Health Canada's dangerous call on pesticide rules

On June 20, the federal government announced it was going to continue increasing maximum residue limits (MRL) of pesticides on food but will eliminate the use of pesticides "for cosmetic purposes" on federal lands.

The government says these steps are "aligned with Canada's commitment" to COP15 and its Target 7 goal of reducing the overall risk from pesticides by at least half by 2030.

The feds are confused. How can increasing MRLs be aligned with reducing pesticide risks?

Why the increase?

The reasons given by Health Canada for increasing MRL is we need to harmonize the levels of pesticides allowed in foods internationally. Why? Because when different countries allow different levels in their foods, inspection agencies have to check for compliance with the different levels. This is too "operationally difficult," according to a spokesperson.

The solution? Standardization. Move up the MRL for food grown in Canada to align with the higher MRL of food grown elsewhere in the world.

Health Canada says "don't worry" about the increases:

"Changing the MRL for an imported food does not change how the same pesticide will be used in Canada. Growers and food producers in Canada are still legally required to follow the use directions on Canadian-registered labels."

Here the assumption is that when use directions — the spray directions on labels — are followed, food grown in Canada will have lower residues than the imported food.

That's nice. Except we have no idea if this is true. No one checks to see if use directions are followed in the field. That is also too "operationally difficult." What's worse? Even if the labels are followed, there can still be high levels. The Western Producer recently reported: "A new study found the maximum residue limit for glyphosate in malt barley was exceeded, even though it was applied according to label requirements.

"Even if you're following the label, we're at risk."

Greeeaaat. So we do worry.

MRL risk assessment promotes high levels

When assessing the risks to Canadians from higher MRL, the Pest Management Regulatory Agency (PMRA) runs a dietary exposure assessment (DEA). This requires data on how much pesticide is in a food eaten by Canadians (the residue level) and how much of that food is eaten by Canadians (the consumption data).

For residue levels, the DEA takes residue levels from field trials that may or may not have been in Canada and puts them into the OECD Calculator, which harmonizes the way MRL are determined across OECD countries.

The problem is the calculator "overestimates" the highest level of residues that were actually found in the field, as explained in the OECD's White Paper. It doesn't reflect actual residues eaten by Canadians, it overestimates them.

It's "made-up science."

For consumption data, the PMRA uses the DEEM-FCID database. The problem is this database measures what Americans — not Canadians — eat and so it does not help assess the dietary risks to Canadians. It's "irrelevant science." Relevant Canadian data is available from the Canadian Community Health Survey and is used by other federal departments, but PMRA doesn’t use it.

(For this and other MRL assessment problems, see Comments to PMRA on GLY increases in PMRL 2021-10).

Why increase? Why not decrease?

So why not standardize to lower MRL to align with Target 7?

Because of who is driving the MRL bus: the pesticide industry and international organizations supporting them. The pesticide industry wants the increases. I wonder why?

Monsanto requested the huge glyphosate increases set out in the proposal PMR 2021-10, which caused public uproar, the 2021 "pause" and the $42-million "transformation agenda" of PMRA. Now that the "pause" has been lifted, Syngenta's proposal is first up.

The science comes from the Joint WHO/FAO Meeting on Pesticide Residues (JMPR), a meeting of "experts" who estimate the field trial residue data and run the OECD Calculator for MRL. For PMRL20021-10, it was clear the recommended crazy-high MRL came from the Ottawa 2019 Extra Meeting of JMPR in 2019.

The JMPR makes recommendations to the Codex Committee on Pesticide Residues (CCPR). At the 2021 CCPR meeting that accepted the glyphosate MRL, CropLife International, the association of the world's largest pesticide companies, was represented by 68 people. Canada had nine.

New consultations

PMRA and the pesticide industry are using made-up and irrelevant science to drive the bus on MRL in the wrong direction — away from Target 7 and the announced federal lands ban.

Canadians were clear in 2021 that we want fewer pesticides. But after two years of painful consultations and the "targeted review," what has PMRA come up with?

It is proposing a "notification process" for these same MRL increases — that uses the same science.

PMRA is taking comments on Notice of Intent 2023-01 until Aug. 19.

Mary Lou McDonald is a founding member and president of the Canadian charity Safe Food Matters Inc. (SFM), which works in the legal and regulatory arena to ensure our food is safe. It is the only NGO to win in the Federal Court of Appeal in a case concerning Health Canada's rejection of its Notice of Objection (NoO) to the re-registration of glyphosate/Roundup. This case, and other files concerning pesticides, are ongoing.