ERO # 019-0481 To Whom It…

ERO # 019-0481

To Whom It May Concern:

As a parent and a resident of Ontario, and as a professional who has worked for decades to advance interdisciplinary and multi-stakeholder approaches to environmental health issues, I am disappointed and concerned about the government’s proposed elimination of the Ontario Pesticides Advisory Committee (OPAC).

The opening of the Pesticides Act for the sole purpose of jettisoning an established, multi-stakeholder body that is committed to serving the best interests of the Province would be regrettable and difficult to justify.

The ERO Notice # 019-0481 that proposes the elimination of OPAC states that “the major function of this Committee is to provide advice on classification.” In fact, the mandate of OPAC, as delineated in the Act, says nothing about classification. Rather, the Act states that OPAC will:

(a) review annually the content and operation of this Act and the regulations and recommend changes or amendments therein to the Minister;
(b) inquire into and consider any matter the Committee considers advisable concerning pesticides and the control of pests, and any matter concerning pesticides and the control of pests referred to it by the Minister, and report thereon to the Minister;
(c) review publications of the Government of Ontario respecting pesticides and the control of pests, and report thereon to the Minister; and
(d) perform such other functions as the regulations prescribe. R.S.O. 1990, c. P.11, s. 10.

The elimination of a multi-stakeholder body established to support the Minister with sound advice on pesticides matters, particularly at a time when changes to Pesticide Regulation 63/09 are also being proposed (ERO # 019-0601), is short-sighted and ill-advised. OPAC is a committee comprised of people with relevant scientific expertise and on-the-ground experience who bring together their knowledge of pesticide-related research, agriculture, forestry, Integrated Pest Management (IPM), human and environmental toxicology, structural/indoor pest management, public health, environmental law, invasive species, pollinator health, and climate change to advise on pesticides matters. Having served as a member of OPAC, I can attest to the seriousness with which committee members undertake their work to serve our Province’s best interests. The elimination of OPAC will deny the people of Ontario the benefit of the fulsome consideration and informed input that pesticides policies (including the recently proposed changes) warrant and that OPAC was established and mandated to provide.

The proposed changes to Pesticide Regulation 63/09 will put important decisions about pesticides use and restrictions in the hands of a Director who has very limited staff support and who could not possibly be expected to possess the breadth of knowledge and expertise that such decisions will require. Without OPAC to provide reasoned and balanced advise to support such deliberations, we risk ending up with decisions that cater to particular sectoral interests rather than the collective needs and well-being of the people of Ontario.

It is my sincere hope that the government will reconsider its proposal to eliminate OPAC and instead embrace the capacity of OPAC to guide our Province continually toward smarter, more sustainable and safer pesticides practices and decisions. Such a move would indeed be ‘better for people and smarter for business.’