These are the comments of…

These are the comments of the David Suzuki Foundation and Environmental Defence.

Summary of recommendations to maintain Ontario’s cosmetic pesticide ban:
• Specify in the Proposed Guide to Pesticide Classes that active ingredients listed in Class 9 at the time this proposal was issued will not be considered for addition to the Allowable List.
• Pesticides classified as Class B (Restricted) by the PMRA should not be considered for inclusion on the Allowable List.
• Adopt the wording in the original 2006 guideline with respect to the factors to be considered in determining whether an active ingredient is appropriate for cosmetic use – see annex. Avoid the misleading and potentially dangerous reference to “safe use” or pesticides.
• Require the Director to apply the precautionary principle in determining pesticides acceptable for cosmetic use.
• Do not exempt cemeteries.

Summary of recommendations to maintain Ontario’s restrictions on NNIs:
• Maintain the current guidelines for pest assessment; withdraw the proposed risk assessment method.
• Maintain the current requirement for a pest assessment report to be completed within the past twelve months in order to purchase and use NNI-treated seeds.
• Maintain the current requirement for a pest assessment conducted by independent, professional pest advisors within the past 24 months in order to purchase and use NNI-treated seeds.
• Maintain current requirements for seed vendors to submit reports on sales of NNI-treated and non-NNI-treated corn and soybean seeds, and for the government to post summary reports annually. Consider extending public reporting requirements to other pesticides and pesticide-treated seeds.