From: Ontario Council of the…

From: Ontario Council of the Canadian Federation of University Women (CFUW Ontario Council)

Thank you for this opportunity to respond to the Consultation regarding Amendments to the Pesticide Regulation (63/09 General). CFUW Ontario Council represents 49 clubs throughout the province. We are a grassroots volunteer non-profit organization dedicated to issues of public concern.

Over the years we have been very involved in this area, even presenting to the Standing Committee on Social Policy concerning Bill 64, Cosmetic Pesticides Ban Act, 2008. We have continued that involvement with ensuing policy, and are pleased to speak to this consultation.

In supporting documents, you will find our full paper including Background. Our recommendations are here.

SUMMARY: CFUW Ontario supports retention of the neonic and cosmetic pesticide controls now in place, and the retention of the Ontario Pesticides Advisory Committee.

RECOMMENDATIONS:
• We strongly recommend maintenance of the Ontario Pesticide Advisory Committee, which enables an arms-length and more concentrated review of new (and old) pesticides coming to market than is possible with the PMRA, as noted in the difficulties cited above. We believe that the health of our urban ecosystems, including human and animal health, is at risk without this intermediary assessment.

• We also urge the Provincial Government to maintain and strengthen controls over pesticides (pesticides and herbicides) that affect the wider ecosystems of our province through unintended spread enabled by wind, water and wildlife (insects among others). This spread, often compounded by bioaccumulation has put our pollination dependent agricultural industries at risk, along with animal and human health.

• In particular we strongly recommend retention of Ontario based tracking and evaluation of neonicotinoid sales and use. We appreciate that three neonics have been named for removal by the PMRA, but there are others, and indeed may be more in the future. We recommend that vendor sales continue to be reported, and that sales data continue to be publicly posted. We also recommend retention of third-party assessment of pest threats as a requirement for accessing neonic treated seeds.

• “Neonics are highly toxic to bees and other beneficial organisms. Seed treatments represent the largest use and have resulted in widespread environmental contamination, contributing to the precipitous decline of pollinators.” (Environmental Defence). The agricultural economy would lose in the long term as pollinators disappear, as well as all surrounding ecosystems if we do not act responsibly now for the future.

• The health of our terrestrial ecosystems, of our aquatic ecosystems, and indeed of ourselves in strongly linked to robust control of toxins in our environment.