Dear Mr. Yurek, Mr. Sarkaria…

Dear Mr. Yurek, Mr. Sarkaria, and Members of the Legislative Assembly of Ontario:

The Structural Pest Management Association of Ontario (SPMAO) is the most experienced and largest professional association for the structural pest management industry in Ontario, a non-profit organization with a board of directors comprised of representatives from our members. SPMAO assists its member companies and licenced pesticide applicators through workshops and training seminars, so they can obtain their professional licences and stay current with the latest policies, standards and best practices. SPMAO represents over 160 licenced companies that actively protect the health and safety of all Ontarians from dangerous and deadly pests. SPMAO members use pesticide products to control ants, bed bugs, cockroaches, mosquitoes, rodents, spiders, stinging insects, and other pests in countless commercial, residential, and institutional settings.

SPMAO appreciates the opportunity to submit comments regarding changes to the Ontario Pesticide Act as part of the Better for People, Smarter for Business Act. SPMAO supports and opposes aspects of the bill. This proposed bill removes burdensome and duplicative regulations regarding the Ontario Pesticides Advisory Committee (OPAC) and pesticide registration and evaluation, however, at the same time it adds new burdensome and extraneous regulations regarding sign posting, thereby creating a hindrance to protecting public health and people from dangerous and deadly pests. Additionally, Ontario is comprised of the largest number of pesticide applicators in all of Canada, and it is important to ensure that the greatest contingent of applicators leads the rest of Canada in professionalism standards. In short, SPMAO enthusiastically supports modernizing Ontario’s Pesticide Act, increasing the professionalism of our industry by requiring recertification and continuing education or re-writing the examination every five years for licenced exterminators, and we oppose extraneous sign posting requirements that aren’t on the product label and approved by Health Canada’s Pest Management Regulatory Agency (PMRA).

Oppose Burdensome and Extraneous Sign Posting Requirements that are a Hindrance to Protecting Public Health

The Better for People, Smarter for Business Act imposes burdensome and extraneous sign posting requirements that ties the hands of protectors of public health and property with red tape. For example, SPMAO members routinely manage dangerous and deadly pests such as mosquitoes that transmit West Nile virus and ticks that transmit Lyme disease and the Powassan virus. Complying with the proposed sign posting requirements outlined in this bill erects hurdles to managing these potentially life-threatening pests. For example, Section 67.1 imposes posting requirements for:

[A] person who performs a structural extermination that involves the use of a pesticide in, on or over land for the purposes of destroying, preventing or controlling animals that bite, sting, are venomous or carry disease.

This requirement should not be blindly applied to these pesticide applications performed by SPMAO members that protect public health; sign posting should only be performed if the label requires it.

In Canada, pesticides are stringently regulated to ensure they pose minimal risk to human health and the environment. Under authority of the Pest Control Products Act (PCPA), Health Canada registers pesticides after a stringent, science-based evaluation that ensures any risks are acceptable; re-evaluates the pesticides currently on the market on a 15-year cycle to ensure the products meet current scientific standards; and promotes sustainable pest management. Further, pesticide labels are legislative documents, and applicators must use the pesticide in accordance with the label. According to Health Canada: