These are the comments of…

Numéro du REO

019-0601

Identifiant (ID) du commentaire

38062

Commentaire fait au nom

David Suzuki Foundation and Environmental Defence

Statut du commentaire

Commentaire

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.