Health Canada – OAG – Petition Response :Concerns about the regulation of the herbicide atrazine and its potential impact on amphibian populations

Frank Woodcock has been busy :
Concerns about the regulation of the herbicide atrazine and its potential impact on amphibian populations
Petition: No. 283

Issue(s): Biological diversity, human health/environmental health, international cooperation, and pesticides

Petitioner(s): Frank Woodcock

Date Received: 22 June 2009

Status: Completed

Summary: The petitioner is concerned about Canada’s regulation of the herbicide atrazine in light of a scientific study that, the petitioner claims, shows adverse effects on amphibian populations. The petitioner seeks information about the federal government’s plans and activities to monitor and research the adverse effects of atrazine on amphibians. The petitioner asks how regulatory decisions are made, given that the objective of Health Canada’s Pest Management Regulatory Agency is to prevent unacceptable risks to human health and the environment from the use of pesticides. The petitioner also asks if the Agency has made information publicly available on atrazine’s adverse effects on the environment.

Federal Departments Responsible for Reply: Environment CanadaHealth Canada

Petition

Frank Woodcock
35 Tyrell St., Simcoe, ON
N3Y 2H2
June 18, 2009
519-428-4031
f_woodcock@hotmail.com

The Auditor General of Canada
Commissioner of the Environment and Sustainable Development
240 Sparks St., Ottawa, ON
K1A 0G6

Attn. Petitions:

Please accept the following petition under the Auditor General Act.

When an herbicide like Atrazine is introduced into the environment there is a butterfly effect leading to a tipping point of unpredictable outcomes.

Scientists Hayes, TB, A Collins, M Lee, M Mendoza, N Noriega, AA Stuart, and A Vonk through their work have discovered hermaphroditic, demasculinized frogs after exposure to Atrazine, at low ecologically relevant doses. They found exposure to Atrazine at levels well below those found in the lakes, rivers, streams, rainwater and drinking water, causing frogs to mature with multiple, mixed gonads thereby becoming demasculinized. Atrazine’s ability to convert testosterone to estrogen appears to cause this phenomenon. This is also found further up the food chain, therefore pointing to the possible potential for Atrazine to affect humans.1

The European Community has banned Atrazine.

On the Health Canada web site under Consumer Product Safety http://www.hc-sc.gc.ca/cps-spc/pest/index-eng.php, it says, “The Pest Management Regulatory Agency is the branch of Health Canada that administers the Act on behalf of the Minister of Health. Our primary objective is to prevent unacceptable risks to people and the environment from the use of pesticides.

To accomplish this, each pesticide goes through a thorough scientific evaluation to determine if it meets current health and environmental standards. Only those pesticide products that meet Health Canada's standards and that are proven to be effective can be accepted for use in Canada.”

Question 1) If the Pest Management Regulatory Agency’s primary objective is to prevent unacceptable risks to people and the environment from the use of pesticides, how can the use of Atrazine in Canada be condoned when it has been proven harmful to amphibians?

Question 2) Is the government of Canada monitoring amphibians by species? Is the government of Canada monitoring amphibians by species regionally? Are their numbers on the decline? Are there differences in rates of decline by species? Are there differences in rates of decline by species regionally?

Question 3) What research has been done or is planned to be done concerning the decline of amphibians by species through Atrazine? What research has been done or is planned to be done concerning the decline of amphibians by species regionally through Atrazine?

Question 4) How can the difference in approach to the banning of Atrazine be explained between the EU and Canada?

Question 5) What obligations does Canada have through OECD to harmonize pest control products with other member countries?

Question 6) If the EU bans Atrazine and the Canadian government does not ban Atrazine, how does the precautionary principal play in this difference?

Question 7) An article appeared in the Vancouver Sun by Sarah Schmidt, Canwest News Service April 16, 2009 concerning Health Canada sitting on a report since March 2008 about an asbestos-cancer link.2 Is the Canadian government sitting on any national or international studies showing the adverse effects of Atrazine on the environment?

[Original signed by Frank Woodcock]

1)
Hayes, TB, A Collins, M Lee, M Mendoza, N Noriega, AA Stuart, and A Vonk. 2002. Hermaphroditic, demasculinized frogs after exposure to the herbicide, atrazine, at low ecologically relevant doses. Proceedings of the National Academy of Sciences (US) 99:5476-5480.
2) http://www.vancouversun.com/Health/Health+Canada+sits+report+about+
asbestos+cancer+link/1501374/story.html

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Minister's Response: Environment Canada

2 November 2009

Mr. Frank Woodcock
35 Tyrell Street
Simcoe ON N3Y 2H2

Dear Mr. Woodcock:

I am writing in response to your Environmental Petition No. 283, to the Commissioner of the Environment and Sustainable Development, regarding the management of atrazine and its potential impacts on amphibians and humans. The petition was received by Environment Canada on July 7, 2009.

In your petition you raise concerns about monitoring of amphibians and reasons for their decline, the harmonization of pest control products through the Organisation for Economic Co-operation and Development, and the role and responsibilities of the Government of Canada with regards to pesticide regulation.

Environment Canada has collaborated with Health Canada to prepare the Government’s response. I have reviewed this response, which is being sent to you by the Honourable Leona Aglukkaq, Minister of Health, and concur with its conclusions.

I appreciate your interest in this important matter.

Sincerely,

[Original signed by Jim Prentice, Minister of the Environment]

The Honourable Jim Prentice, P.C., Q.C., M.P.

c.c.: The Honourable Leona Aglukkaq P.C., M.P.
Mr. Scott Vaughan, Commissioner of the Environment and Sustainable Development

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Joint Response: Environment Canada, Health Canada

3 November 2009

Mr. Frank Woodcock
35 Tyrell Street
Simcoe, Ontario  N3Y 2H2

Dear Mr. Woodcock,

This is in response to your environmental petition no. 283 of June 18, 2009, addressed to Mr. Scott Vaughan, the Commissioner of the Environment and Sustainable Development of Canada (CESD).

In your petition you raised concerns regarding the herbicide Atrazine.

Due to the nature of the issues raised in your petition, I am pleased to provide you with a joint response prepared in collaboration with my colleague the Honourable Jim Prentice, Minister of the Environment.

I appreciate your interest in this important matter, and I hope you will find the enclosed information useful.

Yours sincerely,           

[Original signed by Leona Aglukkaq, Minister of Health]

Leona Aglukkaq

Enclosure

c.c. The Honourable Jim Prentice, P.C., Q.C., M.P.
Mr. Scott Vaughan, CESD


Response of the Federal Departments and Agencies to
Environmental Petition 283 Filed by Frank Woodcock under the
Auditor General Act

Received July 7, 2009

Concerns regarding the pesticide Atrazine

November 4, 2009

Minister of Health, Minister of the Environment

Responses to Petitioner’s Questions

Introduction:

The primary focus of Health Canada’s Pest Management Regulatory Agency (PMRA) is to prevent unacceptable risks to people and the environment from the use of pest control products. Pesticides in Canada are regulated by the federal government under the Pest Control Products Act (PCPA) and Regulations. Health Canada is responsible for administering the Act, including registration and re-evaluation of pest control products. To prevent the use of pesticides from adversely affecting Canadians' health or their environment, Health Canada assesses human health and environmental risks and value of pest control products, before and after registration.

Before a product is registered, it must undergo a thorough science-based assessment and meet strict health and environmental standards. Furthermore, all pesticides are re-evaluated on a 15 year cycle using the same rigorous scientific approach to ensure their continued acceptability. Products are approved for registration, or continued use, by the PMRA only when their use results in an acceptable level of risk to health and the environment and acceptable value, within the Canadian context.

Health Canada completed the health reassessment for atrazine in 2004 and issued a proposed re-evaluation consultation document Atrazine (PACR2003-13). The decision document (RRD2004-12) concluded that the health risks are acceptable with the implementation of mitigation measures, including using atrazine on corn only and reducing the maximum application rate. Subsequently, on 22 May 2007, PMRA published PACR2007-05, Re-evaluation of Atrazine (Environmental Assessment), which presented the outcome of the environmental assessments and the proposed decision for atrazine. The re-evaluation decision RVD2007-05 for the environmental assessment of atrazine concluded on 19 December 2007 that the use of atrazine on corn for weed control does not entail unacceptable risk to the environment. As a result, continued registration of atrazine on corn is acceptable provided that the proposed mitigation measures are implemented.

In addition, as required under subsection 17(2) of the PCPA, the Minister of Health shall initiate a special review if all uses of an active ingredient are prohibited (e.g. banned) in an OECD country for health or environmental reasons. Health Canada continuously monitors its international partners for developments that could affect the acceptability of a pesticide in Canada. The regulatory status of a pesticide in other nations is taken into account when Canadian registration or re-evaluation decisions are made. However, prohibition or withdrawal of a pesticide in a foreign country does not necessarily equate to unacceptable risk in Canada. Withdrawal of a pesticide may be the result of a business decision from its manufacturer to discontinue registration. Or, a pesticide could be prohibited in another nation based on legislation specific to that nation, which would not apply to Canada.

Question #1:
If the Pest Management Regulatory Agency’s primary objective is to prevent unacceptable risks to people and the environment from the use of pesticides, how can the use of Atrazine in Canada be condoned when it has been proven harmful to amphibians?

Under the PCPA, if the proposed uses of a pesticide (e.g. herbicide, insecticide, fungicide) meet stringent health and environmental safety standards and prove value in its application, it shall be registered.

The Minister of Health’s commitment to protecting human health and the environment is embedded in the statutory mandate of the PCPA: “to prevent unacceptable risks to people and the environment from the use of pest control products”. The PCPA defines “acceptable risk” as being “reasonable certainty that no harm to human health, future generations, or the environment will result from exposure to, or use of, the product taking into account its conditions or proposed conditions of registration”. Further, the PCPA includes requirements to protect vulnerable populations, to undertake cumulative and aggregate risk assessments, as appropriate, and to apply the “precautionary principle” where needed as an interim measure pending the completion of a re-evaluation or special review. If the re-evaluation or special review determines that the product is no longer of acceptable risk or value, the registration must be amended or cancelled.  

Prior to the registration or during the re-evaluation of a pesticide for use in Canada, Health Canada’s PMRA conducts an extensive independent review of health and environmental studies required as part of the regulatory process. The evaluation takes into account the available scientific information on potential health and environmental effects, as well as environmental fate, which includes consideration of breakdown products.

The review is a rigorous science based examination of the scientific information available on all aspects of a product. Based on the results of the review, the PMRA compares concentrations of the product in the environment (e.g. food and water) resulting from use, with concentrations that would cause effects in wildlife (e.g. birds, fish, pollinators etc.) or humans to determine if the product poses a risk to the environment or human health.

PMRA recently conducted a thorough re-evaluation of atrazine according to modern standards, and considered all available data on this pesticide including published literature from around the world.  The public was consulted on the proposed decision, and the final decision was published (19 December 2007). PMRA concluded that the continued use of atrazine was acceptable for use on corn, when used according to label directions.

The potential environmental effects including risks of atrazine to amphibians were specifically addressed by the PMRA in its re-evaluation, which included the following public documents: Re-evaluation of Atrazine (Environmental Assessment), PACR 2007-05 and Re-evaluation Decision, Atrazine (Environmental Assessment), RVD 2007-05. Our assessment concluded that the risk of effects resulting from short term exposure to amphibians was determined to be low within Canadian use areas.

Sublethal effects, including reproductive/developmental effects, on amphibians from longer term exposure to atrazine were considered by the PMRA using data reviewed and published by the United States Environmental Protection Agency (U.S. EPA) (2007) as well as the conclusions of two Scientific Advisory Panels (SAP) convened by the U.S. EPA specifically to discuss the issue of the effects of atrazine on amphibians.  These panels consisted of experts in the scientific fields of amphibian toxicology, reproduction, endocrinology, demography, and environmental risk assessment. They also concluded that exposure to ambient concentrations of atrazine is not expected to pose an appreciable risk to amphibians on a short term basis. Canadian government scientists participated on the panels.

The initial SAP reached a consensus that sublethal effects reported in amphibians were attributable to atrazine, but the atrazine exposure concentration at which effects occurred was unclear based on available data due to differing research findings, protocols and questions about the validity of how the studies were conducted. To address this uncertainty in the reported effects, the SAP recommended that additional studies designed to better understand this determination be conducted.  Based on the SAP recommendations, the U.S. EPA requested that additional studies be conducted.  Canadian scientists, including the PMRA, agreed with the conclusions and recommendations of the SAP.

In response to the U.S. EPA’s request, additional studies were conducted and a second SAP was convened in 2007 to review additional studies.  The PMRA also participated on this panel. Overall, the results from the studies showed that atrazine had no effect on gonadal development in Xenopus Laevis, which is a frog commonly used in research. The panel was in general agreement with the results and conclusions of the studies and those of the EPA review.  The PMRA agrees with the general conclusions of the U.S. EPA and of the 2007 Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) SAP, that atrazine does not adversely affect amphibian gonadal development at concentrations tested. If new papers in the scientific literature regarding the potential effects of atrazine on amphibians become available, the PMRA can consider the information.

Question #2:
Is the government of Canada monitoring amphibians by species? Is the government of Canada monitoring amphibians by species regionally? Are their numbers on the decline? Are there differences in rates of decline by species? Are there differences in rates of decline by species regionally?

Is the Government of Canada monitoring amphibians by species?

Canada’s provinces and territories are responsible for the management of Canada’s amphibians.

Under the Species at Risk Act (SARA) Environment Canada supports two processes which contribute to the assessment of amphibians in Canada: Committee on the Status of Endangered Wildlife in Canada (COSEWIC); and the General Status Program. Information documented as part of the COSEWIC process and the General Status Program is available for use as a source of amphibian information in Canada. Details on SARA can be found at the Species at Risk Registry . In addition, Environment Canada’s Canadian Wildlife Service is participating in amphibian monitoring in Quebec.

COSEWIC: COSEWIC is an arm’s length advisory body to Environment Canada which is comprised of a committee of experts that assesses the conservation status of wildlife species that may be at risk in Canada. Established under the Species at Risk Act (SARA) COSEWIC ensures that wildlife species continue to be assessed under a rigorous and independent scientific process. COSEWIC status categories include Extinct, Extirpated, Endangered, Threatened, Special Concern, Data Deficient, and Not At Risk. Detailed information regarding the COSEWIC assessment process can be accessed at . COSEWIC status reports can be accessed on the SARA Public Registry [].

General Status Program: Environment Canada participates in the assessment of the general status of Canada’s wild species through the National General Status Working Group (NGSWG).  General status assessments are used to classify species into one of 10 general status ranks; Extinct, Extirpated, At Risk, May Be At Risk, Sensitive, Secure, Undetermined, Not Assessed, Exotic or Accidental.  Among other conservation benefits, the general status ranks are an important source of information for priority candidate lists of the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).

Environment Canada is responsible for the coordination and development of the Wild Species report series which presents the general status assessment information and is also responsible for maintaining the Wild Species website [www.wildspecies.ca].  The website permits visitors to access the Wild Species reports and the general status Search Tool  [] (an online general status database).  A review of the provincial and territorial general status ranks for amphibian species (accessed via the general status Search Tool) provides the reader with a snapshot of the status of amphibians by province/territory.

The general status Search Tool does provide summary information for all amphibians in Canada as a taxonomic group, for each species of amphibian in Canada, and also by province/territory.

Is the Government of Canada monitoring amphibians by species regionally?

COSEWIC: COSEWIC wildlife species assessments are done at a national level and not at a regional level. Environment Canada, in its support of COSEWIC, is not contributing to the monitoring of amphibians regionally and does not have information about rates of decline by species regionally.

General Status Program:  Environment Canada, in its support of the General Status Program, is contributing towards information about amphibian numbers (as a group and also by species) over time and also at the regional scale (provincial/territorial).

Environment Canada’s Canadian Wildlife Service’s Contribution to Amphibian Monitoring in Quebec

In Quebec, Environment Canada’s Canadian Wildlife Service participates in monitoring amphibians in two ways. Amphibian inventory work is underway in Quebec’s National Wildlife Areas (NWAs). Since 2004, amphibian inventories have been established in each of the eight National Wildlife Areas in Quebec. These data will serve as a baseline to evaluate future amphibian population trends for amphibians found in these NWAs.  In addition, since 1997, a specific survey for four species of anurans (amphibians without tails as adults) has been underway in the Cap Tourmente NWA.  Related to SARA, the Quebec regional office of the Canadian Wildlife Service participates in provincial recovery teams for the Western Chorus Frog and some salamanders found in Quebec streams (Allegheny Mountain Dusky Salamander, Northern Dusky Salamander, Northern Two-lined Salamander and the Spring Salamander).

Are their numbers declining?
Are there differences in rates of decline by species?
Are there differences in rates of decline by species regionally?

Questions related to amphibian decline can not be answered definitively by using COSEWIC or general status information only. The text included herein is a summary of the COSEWIC and general status information that relates to these questions.

COSEWIC: The total number of amphibian species assessed by COSEWIC is 36. Of these 36 species, 20 have been assessed only once and nine have been assessed multiple times.

Assessment results for the 20 species assessed once are: Extirpated = 1, Endangered = 2, Threatened = 1, Special Concern = 2, and Not at Risk = 14. Of the nine amphibian species reassessed, four species have been reassessed once. Two of these species have gone into a higher risk category upon re-assessment (Special Concern to Threatened and Threatened to Endangered), and two species have not changed (both originally assessed as Endangered and remained Endangered on reassessment). Five species have been reassessed twice but these reassessments did not lead to a change.

Details related to COSEWIC amphibian assessments can be accessed here: .

Differences in rates of decline by species regionally are not applicable to COSEWIC as COSEWIC species assessments are conducted at the national scale.

General Status Program:

Highlights from the Wild Species 2000 report that relates to amphibians are:

  • Canada is home to 45 species of amphibians.
  • Twenty-nine (64%) amphibian species in Canada are considered Secure.
  • Four (9%) amphibian species in Canada are considered At Risk.
  • Amphibians are believed to be environmental indicator species.
  • Globally, populations of many amphibian species are believed to be declining.

A detailed summary of the general status data for amphibians from the Wild Species 2000 report can be accessed at: http://www.wildspecies.ca/wildspecies2000/en/SP02DE.html .

Highlights from the Wild Species 2005 report related to amphibians are:

  • More than two-thirds (65%) of amphibian species have Canada General Status Ranks (Canada ranks) of Secure, but 20% have Canada ranks of At Risk and 15% have Canada ranks of Sensitive.
  • Since Wild Species 2000, the Rocky Mountain Tailed Frog has been declared a separate species from the Coast Tailed Frog, increasing the total number of amphibian species in Canada to 46.
  • Compared to Wild Species 2000, the Canada ranks of 77% of amphibian species remain the same, 11% of amphibian species have been moved to a Canada rank with an increased level of risk, and 11% of amphibian species have been moved to a Canada rank with a reduced level of risk. Most of the changes were due to COSEWIC assessments (80%). None of the changes were due to biological changes in species abundance, distribution or threats.  For a comprehensive description of the reasons for the changes in amphibian ranks in the 2000 and 2005 reports please see:
  • On a global scale, many amphibian species are at a high level of risk of extinction; the recent Global Amphibian Assessment ranked nearly one-third (32%) of the world's amphibians as Threatened, compared with 23% of all mammal species and 12% of all bird species.

A detailed summary of the general status data for amphibians from the Wild Species 2005 report can be accessed at: .

The NGSWG is preparing the Wild Species 2010 report in which amphibians are assessed for the third time.  Accordingly, the most recent amphibian data (2008) is currently in draft format.  A copy of the draft 2008 amphibian data can be requested by contacting the General Status Program [wildspecies@ec.gc.ca]. 

Question #3:
What research has been done or is planned to be done concerning the decline of amphibian species through Atrazine? What research has been done or is planned to be done concerning the decline of amphibians by species regionally through Atrazine?

Intensive row crop agriculture (IRCA) for corn and soybean production is predominant in eastern and central North America.  Research results on atrazine are mostly tied to investigations of pesticide mixtures and their effects in the environment.  IRCA relies heavily on pesticides and nutrient inputs to maximize production under conventional systems.  The occurrence of a suite of potential endocrine-disrupting and lethal substances in water samples and amphibians inhabiting farm ponds and agricultural drains in IRCA areas of southwestern Ontario, were assessed and compared to reference locations devoid of local application of crop pesticides and fertilizers.  atrazine and metolachlor were detected in most samples, exceeding 1µg per litre at some IRCA sites.  Northern leopard frogs (Rana pipiens) and green frogs (Rana clamitans) were examined for sex steroids and vitellogenin-like proteins.  Gonads were histologically examined for evidence of abnormalities.

Some evidence of exposure to endocrine disrupting compounds was apparent from frog biopsies and physiological measurements.  The occurrence of testicular ovarian follicles in male R. pipiens was 42% higher (p < 0.05) at agricultural sites, particularly those in Chatham county, compared to frogs from reference sites (7%).  Circulating sex steroid levels did not seem to be affected by pesticide concentration from agricultural and reference sites. Nor were differences detected in the weight of the gonads or stage of spermatogenesis between frogs from agricultural and non-agricultural regions (p > 0.05).  Neither gonad size, gonad maturity, nor sex steroid levels differed between normal males and those with testicular oocytes.  Although the proportion of testicular oocytes did not correlate directly with atrazine concentrations, it did correlate with a mixture of pesticides and nutrients, particularly atrazine and nitrate, while the number of pesticides detected at each site was also important1.

1McDaniel, T.V., P.A. Martin, J. Struger, J. Sherry, C.H. Marvin, M.E. McMaster, S. Clarence and G. Tetreault. 2008. Potential endocrine disruption of sexual development in free ranging male northern leopard frogs (Rana pipiens) and green frogs (Rana clamitans) from areas of intensive row crop agriculture. Aquatic Toxicology 88 (2008) 230–242.

Question #4:
How can the difference in approach to the banning of Atrazine be explained between the EU and Canada?

Conclusion of unacceptable risk of harm by one nation does not necessarily equate to unacceptable risk in Canada.  This can be due to differences in country-specific parameters (e.g., environmental conditions, use patterns or dietary habits).  Acceptability of risk in Canada must be assessed within the Canadian context.  Concerns from another nation that are found to affect the continued acceptability of a pesticide in Canada could result in action being taken.

While regulatory and environmental conditions in Canada are different than those in other nations, efforts are made internationally to ensure that methods and approaches to pest control regulation meet agreed upon standards. Pest control products of acceptable risk are registered for use in Canada only if it is shown that their use would be efficacious and if conditions of registration can be established to prevent adverse health impact or pollution of the environment.

Atrazine is prohibited in four OECD member countries and the EU based on the potential hazard that may be caused by contaminated groundwater and drinking water. Health risks from potential drinking water contamination in Canada have been examined by the PMRA in the health risk component of the re-evaluation and have been found acceptable provided the required risk reduction measures are implemented (including using atrazine on corn only and reducing the maximum application rate).

Regulatory action by another jurisdiction can be taken into account in evaluating a registration application or in conducting a special review or re-evaluation of a registration. The reasons for action by another jurisdiction are considered in the context of Canadian use, which may be different from the use in the other jurisdiction. Under the PCPA, all registration or post-registration decisions are based on science, and assessments of the health and environmental risks and value of the pest control product when used as intended in Canada.

Question #5:
What obligations does Canada have through the OECD to harmonize pest control products with other member countries?

The PMRA has no obligations to harmonize pest control products with other OECD member countries, however, the PCPA which was brought into force in June 2006, obligates the Minister of Health to initiate a special review if all uses of an active ingredient have been prohibited in an Organisation for Economic Co-operation and Development (OECD) country for health or environmental reasons (subsection 17(2) PCPA).  The purpose of a special review would be to verify acceptability of the pesticide, targeting a specific issue. 

Re-evaluation of an active ingredient, however, examines all aspects of human health and environmental risk and is based on all available information including any concerns identified in an OECD country. Therefore, it is a much more thorough assessment than a special review.  Since registration and re-evaluation decisions on atrazine took into account the concerns raised by other jurisdictions, such as the OECD, the statutory intent of subsection 17(2) was met.

Health Canada completed the health reassessment for atrazine in 2004 and issued a proposed re-evaluation consultation document Atrazine (PACR2003-13). The decision document (RRD2004-12) concluded that the health risks are acceptable with the implementation of mitigation measures, including using atrazine on corn only and reducing the maximum application rate. Subsequently, on 22 May 2007, PMRA published PACR2007-05, Re-evaluation of Atrazine (Environmental Assessment), which presented the outcome of the environmental assessments and the proposed decision for atrazine. The re-evaluation decision RVD2007-05 for the environmental assessment of atrazine concluded on 19 December 2007 that the use of atrazine on corn for weed control does not entail unacceptable risk to the environment. As a result, continued registration of atrazine on corn is acceptable provided that the proposed mitigation measures are implemented.

The PMRA is continuously monitoring its international partners for developments which may affect the acceptability of a pesticide in Canada, and concerns associated with a pesticide that are identified in other nations are taken into account, either through special reviews or when making a registration or re-evaluation decision.

The Minister of Health’s commitment to protecting human health and the environment is embedded in the statutory mandate of the PCPA: “to prevent unacceptable risks to people and the environment from the use of pest control products”. The PCPA defines “acceptable risk” as being “reasonable certainty that no harm to human health, future generations or the environment will result from exposure to, or use of, the product taking into account its conditions or proposed conditions of registration”. Further, the PCPA includes requirements to protect vulnerable populations, to undertake cumulative and aggregate risk assessments as appropriate, and to apply the “precautionary principle” where needed as an interim measure pending the completion of a re-evaluation or special review. If the re-evaluation or special review determines that the product is no longer of acceptable risk or value the registration must be amended or cancelled. This is a very high standard of protection and is comparable to the standards employed by jurisdictions in member countries of the OECD.

Question #6:
If the EU bans Atrazine and the Canadian government does not ban Atrazine, how does the precautionary principle play in this difference?

The “precautionary principle”, as recommended in the Rio Declaration on Environment and Development issued from the United Nations Conference on Environment and Development in 1992, has been incorporated into the PCPA. As explained in Question #5, the precautionary principle can be applied as an interim measure in cases when the full scientific re-evaluation of a pest control product has not yet been completed and there is potential for serious or irreversible damage if the product continues to be used.

However, the PMRA’s present standards of acceptability through its regulatory process provide a significantly higher level of protection from risk of harm than does the application of the precautionary principle alone.

In the current evaluation and re-evaluation processes, special emphasis is put on the protection of subpopulations including infants, children, and pregnant women. Pesticide exposure from all sources, including food and water, is assessed and evaluated and cumulative effects of pesticides that act in the same way are taken into account. Only pesticides with acceptable health and environmental risks and that make a useful contribution to pest management are registered. These processes provide Canadians with access to newer, safer pesticides. The PMRA’s re-evaluation program, in accordance with the PCPA, requires that all pesticides be re-evaluated every 15 years to determine if their use continues to be acceptable under today's standards for health and environmental protection. Pesticides which do not meet modern standards face restrictions of use, phase-out or are not accepted for continued registration.

In accordance with the PCPA, a pesticide cannot be registered, or remain registered, for use in Canada unless its associated risks to health or the environment have been determined to be acceptable.  Risks are acceptable if, on the basis of extensive scientific data, the PMRA has determined that there is reasonable certainty that no harm to human health, future generations or the environment will result when the pesticide is used as directed. This high standard of acceptability must be met before and after the pesticide is registered.

Conclusion of unacceptable risk of harm by one nation does not necessarily equate to unacceptable risk in Canada.  This can be due to differences in country-specific parameters (e.g., environmental conditions, use patterns or dietary habits).  Acceptability of risk in Canada must be assessed within the Canadian context, but concerns from another nation that are found to affect the continued acceptability of a pesticide in Canada would entail immediate action.

Under the PCPA, the Minister of Health may cancel or amend a registration if, in the course of a special review or re-evaluation, the Minister has reason to believe that the cancellation or amendment of a registration is necessary to deal with a situation that endangers human health or the environment, taking into account the "precautionary principle". Accordingly, "Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent adverse health impact or environmental degradation.” (subsection 20(2) of the PCPA). Upon completion of the re-evaluation or special review, action taken by application of the precautionary principle will be confirmed, revised or reversed, as the case may be.

Question #7:
An article appeared in the Vancouver Sun by Sarah Schmidt, Canwest News Service April 16, 2009 concerning Health Canada sitting on a report since March 2008 about an asbestos-cancer link. Is the Canada government sitting on any national or international studies showing the adverse effects of Atrazine on the environment?

The Pest Management Regulatory Agency (PMRA) is not aware of any new atrazine scientific studies (national or international) that are relevant to effects in the environment.  The results of studies conducted by Environment Canada and the Department of Fisheries and Oceans are regularly shared with the PMRA. After review, PMRA may use the data to amend or support their regulatory decisions. Studies are also submitted to international peer-reviewed scientific journals for publication. Published studies are available to the general public, other researchers, and regulatory bodies. In addition, close contact is maintained with colleagues at the U.S EPA who are responsible for conducting risk assessments of pesticides in the U.S.

http://www.oag-bvg.gc.ca/internet/English/pet_283_e_32986.html

 

 

 

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