ACRE and Chelsea's pesticide bylaw
The federal government should provide the same level of leadership, vision and support that municipalities such as Chelsea and Hudson have demonstrated to protect human health and that of the environment through the regulation and reduction of chemical pesticide use. The federal government's role is crucial as contaminants do not respect municipal boundaries. The federal government's commitment to the health of Canadians can be made clear by the immediate ban of chemical pesticides for cosmetic purposes.
In demonstrating its vision and support, the federal government should act in accordance with the following definition of the precautionary principle:
"Where there are threats of serious or irreversible damage, the lack of full scientific certainty shall not be used as a reason for postponing measures to prevent environmental degradation". There should be no reference to cost-effectiveness in this principle.
The first criterion to be considered in the registration or re-evaluation of a pesticide should be the need for the product. If the product does not correct a legitimate problem, it should not be considered for evaluation for registration purposes.
When the currently available evidence indicates that use of a chemical pesticide may pose an "unacceptable risk of harm", that chemical pesticide should not be registered under the Pest Control Products Act, or, if it is so registered, it should be de-registered.
Persistent and bioaccumulative pesticides should be immediately de-registered.
The federal government should de-register any product as soon as a less toxic product or method becomes available (the "substitution rule").
Pesticides registered as Domestic under the Pest Control Product Act (PCPA) should be further divided into sub-categories in accordance with their known toxicity.
All registered pesticides should be re-evaluated as to whether they may be endocrine disruptors. Pesticides which are known to be, or which are suspected to be, endocrine disruptors should be de-registered.
The federal government should impose a tax on cosmetic pesticides and use the funds generated by such tax to clean up contaminated areas or to fund educational programmes aimed at encouraging organic methods of lawn care or farming.
Chemical pesticides should not be readily available to the general public over the counter.
All chemical pesticides should include a warning similar to those found on cigarettes such as WARNING: THIS PRODUCT MAY CAUSE SERIOUS HEALTH CONSEQUENCES TO HUMANS OR THE ENVIRONMENT or WARNING: THIS PRODUCT HAS NOT BEEN EVALUATED AS AN ENDOCRINE DISRUPTOR AND ITS EFFECT ON THE ENVIRONMENT OR HUMAN HEALTH IS NOT KNOWN.
The label on the chemical pesticides should include a full description of the contents of the product (including inert ingredients) together with the percentage of such ingredients and the date of the most recent evaluation of the product. All registered products must be re-evaluated on a regular basis. The evaluation process must include both active and inert ingredients and must evaluate these ingredients both alone and as a formulation.
Protection of the natural environment should be given the same weight as the protection of human health.
The federal government should provide sufficient funding for an on-going education programme on the risks associated with the use of chemical pesticides and other common toxic household products.
The federal government should: encourage organic methods of farming and lawn care, allocate funds to inform and educate Canadians about alternatives to chemical pesticides, and fund research into alternatives to chemical pesticides. There should be an office within the federal government which manages these initiatives (similar to the Pest Management Alternatives Office which was disbanded).
The federal government should provide a subsidy and technical assistance to lawn care companies who wish to promote organic practices and to farmers who wish to adopt organic methods of farming.
All the information provided by pesticide manufacturers for registration purposes must be readily available to the public. The public must be able to participate in the registration process as well as in the regular re-evaluation process. An atmosphere of trust through full disclosure must be created and maintained.
The federal government must fund research into the association between chemical pesticides and human health with a specific emphasis on the health of children and other vulnerable members of society such as pregnant women and fetuses. Risk-assessment guidelines must be created which explicitly recognize the impact of chemical pesticides upon these groups. These guidelines must attempt to capture the cumulative exposure of individuals to multiple sources of contaminants over time from all sources including food, water and air. The particular vulnerability of children must be considered when setting limits for pesticide residue in food.