Canada – Information Note – Strengthening Consideration of Cumulative Effects on the Environment and Species at Risk in PMRA’s Environmental Assessments

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Health Canada’s Pest Management Regulatory Agency
17 June 2024

Introduction
Pesticides in Canada are regulated under the Pest Control Products Act (PCPA), which is administered by Health Canada’s Pest Management Regulatory Agency (PMRA). The PMRA’s primary mandate under the Pest Control Products Act is to prevent unacceptable risks to Canadians and the environment (including wildlife) from the use of these products.

Before a pesticide is allowed to be used or sold in Canada, it must undergo a rigorous scientific assessment process that provides reasonable certainty that no harm to human health and the environment will occur when pesticides are used according to label directions. Depending on the type of pesticide being evaluated, results from numerous scientific studies (in some cases hundreds of studies) are reviewed to determine whether the pesticide would have any negative effect on people, animals (including aquatic organisms such as fish, amphibians and invertebrates; and terrestrial organisms such as birds, small mammals, earthworms, pollinators and other beneficial insects) or aquatic and terrestrial plants. The PMRA also regularly re-evaluates pesticides that are on the market to determine whether they continue to meet the Agency’s health and environmental standards and hence whether they should continue to be permitted for use in Canada.

During the PMRA’s consultation with a broad range of interested stakeholders and partners, including Indigenous organizations, in spring 2022, stakeholders raised that environmental risk assessments should be strengthened with regards to species at risk and the consideration of cumulative effects on the environment.

Cumulative effects on the environment
The PMRA’s current environmental risk assessments focus on single active ingredients, which aligns with the Pest Control Products Act and associated regulations. The PMRA does not have methodologies in place to assess cumulative effects of pesticides for organisms or groups of organisms that may be exposed to multiple pesticides in the environment. With the exception of co-formulated products, no jurisdiction has functional guidance that can be used to perform cumulative environmental risk assessments for pesticides.

To strengthen environmental protection from risks posed by pest control products, Health Canada is proposing to amend the Pest Control Products Regulations to include an explicit authority for the Minister of Health to require information from applicants and registrants on cumulative effects on the environment and a requirement for the Minister to consider such information in environmental risk assessments.

To meet these proposed new obligations, the PMRA will develop a framework on how best to incorporate consideration of cumulative effects on the environment in environmental risk assessments of pest control products. The development of this framework and the methodology to assess cumulative effects on the environment will be conducted in collaboration with domestic and international regulatory partners, as well as through leveraging the expertise and advice of the Science Advisory Committee on Pest Control Products. The PMRA will welcome stakeholder feedback on the proposed framework, once ready for consultation.

The PMRA will provide updates on this initiative to all external stakeholders, partners, and the public as they become available.

Species at risk
Health Canada is proposing to amend the Pest Control Products Regulations to include an explicit authority for the Minister of Health to require information from applicants and registrants on species at risk. This is aimed at supporting the protection of species at risk in regulatory decision-making on pest control products. Although the PMRA currently considers species at risk in its environmental risk assessments, the addition of a specific mention of species at risk in the Regulations emphasizes the importance that the PMRA places on protecting species at risk and the environment. The PMRA will work with federal partners to ensure that environmental risk assessments are informed by all available information on species at risk.

Related links
Consultation – Canada Gazette, Part I: Volume 158, Number 24: (Strengthening the Regulation of Pest Control Products in Canada)