More than 8,000 comments, signatures on petitions or submissions were received between December 2009 and the end of February 2010 in response to the ministry’s request for comments on the cosmetic use of pesticides in British Columbia. These responses included: petitions with individual signatures (more than 4,000 signatures); copies of letters or e-mails sent to Members of the Legislature (MLAs) or the Minister of Environment (about 3,000 individual items of correspondence); individually signed form (or template) letters (more than 500); and responses or submissions specifically addressing the consultation issues and topic areas identified in the consultation paper prepared by the ministry (more than 800 by e-mail, fax or attached file). A number of respondents also submitted or included reference to supplemental materials for the ministry to consider, including: newspaper articles and letters to the editor; scientific papers in-cluding toxicology and health studies or reviews; "model" legislation or municipal bylaws ad-dressing the cosmetic use of pesticides; and detailed legal briefs or organizational programs re-lated to integrated pest management programs or the cosmetic use of pesticides. All comments and materials have been compiled and are being reviewed by ministry staff.
Petitions and Template Letters :
"Cancer has and will continue to have a tremendous impact on British Columbian commun-ities. The provincial government plays an important role in supporting British Columbians to take control of their health and reduce their risk of cancer. By committing to consult with the public on new statutory protections to further safeguard the environment from cosmetic chemical pesticides, the government has taken a good first step in the right direction. Ac-tion by the B.C. government is necessary as it has the power to restrict the sale of cosmetic pesticides across the province. The cosmetic use of pesticides is harmful to public health and the environment. Pesticides has been linked to non-Hodgkin lymphoma, adult and childhood leukemia, brain, kidney, pancreatic, prostate, and some lung cancers, and studies show the children are more vulnerable. The use of pesticides for cosmetic purposes is unnecessary, as safe and effective alternatives exist. For several years, the Canadian Cancer Society and its partners have been advocating for strong, province-wide cosmetic pesticide legislation. British Columbians are strongly in favour of a ban, British Columbia municipalities are also calling on the B.C. government to pass provincial cosmetic pesticide legislation, and several provinces have bans in place or in progress. Now is the time for the B.C. government to take its next step with the creation of a quick timetable for action. This is to request that the government put a stop to the sale and use of cosmetic pesticides by January 2011. Please implement a strong and effective ban on the sale and use of cosmetic pesticides province-wide."
• "We the undersigned would like the government to put a stop to the sale and use of cos-metic pesticides by January 2011. Please implement a strong and effective ban on the sale and use of cosmetic pesticides province-wide."
• "I DO NOT support a ban on lawn and garden products. These products are thoroughly as-sessed by Health Canada and are important tools for ensuring British Columbia’s green spaces remain vibrant and healthy. I trust Health Canada to ensure that the pesticides it ap-proves are safe and effective, and I want to be sure that I have access to these products to protect my property from insects, weeds and diseases. Please don’t let misinformation influ-ence you to ban products that I consider important and that Health Canada has approved as safe."
• "I am writing as a member/client of the XXXX Golf and Country Club in response to the current consultation process being conducted by the Government of British Columbia to as-sess the views of the public with respect to the cosmetic use of pest control products. Turf on golf courses is NOT cosmetic or non-essential. The greens, tees and fairways are playing surfaces that are necessary to the game and to the business of golf. Since the business of golf depends on the quality of the playing surface, the negative economic impact of unsuitable or unplayable turf conditions would be economically devastating to golf facilities. As such, turf is essential to the business of golf and pesticides are vital to the proper health and care of turf. Although golf courses make every effort to have the strongest stand of turf possible by practicing good IPM (integrated pest management) there are times when it is necessary for superintendents to use pesticides. Even with the best water management, topdressing, aeri-fying, fertility and mowing practices in order to maintain good playing conditions, pesti-cides are needed. There are fungal organisms that can destroy large areas of turf overnight that must be treated when the climatic conditions for disease development are observed. Thank you for your consideration of my submission."
• "I support a ban on the use and sale of non-essential pesticides in British Columbia."
• "The sale and use of cosmetic pesticides (including Killex, Roundup, WeedNFeed, 2,4-D and fertilizer/pesticide combination products) must be banned in B.C. There is no safe way to use pesticides on our lawns, gardens, school yards, parks, sports fields and golf courses. This includes Integrated Pest Management (IPM) use. Pesticides do not stay where they are used by a resident or a licensed IPM applicator and continue to harm long after the initial ‘kill’. There is no justification for the continued sale and use of cosmetic pesticides. Numer-ous safer, non-toxic and effective products are widely available. Ontario and Quebec have bans – B.C. needs a ban too. The Government of British Columbia needs to protect all British Columbians and the environment from unnecessary and harmful exposure to cosmetic pesticides (including IPM use). I fully support the 18 member health and environmental coalition’s January 14, 2010 request that our Government pass legislation in 2010 to ban sale and use of cosmetic pesticides. Thank you for including my ‘no IPM’ pesticide ban request in the B.C. Government’s consultation process."
Response Form Question 2.1: Do you have any comments regarding new restrictions addressing the cosmetic use of pesticides?
Responses were sharply divided on this question. One the one hand, many individuals and groups expressed support for "banning the use and sale of cosmetic chemical pesticides." Other respondents commented that "there is no need to develop additional regulations for cosmetic pesticide use in B.C." Examples of comments made in support of new restrictions on the cosmetic use of pesticides included:
• "We absolutely need stricter regulations on the use of pesticides especially in environments where children live, learn and play";
• "All use of pesticides is cosmetic, even on fruit trees…new restrictions addressing the cos-metic use of pesticides is a must";
• "A province-wide regulation restricting the use of non-essential, cosmetic pesticides, as well as their sale, will help to achieve the short term reduction and long term elimination of non essential pesticide use";
• "Any pesticide that is harmful to humans should be banned, not just restricted – organic practices address issues of diseases and pests in a positive way – eliminating one pest, chemically, impacts the whole ecosystem and ends up causing more problems – it’s time to move past these outdated forms of control";
• "Anything that bioaccumulates, persists in the environment, or affects hormonal systems at any concentration should be banned"; and
• "I would like to see a restriction of all non-natural pesticides for cosmetic use and to ban the sale of these products."
Examples of comments made by respondents voicing opposition to any new restrictions ad-dressing the cosmetic use of pesticides included:
• "The current regulatory regime in B.C. has been effective in ensuring that the application of pesticides is safe for humans and the environment and effective for the control of potentially damaging pests and vegetation";
• "No other common household product goes through the level of scrutiny and regulatory oversight that pesticides do…there is no reason why pesticides, in particular lawn and gar-den products, should be singled out and targeted for additional regulations’; and
• "There are no effective alternatives on the market today to the traditional Health Canada registered products – NONE."
Examples of other comments made by respondents included:
• "Why is this being considered?…[while] some cosmetic use of pesticides is needless…how much of it should be eliminated I do not know…given my own experience I do not see the need for much pesticide use by anyone – if truly required, leave it to those qualified to prac-tice IPM, do appropriate assessments and apply products responsibly";
• "…‘cosmetic pesticide’ terminology is highly subjective";
• "Control [of] invasive species…is a necessity";
• "Make it clear that a certified, registered applicator can apply pesticides on food crops at [a] residence";
• "Regulation should apply to the user, not to the classification of the land – the user should be someone who is trained and certified to use pesticides under certain restrictions, i.e., on-farm, municipal, or provincial lands & forests";
• "Cosmetic use could be separated along the lines of percent infestation with thresholds established as minimum before applying a pesticide…another way…would be to separate residential use from commercial use by allowing business the option (based on levels of threat to the ‘crop’, impact on revenue and a working IPM program) to control…to ensure continued viability of the operation"; and
• "The ability of municipalities to enact and enforce bylaws regulating the use of pesticides must be retained, the authority to enact such bylaws to protect either human health and eco-systems or both should be made available [and] bylaws and regulations must be extended to commercial and public lands for outdoor non-essential use."
Do you have any additional comments or suggestions for the ministry regarding statutory protections to safeguard the environment from the cosmetic use of chemical pesticides?
Over 800 detailed responses to the consultation questions were received over the consultation period (December 2009 to February 2010), many with comments or supplementary references or materials in addition to comments on the consultation issues identified by the ministry. These additional comments included:
• Letters or motions of support (i.e., for restrictions or bans on the cosmetic use of pesticides) from organizations or municipal government bodies;
• Technical studies, such as herbicide review reports, medical reviews and submissions to other government bodies;
• Legal briefs and examples of existing or model bylaws and regulations addressing the cos-metic use of pesticides;
• Web links to additional information or resources (such as education campaigns or related research) for consideration by the ministry;
• Text from, or references to, newspaper and journal articles and letters to the editor; and
• Correspondence and copies of presentations made to municipal Councils.
In total, several hundred pages of these additional comments were received, compiled and forwarded to the ministry for review and consideration.
1 of many Activst Groups have (assumed) Claimed: 88% want Ban
BC Consultation Paper:
BC Consultation Summary Comments: