinator
- Vicky Butz, Senior Scientific Project Coordination Biologist
- Elizabeth Donner, Strategic Engagement Advisor, Policy and Operations Directorate
Health Canada – Regulatory Operations and Enforcement Branch
- Natacha Boivin, Cost Recovery Manager, Planning and Operations Directorate
- Sally Gibbs, Acting Director General, Environmental Health, Consumer Products and Pesticides Directorate (EHCPPD)
- Rick O'Leary, Senior Advisor to A/DG, Environmental Health, Consumer Products and Pesticides Directorate
Environment and Climate Change Canada
- Matthew Cloutier, Director General, Science Policy, Planning, and Partnerships Directorate
- Nathan Pritula, Manager, Science Policy, Planning, and Partnerships Directorate
- Hugues Morand, Manager, National Biodiversity Policy, Canadian Wildlife Service
Agriculture and Agri-Food Canada
- Nicole Howe, Executive Director, Market and Industry Services Branch
- Troy Lau, Deputy Director, Crops and Horticulture Division
- De Champlain, François, Sector Specialist - Plant Health and Pesticides
Ontario Ministry of Agriculture, Food and Agribusiness
- Scott Duff, Director, Economic Development Policy
Regrets
- The Assembly of First Nations
- Dr. Valérie Langlois, Professor, Institut national de la recherche scientifique (INRS), Centre Eau Terre Environnement, ex officio member, SAC-PCP co-chair
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