Introduction
Efficiency
Substitution
Redesign
Financing the transition
Introduction (adapted from MacRae et al., 2012)
Agricultural pesticide use remains a strategic target for social movements as the evidence of harm to ecosystems and human health is now well established. The harm is made even more questionable by on-going questions regarding cropping system level effectiveness, given that on a global scale pests have accounted for about 13% of crop losses (Oerke and Dehne, 1997). Although there has been progress reducing use of many of the most problematic pesticides, the pace of change has been much slower than many advocates, and indeed many farmers, would have hoped. The promise of Integrated Pest Management (IPM) as a way of reducing pesticide use has not been realized (cf. Deguine et al., 2021). MacRae et al. (2012) examined the tensions across the traditional policy network and with ENGOs from the late 80s, including the pesticide registration review of 1988-92 that led to the transfer of regulatory authority from Agriculture and Agri-food Canada to Health Canada, the passing of a new Pest Control Products Act (adopted in 2002, brought into force in 2006), and the development of a new programme to encourage pesticide reduction, the Pesticide Risk Reduction and Minor Use Programme (PRRMUP).
Reliance on pesticides is both deeply cultural and deeply regulatory. The industrial food production paradigm and practice is heavily wedded to synthetic chemical inputs, including pesticides. The dominant paradigm of agriculture science (see Goal 3) is deeply applicable, and pesticides have been a central tool of the long standing cultural notion that we are at war with nature. The policy system has clearly adopted such paradigms. The dominant assumption, therefore, is that pesticides are useful if their inherent toxicity (as killing agents) is properly applied and managed, despite significant evidence that they are often ineffective (cf. the Task Force on Systemic Pesticides, 2018). That ineffectiveness is expressed in many ways including pest resistance and associated loss of product utility, negative effects on non-target organisms, direct failure to control the targeted pest, and generation of secondary pest problems. Equally important, the policy system has doubts about alternative approaches, partly reflected in the absence of an effective national strategy to reduce pesticide use[1]. One reason for the absence of an effective strategy is that many pest problems result from poor farm design (issues of rotation, location, canopy, timing, borders, etc), and pesticide use contributes to that problem by allowing farmers to believe that design improvements are unnecessary. There has been a reluctance on the part of government regulators and extension staff to propose significant changes to farm design, that being considered the purview of the individual property owner. Pesticide costs are low relative to reliance[2] and many externalized costs are unpaid by pesticide users (Tegtmeier and Duffy, 2004). This has discouraged farmer willingness to invest in new approaches and created an accentuated aura of importance for pesticides as the primary pest control method. Issues of economy and geography are also important because pesticide use varies tremendously across regions and crops, with regulatory decisions having differential impacts. Some sectors, consequently, have been more interested in alternative approaches and this has helped create strange alliances, for example the apple and canola industries participating in advocacy work with World Wildlife Fund Canada (see MacRae et al., 2012).
The federal government has authority for registration, classification and labeling, and the provinces for regulating use, which includes training and licensing of users, and management of pollution associated with use, such as spills and recycling of pesticide containers (Hill, 1994). The provinces also often have plant protection legislation to reduce incidence of imported pests. Many provinces have significant cosmetic pesticide use restrictions, and if they do not, municipalities have some authority over use regulation have exercised that authority by implementing different types and degrees of bans on cosmetic use.
The federal registration authority is expressed through the Pest Control Products Act (PCPA). It first appeared in 1927, as the Agricultural Pests Control Act. However, pesticides had been controversial for at least 40 years before this Act first appeared, and the controversies inspired the passage of legislation in many jurisdictions to protect bees from spraying, only partially successful (cf. Bonnell, 2021). The Agricultural Pests Control Ac allowed the Minister of Agriculture to deny registration on the grounds of adulteration, lack of efficacy, copy-cat qualities, and threats to public health. This latter provision was very general, although there were some more specific controls over pesticide residues in the Food and Drugs Act of 1920. The Agricultural Pests Control Act was amended in 1939, with some expanded provisions related to its main purposes - to ensure farmer access to non-fraudulent products - and a new name, the Pest Control Products Act (PCPA). From 1939 to 1969, there were only incremental adjustments to the Act. Experimental evidence to justify a product’s use was first introduced in 1949 and modified in 1954, but regulators did not challenge the validity of manufacturers’ claims. The 1969 version of the legislation was considered a very significant modernization because it was the first to substantially recognize pesticides’ potential for harm (Hill, 1994). The Act was not significantly revised between 1969 and 2002, despite substantial new knowledge about pesticides and their chemistry. Nearly 20 years after adopting the new Act in 2002, during the 2021 federal election campaign, the government promised to strengthen the PCPA and the PMRA, announcing in August a $42 million investment in approving environmental and health oversight. A public consultation on these matters closed in May of 2022.
The legislative framework has never been designed to encourage pesticide reduction, focusing instead largely on the conditions to be met for the registration – or pre-market clearance - of pesticides (Castrilli and Vigod, 1987). This situation exists because food safety legislation in Canada has been built on an anti-adulteration platform (Ostry, 2006; Blay-Palmer, 2008) that is not designed to encouraging changes in production practices that would focus on pest prevention and thereby reduce reliance on pesticides. Some analysts trace the problem to the absence of provisions in the Canadian constitution (the British North America Act of 1867) that expressly authorize the regulation of poisons (Hill, 1994). Some provinces have developed significant pesticide reduction strategies as part of their authority for agricultural land use and practices, but most of these have experienced only limited success. Some commodity organizations have also participated in programming spearheaded by federal programmes, but farm adoption of new systems has been limited.
In the 1980s, the Plant Products Division (PPD) of AAFC was responsible for administration of the Pest Control Products Act, but it did get assistance from other departments informally, principally Health Canada, Environment Canada (EC) and Fisheries and Oceans Canada. These arrangements had started in the 1960s. The collaborations were formalized in the 1980s, as AAFC attempted to fend off calls for transfer of authority to Health or Environment Canada. They also created a Pesticides Directorate in the 80s to take over responsibilities from the Plant Products Division. Additionally, through this period a series of changes were initiated by the civil service, attempts to address (ultimately unsuccessfully) the critics’ concerns. HC and EC were not satisfied either, in part feeling that their reputations as effective regulators were being challenged by the critics, and their advice not properly heeded by AAFC. AAFC could refuse Health Canada’s recommendations on registrations and Environment Canada’s big concern was the lack of attention given by the Minister of Agriculture to environmental issues.
In the 1990s, authority was largely transferred to a new unit within Health Canada, the Pest Management Regulatory Agency (PMRA). Through the late 90s and early 2000s, it seemed no one was happy with the regulatory system that emerged from the re-organization, nor other associated changes. Farmers continued to complain about the growing gap between Canada and other OECD jurisdictions regarding the rate and quantity of new pesticide approvals. Pesticide manufacturers were still upset about the slowness of approvals and the costs associated with submitting conforming data packages. Several provinces that had ramped up support for Integrated Pest Management (IPM) in the 80s and 90s, including BC, Ontario and Quebec, were frustrated by the lack of support in the regulatory system for approval of IPM-compatible pesticides. A few farm and commodity organizations were attempting to advance voluntary IPM initiatives, feeling they could not wait for regulatory improvements. What appeared to be significant progress on pesticide registration reform and IPM adoption in the US and EU fuelled domestic frustration amongst all actors in the policy network. Although an Alternatives Office had been created at PMRA, and several commodity-based initiatives had been launched to develop sector-wide plans for reducing pesticide risks, many farm and NGO participants felt progress was slow, and resources for implementation inadequate. Environmental and health groups, despite the transfer of authority to Health Canada, saw only limited changes with the potential to improve human and environmental health, and were loud critics of PMRA’s environmental and health review processes.
Staff at the PMRA regularly argued that the improvements demanded by business, farm and commodity groups, and ENGOs could not be implemented under existing legislation. There were, thus, widespread demands for a new act. In this environment, a new bill was tabled in 2002. The PCPA of 2002 added new focus on the impacts of pesticides on children and other vulnerable populations, and there were some improved provisions for public accountability and health effects reporting. However, relative to demands at the time it was weak and parliamentary deliberations led to almost no substantive improvements in the bill (for details, see MacRae et al., 2012), Broadly, there remain significant deficiencies, including: limited and inaccurate use of the precautionary principle; inadequate focus on reducing reliance on pesticides; insufficient attention to environmental harm; and limited public participation, information access and accountability. Specific deficiencies, originally written for the EU pesticide regulatory system, but pertinent to all Western systems are captured in a critique by Citizens for Science in Pesticide Regulation: A European Coalition (2018). The rest of this section proposes strategies to address the weaknesses of the act and the associated program interventions. Discussion of municipal restrictions on cosmetic pesticide use is addressed under Goal 5, Sustainable Food, Efficiency, Other urban interventions.
Financing the transition
There is an urgent need to reduce the costs of farming. Long term farm income data show that while gross returns are relatively flat, expenses have risen considerably, with net income thus in decline (Qualmann, 2019). Pesticides represent about 5% of farm operating expenses (Statisics Canada, 2020). Reducing pesticide use saves money for farmers when part of a well designed lower input system that relies more on the internal resources of the farm for pest management while keeping yields at relatively comparable levels. Reducing the number of pesticide approvals reduces regulatory costs, particularly staff time, though equally, the regulatory changes all require staff time investments. At the provincial level, the costs of transition depend significantly on how the province decides to ramp up transition advisory services, whether to do it all internally (the most expensive in transition terms given the low number of suitable extension staff currently in most provinces) or to make it part of the Canadian Agricultural Partnerships model with cost-sharing between farmers, the provincial and the federal governments. The key unknown in transition is cost savings associated with reduced pollution, particularly of water ways. Although studies of savings have been done in other jurisdictions (cf. Pretty et al., 2000; Tegtmeier and Duffy, 2004), they are largely lacking in Canada. These savings may accrue to other provincial departments and to municipalities if the improvements reduce costs associated with water treatment facilities.
Endnotes:
[1] MacRae was involved as a consultant in efforts to set up the Pest Management Centre and PRRMUP, providing extensive advice to the federal government on how to improve the programs. Only some of that advice was heeded.
[2] 6% of farm operating expenses in 2011 Statistics Canada (2011)
