Canada’s horticultural growers say they’re concerned about a review of many of the broad-spectrum crop protection chemistries they’ve relied on for years.
The Pest Management Regulatory Agency (PMRA) is conducting the review, with a final outcome due in 2018. That gives growers and other industry stakeholders the rest of 2017 to strengthen their arguments and garner support from more players in the industry to change what’s now on paper.
Craig Hunter, who oversees research and crop protection issues for the Ontario Fruit and Vegetable Growers’ Association (OFVGA), says the biggest challenge comes from Canada’s procedures in conducting the review. It all stems back to 1996 when the U.S. passed its Food Quality Protection Act, which required U.S. registrants to re-evaluate all pesticides on a 15-year cycle.
Canada adopted the same approach in 1998, with the PMRA starting the process soon after, although the agency was already two years behind. Some were conducted as joint reviews, but most were not, and in the initial re-evaluation, about 150 ingredients were dropped — most because the registrants declined to spend the money to defend them, says Hunter.
That left 406 products to be re-evaluated, and the PMRA is not done yet, meaning it’s three years late in getting its first 15-year plan completed. Since it’s due to start the next cycle (and will likely be two to five years behind the U.S.), it’s unlikely there’ll be as many joint reviews done as there could or should have been.
“The first 15 years, we lost those 100 active ingredients, and some of them were pretty important products to us,” adds Hunter.
He says there have been a lot of new registrations in those 15 years, especially fungicides. But most are single-site, single mode-of-action products which are prone to resistance if not used in combination with others in careful rotation.
Several potato products
Re-evaluations in 2015 and released for comment in 2016 included almost all of the broad-spectrum potato fungicides including Captan, Bravo, Polyram and Thiram. Mancozeb was another that was re-evaluated the year before. All of those products are needed to prop up the use of the newer fungicides, yet in every case, the proposals on these older fungicides were either to eliminate the use entirely, or greatly reduce the number of applications. Or they were targeted because they suggested a hugely increased re-entry time after application — to the point where growers couldn’t use them in most horticultural crops because workers have to go into those fields.
The proposal threatens the life expectancy of 30 or more other fungicides that have been registered in the last 20 years.
Hunter says this could affect all of horticulture as well as pulse crops in parts of Western Canada. It’s not about residue limits, it’s about worker safety and protection. But he says the PMRA has made its decisions using flawed information. Registrants told the PMRA to use the data in the post-application workers safety database, which was put together by some of the larger companies, merging studies that they’d all conducted and collected in one database.
“But that database is out of date, and never did apply to horticulture in Canada and sure as hell doesn’t apply to horticulture in 2016,” says Hunter. “But they either referred to that database by registrants who didn’t want to spend the money to do ‘modern work,’ or they referred to the database in the absence of other data. So their assumptions on worker activity are invalid in many cases.”
Worker safety concerns
Hunter says the horticulture sector has tried hard to document farm worker activities for the PMRA, but it’s running up against a policy that prevents the agency from putting the use of personal protective equipment (PPE) on a label. Personnel say they have no way of ensuring that growers will see that workers wear gloves or other protection if they’re going to be in a treated crop. Hunter says the industry disputes that.
“Farmers, first and foremost, want to protect their workers, a) because they want them to keep working and b) they don’t want the liability of workers who have problems either now or down the road,” he says. “But we’ve been using these products for 40 years and have not had any — any — documented problems with post-application worker exposure to the products that we use according to the label.”
Hunter says that during a national conference call involving PMRA personnel, grower groups and provincial representatives, the PMRA spoke of different provincial worker-protection legislations confounding the process. Yet there are grower safety courses in all but one province, and in horticulture, there are on-farm food safety programs where everything is documented, including pesticide use and an acknowledgement that label instructions for personal protection for operators have been followed. Technological advances also make it easier for such accountability practices, including apps for smartphones to enter application data.
“The ball’s in the PMRA’s court: they have to say that they will put these on the label, and they’ll have to tell us how they will audit or inspect to make sure people are following them,” says Hunter. “And of course, it’s up to farmers to follow the label for this like everything else, like making sure the re-entry interval is followed.”
Hunter says he is continually frustrated by the agency’s inability to adapt to the modern reality of what farmers do, what farming looks like and the farmers’ obligations for their workers.
“If there are some bad actors out there, and I suspect there are, nail them to the wall,” says Hunter. “Why should the vast majority of the people who are doing the right thing be denied, in this case, our major fungicides, that without them we’re in serious trouble, all because of a few bad actors?”
Hunter says more farmers need to step up and speak out to help the PMRA realize that the bad farmers are the exception, not the rule. And they’ll make their workers wear gloves and if that’s what it takes to allow the growers to continue. He has already spoken with the registrants and they’re pledging to put those kinds of directives on the label — if the PMRA will let them. Some companies have even offered to provide workers with the gloves, if that’s what it takes to maintain the uses of these products.
Hunter says that potato producers will be directly affected by the potential loss of Mancozeb and Bravo, two of the primary fungicides for late and early blight, along with some uses of Polyram.
“Our growers will be in big trouble without the use of these, and if they use some of the other products that are available that are single-site modes of action, they’ll be lost in five years or so because of resistance,” says Hunter. “And once you get resistance, you can never go back to them again — you’ve lost them.”
Another indication of changing times is the PMRA’s seeming reliance on the “precautionary principle” in many of these evaluations: the agency concedes in its documents that neither the European Union nor the U.S. is imposing these directives.
Hunter met with federal Health Minister Dr. Jane Philpott in May 2016 and discussed the evaluations, among other issues. The minister told Hunter that she can’t interfere with the agency’s dealings, although he made her and her staff aware of the details of the discussions with the agency and the fact that the review is to be completed by 2018 with the final outcomes of the re-evaluations also due next year.
This article was originally published in the 2017 issue of the Potato Guide.