Ontario Vegetation…

Ontario Vegetation Management Association Comments on Amendments to the Pesticide Regulation 63/09 General

The Ontario Vegetation Management Association (OVMA) is a professional organization, established in 1984, that promotes environmentally safe vegetation management for the benefit of everyone. OVMA is a non-profit organization supported by membership dues and donations. Participants in OVMA include representatives from every sector of Ontario’s vegetation management industry.

The OVMA commends the removal of duplication of rules and regulations and updating the Pesticides Act. The federal pesticides classification system adminstered by the Pest Mangement Regulatory Agency under Health Canada who control all pesticide label registrations in Canada should be the authority.

Health Canada’s PMRA is resourced and equipped to review and register pesticides for all of Canada and is something all other provinces have recognized. Ontario would continue to maintain Ontario’s general regulatory requirements, including licensing and permitting realigned to the federal categories.

Federal Pesticide Class Post-2020 Ontario Pesticide Class Pre-2020 Ontario Class
Manufacturing Class A Class 1
Restricted Class B Class 2,3,4,7
Commercial Class C Class 2,3,4,
Domestic Class D Class 5,6,7,8
N/A Class E – Treated Seeds Class 12
Seeds

Harmonizing the classification system will move us from the current 12 Ontario Classes to 5 classes (A-E). Currently registrants must submit the same registrations package as they do to register the product to the Ontario Pesticides Advisory Committee for Ontario classification. Products must be listed in the Ontario Pesticides Classification database.

Ontario Class 7 to 11 (5 classes) are there as a result of the "cosmetic" pesticide use ban, a very scary example of a not scientifically based regulatory system. By posting a list of acceptable Domestic use, those classes can be eliminated. Note that this is still a non-science based classification and in the long run should be elimnated.

Eliminating OPAC will go a long way towards eliminating unnecessary duplication in pesticides regulation.

Ontario will continue to deviate from Health Canada, PMRA in two key ways. Ontario will maintain its cosmetic pesticide ban and restrictions on the sale and use of neonicotinoid -treated corn and soybean seeds. Longer term, these need to be addressed.

Ontario remains committed to its cosmetics pesticides ban, including existing exemptions as it prevents a patchwork of municipal bans. This is unfortunate, but politically epedient.

The OVMA would agree that cemeteries be added to the list of 'cosmetic use' exemptions.

Summarizing for our Industry - Section 8 (PGPC.PDF) Using Pesticides as a Licensed Exterminator
- Federally registered products are automatically classified in Ontario.
- Our members primarily use new class B & C pesticides (old classes 2,3 and 4).
- Can use some products not allowed under the cosmetic pesticides ban, but there will no longer be a database to identify allowable uses or even what type of sign you would need for notification. This needs work.

We would suggest that it may make more sense to allow "control of control of animals that bite, sting, are venomous or carry disease" by an Industrial Vegetation class exterminator as often ticks and mosquitos are in vegetation control areas, not just around structures.

Fumigation Commodity licence holders can now use all insecticides (other than certain fumigant gases) to manage pests of commodities. New conditions added to the Fumigation Soil licence (Table to section 53 of the Regulation) provide authorization for certain land exterminations this removes some unnecessary, illogical regulation.

The OVMA appreciates the Changes to signage requirements. We no longer need to call or email MECP to start the notification process.

Unfortunately there will be more permits required for aerial applications.

Thank you for allowing us to comment on these regulations.

Keith Lockhart
Business Manager OVMA