Redesign (pesticides)

At this stage of the transition, the food system is well on its way to functioning within the ecological limits of the planet.  No conventional farms exist, all producers are following environmental production protocols and a significant percentage of farms engage in permanent multistory agriculture (see Goal 5, Sustainable food, Redesign).  Pest prevention strategies are very sophisticated and reliance on pesticides as management tools has been dramatically reduced, with the result that few products with traditional pesticide profiles are left on the market. As well, the gradual internalization of costs means that such products are substantially more expensive unless they have minimal negative impacts. The PMRA has a cycle of pesticide re-evaluations informed by the PCPA (currently Regulatory Directive 2012-02). A revised PCPA, as part of Substitution strategies, would require an accelerated approach with more stringent environmental and health conditions and more pesticides would be withdrawn.

Because the market  for pesticides is now small and very specific to particular challenges, a different approach to R&D and safety testing is taken.  It builds on the current Pesticide Risk Reduction and Minor Use Program approach of AAFC's Pest Management Centre.  This program has two important and intersecting sub-components to build upon, albeit not always successful.  One was a commodity specific pesticide risk reduction strategy process undertaken by stakeholders within a commodity area, and facilitated by the Pest Management Centre and the Alternatives Unit of the PMRA.  When these discussions were effective, the groups would identify a range of pest management strategies and then gather the resources to develop and implement them and make them widely available to farmers.  In the second, a multi-stakeholder group, including industry actors, with regional representatives sets priorities for minor use pesticide approvals (based on existing, albeit sometimes limited, data on cropping systems and pest challenges), and then facilitates collection of data on safety and efficacy. A core feature of this process is assessing the range of options for pest management currently available. Once priorities are identified, some of the trials are undertaken by government researchers (see MacRae et al., 2012).

At this redesign stage, all pesticides are essentially minor use because they are very region and farming-system specific.  There are few universally applications because each farm is different, including that prevention strategies as applied are relatively unique to each setting. As a result, pesticide development is a much more targeted process and the market place can no longer be relied upon to develop suitable products, since pesticide manufacturers can not recoup the speculative R&D and regulatory approval costs.

The PRRMUP processes must be adapted for these conditions, with the following elements:

1. A multi-stakeholder group continues to set priorities, but considers a wider range of crops and farming systems than the original process.  The group is well versed in existing sustainable production protocols and agroecological practice (see Goal 5, Sustainable Food).  As articulated elsewhere on this site, there are fuller data sets regarding cropping systems, animal production and pest challenges across the country that help inform priority setting.

2. Because Canada has always been a minor market for pesticide developers, it is likely that any product that might be helpful for solving a specified problem has already been developed and registered in another jurisdiction.  In other words, a developer is unlikely to have manufactured a product that is unique to Canadian conditions.  So, it is likely that the pest challenge to address has possible solutions elsewhere or the product has already been used in the Canadian market place in a different context.  Consequently, the government may be able to use an expanded version of the existing URMUR and URMULE programs.  One of it's new features, however,  is that it is not user-requested (UR), but rather program requested (PR).  Governments would provide even more support than currently, to determine whether a product is a good solution for the identified program.  If no product existed elsewhere or a label expansion was not feasible, the federal government could consider providing a payment (subsidy) to a manufacturer to develop one, but the expense and timelines (often 10 years and over $100 million) make this an unlikely option.

3. For URMUR and URMULE programs, all assessments of human and environmental safety would be carried out by independent laboratories and paid for by the applicant, following protocols set out by government regulators.  This eliminates the current problem that applicants perform their own tests.

4. All this means that only pesticides with an Environmental Impact inherent toxicity  rating below 20 are likely to be considered for use  (Kovach et al., 1992).

5. Another round of revisions to the revised PCPA (see Substitution) would be required.