-PMRA uses primarily…

-PMRA uses primarily industry supplied testing to make decision

PMRA is greatly backlogged at present. By federal law, all pesticides are supposed to be re-evaluated every 15 years. The PMRA cannot possibly do this, and they have admitted this.

PMRA uses different standards to the OPAC. 2-4D e.g. is permitted for lawns (glyphosate) It is NOT permitted under cosmeticpesticide bans

Bioaccumulation testing (as required by the Pesticide Act, Canada, has not been carried out for most pesticides.

OPAC included many different experts, including beekeepers.

Damage to ecology through accidental spread is not considered by PMRA

Conditional approvals are no longer being issued (to enable a pesticide to get on the market before damage can be assessed)- however, there is a huge backlog of previous conditional approval pesticides being used NOW, and there is no timetable for completing their assessments and/or getting them off the market.

It is ludicrous to suggest that one government appointed "Director" can make decisions about which pesticides should be added to the cosmetic ban acceptance list. That is an invitation to corruption, ignorance and environmental disaster.

ALL neonictinoid tracking (of seed sales, of independent assessment of need, and of use) should remain in place. Three of the most dangerous neonics have now been slated for removal (experts have called for IMMEDIATE removal- the worst one, Imidacloprid, won't come off until 20121. ) but there are others- and there will undoubtedly be more.