I am pleased to comment on…

I am pleased to comment on aspects of insecticide registration and evaluation proposed in this consultation:

re: Disbanding OPAC and using PMRA designations as the base for insecticide regulation, including the Cosmetic Pesticide Ban.

-OPAC has done an excellent job of classification and guidance for cosmetic pesticide use. The 11 category framework and maintenance is admired across Canada.

-The OPAC system has created oases of health and safety for pollinators, for all beneficial insects and their interactive ecological systems, for wildlife, and for humans and pets. It simply would not make sense to give this up.

-Reintroduction of a cosmetic pesticide ban under the control of one "Government -Appointed Director" is certainly an invitation to misinformation, critical delay, lack of the wide range of knowledge necessary, and even corruption.

-PMRA classification has many, many problem issues.

- Conditional approvals, although now ended, were given to hundreds of pesticides now in the market. There is no plan to review those pesticIdes in a timely manner.

- There is no work done on interactive effects and bioaccumulation, although this is mandated by the Pest Control Act.

- The PMRA has a huge backlog, absolutely preventing the mandated 15 year review for all pesticides.

- The PMRA does NOT include cosmetic pesticide discussion. For example 2-4D (Glyphosate) is approved for lawns. It is NOT acceptable for cosmetic pesticide bans.

- PMRA decisions are based almost entirely on industry-generated tests and reports. This creates an extremely questionable base of accuracy.

I STRONGLY RECOMMEND RETENTION OF OPAC AND THE CURRENT COSMETIC PESTICIDE BAN.

re: removal of record-keeping and assessment controls for neonicotinoid use:

The evidence is overwhelming that neonics are extremely harmful to our ecosystems - which include us. They have already proven deadly to pollinators, which form an important part of agriculture and therefore to our agriculture economy.

Continued use of neonics is a recipe for short-term gain vs. long term collapse of crops depending on pollinators- because the pollinators won't be there.

The PMRA has just named three neonics for removal or highly restricted use- The timeline is too long for these measures. The harm is already beyond acceptable levels. There are still more neonics, and there can certainly be more developed in the future.

It is vital to maintain all possible record-keeping, monitoring and assessment of neonicotinoid use.

I STRONGLY RECOMMEND RETENTION OF TRACKING AND EVALUATION OF NEONIC COATED SEED SALES, AND OF INDEPENDENT ASSESSMENT OF NEED FOR THE USE OF THESE SEEDS.