Standing Committee On Health

Subject: Standing Committee On Health
Date:     Fri, 31 May 2002 10:32:37 -0400
From:      Stephen Tvedten <steve@getipm.com>
Organization:     Get Set Inc. (www.getipm.com)

To: Paul Helliker <phelliker@cdpr.ca.gov>
Director, State of California, Department of Pesticide Regulation

June Irwin (Individual Presentation): As a practicing physician specialized in dermatology, I have seen, since 1985, the results of exposure to the pesticides in lawn chemicals. I have brought this to the attention of municipal, provincial, and federal governments. A press release on July 3, 2001 from la Direction de la Santé Publique Trois-Rivières confirms these risks.

The spraying or the application of chemicals and pesticides-that is, herbicides, insecticides, fungicides, rodenticides, and their secret hazardous ingredients-on lawns, trees, parks, within and about houses and schools, is an infringement on the common right and liberty of all citizens to breathe clean air and to remain in health. It is the responsibility of both the provincial and federal authorities.

We have been, for many years, a human experiment, without doctors being able or ready to keep records. The official newspaper of the American Public Health Association published in 1987 the statement that "all of the commonly used home and garden insecticides and weed killers, such as 2,4-D, Sevin, and mosquito repellants, have the potential for causing nervous-system and psychological problems." It is felt the domestic exposure problem is much greater than that of occupational exposure.

Since 1987, the ministers in the federal government have been informed by physicians like myself that people, especially children, were getting sick after exposure to these products, whether on their own property or on a neighbouring property.

The federal and provincial governments have also been asked repeatedly to inform doctors and the public of the contents of the chemical fertilizers and pesticides, and to disclose non-pesticide ingredients in these products.

While Health Canada wrote to physicians warning them either about certain prescription and over-the-counter medications, or about cigarette and second-hand smoke, despite repeated requests, health practitioners such as myself were never warned by Health Canada about the health effects of commonly used lawn, house and garden pesticides.

This information is critically important to safeguarding people's health and lives. If that information had been made public, all doctors could have kept records and could have issued warnings to the general public.

Mr. David Bennett (National Director of Health, Safety, and Environment, Canadian Labour Congress): Though workers are a major risk group for pesticides, they are nowhere included as an identifiable subgroup in the bill before us. Secondly, there is no mechanism in the act to facilitate access to lower-risk pesticides. The intention is there, but there is no mechanism in the act that enables the government to do it.

The test for acceptable risk is subjective. It's what the minister considers to be acceptable in evaluating health risks for the purpose of affirming or denying registration. The test of government policy is intolerably vague and licentious. Now, in fact, the government policy is one of risk management, which does not address the main issue the public is concerned with; that is, will pesticides continue to damage human health or will they be restricted in some effective way?

In determining acceptable risk, registration will only be granted if conditions of registration can be established to prevent adverse health effects. The problem with pesticides is that their escape into the human environment cannot be controlled. The only way to achieve pollution prevention is by eliminating their use, that is, by denying registration. Personal protective equipment cannot protect workers against chronic health effects. The only way to reduce the use of toxic pesticides is by restricting the use of pesticides to specified crops in specified quantities. But since it would require draconian policing and enforcement, this provision is not likely to be effective. Apart from saying that health-risk evaluation must be scientifically based and that the criterion of registration is acceptable risk, there is no indication of the procedure that will be used in evaluating pesticides.

Mr. Rob Merrifield: So you're more concerned with the inappropriate use of them once they're registered. One of the other witnesses had suggested that cosmetic use is more dangerous than commercial use. Is that what you're suggesting? Actually, you had suggested that. That was my question to you. I wrote it down when you were talking about danger in the workplace. Do you find that the cosmetic is more dangerous than the commercial, or vice versa, or is there no difference?

Mr. David Bennett: There are all sorts of figures about the domestic use of pesticides per square foot compared to agricultural applications per square foot. The question isn't essentially one of which application is more or less dangerous than another. The question really is that Parliament is being asked to make a political decision about what pesticides it's going to allow to be used in Canada. This is a political decision for which evidence can be produced on both sides for saying this is a wise policy or not a wise policy.

What I'm saying is that if we get bogged down in questions of health effects, we're going to get an interminable argument. What will happen, despite the good intentions of this act, is that the regime of pesticide registration will not in fact change.

Mr. David Bennett: The situation with the right to know and pesticides is that the national system we have, the workplace hazardous materials information system, does not apply to chemical pesticides. What the bill is saying, by implication, is that there should be a right to know over chemical pesticides--for example, embodied in material safety data sheets that would accompany the first shipment of the pesticide to a farmer or to other users.

Then the question arises, how will the government do this? I'd like to point out that in 1992, Parliament accepted a committee recommendation that pesticides come up to the same standards for industrial chemicals as the workplace hazardous materials information system. They did not say to bring pesticides under WHMIS as a system, but they said there must be equivalent standards.

Well, what are the standards? For industrial chemicals, workers have the right to know all the ingredients in a chemical product. So if WHMIS applied to chemical pesticides, we would get the names divulged of the active ingredient and of all the formulants insofar as they were classified as toxic. In industrial chemicals, for classification purposes, nearly all the ingredients are classed as toxic. That would be a good move; we would have a label, a workplace label, and a data sheet, up to WHMIS standards for chemical pesticides.

But then the big question arises, how do you handle confidential business information, the very thing that workers and everyone else really want to know?

In WHMIS, we have a very effective system in Canada for making sure that only those things that are genuinely confidential are withheld from the public. They're not withheld from the government; they're withheld from the public. This is done through a commission called the workplace Hazardous Materials Information Review Commission, the HMIRC, which basically examines labels and data sheets. It's presented with evidence, and then it says in some cases, no, that's not a trade secret; you have to divulge it. In other cases, it says this is a trade secret; it can be withheld. The government is then the trustee. The government, not the manufacturer, decides whether this is a genuine trade secret. This has been a very effective system for well over a decade, and in fact the organization is a credit to Canada.

But here comes the fight: Will Health Canada allow the Hazardous Materials Information Review Commission to review pesticide labels and data sheets? >From what we understand, Health Canada is adamantly opposed to this. It wants to have its own system of handling confidential business information, and we know from past experience that this way of handling it is not in the public interest.

So I would ask this committee to make it part of its business to say that if pesticides come up to the right-to-know standards for industrial chemicals, that includes submitting pesticides to the Hazardous Materials Information Review Commission.

Ms. Barbara McElgunn (Health Policy Officer, Learning Disabilities Association of Canada)

PMRA lacks the independent research capacity to conduct audits on registrants' data or the conduct of experimental lab analyses. They have little or no capacity to conduct independent research on environmental fate data or exposure data, or to conduct the necessary research to further their mandate to assist the development and regulation of alternative and safer forms of pest control.

Under developmental neurotoxicity testing, our recommendation is that we have urged government for many years to require testing that would ensure the safety of priority chemicals-pesticides, food additives, and cosmetic products-to protect brain development and function, prenatally and in early life. The PMRA's data requirements for registration and re-evaluation should be published in regulations for consistency and transparency. The U.S. EPA toxicology working group has recommended this type of testing be a core data requirement for many pesticides.

Ms. Judy Wasylycia-Leis: Maybe my last question could be answered by Barbara and Janet, over the very notion of a ban.

Ms. Barbara McElgunn: I guess I'm a pragmatist. It would be lovely if the minute we had a ban all that product disappeared from the shelves and all the product disappeared from any use.

I don't know why there is historically a process whereby the registrant can sell off the remaining stocks of that particular product, but it happens in the United States and in Canada. I know this probably needs to be looked at. Indemnity, in other words, has to be the registrant's in order to get rid of that in a safe way, to destroy the remaining stocks. Right now we don't have any way of getting that on, but in the best of all good worlds, it would be wonderful if that would happen.

Ms. Janet Kasperski (RN, MHSc, CHE, Executive Director, Ontario College of Family Physicians): In spite of these major concerns regarding developmental neural toxicity, endocrine and reproductive toxicity, and immunotoxicity, the report finds reasons for concern regarding the adequacy of pesticide toxicology tests used for risk assessment in children.

The report suggests strategies to reduce the exposure of children, but it also calls for the development of appropriate toxicological tests to assess perinatal and childhood toxicology that lead to developmental problems and interference with the functioning of nervous, reproductive, endocrine, and immune systems.

In Canada, pesticide manufacturers and others who see the value in continued use of pesticides point to those articles that only demonstrate inconsistent findings. The rest of us tend to point to those that demonstrate the causal relationship between pesticides and harm.

The Pest Management Regulatory Agency has often been presented with these two conflicting bodies of evidence because of lack of access to a more balanced body of evidence provided by credible research scientists.

The Chair: Dr. Gilka, you wouldn't know, but we have just been studying assisted human reproduction and have been informed of the rising incidence of infertility. You are the first witness, in this study or in the previous one, I've heard talk about pesticide residues in the fluid around eggs and in sperm. So you made a link for us between our two areas of investigation, which was very interesting.

I'm also interested in your observations of certain phenomena when you were beginning practice as opposed to today. I think that should be stark warning to all of us as to what is going on, these accumulations of residue.

Dr. Libuse Anna Gilka (Representative, Physicians and Scientists for a Healthy World, Inc.): If I may, I'll make just one comment. The concentrations of the pesticides have been considered negligible because they are compared in such terms as "one part per million" or "one part per billion". Now, one part per million would represent 1¢ per $10,000, and one part per billion would be 1¢ per $10,000 million, which seems so negligible that you don't need to worry. And compare it with time--for example, one part per million would be one minute in 695 days.

From that comparing we get a sense of security, but the problem is, if you start to compare that with a dose that is prescribed as medication, then you will find that the doses in parts per million and parts per billion are how we prescribe things like valium. If I prescribe 5 milligrams of valium to somebody who weighs 220 pounds--100 kilograms for easy calculation--then the concentration in the tissue of the body of that individual will be 0.05 parts per million.

The Chair: You're saying we shouldn't be lulled into accepting these numbers, which sound so innocuous, because they aren't innocuous.

Dr. Libuse Anna Gilka: Exactly. For example, hormones like estrogens are active even in parts per billion or parts per quadrillion; they still exert an effect. When we put it into proper context to understand it and compare it with medication and substances that are produced in the body that are so powerful, then we realize that these are not negligible doses but ones with a profound effect.

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