When developing regulations…

When developing regulations regarding pesticides, one must consider the negative health impacts of pesticide exposure to all the residents of Ontario, including those who are chemically injured. Chemical Injury is more commonly known by its key symptom of Chemical Sensitivity or Chemical Intolerance.

People, who are chemically injured, have toxic reactions when they are exposed to toxic chemicals, especially to pesticides. This is due to their bodies having a difficult time metabolizing and eliminating toxic chemicals from their bodies. Some of them are unable to produce adequate glutathione to metabolize the toxic chemicals. For some people, exposure to pesticides will give them a severe toxic reaction, resulting in a major set back to their health. For others, exposure to pesticides can be fatal. The toxic reactions experienced by the chemically injured will be similar to that which is experienced by the experimental test laboratory animals. Therefore, avoidance of exposures to toxic chemicals, including pesticides, is vital for recovery of health, and in severe cases, avoidance is vital for the person's survival.

In 2016, according to a Community Health Survey done jointly by Statistics Canada and the Ontario Ministry of Health, there were over 400,000 people in Ontario that were medically diagnosed with Chemical Injury. Chemical Injury affects both genders and every age group from infancy to old age.

Since there are over 400,000 people spread throughout Ontario that cannot tolerate exposure to pesticides, the Pesticide Act must include legislation that grants them protection from exposure. This protection would need to include things like bans, notifications and buffer zones.

Notification requirements must be increased, not decreased! Notification is vitally important, in order to help the chemically injured be aware of the potential danger and take action to protect themselves from exposure. For example, they may need to change a doctor's appointment or other activity, so that they are not out doors when the pesticide application is happening or afterwards as it vapourizes and breaks down. It does not matter that only a few people benefit from the notification notice. If the various notification methods help even one chemically injured person avoid exposure and toxic reactions, then it is worth every penny and every bit of time, effort and energy.

Notifications in the news papers, on web sites, signage along the roads and at access points are all necessary steps that everyone who uses pesticides need to take. This includes farmers, operators of golf courses and sports fields, forestry workers, municipal governments, and every one else. Notifications in the newspapers need to appear regularly for two weeks to a month ahead of time, and the notification notices need to be large enough to grab a person's attention. Detailed annual reports are still vital to inform the chemically injured of the pesticide(s) to which they may have been exposed on certain dates. This is crucial information for both the diagnosis and treatment of the chemically injured.

In order to protect the life of the chemically injured, very large buffer zones need to be granted when there is the application of Class B and C pesticides, and especially when it is an aerial application. When it is a farmer applying Class B and C pesticides, then newspaper notification and notification on municipal government web sites are a must. Also, there must be large signage along farmers fence lines and at every intersection of road leading past the farmers land. This is crucial as the pesticides used by farmers are very potent and hazardous to human health. This makes exposure to them very dangerous for the chemically injured person.

The forest is an ideal place for the chemically injured to live, as trees are natural air purifiers. Therefore, forestry pesticide application should be banned. The forest industry has many other tools to use to manage the forests. It does not need to use pesticides to accomplish its goals. Also forest management companies typically use the herbicide Vision Max, a restricted pesticide that is very potent and very dangerous for the chemically injured.

The Hydro power companies have transmission lines and distribution lines that are interwoven throughout the province. Unless people live off the grid, they need to be connected to the distribution lines. This is a legitimate need, not a want. Therefore, to protect the health and life of the chemically injured, the application of pesticides along the transmission lines and distribution lines needs to be banned. The Hydro power companies do not need to use pesticides to accomplish their goals. Hydro-One uses the herbicide Garlon XRT on both its transmission lines and distribution lines. Garlon XRT is a restricted pesticide that is very potent and very dangerous for the chemically injured.

Currently, municipal governments are applying herbicides along the roadsides to control wild parsnip and other weeds. Some chemically injured people live on or near those roads. Therefore, to protect the health and life of the chemically injured, this is another area where pesticide usage needs to be completely banned. The sides of railway tracks are another area where pesticides need to be banned, in order to protect the health and life of the chemically injured that live nearby. Since there are other ways of dealing with the weeds and tall vegetation, pesticide usage is not needed on either roadsides or along railway tracks.

One of the proposed regulation changes, in the area of a cosmetic ban, includes adding cemeteries to the exception list. This change must not happen. Cemeteries are places for everyone, including those who suffer from chemical injury and those who are disabled with it. Therefore if pesticides are used in cemeteries, even on just one plot, cemeteries would become inaccessible places for the chemically injured. Going to the cemetery for the internment of a loved one or visiting the grave of a loved one, would become very dangerous activities for the chemically injured, putting their own health at great risk.

The death of a loved one is emotionally difficult enough, without adding the cruel blow of preventing chemically injured individuals from going to the internment of a loved one or from visiting the grave of their loved one. Therefore, I strongly urge you to keep cemeteries accessible for the chemically injured by removing cemeteries from the exemption list.

Also rural parks, hiking and biking trails, and campgrounds are mentioned as places where pesticides can be used. However, in order to keep them accessible to the chemically injured, these are also places where pesticides must be banned.

Additionally, pesticides must be banned on all outdoor areas associated with an educational institution or facility, including a daycare facility, nursery school, primary school, high school, private school or post-secondary institution. This is due to the fact that exposure to toxic chemicals negatively impacts the cognitive ability of the chemically injured. Exposing chemically injured students to pesticides will result in them having a more difficult time academically, as well as negatively impacting their general health condition.

In conclusion, I appeal to you for compassion and I strongly urge you to take the health and lives of the chemically injured into consideration as you draft the new pesticide regulating legislation.

Thank you,

Health Risk Navigation Inc
https://hrni.ca

P.S. I am commenting on my own behalf, as I am physically disabled with Chemical Injury. I am also commenting on behalf of the more than 400,000 people in Ontario who have been medically diagnosed with Chemical Injury. Flora