Following is a letter to the Pest Management Regulatory Agency of Health Canada from Sask Wheat regarding Regulatory Proposal PRO2020-01, Streamlined Category B Submissions and Tank Mix Labelling. This letter was submitted on September 29, 2020.
On behalf of the Saskatchewan Wheat Development Commission (Sask Wheat), please accept the following comments on the PMRA’s Regulatory Proposal PRO2020-01 on Tank Mix Labelling.
Sask Wheat is a producer-led organization established to grow the Saskatchewan wheat industry, representing 26,000 wheat producers in the province. Sask Wheat provides leadership in identifying and supporting research, market development and advocacy that contributes to profitable and sustainable wheat production for Saskatchewan farmers.
Sask Wheat is strongly supportive of the PMRA’s mandate to ensure the protection of human health and the environment. We fundamentally rely on Canada’s regulators, including the PMRA, to maintain the confidence of Canadians and our international customers and to support the competitiveness of Canadian producers.
PMRA’s Regulatory Proposal PRO2020-01 on Tank Mix Labelling indicates that “if a label contains no guidance related to tank mixing, then tank mixes are not permitted.” This is a reversal of PMRA’s long-standing 2009 guidance authorizing the use of tank mixes that do not have specific labels.* This proposed change appears to be administrative in nature, and not based on specific safety concerns as identified by the PMRA. This proposal is also not in alignment with the broader Government of Canada approach to reducing regulatory burden or with US regulations through the EPA, which will put Canadian producers at a disadvantage to their American counterparts.
Until now, the PMRA’s interpretation of the Pest Control Products Act has allowed the use of tank mixes that are not specifically excluded on approved labels, as long as the directions on each individual label are otherwise followed. This has stood the test of time and should be reaffirmed. PMRA’s current approach is fit for purpose and sufficient when label amendments are necessary.
This proposal would increase producers’ environmental impact and hurt their competitiveness. The current tank mix regime has allowed producers to combine the application of a variety of inputs. This has reduced time spent in-field and ensured producers can apply products in a timely manner in an often-short application window. Changing the current regime will increase the number of passes required over a field, leading to higher rates of soil compaction, crop damage, and fuel use. Producer competitiveness will suffer as operating margins will come under further pressure.
Furthermore, the proposed changes create a significant amount of uncertainty for farmers and other members of the value chain. For example, the full range of precise changes, as well as when the changes would be made, are both unknown, making it impossible for producers to confidently make crop protection product purchasing decisions and to plan for the upcoming growing season.
Additional commercial uncertainty may result from impacts on established grain industry protocols, which now routinely require growers to declare that they have applied products according to label directions before being allowed to deliver grain into the commercial handling system. Unpredictable changes or inadequate adjustment periods would increase these impacts.
The uncertainty on transition time is an immediate problem, as PMRA has indicated that the changes might instantly be brought into force. If that happened, an unlabeled tank mix that growers may have been using for a decade or more would become illegal the day after the policy is signed.
In addition to making it harder for producers to use technologies with a history of safe use, Sask Wheat is concerned that the proposal adds new regulations without improving safety, is being advanced with unworkable timelines, and will work at cross-purposes to other PMRA initiatives to reduce existing burdens on PMRA’s internal resources. If it is absolutely necessary for PMRA to move forward with the proposal for internal administrative purposes, then this must allow sufficient time for submissions, approvals of necessary label amendments, and capacity-building and education throughout Canada’s grain value chain.
Canada must lay a strong foundation to support economic recovery in the years ahead. To truly unleash the agri-food sector as the major economic driver identified in the 2017 Report of the Federal Government’s Advisory Council on Economic Growth, Canada must work to remove non-science-based and unnecessary regulatory impediments to innovation and competitiveness.
Thank you for your consideration,
Chair, Sask WheatSource : saskwheat.ca