Comment:
NAFTA - Harmonization Proposal
US / CANADA Pesticide Harmonization escapes most comments
To whom it may concern,
These proposed changes would weaken existing Canadian regulations in significant ways.
Yet, those who normally observe and comment on pesticide regulatory matters in Canada may have missed the 45-day window of comment which began on October 5, 2001. Another 60 day comment period should be offered beginning in January or February of 2002. It is important that this Harmonization proposal be re-submitted for public comment so that policy makers and ordinary citizens may have an opportunity to provide critical input. Road salt issues have just been given a 60-day period of comment. A strong case can be made that this initiative surpasses road salt in importance. Pesticides are used widely in Canada, and their impact on air, soil and groundwater should be carefully monitored and assessed. One of the ways this proposal would weaken the requirements is to permit measurements made in the U.S. to SUBSTITUTE for measurements in Canada, if in someone's opinion, they are conducted "at appropriate sites in relevant ecoregions." There are many potential problems with this. The tendency for pesticide residues to concentrate in northern latitudes, for example, is only one aspect of the environmental fate data that would be missed and go un-assessed if these regulations are passed.
BASIC ASSUMPTION: The meaning of "environmental damage" includes physiological and genetic damage to living organisms, including people.
1. "Harmonization" proposals for U.S. and Canadian regulatory policies should STRENGTHEN regulations for environmental protection in Canada, not weaken them as this proposal does.
2. Besides the legitimate concerns mentioned above regarding the role that the substitution of U.S. sites will play in failing to measure and record accurately the deposition of pesticides in the north by atmospheric distillation (i.e., grasshopper or 'leap-frog' transport phenomenon), other problems would arise. In addition to the under-reporting of pesticide residues and their impact on human health, terrestrial and aquatic wildlife, groundwater, etc., that this would lead to, there is nothing to guarantee that the decision process about what shall constitute "appropriate sites" or "relevant ecoregions" in the U.S. will not be somewhat subjective and open to possible abuse.
3. No requirement is included for measuring pesticides in precipitation in Canada's vast areas of ice and snow. Spring thaws and ice melt in these areas will inevitably result in large PULSES of pollution to the environment, and these will go unmeasured and unassessed.
4. The requirement for shallow soil (thin layer) measurements appears to have been cancelled with very negative consequences. This is where arsenic leaching under playground equipment treated with copper chromated arsenates (CCA) would show up, for example. Measurements at even a 6" depth have apparently missed the heavy concentrations of arsenic deposited at these sites in the first 2" of soil. Also, ignoring thin layer soil measurements would appear to eliminate the possibility of measuring pesticide deposition from precipitation anywhere in Canada. See the 1996 research by Wayne Belzer et al., "Atmospheric Concentrations of Agricultural Chemicals in the Lower Fraser Valley (DOE FRAP 1997-31), or that by Bernard D. Hill et al., 1998, "Phenoxy herbicides in Alberta rainfall: cause for concern?" - or the contributions of herbicides in erosion dust to airborne levels (see the work of Larney et al. at the Lethbridge Research Centre, or Majewski & Capel (1995)).
5. Some of the new proposed "Required" (R) categories appear to be made up of collections of "Conditionally Required" (CR) categories, and therefore are not as obligatory as they would first appear.
6. The distinction between "aged soil" and "unaged soil" has been removed. Soil that has been recently disturbed such as at pipeline, highway, or other construction sites, or in ploughed fields, etc., can have significant problems with acid rock drainage (ARD), with runoff pH's being as low as 2, on a par with stomach acid. Low pH hugely magnifies the leach rates of a number of heavy metals in soils and pesticides, (e.g., mercury and arsenic); these are amphoteric and leach much faster when soil pH's deviate from neutral.
7. Because chemical pesticides are almost always fat soluble, "Bioaccumulation" can generally be regarded as a given. The change in the required assessments from "R" to "CR" (conditionally required) is worrisome because bioaccumulation is no longer assumed to take place, and the decision whether data should be gathered or not may be open to subjective influences. Industry representatives sit on PMRA committees and have input into PMRA decisions. This is not at all reassuring.
8. There is no mention of tracking the environmental fate of the breakdown products or metabolites of pesticides. These all contribute significantly to end point impacts, to synergism (when this occurs), as well as to bioaccumulation.
9. In a number of areas, the new proposed regulations would require fate data on only listed ingredients (TGAI), omitting assessments of the impact of the full formulation (or end-use product (EP)). Since an increasing number of "active" ingredients are being moved by industry into the "unlisted" components, and because unlisted ingredients can be more toxic than listed components, wherever EP assessments have been excluded, the real effects of releasing pesticide products registered in Canada will be missed. This is unacceptable environmental assessment regulatory policy
10. Effects on non-target organisms are widely acknowledged as a central concern. This includes lower and higher plants, nitrogen fixing bacteria and other essential simple organisms, beneficial insects (e.g.,
pollinators), all forms of wildlife (aquatic and terrestrial), as well as people, including children. No data requirements have been included to assess the hormone disruption effects of many pesticides and their formulant combinations on non-target organisms, including human populations and migratory species such as salmon. Many organochlorines, synthetic pyrethroids, phenoxyherbicides, as well as other components such as mercury and nonylphenols affect endocrine function. At least 850 different pesticide products that are registered for household use are known to have hormone disrupting effects, posing serious health risks to the entire community, especially to children and the unborn. Many of these components show up in both domestic and agricultural pesticides.
11. The use of High Volume Air Samplers in agricultural, northern, and urban areas should be explicitly required with specifications as to sampling grids, frequency and timing of sampling to represent seasonal peaks and chronic exposures. From a demographic point of view, the largest numbers of Canadians reside in urban areas and are therefore potentially affected by pesticides transported in urban air from both long-range and proximal sources (including agricultural and non-essential pesticide drift). Assessing the exposure rates of urban dwellers must take a more prominent and consistent place in regulatory policy, rather than being largely neglected as it is at present.
12. The location of drinking water wells and associated groundwater resources must be identified and mapped, and an obligatory structure for regular well water sampling of pesticide residues and breakdown products, as well as interactions with other water components (i.e., organic matter and chlorine), needs to become an integral part of this proposal. Looking abroad, Canadian standards for 2,4-D in drinking water are set at 100 ppb, while European standards for pesticides in drinking water are much more stringent - enough to sometimes be exceeded by levels of pesticides in rainfall of about 4 ppb. Harmonizing our standards with the U.S. could have the negative result of enshrining a status quo that needs improving, as well as preserving the huge gaps in our existing data gathering on pesticide residues in drinking water. This could make it extremely difficult to upgrade our water quality monitoring and standards to match or exceed those in Europe (which all Canadians deserve). Further, the U.S. has a Clean Water Act, a Safe Drinking Water Act, and a Clean Air Act and Canada does not. Thus, measurements in the US need not reflect conditions in Canada, where these regulations do not exist. Substituting US measurements, reflecting US conditions, under US acts will not serve the interests of Canadian public health.
13. To effectively solve a problem, you have to first describe it. Escalating health care costs are a fact everywhere in Canada. Arguments against correcting this proposal's weaknesses and omissions regarding the data Canada should require on the environmental fate and impact of pesticides will be widely received as unconvincing, at best, if they are based on cost. Gathering more complete and accurate environmental fate data is cost-effective. Good science is built on a solid foundation of accurate descriptive measurements. Thus, a proactive approach to correcting and preventing environmental damage is to remedy some of the existing weaknesses in the regulatory system identified by Canada's Federal Commissioner of the Environment and by the Standing Committee on Environment and Sustainable Development in the House of Commons report, "Pesticides - Making the Right Choice for the Protection of Health and the Environment."
Edward M. Oberweiser 2080 7th Avenue Santa Cruz, CA 95062
LETTER WRITTEN TO CANADA:
Dear Prime Minister,
As a US citizen with a great deal of experience and knowledge of pesticide regulation in the US, I would like to comment on Regulatory Proposal PRO2001-02, "Harmonization of environmental chemistry and fate data requirements under NAFTA."
The chief architect of pesticide regulation in the US was the pesticide industry itself. Present regulation benefits the pesticide industry and not the health of citizens. Regulations in the US do not protect people from pesticides. Of particular vulnerability are the young, still-developing children, and those yet to be born. Compared to adults, who the regulations are supposedly written for, their food intake in relationship to their body mass is substantially greater, increasing their exposure to pesticides.
Pesticides can be made thousands of times more toxic in combinations with other pesticides that have yet to be studied because of the complexity and cost of such experimentation. Combinations of pesticides with other synthetic chemicals which can also greatly multiply the toxicity have not been studied either. These combinations are commonly found in the everyday life of all people, regardless of size, age, or circumstances.
Pesticides and other synthetic chemicals can act as hormones in the bodies of humans and other animals, thereby disrupting the normal functioning of the endocrine system. It is essential that the endocrine system function properly, otherwise untold numbers of deleterious health effects will be facilitated. Among the effects that have increased substantially since the advent of pesticides and other synthetic chemicals are: all cancers, a reduction in sperm quantity and quality, emotional abnormalities, loss of cognitive functioning, sexual abnormalities, and much more.
These synthetic chemicals are stored in the body fat of all people. When a mother breast-feeds her child, these toxicants are fed to the child. Even before birth, they pass through the placenta to reach the child. Pesticide residues accompany a man's sperm as it enters the mate's vagina. It can also cause genetic damage to the sperm itself. Many of the effects are not manifested or realized until the child has passed puberty, making the connection to pesticides and other synthetic chemicals extremely difficult to impossible.
There is no escaping these insidious and ubiquitous synthetic chemicals. The only way to reduce our exposure is to end the use of them. Pesticides make up a large part of such exposure, whether or not the person uses them in their home or property. They are carried in the air, water, and food supply.
The logical approach would be to end the use of pesticides. To do so there must first be a system in place to educate people of the harm they are exposing themselves, their families, and future generations to. There needs to be a general understanding of what pest control requires, rather than a prophylactic spraying of pesticides. Most common household cleaners kill insects better than pesticides and are substantially less toxic and more economical.
Governments must end subsidies and investments in pesticide/agbiotech industries and assist farmers to utilize organic farming methods. Up until about 50 years ago there were no synthetic pesticides. To this day, crop losses to pests have not decreased since they were introduced. And not one single species of pest has been eliminated.
What has been accomplished by the use of synthetic pesticides is the pollution of a great deal of the world's extremely limited and decreasing potable water supply. We all carry several pesticides in our blood, effecting every function of our bodies. Physical, emotional and mental capacity has all been affected.
It is high time that we tell the truth to fellow citizens and ourselves.
I beg you to reject this attempt to weaken the pesticide regulations of your country. Since the pesticide industry has brought this to our attention, I would like to suggest that this is an appropriate occasion to drastically increase the their regulation.
Best regards, Paul Goettlich Berkeley, California, USA
RESPONSE FROM CANADA:
Dear Paul Goettlich:
On behalf of the Right Honourable Jean Chrétien, I would like to thank you for your e-mail, in which you raised an issue that falls within the portfolio of the Honourable David Anderson, Minister of the Environment.
Please be assured that the statements you made have been carefully reviewed. I have taken the liberty of forwarding your e-mail to Minister Anderson, so that he too may be made aware of your comments. I am certain that the Minister will give your views every consideration.
L.A. Lavell
Executive Correspondence Officer
Agent de correspondance
de la haute direction
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