Health Canada’s Management Actions On The Safety Of Pest Control Products – Response To The 2015 Audit – 2016 01 26

 

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Summary

 

 

Health Canada Does Not Permit The

Use Of Unsafe Pest Control Products

 

Conditional Registrations Are Used Only

Where Risks Have Been Deemed Acceptable

 

Health Canada Intends To Identify Further

Opportunities To Improve Communication

 

The Issues Concerning The Safety Of Pest

Control Products Have Been Successfully

Resolved By Health Canada

 

Canadians Have No Need To Worry

 

 

 

Overview

 

 

In fall 2015, the Commissioner of the Environment and Sustainable Development ( CESD ), under the authority of the Auditor General, conducted an AUDIT of the Pest Management Regulatory Agency ( PMRA ) of Health Canada.

 

Within the Government of Canada, Health Canada’s Pest Management Regulatory Agency ( PMRA ) is responsible for administering the Pest Control Products Act on behalf of the Minister of Health.  At the Pest Management Regulatory Agency, before a pest control products is allowed to be used or sold in Canada, it must UNDERGO A RIGOROUS SCIENTIFIC ASSESSMENT PROCESS which provides reasonable certainty that NO HARM WILL OCCUR, including chronic effects such as cancer, when used according to label directions.

 

According to the AUDIT, PMRA should ensure that registrants respect the TIME-LINES specified in CONDITIONAL REGISTRATIONS for providing required information.  PMRA AGREES ! 

 

CONDITIONAL REGISTRATIONS are used only where risks have been deemed acceptable !  Since 2008, Pest Management Regulatory Agency ( PMRA ) has TAKEN ACTION to limit the number of CONDITIONAL REGISTRATIONS, WHICH ARE USED ONLY WHERE RISKS HAVE BEEN DEEMED ACCEPTABLE and where additional, confirmatory information has been considered desirable.  Currently, A MERE 1 PER CENT of registrations of pest control product are CONDITIONAL in nature      most of these have been CONDITIONAL for LESS THAN 5 YEARS.  Some pest control products have been CONDITIONALLY REGISTERED for longer periods, mainly because Pest Management Regulatory Agency ( PMRA ) has required information that would take multiple years to generate ( for example, new types of scientific studies to be carried out ).  Pest Management Regulatory Agency ( PMRA ) believes it could be possible to eliminate the use of CONDITIONAL REGISTRATIONS, and is developing options towards that goal.  For the remaining CONDITIONAL REGISTRATIONS, on a bi-annual basis, Pest Management Regulatory Agency ( PMRA ) will POST A STATUS REPORT on CONDITIONAL REGISTRATIONS, including whether the requested information has been received, the actions that have been taken, and the performance in reviewing the data within the 2 year time-line.  Where necessary, Pest Management Regulatory Agency ( PMRA ) will use existing authorities in the Pest Control Products Act to ensure that the requested information is provided according to the established time-lines.

 

Health Canada intends to identify further opportunities to IMPROVE COMMUNICATION !  In 2016, Pest Management Regulatory Agency ( PMRA ) of Health Canada will IMPROVE COMMUNICATION with stake-holders and the Canadian public regarding the REMOVAL of pest control products or their uses.  Pest Management Regulatory Agency ( PMRA ) will also REVISE DECISION DOCUMENTS to provide a CLEAR SUMMARY of the products it has decided to REMOVE from the market, what uses it has decided to CANCEL, what MITIGATION MEASURES it has decided to put in place, and when these changes will take effect. 

 

Health Canada DOES NOT allow the use of unsafe products !  The assessments from Health Canada, and other science-based national regulatory agencies, have clearly demonstrated that pest control products used in the Urban Landscape are LESS TOXIC THAN Aspirin, baking soda, caffeine, cannabis, nicotine, table salt, and Tylenol.  Additionally, these products are NO MORE TOXIC THAN ethanol ( an edible beverage constituent in beer, wine, and other intoxicating beverages ), mouthwash ( Listerine ), and Vitamin C.  These pest control products are scientifically-safe, practically non-toxic, will cause NO harm, will NOT cause cancer, and will NOT cause irreversible damage if consumed orally.  The probable lethal dose for a person ingesting the concentrated form of many of these products is ONE LITRE, the volume of an entire milk carton.  By comparison, drinking SIX LITRES of water, a fluid that is seemingly harmless, can lead to water poisoning or dilutional hyponatremia, which is a potentially fatal disturbance in brain functions.  In essence, water is only FIVE TIMES SAFER than many of these products. 

 

The issues concerning the safety of pest control products have been SUCCESSFULLY RESOLVED by Health Canada !  Canadians have NO NEED TO WORRY !  When used properly, pest control products are SCIENTIFICALLY-SAFE, and will NOT CAUSE HARM TO PEOPLE, ANIMALS, OR THE ENVIRONMENT.   

 

http://pesticidetruths.com/2014/03/01/pesticides-are-scientifically-safe-safe-to-use-less-lethal-to-humans-than-caffeine-2014-02-27/

 

http://pesticidetruths.com/toc/children-are-not-at-risk/

 

http://pesticidetruths.com/2012/10/11/posters-there-is-a-real-trend-against-pesticide-bans-victories-against-terrorists-our-children-are-safe-when-pesticide-bans-are-stopped-2012-10-11/

 

 

 

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Health Canada’s RESPONSES To The 2015 AUDIT On The Safety Of Pest Control Products

 

 

 

January 26th, 2016

 

Health Canada Web-Site

 

Selected And Adapted Excerpts

 

 

 

In fall, 2015, the Commissioner of the Environment and Sustainable Development ( CESD ), under the authority of the Auditor General, conducted an AUDIT of the Pest Management Regulatory Agency ( PMRA ) of Health Canada.

 

RECOMMENDATIONS from the CESD REPORT 1 PEST CONTROL PRODUCT SAFETY are listed below, in addition to Health Canada’s RESPONSES and its PLANNED MANAGEMENT ACTIONS.

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada has ALREADY DELIVERED on several RECOMMENDATIONS made by Commissioner of the Environment and Sustainable Development.

 

 

 

References    Health Canada Audit

 

 

Reference — Health Canada — 2016 01 26 — Response To The Commissioner Of The Environment

Reference — Health Canada — 2016 01 22 — Corporate Plans And Reports

Reference — Health Canada — 2016 01 19 — Consultation Regarding Conditional Registrations

Reference — Health Canada — 2016 01 19 — Conditional Registrations

Reference — Health Canada — 2016 01 18 — Gov Of Canada To Discontinue Conditional Registrations For Pesticides

Reference — Health Canada — 2015 00 00 — Reports of the Commissioner Of The Environment & Sustainable Development

 

 

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Recommendation  1     Time-Lines For Conditional Registrations

 

 

According the Commissioner of the Environment and Sustainable Development ( CESD ) 

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada should ensure that registrants respect the TIME-LINES specified in CONDITIONAL REGISTRATIONS for providing required information. 

 

It should also assess the data within its established two year TIME-LINE to determine the continued acceptability of pest control products and active ingredients.

 

 

 

Recommendation 1     Time-Lines For Conditional Registrations

 

RESPONSE from Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

AGREED. 

 

Since 2008, Pest Management Regulatory Agency ( PMRA ) of Health Canada has TAKEN ACTION to limit the number of CONDITIONAL REGISTRATIONS, WHICH ARE USED ONLY WHERE RISKS HAVE BEEN DEEMED ACCEPTABLE and where additional, confirmatory information has been considered desirable. 

 

Currently, A MERE 1 PER CENT of registrations of pest control product are CONDITIONAL in nature      most of these have been CONDITIONAL for LESS THAN 5 YEARS. 

 

Some pest control products have been CONDITIONALLY-REGISTERED for longer periods, mainly because Pest Management Regulatory Agency ( PMRA ) has required information that would take multiple years to generate ( for example, new types of scientific studies to be carried out ).

 

Pest Management Regulatory Agency ( PMRA ) believes it could be possible to eliminate the use of CONDITIONAL REGISTRATIONS, and is developing options towards that goal. 

 

Stake-holders will be consulted on any proposed change in policy.

 

For the remaining CONDITIONAL REGISTRATIONS, on a bi-annual basis, Pest Management Regulatory Agency ( PMRA ) will POST A STATUS REPORT on CONDITIONAL REGISTRATIONS, including whether the requested information has been received, the actions that have been taken, and the performance in reviewing the data within the 2 year TIME-LINE. 

 

Where necessary, Pest Management Regulatory Agency ( PMRA ) will use existing authorities in the Pest Control Products Act to ensure that the requested information is provided according to the established TIME-LINES.

 

 

 

Recommendation 1     Time-Lines For Conditional Registrations

 

PLANNED MANAGEMENT ACTIONS by Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

   Finalize decision on whether to eliminate the future use of CONDITIONAL REGISTRATIONS

 

   Improve transparency of remaining CONDITIONALLY REGISTERED products

 

   Use existing authorities, where appropriate, and engage in more active oversight in an effort to ensure that requested information is provided according to the established TIME-LINES

 

 

 

Recommendation 1     Time-Lines For Conditional Registrations

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada Will DELIVER The Following 

 

 

   LIST OF PEST CONTROL PRODUCTS CONDITIONALLY-REGISTERED including the conditions of registration      COMPLETED ( See references below )

 

   Publish a bi-annual status report to clearly identify which products are CONDITIONALLY-REGISTERED, the conditions of registration, when confirmatory data is due / received, outcome of review, and review performance ( September 2016 and on-going )

 

   CONSULTATION DOCUMENT ON WHETHER TO ELIMINATE THE USE OF CONDITIONAL REGISTRATIONS      COMPLETED ( See references below )

 

   Publish a final decision on whether to eliminate the future use of CONDITIONAL REGISTRATIONS ( June 2016 )

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References  ―  Health Canada Conditional Registrations

Reference — Health Canada — 2016 01 19 — Consultation Regarding Conditional Registrations

Reference — Health Canada — 2016 01 19 — Consultation Regarding Conditional Registrations

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Recommendation 2      Cumulative Health Effects

 

 

According the Commissioner of the Environment and Sustainable Development ( CESD ) 

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada should finalize and apply the methodology required to ensure that it considers CUMULATIVE HEALTH EFFECTS of pest control products in its re-evaluations, as required by the Pest Control Products Act.

 

 

 

Recommendation 2      Cumulative Health Effects

 

RESPONSE from Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

AGREED. 

 

The Pest Management Regulatory Agency ( PMRA ) AGREES with the RECOMMENDATION and the importance of ensuring that the CUMULATIVE EFFECTS of pest control products are considered where necessary.

 

This is an emerging area in the science used to regulate pest control products and Pest Management Regulatory Agency ( PMRA ) is actively working with international partners to understand how to best apply these principles to protect the health and safety of Canadians. 

 

Most countries, including Canada, are working on a CUMULATIVE RISK ASSESSMENT METHODOLOGY for pest control products. 

 

However, the international scientific community has not yet reached a consensus on how to best assess the CUMULATIVE EFFECTS of pest control products.

 

Pest Management Regulatory Agency ( PMRA ) anticipates having its own methodology for CUMULATIVE RISK ASSESSMENT in place in the 2017-2018 fiscal year.

 

 

 

Recommendation 2      Cumulative Health Effects

 

Planned Management Actions by Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

   Complete and apply a methodology for cumulative RISK ASSESSMENTS by 2017-2018

 

 

 

Recommendation 2      Cumulative Health Effects

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada Will DELIVER The Following 

 

 

   PMRA’S APPROACH TO ASSESSING CUMULATIVE EFFECTS OF PEST CONTROL PRODUCTS      COMPLETED ( see Below )

 

   Publication of a methodology document for public consultation related to conducting cumulative RISK ASSESSMENTS ( September 2017 )

 

   Implementation of the methodology ( March 2018 )

 

Reference  ―  Health Canada Cumulative Effects

Reference — Health Canada — 2016 01 25 — Approach To Assessing Cumulative Effects Of Pesticides

 

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Recommendation 3      Completing Re-Evaluations

 

 

According the Commissioner of the Environment and Sustainable Development ( CESD ) 

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada should establish realistic TIME-LINES for COMPLETING RE-EVALUATIONS of active ingredients registered before 1995, and should complete them accordingly.

 

 

 

Recommendation 3      Completing Re-Evaluations

 

RESPONSE from Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

AGREED. 

 

Pest Management Regulatory Agency ( PMRA ) has completed the majority of its RE-EVALUATIONS of active ingredients registered before 1995 and is committed to completing the remainder of the RE-EVALUATIONS by 2020. 

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada continues to make progress on the remaining 46 RE-EVALUATIONS, and where necessary, has implemented interim measures to further protect health and the environment during the review process.

 

The Minister of Health’s multi-stakeholder Pest Management Advisory Council ( PMAC ) recently supported PMRA’s three-year RE-EVALUATION WORK PLAN. 

 

Pest Management Regulatory Agency ( PMRA ) will UPDATE the current work plan, in collaboration with the Council, in order ensure that the remaining 46 RE-EVALUATIONS are completed by 2020. 

 

In completing the RE-EVALUATIONS, Pest Management Regulatory Agency ( PMRA ) will collaborate with other foreign regulators, as appropriate, including the US Environmental Protection Agency ( U.S. EPA ).

 

Pest Management Regulatory Agency ( PMRA ) will continue to report on progress on an annual basis.

 

 

 

Recommendation 3      Completing Re-Evaluations

 

PLANNED MANAGEMENT ACTIONS by Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

   Consult Pest Management Advisory Council ( PMAC ) on the UPDATED multi-year RE-EVALUATION WORK PLAN, and revise accordingly

 

   Publish a revised multi-year RE-EVALUATION WORK PLAN, to be UPDATED annually

 

   Collaborate with other foreign regulators, including U.S. EPA, as appropriate

 

   Report on the progress of the RE-EVALUATION of the remaining active ingredients registered before 1995 in PMRA’s annual report to Parliament

 

 

 

Recommendation 3      Completing Re-Evaluations

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada Will DELIVER The Following 

 

 

   Present the revised multi-year RE-EVALUATION WORK PLAN at the next PEST MANAGEMENT ADVISORY COUNCIL MEETING ( February 17-18, 2016 )

 

   Publish the new multi-year RE-EVALUATION WORK PLAN ( March 2016 ), and UPDATE annually

 

   On-going engagement and collaboration with stake-holders

 

   Provide a progress UPDATE in PMRA’S ANNUAL REPORT ( Corporate Plans And Reports, December 2015 and annually )

 

 

 

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Recommendation 4      Work-Planning For Re-Evaluations

 

 

According the Commissioner of the Environment and Sustainable Development ( CESD ) 

 

With respect to its overall WORK PLANNING FOR RE-EVALUATIONS, Pest Management Regulatory Agency ( PMRA ) of Health Canada should ensure that its schedule of work is complete and up-to-date.

 

 

 

Recommendation 4      Work-Planning For Re-Evaluations

 

RESPONSE from Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

AGREED. 

 

The Pest Management Regulatory Agency ( PMRA ) of Health Canada will publish UPDATED WORK PLANS in early 2016 and UPDATE them on a yearly basis. 

 

These will include clear expectations for TIME-LINES, as well as the expected publication date of the final RE-EVALUATION decision.

 

Pest Management Regulatory Agency’s current approach to RE-EVALUATION favours receipt of new information, including INCIDENT REPORTS, from any and all stake-holders even where this material might arrive very late in the review process. 

 

While this approach helps ensure RE-EVALUATIONS are based on the latest and most complete set of information available, it unfortunately often delays the final decision as Pest Management Regulatory Agency ( PMRA ) must then reconsider its ASSESSMENT. 

 

To address this challenge and to meet pre-established TIME-LINES, Pest Management Regulatory Agency ( PMRA ) will consult on and develop a policy with clear rules and criteria for submitting information in order to make TIMELY decisions.

 

 

 

Recommendation 4      Work-Planning For Re-Evaluations

 

PLANNED MANAGEMENT ACTIONS by Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

   The revised multi-year RE-EVALUATION WORK-PLAN mentioned at Recommendation 3    Completing Re-Evaluations will include clear TIME-LINES for all RE-EVALUATIONS ( of active ingredients registered before 1995 and cyclical RE-EVALUATIONS ) and special reviews to the final decision stage

 

   Develop a policy to ensure the TIMELY submission of information in support of RE-EVALUATION decisions

 

 

 

Recommendation 4      Work-Planning For Re-Evaluations

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada Will DELIVER The Following 

 

 

   Publish and UPDATE annually the multi-year RE-EVALUATION work-plan mentioned at Recommendation 3    Completing Re-Evaluations

 

   Publish a consultation document on the proposed rules and criteria for submission of information in support of RE-EVALUATIONS ( March 2016 )

 

   Publication of the final policy document ( August 2016 )

 

 

 

Web-Page    Health Canada Incident Reports

 

 

INCIDENT REPORTS — HEALTH CANADA & OTHER ( Web-Page )

 

http://pesticidetruths.com/toc/incident-reports/

 

 

 

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Recommendation 5      Unacceptable Risks

 

 

 

According the Commissioner of the Environment and Sustainable Development ( CESD ) 

 

When the Pest Management Regulatory Agency determines that the RISKS posed by a pest control product are UNACCEPTABLE for all uses, it should act promptly to CANCEL [ ?!?! ] the pest control product’s registration.

 

 

 

Recommendation 5      Unacceptable Risks

 

RESPONSE from Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

AGREED. 

 

The Pest Management Regulatory Agency AGREES that UNACCEPTABLE RISKS presented by pest control products should be ADDRESSED PROMPTLY.

 

Where UNACCEPTABLE RISKS are identified but can be appropriately addressed through MITIGATION MEASURES, Pest Management Regulatory Agency ( PMRA ) of Health Canada ACTS PROMPTLY to require such MEASURES. 

 

These can range from CANCELLATION of certain uses, to the enhancement of the use of personal protective equipment by workers, to the implementation of additional application restrictions. 

 

Where RISKS are imminent and no appropriate mitigation measures exist, PMRA’s policy is to CANCEL ALL USES.

 

In some circumstances where RISKS are only considered unacceptable in the context of very long-term usage, and where MITIGATION MEASURES can be put in place as an effective interim solution, Pest Management Regulatory Agency ( PMRA ) may implement a PHASE-OUT PERIOD commensurate with the level of RISK. 

 

This approach ensures the protection of human health and the environment and provides lead-time for improved products to be introduced. 

 

The use of orderly product PHASE-OUTS, where RISK can be mitigated in the interim, is a widely accepted practice in use by the United States Environmental Protection Agency and other advanced economies.

 

In 2016, to improve transparency, Pest Management Regulatory Agency ( PMRA ) of Health Canada will consult publicly on its current approach for establishing a PHASE-OUT of products ( including extensions ).

 

 

 

Recommendation 5      Unacceptable Risks

 

PLANNED MANAGEMENT ACTIONS by Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

   Analyze, develop and consult on PMRA’s approach for establishing PHASE-OUT schedules

 

 

 

Recommendation 5      Unacceptable Risks

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada Will DELIVER The Following 

 

 

   Consult publicly on its current approach for establishing a phase-out of products ( including extensions ) ( June 2016 )

 

   Publication of the final approach document ( August 2016 )

 

 

 

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Recommendation 6      Registry Of Conditionally-Registered Products

 

 

According the Commissioner of the Environment and Sustainable Development ( CESD ) 

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada should MAINTAIN ITS PUBLIC REGISTER of pest control products as required by the Pest Control Products Act to clearly communicate which products are CONDITIONALLY-REGISTERED and what their associated conditions of registration are.

 

 

 

Recommendation 6      Registry Of Conditionally-Registered Products

 

RESPONSE from Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

AGREED. 

 

At present, while some information on which products are CONDITIONALLY-REGISTERED and their associated conditions is currently available on PMRA’s web-site, other information is provided to members of the public upon request.

 

Recognizing the importance of promoting greater transparency in the regulation of pest control products, Pest Management Regulatory Agency ( PMRA ) of Health Canada is constantly striving to find ways to more effectively communicate information on CONDITIONAL REGISTRATIONS with regulated parties, affected stake-holders and all Canadians. 

 

In 2016, all conditions associated with CONDITIONAL REGISTRATIONS will be published on the Health Canada web-site.

 

 

 

Recommendation 6      Registry Of Conditionally-Registered Products

 

PLANNED MANAGEMENT ACTIONS by Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

   The public registry will be UPDATED, and will include all necessary information on CONDITIONALLY-REGISTERED products.

 

 

 

Recommendation 6      Registry Of Conditionally-Registered Products

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada Will DELIVER The Following 

 

 

   An UPDATED public registry which includes all CONDITIONALLY-REGISTERED pest control products, associated end use products, and conditions of use ( March 2017 )

 

 

 

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Recommendation 7      Improved Communication

 

 

According the Commissioner of the Environment and Sustainable Development ( CESD ) 

 

To ensure that end-users can make informed decisions on the use of pest control products, Pest Management Regulatory Agency ( PMRA ) of Health Canada should consistently COMMUNICATE timely and readily accessible information on      which products it has decided to REMOVE from the market, which uses it has decided to PROHIBIT, what MITIGATION MEASURES it has decided to put in place, and when these changes will take effect.

 

 

 

Recommendation 7      Improved Communication

 

RESPONSE from Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

AGREED. 

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada acknowledges that the current COMMUNICATION of the information CAN BE IMPROVED by clearly identifying which products ( rather than active ingredient ) are implicated. 

 

Recently, Pest Management Regulatory Agency ( PMRA ) has INCREASED THE CLARITY of its regulatory documents by including TIME-LINES for the implementation of regulatory decisions.

 

In 2016, Pest Management Regulatory Agency ( PMRA ) will identify further opportunities to IMPROVE COMMUNICATION with stake-holders and the Canadian public regarding the REMOVAL of pest control products or their uses, and the associated TIME-LINES. 

 

Pest Management Regulatory Agency ( PMRA ) will also REVISE DECISION DOCUMENTS to provide a CLEAR SUMMARY of the products it has decided to REMOVE from the market, what uses it has decided to CANCEL, what MITIGATION MEASURES it has decided to put in place, and when these changes will take effect.

 

 

 

Recommendation 7      Improved Communication

 

PLANNED MANAGEMENT ACTIONS by Pest Management Regulatory Agency ( PMRA ) of Health Canada

 

 

IMPROVE THE COMMUNICATIONS OF RE-EVALUATION DECISIONS BY 

 

1.   AMENDING NEW REGULATORY DECISION DOCUMENTS in order to better identify 

 

   which products are REMOVED from the market

 

   what uses are PROHIBITED

 

   new MITIGATION MEASURES

 

   when changes will take effect

 

2.   IMPROVE THE COMMUNICATION OF REGULATORY DECISIONS

 

 

 

Recommendation 7      Improved Communication

 

Pest Management Regulatory Agency ( PMRA ) of Health Canada Will DELIVER The Following 

 

 

   NEW MOBILE APP that allows users to access pest control product labels      COMPLETED

 

   Consult with the Pest Management Advisory Council ( PMAC ) to explore options for ENHANCED COMMUNICATIONS and outreach regarding RE-EVALUATION OUTCOMES ( March 2016 )

 

 

 

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To fight the war against Anti-Pesticide Terrorism, you need facts !

 

Read    PESTICIDE TRUTHS

 

Watch    UNCLE ADOLPH

 

Listen To    NORAHG

 

Learn From    FORCE OF NATURE

 

 

Discover What Anti-Pesticide & Enviro-Lunatic Terrorists Are Doing And Saying About Subversively Imposing Their Life-Style Choices Against Our Society.

 

Read    Reports, Blogs, & Videos, From Force Of Nature, NORAHG, Pesticide Truths, & Uncle Adolph    The Whole Truth From An Independent Perspective.

 

Communities and businesses are being HARMED and DESTROYED and RAPED by LUNATIC-TERRORISTS who ARBITRARILY AND RECKLESSLY IMPOSE PROHIBITIONS against pest control products used in the Urban Landscape and by the Agriculture Industry, and who PERPETRATE OTHER ACTS OF ENVIRONMENTAL TERRORISM.

 

We are living in the 9|11 Era of Anti Pesticide & Environmental Terrorism where at least ONE SUBVERSIVE ACT OF TERRORISM is perpetrated EVERY SINGLE DAY by LUNATIC-TERRORISTS.

 

A LUNATIC is a person whose actions and manner are marked by extreme recklessness.

 

The RECKLESS ACTS OF SUBVERSION by these LUNATIC-TERRORISTS has led to the ARBITRARY IMPOSITION of Anti-Pesticide PROHIBITION in several jurisdictions throughout North America.

 

The result was CATASTROPHIC CARNAGE !

 

Because of LUNATIC-TERRORISTS, provinces like Ontario now have a TRAIL OF ECONOMIC DESTRUCTION WITH HUNDREDS OF SMALL BUSINESSES DESTROYED and THOUSANDS OF PEOPLE OUT OF WORK, a MORE DANGEROUS OUTDOOR ENVIRONMENT, and a BLACK MARKET IN PESTICIDES.

 

Only TRUE LUNATICS would wish to create a TRAIL OF ECONOMIC DESTRUCTION WITH HUNDREDS OF SMALL BUSINESSES DESTROYED and THOUSANDS OF PEOPLE OUT OF WORK.

 

Because of LUNATIC-TERRORISTS, we are living in the DARK AGE OF ANTI PESTICIDE TERRORISM where sound science is trumped by FAKE SCIENTISTS, JUNK SCIENCE and UNVERIFIABLE SECRET EVIDENCE through FABRICATION, INNUENDO, and INTERNET RUMOR    scientific research PROVES that pest control products will CAUSE NO HARM and can be USED SAFELY.

 

An informed public is better able to protect itself and its communities and businesses from LUNATIC-TERRORISTS who are THE LEAST QUALIFIED TO PROVIDE ANY ADVICE about pest control products or the environment.

 

NORAHG is the National Organization Responding Against HUJE that seek to harm the Green space and other industries, and the well-being of our communities.

 

NORAHG morally represents the VAST SILENT MAJORITY of people associated with turf and ornamental plant maintenance who are OPPOSED to LUNATIC-TERRORISTS and their Anti Pesticide PROHIBITIONS, resulting in the CLOSURE or ABANDONMENT of green spaces under the RIDICULOUS PRETEXT CONCOCTED BY LUNATICS of somehow « saving » the environment.

 

NORAHG is a NATIONAL NON-PROFIT NON-PARTISAN organization that does not accept money from corporations or governments or trade associations, and represents NO VESTED INTERESTS WHATSOEVER.

 

NORAHG is dedicated to reporting PESTICIDE FREE FAILURES, as well as the work of RESPECTED & HIGHLY RATED EXPERTS who promote ENVIRONMENTAL REALISM and PESTICIDE TRUTHS.

 

NORAHG strikes back against the MYTHS concerning the need for prohibition against pest control products.

 

NORAHG RESPONDS on behalf of the VAST SILENT MAJORITY of THE PUBLIC THAT DOES NOT WANT PESTICIDE BANS, and SUPPORTS those who work in the Professional Lawn Care Industry, the Golf Industry, and the Agriculture Industry.

 

 

RESPECTED & HIGHLY RATED EXPERTS

 

http://pesticidetruths.com/2014/11/14/the-wisdom-of-real-experts-who-speak-out-against-the-conspiracy-to-impose-reckless-and-arbitrary-prohibition-against-conventional-pest-control-products-2014-11-14/

 

 

THE MYTHS ABOUT BANNING PESTICIDES

 

http://pesticidetruths.com/2012/11/15/the-myths-about-banning-pesticides-part-2-white-paper-report-on-pesticide-bans-2012-11-15-reports/

 

 

VAST SILENT MAJORITY

 

http://pesticidetruths.com/toc/the-wisdom-of-canadian-consumer-specialty-products-association/

 

 

NORAHG is opposed to PESTICIDE FREE jurisdictions where LUNATIC-TERRORISTS have DOOMED CHILDREN to SUFFER INJURIES since Anti-Pesticide PROHIBITION inevitably leads to public and residential green spaces that become DANGEROUS AND PEST-INFESTED GARBAGE DUMPS.

 

Go to the following links 

 

 

ANTI-PESTICIDE PROHIBITION DESTROYED GREEN SPACES

 

http://pesticidetruths.com/toc/carnage-leading-to-garbage-dumps/

 

 

PESTICIDE BANS MADE OUR GREEN SPACES LOOK #@!!% UGLY – PHOTO GALLERY

 

http://pesticidetruths.com/toc/carnage-leading-to-garbage-dump-green-spaces-photo-gallery/

 

 

EMERALD ASH BORER – SAFE & EFFECTIVE INSECTICIDES VERSUS CHAIN SAWS

 

http://pesticidetruths.com/2014/01/19/emerald-ash-borer-wisconsin-municipalities-safe-effective-insecticide-treatments-versus-chain-saws-2014-01-05/

 

 

NORAHG is concerned that, because of PESTICIDE FREE MAINTENANCE of parks and sports fields, CHILDREN ARE AT HIGHER RISK OF SUFFERING INJURIES with DANGEROUS PLAYING SURFACES CREATED BY #@!!% PESTICIDE BANS.

 

 

CHILDREN ARE NOT AT RISK

 

http://pesticidetruths.com/toc/children-are-not-at-risk/

 

 

NORAHG pledges to deliver comprehensive reports that are worthy of peoples’ time and of peoples’ concern, reports that might ordinarily never have breached the parapet.

 

NORAHG was the brainchild of William H Gathercole and his colleagues in 1991.  Mr Gathercole is now retired, although his name continues to appear as founder.

 

Force Of Nature was launched by NORAHG for CONTINUOUS transmission on the Internet on January 1st, 2009      however, the VERY FIRST Stand-Alone Force Of Nature Report was issued on September 19th, 2008.

 

On March 15th, 2010, Uncle Adolph independently launched The Pesticide Truths, an easy-to-use Web-Site that collects relevant reports of information right-off-the-press.

 

Primus inter pares, first among equals, describes Pesticide Truths, Uncle Adolph, and Force Of Nature    they are formally equal to each other and are all accorded equal respect.

 

The reports and blogs from Pesticide Truths, Uncle Adolph, and Force Of Nature, in some ways, are like Google for everything concerning the SUBVERSIVE ACTIVITIES of Anti-Pesticide and Enviro-Lunatic Terrorists.

 

Many of these reports and blogs provide a sequence of historical events WITH COMMENTARY, the neutrality of which might be disputed.

 

This is what we do.  Don’t thank us.  It’s a public service.  And we are glad to do it.

 

For The Complete Library of reports from Force Of Nature, NORAHG, Pesticide Truths, and Uncle Adolph, go to the following archives 

 

 

ABOUT UNCLE ADOLPH

 

http://pesticidetruths.com/about-2/

 

 

FORCE OF NATURE WEB-PAGES

 

http://pesticidetruths.com/toc/

 

 

NORAHG FON ON FACEBOOK    NORAHG RESPONSES

 

https://www.facebook.com/norah.gfon

 

 

PESTICIDE LINKS    PESTICIDE QUESTIONS ANSWERED BY HEALTH CANADA

 

http://pesticidetruths.com/pesticide-qa-links/

 

 

TABLE OF CONTENTS    THE COMPLETE LIBRARY OF WEB-PAGES, REPORTS, & REFERENCES

 

http://pesticidetruths.com/toc/table-of-contents/

 

 

THE PESTICIDE TRUTHS WEB-SITE    ARCHIVE OF REPORTS

 

http://pesticidetruths.com/

 

 

UNCLE ADOLPH’S ORIGINAL PESTICIDE TRUTHS BLOG

 

http://www.uncleadolph.blogspot.ca/

 

 

UNCLE ADOLPH ON SCRIBD    OFFICIAL DOCUMENTS

 

http://www.scribd.com/uncleadolph

 

 

UNCLE ADOLPH ON YOUTUBE    VIDEO LIBRARY

 

https://www.youtube.com/channel/UCVWnwRmNln9JACP3Ap3GF5g

 

 

 

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