Pesticides


26 April, 2009
Ms Kathryn Seely Public Issues Manager
Canadian Cancer Society, BC/Yukon
Ms Seely:
I watched with interest your interview on Global TV last Thursday evening (April 22/10). I must say I wasmost disappointed, but certainly not surprised, by your comments―considering the Canadian Cancer Society’s unscientific stance on pesticides. You stated, among other things, that the International Agency for Research on Cancer (IARC) and the US National Toxicology Program have declared that “pesticides are reasonably anticipated to be linked to cancer.” Please provide me with a link to, or pdf of, such a generalized statement made by each of these organizations. I find it extremely difficult to believe that a highly respected institution such as the IARC would make a blanket proclamation that flies in the face of actual science and scientific professionalism.
It would seem that neither you nor others in the CCS are aware (or ignore the fact) that pesticides are not all the same, are not classified identically, do not all act in the same manner, and would not have identical (or, perhaps, even similar) physiological manifestations in either humans or animals. You may as well proclaim that all pharmaceuticals result in identical health problems – a statement which employs the same logic. Such baseless declarations only serve to illustrate a complete failure to comprehend the simple fundamentals of science, and is most disturbing originating from a representative of an organization supposedly based on science.


to read the full letter click here...


O9 May 2009
Ms. Barbara Kaminsky CEO, Canadian Cancer Society, BC/Yukon


Ms. Kaminsky:

I have been following the Canadian Cancer Society Campaign to ban ‘cosmetic’ pesticides with great interest and even greater dismay. The position the Society is taking has no basis in real science, and its ramifications are likely to cost more in illness than it prevents. I have in the past respected the aims of the Society, but I find that its position on this issue is devoid of any scientific rationale.

In the interest of full disclosure: although I have been retired for 4½ years, I am still the Communications Director of the Integrated Environmental Plant Management Association of Western Canada. I am a volunteer and, although elected, receive no payment for the work I do. I have no ownership, shares, or interest of any type in any business even remotely connected to the pesticide manufacturing, sales, advertising, or service industries. In other words, I have no financial stake in whether or not pesticide bans are enacted. I continue in my official position because of my concern with anti‐pesticide activist organizations spreading fear on both a local and national basis through unfounded accusations, using misrepresented, misunderstood, pseudo‐scientific, or poorly conducted ‘studies.’

I am deeply disappointed to see that the Canadian Cancer Society has aligned itself with these activists, accepting unqualified persons as ‘experts’ in a discipline for which they have no scientific training.

to read the full letter click here....







12 May, 2010

Kathryn Seely
Kathryn:

Unfortunately, you have once again missed the point entirely and, I hope, not intentionally. It would seem that you have simply put together excerpts from other generic responses, with the result that none of my specific questions have been answered. Of course, all of the following (which you mention in your email) are most obvious and indisputable: the IARC and other organizations test chemicals; they test for carcinogenic potential; the US National Toxicology Program lists some active ingredients of pesticides as possible carcinogens; the EPA looks at the cancer-causing properties of pesticides. These are good programs, and are necessary; however―and this is a big however―all this is not the same as your unscientific and baseless blanket statement that the International Agency for Research on Cancer (IARC) and the US National Toxicology Program have declared that “pesticides are reasonably anticipated to be linked to cancer.” As is often the case with proclamations from representatives of the Canadian Cancer Society, you were generalizing about all pesticides. Someone listening to your Global interview could not hear it any other way – particularly since this is the same rote pronouncement that the CCS and other anti-science groups continuously repeat. As usual, you do not reference Health Canada’s Pest Management Regulatory Agency (PMRA), which also looks into the carcinogenic potential of pesticides, and―it is significant to note―does not register products that might increase the chances of an individual developing cancer. If you had said that some pesticides are reasonably anticipated to be linked to cancer, and that these specific pesticides are not registered as ‘cosmetic’ pesticides in Canada, I would have no problem with the veracity of such a statement. Pesticides are not all the same, no matter how many times the CCS attempts to convey that mistaken idea. As stated in my letter to you of April 26, It would seem that neither you nor others in the CCS are aware (or ignore the fact) that pesticides are not classified identically, do not all act in the same manner, and would not have identical (or, perhaps, even similar) physiological manifestations in either humans or animals


to read the full letter click here....


From: Kathryn Seely [mailto:kseely@bc.cancer.ca]
Sent: June-19-12 11:14 AM
To: IEPMA
Cc: Bennett, Bill; Rob.Fleming.MLA@leg.bc.ca
Subject: RE: CCS Response to questions previously asked and to more regarding your appearance, representing the CCS, before the Special Committee on Cosmetic Pesticides
Dear John:
In response to your email of June 1st, attached is Dr. Carolyn Gotay's April 2010 letter to the BC MLAs, as well as Barbara Kaminsky's letter to the Vancouver Sun (below), both of which speak to the evidence and why the Canadian Cancer Society believes we know enough to exercise precaution now, especially when these chemicals are unnecessary, and exposure to them is irreversible. Also of interest is the Ontario College of Family Physician’s news release, issued today and attached, which speaks to what other health impacts pesticides might have. I don’t believe that you and I will ever be able to agree on the issue of cosmetic pesticides, and so think we should simply‘agree to disagree’. I think you are a good advocate and, one day, would like to be on the same ‘side’ of an issue as you. Thank you for your continuing interest in the Canadian Cancer Society. Best, Kathryn

To the editor in response to “Pesticide decision must respect scientific evidence”,June 6 2012

While the connection between pesticides and cancer isn't conclusive, the Canadian Cancer Society is very concerned about the growing body of evidence suggesting pesticides may increase the risk of several different types of cancers, including non-Hodgkin lymphoma, multiple myeloma, prostate, kidney and lung cancers. Studies on pesticides and childhood cancer show a possible connection with leukemia, brain tumours and non-Hodgkin lymphoma. The Canadian Cancer Society maintains that the health of British Columbians should take precedence over perfect lawns. It's important to note that pesticide registration by the Pest Management Regulatory Agency (PMRA) does not mean that a pesticide is safe or without risk. When PMRA registers a pesticide it means that risk to both human health and the environment is minimized—but not eliminated—if the product is used for its intended purpose and according to label directions. In its assessments, PMRA does not differentiate between cosmetic use and non-cosmetic use. So, while a definitive cause and effect relationship between cosmetic pesticide use and cancer has not been established, the Canadian Cancer Society believes that enough is known to be prudent and prevent exposure to children, especially when the use of these chemicals is unnecessary. In this respect, prohibiting the use of cosmetic pesticides is both responsible and respectful of the state of the scientific evidence. We hope that Premier Clark and Environment Minister Lake will continue to support eliminating the use of cosmetic pesticides in BC. Wouldn’t we all rather be safe than sorry?

Barbara Kaminsky

CEO, Canadian Cancer Society, BC and Yukon

565 West 10th Ave, Vancouver, BC 604 675-7100




From: IEPMA [mailto:iepma@shaw.ca]
Sent: Friday, June 01, 2012 10:06 AM
To: Kathryn Seely
Cc: 'Bennett, Bill'; Rob.Fleming.MLA@leg.bc.ca
Subject: Request for an answer to questions previously asked and to more regarding your appearance, representing the CCS, before the Special Committee on Cosmetic Pesticides

Kathryn:
It has now been two years since I forwarded you what turned out to be the last of an ongoing series of correspondences between us—and something for which I have yet to receive a reply. As you may recall, I first wrote to you because of questions I had regarding comments you made during your appearance on the Bill Good CKNW Radio Show of February 10, 2010.
As outlined in my last letter to you (May 12, 2010, attached), I was frustrated by your prior responses and by what seemed to be just cut and pasted generic statements, none of which specifically answered my questions. I have, in the past, seen another reply of yours to a request for information from a colleague of mine, who was given virtually the identical vague and generic answers.
As there is much in the media at the moment due to the release of the report from the BC Special Committee on Cosmetic Pesticides, I thought I would take this opportunity to again request a reply from you, and most particularly a response to the eight numbered questions at the end of the attached letter.
Furthermore, when both you and Barbara Kaminsky appeared before the Special Committee on November 8 of last year, Ms Kaminsky stated the following:
People know that we're nationally respected, and our positions on cancer are based on very good evidence that's generated often through our national office and then as a consistent position across the country. We have access to a wide variety of experts, not only within Canada but nationwide.
‘Having access’ to experts is not the same as contacting them or actually making use of their knowledge and advice. Again (as is also requested in the attached letter), what, exactly, is this body of ‘good evidence’ (other than some selected epidemiological studies with weak links) and just who are the ‘wide variety of experts’ with specific pesticide expertise and training upon whom the CCS is claiming to rely? And, more specifically, who are the experts more qualified than the 350 scientists of the PMRA, and expert toxicologists such as Dr. Keith Solomon (who also testified before the Committee)?

Fortunately, the PMRA itself does not rely solely upon selected epidemiological studies (which seems to be the case with the CCS). Epidemiology is widely recognized as a very inexact science, due to a number of issues, not least of which may be the presence of possible and unknown confounding factors. This is particularly true when one is considering observational studies, the only type of epidemiological study on pesticides which can be undertaken involving human subjects. As explained by the PMRA, “Epidemiology studies identify associations rather than causation, and are examined in conjunction with well conducted toxicity studies that are specifically designed to elicit toxic effects over a series of dose levels” (quoted from Additional Questions for Health Canada, requested by the Special Committee, April 30, 2012).

In the same set of PMRA answers, it was further explained that:

When determining the acceptability of a pesticide, PMRA scientists critically examine the totalityof the scientific database for pesticide active ingredients and end-use products, including the epidemiological studies in the OCFP report. When new studies in the public literature are released, the PMRA examines them to determine if further regulatory action is required on the pesticides mentioned in the study. [Emphasis added]

In his October 6, 2011 appearance before the Committee, the PMRA’s Lindsay Hanson stated that “Health Canada approves only those pesticides that show no increase to health risk, including cancer.”

A question from a December 23, 2011 set of inquiries submitted to the PMRA by the Committee asked the following: “We have been told that homeowners, and particularly their children, are exposing themselves to carcinogens, neurotoxins and endocrine disruptors when using cosmetic pesticides. Is this true?” The PMRA’s straight-forward answer: “No.”

Ms Kaminsky told the Committee on November 8 that “Previously, with the Ministry of Environment, we presented a fairly high stack of studies, but basically, over a hundred studies from very credible sources have been looked at in terms of weighing the evidence.” Compare this statement to one by the PMRA, in one of the Committee appearances by its representatives:
We estimated that just proprietary studies that are submitted to us, which we keep on file, amounted to about 23 million pages of scientific studies that are used to support the decisions that we make on pesticides, which is fairly significant. [Emphasis added]
(Jason Flint (Director, Policy and Regulatory Affairs Division, Policy, Communications and Regulatory Affairs Directorate), January 17, 2012 appearance before the Special Committee)
You told the Committee, also on November 8, that “We know that legislation is good for business. Viable alternatives exist.” Ms Kaminsky later added the following:
Always the economic concerns about: ‘It will ruin business.’ We can see from applications of this type of legislation in other jurisdictions that the industry does just fine, thank you.
First, it should be pointed out that there are no ‘viable’alternatives available. If there were, the BC applicator companies would quickly adopt them: a service, not a particular product, is what is being offered. And exactly which companies are doing ‘just fine’? You should try forwarding that statement to the many companies and many hundreds of former employees now out of work in Ontario. From my contacts in that province, I know that those companies that are even still in business have dwindling profit margins and sky-rocketing lists of complaints about ineffective (‘organic’)controls, and many of them expect to have to soon close their doors. The loss of income and huge disruption in the life of the many unemployed could, perhaps, be rationalized if the banning of federally-registered products actually resulted in saved lives and the lessening of disease—something which will not occur.
I would like to know how many millions of donated dollars for research that the CCS has spent on this issue across Canada, for devising and personally delivering presentations to a myriad of municipalities, lobbying every level of government, creating and distributing both web and print-based brochures, paying for press releases and media advertising, and much else. All this significant expenditure, and not one life will be saved. Meanwhile, I am most certain that the same effort and resources put, for example, into further increasing public knowledge of, and awareness about, the hazards of smoking for Canadians would result in saved lives and a diminishment in the development of cancer by many citizens.
It is very difficult to understand the Society’s stance and its squandering of precious resources on the pesticide issue. One would hope that this misplaced and unwarranted emphasis is not for the reason suggested by Greg Thomson, the director of research for Charity Intelligence, a donation-supported charity whose mission (according to its website) is “To help donors make informed and intelligent giving decisions that can have the greatest impact for Canada.” The following is taken from a recent media article:
[Thomson] said the society’s advocacy for pesticide bans isn’t entirely motivated by its desire to protect Canadians from the dangers of pesticides. Its stance is also about raising money.
“There’s a lot of statements that come out of large charities that have to be tempered by the fact that they are marketing statements,” said Thomson, who studies the cancer society for Charity Intelligence.(“Pesticide Ban Position Questioned,” by Robert Arnason, The Western Producer, February 16, 2012)
I did not think that you would object to my cc’ing this email to the Chair and Deputy Chair of the Special Committee—Mr. Bill Bennett and Mr. Rob Fleming—as I am certain that they would also like to know your answers.
I await your response.
Thank you
John J. Holland

05 July, 2012

Kathryn Seely

Kathryn:

I am glad to see that you have finally replied, even if it took over two years for you to do so. You state that one day you would like us both to be on the same ‘side’ of an issue. However, the only way that might occur is if we both comprehensively examined all aspects of a particular issue. In respect to pesticides, I would like us to be on the same side; of course that would only be possible if you also researched the real evidence available on pesticide safety and came to the same conclusions as did the scientific experts and respected regulatory agencies, such as the PMRA, the EPA, and the International Agency for Research on Cancer (whose stance on the possible carcinogenicity of pesticides is continually misrepresented by the Canadian Cancer Society).

As I have stated before, any final conclusion to this issue will have no financial effect on me, since I have been retired for almost eight years. I only remain involved in this debate because of my belief in science combined with my extreme dismay at how otherwise intelligent people can be – and have been – so easily misled. Misleading is a word that could be used to describe the Dr. Carolyn Gotay and Barbara Kaminsky letters and the Ontario College of Family Physicians press release that you attached to your response, and which you claim “speak to the evidence” and possible other “health impacts.”Although I really do not wish to give an extensive critical review for the entirety of Dr. Gotay’s letter to the members of the BC Legislative Assembly, I will address several of the claims she forwards. Dr. Gotay (a clinical psychologist, and not a pesticide expert) states that “Lower rates of lymphoma have been reported in countries after they enact pesticide bans (e.g., Sweden, Finland, Denmark), whereas declines are not observed in countries without such bans (e.g., UK, Norway, Israel).” Here we have a perfect example of cherry-picked, yet still weak, ‘information’. First, Dr. Gotay provides the incorrect source for her statement: her citation for the claim is given as footnote #5 (Turner et al, “Residential Pesticides and Childhood Leukemia”), when, in fact, her ‘information’ is derived from the study cited as footnote #4 (J. Dreiher and E. Kordysh, “Non-Hodgkin Lymphoma and Pesticide Exposure: 25 Years of Research”). Second, and not explained by Dr. Gotay, the bans to which reference is made are for 2,4-D, not pesticides in general, and 2,4-D is a product which those against pesticides attempt to link to Non- Hodgkin’s lymphoma. Third, in her list of countries for which rates of lymphoma have declined, she very conveniently omits the United States – which was actually included in Dreiher and Kordysh’s list of four, not three, countries.
According to the PMRA, ... although the United States showed a levelling off of non-Hodgkin’s lymphoma, there was no reported decrease in the use of phenoxyacetic acids. Norway no longer uses 2,4-D, yet there is no decline in non- Hodgkin’s lymphoma. Therefore, the decline of non-Hodgkin’s lymphoma incidence cannot be specifically related to a decrease in 2,4-D use. “Re-evaluation Decision – (2,4-Dichlorophenoxy) acetic Acid [2,4-D],” PMRA, May 16, 2008

Fourth, and also not mentioned by Dr. Gotay, the authors of the study state the following:

In most studies reported, the risk of pesticide-exposed individuals is similar to that of farming in itself. In addition to pesticides, farmers have other risk factors for NHL including other chemicals (organic solvents, emulsifiers, fuels, and oils), zoonotic viruses, and chronic antigenic stimulation. The latter means NHL may be a complication of an autoimmune process following prolonged antigenic stimulation such as consuming animal protein or constant exposure to grain proteins and animal hair, dander, saliva, feathers, and manure. Other exposures include mycotoxins, endotoxins, and fungi. “Non-Hodgkin Lymphoma and Pesticide Exposure: 25 Years of Research,” J. Dreiher and E. Kordysh, Acta Haematologica, 2006

Dreiher and Kordysh conclude that “In summary, despite 25 years of research, the association between pesticides and NHL has not been clearly defined.” Is this the best supporting evidence that the CCS can offer to illustrate its claim that bans decrease the incidence of lymphoma? Dr. Gotay maintains that “the unfortunate farmers who developed lymphoma because of pesticide exposure provide an indication of cancer risk for the rest of the population...” However, as outlined in the above quotation, the “rest of the population” does not come into contact with anything close to the same combination of environmental factors as would farmers. Whatever contributes to an increased risk of NHL in farmers can in no way be correlated to similar risks to the general public. This conclusion does not require the expertise of an epidemiologist or a toxicologist to determine.

Dr. Gotay also speaks of “considerable evidence.” One would wonder why only selected epidemiological studies with weak links are always chosen as the ‘evidence,’ while other epidemiological studies and all the toxicological evidence are completely ignored. The vast majority of scientific evidence has led responsible regulatory agencies to conclude that the so-called cosmetic pesticides are safe to use. Unlike what CCS personnel may infer – such as Jerilyn Maki did in her June 5 presentation to Kamloops City Council – the ‘weight’of the evidence does not speak in favour of a ban. As a lawyer, you must be aware that ignoring the majority of the evidence is neither a moral nor justifiable stance. A case should not be decided simply by the acceptance of a biased and very weak side of the argument while simultaneously rejecting the much greater and more convincing body of evidence. The PMRA and EPA are privy to all the information that the CCS can access, and a great deal more. The big difference is that these agencies can, and do, consider all the evidence – not just the epidemiological tidbits that correspond to previously announced beliefs. As the PMRA states:

When determining the acceptability of a pesticide, PMRA scientists critically examine the totality of the scientific database for pesticide active ingredients and end-use products, including the epidemiological studies in the OCFP report. When new studies in the public literature are released, the PMRA examines them to determine if further regulatory action is required on the pesticides mentioned in the study. Excerpted from “Additional Questions for Health Canada (PMRA),”requested by the BC Special Committee on Cosmetic Pesticides, April 30, 2012. [Emphasis added]

Is this approach not what science requires, and what legal training emphasizes? In a similar manner to that of the OCFP, why does the CCS so cavalierly promote selected epidemiological studies while turning a blind eye to the major – and very convincing – weight of the evidence? In my opinion, it is disgraceful to ignore the science when it comes to the very core of the CCS’s purported reasons for existence: identifying and preventing the causes of cancer. This is very clearly not what your past and present supporters would expect and is a disturbing departure from past practice.
I also do not want to critique the entire contents of Ms. Kaminsky’s letter to the editor which you attached: it is simply not worth the time it would require. I will just address her claim that “When PMRA registers a pesticide it means that risk to both human health and the environment is minimized – but not eliminated – if the product is used for its intended purpose and according to label directions.” The obvious intimation here is that a product causes health hazards if not used exactly according to label recommendations. You made a similar suggestion in your own appearance before the Special Committee, when you stated that “Health Canada is not the full answer. We've heard that they study pesticides and come up with a determination of whether it's an acceptable risk, but only when used according to label directions” (“Canadian Cancer Society Presentation to the BC Special Committee on Cosmetic Pesticides,”November 08, 2011). As you must be aware, no regulatory agency will make a statement suggesting that the improper use of pesticides may not result in adverse effects.

to read the full letter click here....




May 10, 2010


Mr. Fleming:

In this, my reply to your email response of April 27, I will be addressing the comments you made, as well as providing some necessary background information. The letter is lengthy, but I would ask that you take the time, and have the patience, to read it. It a simple matter for those opposed to the use of pesticides to make blanket statements that there definitely exists a ‘pesticide/cancer link’ or to make a proclamation that ‘children are more susceptible to harm from pesticides.’ Although it is all too easy to follow the rhetoric of anti-pesticide organizations, when they even include the respected Canadian Cancer Society, it must first be understood that none of these organizations have on their payroll qualified scientists in pesticide science. And, unfortunately, it requires much lengthier explanations to discount the unscientific pronouncements and emotional proclamations of those either unaware of, or purposely ignoring, the scientific facts―hence, the length of this letter.

This is a more complex issue than simply that which is encompassed by the “industry versus health professionals” statements so often being made. Few family physicians―or their professional associations―are qualified experts in pesticide science. Nor are those who are the sources and coordinators of the steady stream of misinformation being fed to the health professionals to provide a basis for their opposition: the anti-pesticide organizations. You say your Bill was modelled on that of Ontario and Quebec, but banning the use of ‘cosmetic’pesticides does not put one in the forefront of progress: it actually allies you with those who represent the antithesis of science. Politicians across Canada are being seduced by the unscientific, but politically appealing, stance of anti-pesticide organizations. As a politician, you are probably even more aware than most that you cannot always believe what you hear or read. Even if a claim originates from what you might consider a reputable source (including the Canadian Cancer Society), it cannot always be taken as fact.

November 2009

Pesticides: A Brief Outline of Real Science and Actual Fact

B.C. INTEGRATED PEST MANAGEMENT ACT ― This Act provides British Columbia with the strictest regulations in Canada governing all aspects of pesticide use.

HEALTH CANADA RE-EVALUATIONS ― By the end of 2009 or early 2010, Health Canada plans to have reevaluated all pesticides registered in Canada prior to 1995. At least 80% of this work was completed by July/09, with the most common landscape and garden pesticides such as 2,4-D already re-evaluated. Health Canada has a mandate to approve only those pesticides that show no significant increased health risk, including cancer.

2,4-D RE-EVALUATIONS ― 2,4-D is the active ingredient in the majority of lawn weed control products, and also has the distinction of being one of the main targets of anti-pesticide activity and attacks by many organizations and activists―at least, those who are unable to appreciate or understand the vast amount of research to which this product has been subjected.

2,4-D HISTORY ― 2,4-D was first registered in Canada in 1946. Since that time, there have been numerous re-evaluations, by the PMRA (Health Canada’s Pest Management Regulatory Agency), the U.S. EPA, the World Health Organization (W.H.O), and the European Commission. In fact, despite the opposite claims of many anti-pesticide organizations (including the Canadian Cancer Society), no regulatory body inthe world classifies 2,4-D as a human carcinogen. The PMRA has stated that “No other international body considers 2,4-D to be a human carcinogen. Based on all available and relevant data, Health Canada agrees with this position” (Questions and Answers: Final Decision on the Re-evaluation of 2,4-D, PMRA, January 14, 2009, available online). The U.S. EPA has stated that “The Agency has determined that the existing data do not support a conclusion that links human cancer to 2,4-D exposure” (“Decision not to Initiate Special Review,”August 08, 2007, available online). According to many internationally respected experts on 2,4-D, including Dr. Len Ritter (Executive Director, Canadian Network of Toxicology Centres) and the respected American toxicologist Dr. Frank N. Dost, 2,4-D is probably the most studied and best understood of any chemical―not just pesticide―in existence.

HEALTH CANADA’S PMRA — Employs over 350 qualified scientists, including biologists, chemists, toxicologists, epidemiologists, plant pathologists, weed scientists, and entomologists―all dedicated to the evaluation of pesticides. One must wonder why the Canadian Cancer Society never references the findings of the PMRA in its campaign against the use of pesticides, and instead prefers to claim that pesticides are “known” to cause cancer.

ONTARIO COLLEGE OF FAMILY PHYSICIANS 2004 PESTICIDE LITERATURE REVIEW ― This ‘study’ has been widely used by anti-pesticide groups as part of their claim of a “growing body of evidence,” and has then been accepted by many municipalities as proof of pesticide carcinogenicity. However, the Reviewhas been internationally discredited, due to the fact it consists of cherry-picked epidemiological studies, with virtually no reference to important and relevant toxicological research. Copied below, as one example, are excerpts from an analysis of the OCFP Reviewin the U.K. Government’s Report to the Royal Commission on Environmental Pollution (by Dr. Michael Burr, 2005, available online):
-The treatment of review papers is unclear and appears inconsistent.
-The review takes a rather superficial approach in bringing together the findings of the individual studies.
-Few of the cited studies adequately address the issue of confounding by co-exposures. Much of the evidence supporting an association between pesticide exposure and cancer is derived from occupational exposures, e.g. in agriculture, where animal viruses, diesel fumes, fertilisers and other factors may play a role.
-The review seems to over-interpret the findings, given the limitations of the relevant studies; strong conclusions are drawn from evidence of rather weak quality.

PRECAUTIONARY PRINCIPLE ― This principle is used as the ultimate tool and guiding light by those opposed to the use of pesticides. There are numerous definitions of this principle (which is also seen as anti-science by many scientists), but the generally accepted one is that of the Rio Declaration, from a United Nations Conference on Environment and Development held in Rio de Janeiro in 1992. This document states that "Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation." As Dr. Keith Solomon (Professor at the Centre for Toxicology and Department of Environmental Biology, University of Guelph and Director, Canadian Network of Toxicology Centres) explains: Landscape and garden use of pesticides does not qualify for consideration under the precautionary principle. They are not serious, they are selective to pests, have low toxicity to non-target organisms, and are well understood.... The effects of these pesticides are not irreversible. There is rapid recovery through reinvasion and weed seeds and most need to be used at least once per year. (“Questions and Answers about Landscape and Garden Pesticides,” Dr. Keith Solomon, March 27, 2007) The Rio Declaration, however, did not embody a vague enough definition for anti-pesticide and unscientific organizations such as the Canadian Cancer Society, which instead choose to use the definition contained in the Wingspread Statement: “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.” Note that “serious and irreversible” has been deleted from the original. This ‘statement’ of the principle was formulated by a small group of environmentalists meeting in the U.S. in 1998, and it is not difficult to see why it would be chosen over the Rio Declaration as the weapon of choice. In a 2006 published report by the prestigious British House of Commons Select Committee on Science and Technology, it was stated that “the term ‘precautionary principle’ should not be used, and [we] recommend that it cease to be included in policy guidance.” Also stated was the following: In our view, the terms "precautionary principle" and "precautionary approach" in isolation from any such clarification have been the subject of such confusion and different interpretations as to be devalued and of little practical help, particularly in public debate. Indeed, without such clarification and explanation, to elevate the precautionary approach or principle to a scientific methodology, which can be proved or disproved to have been applied in any particular case, is both unrealistic and impractical. It also provides ammunition for those seeking to promote an overly cautious approach to innovation or exposure to any risk at all. (Science and Technology – Seventh Report, House of Commons Science and Technology Committee Publication, 2006)

INCONVENIENT FACTS

-Despite claims to the contrary, there are no viable, efficacious, or economical products to replace present pesticides.
-There are only two ‘alternative’ products approved for lawn care by Health Canada: Sarritor and corn gluten. Sarritor is 5-10 times more expensive― and certainly no safer―than 2,4-D, and works only on top growth, necessitating even more applications. Corn gluten can only used as a preemergent― which means it is not effective for pre-existing weeds―and provides only poor results.
-Despite claims to the contrary, children and pregnant women aretaken into account when pesticides are registered in Canada: [E]xtra safety factors were applied to the no effect level identified in animal toxicity studies to protect population groups, such as children and pregnant women, that may be more susceptible to the potential effects of pesticides. This resulted in reference doses that were 300- to 1000-fold lower for these groups for these sensitive groups, which are more protective than the minimum 100-fold safety factor. Thus, products will not be considered acceptable for continued registration unless the estimated human exposure is at least 300 times to 1000 times less than the level at which there were no observed effects in the studies examined. These levels ensure the most sensitive population groups – children and pregnant women – are protected.
(Health Canada’s PMRA, Re-evaluation Decision RVD2008-11, May 16, 2008, available online)

-Many ‘organics’ are considerably more toxic than conventional counterparts. For example, consider copper, which is used by organic farmers, and is, indeed, labelled as ‘organic.’ Yet, copper is nondegradable, corrosive, more toxic than its conventional counterparts, and can cause kidney and liver damage.
- Claims by anti-pesticide organizations that business increases for applicator companies after a ban are completely false. The Statistics Canada figures used as “proof” are gleaned from a catch-all category that includes all landscape related companies, such as landscape installation and grasscutting operations. If switching to products deemed ‘organic’ increases income, why would applicators be opposed?

BOTTOM LINE ― The Canadian Cancer Society is nota scientific body: it is a fund-raising organization, consisting of volunteers and administrators. Much the same can be said for other non-scientific organizations, such as Toxic Free Canada and the Canadian Association of Physicians for the Environment (CAPE). The anti-pesticide organizations have no one in their employ with recognized pesticide training or appropriate scientific expertise. Compare this with the over 350 qualified scientists at Health Canada’s PMRA, and the thousands at the U.S. EPA. What is the rationale that causes municipalities to choose to listen to those emotionally and irrationally opposed to the use of pesticides, rather than the actual experts? Why is it that uninformed opinion and unsubstantiated claims take precedence over science for so many Councils and Councillors? According to Dr. Keith Solomon (University of Guelph professor of toxicology), an award-winning and internationally respected expert on pesticides, a lot of this has to do with “bylaw envy.” There has, in addition, been an almost universal lack of due diligence: if a number of municipalities pass a pesticide ban, then this alone is taken as acceptable ‘proof’ of the need for further bans and one municipality simply copies the bylaws of others. Add to this mix the non-scientific approach of the Canadian Cancer Society (which, because of other―good―work done by them, manages to still be viewed as highly respected and reputable) and other anti-pesticide organizations. Many unsubstantiated claims are presented to Councils, using a combination of misinterpreted, poorly conducted studies and fraudulent information. Thus is laid the groundwork for what appears superficiallyto be suitable grounds for a ban. However, ‘facts’ cannot be validated by majority votes, and science is not determined through groundless emotion or uninformed public opinion polls.

For additional detailed scientific information from respected non-industry scientists and sources, contact:

John J. Holland, Communications Director

Integrated Environmental Plant Management Association of Western Canada (IEPMA)

iepma@shaw.ca or 250-764-7628





2011 Legislative Session: Fourth Session, 39th Parliament
SPECIAL COMMITTEE ON COSMETIC PESTICIDES
Tuesday, November 8, 2011
10:30 a.m.
Jacquie Doherty and Paul Visentin
Integrated Environmental Plant Management
Association of Western Canada (IEPMA)
B. Bennett (Chair):We have two witnesses left this afternoon, committee members.

Most people have been in the room for a while, so I'm not going to go through the introductions again. You have 30 minutes to present. You can use all 30 minutes for a formal presentation, or you can leave some time at the end for questions. Your choice. I'll keep track of the clock, and if you get close to 30 minutes I'll let you know.So go ahead and introduce yourselves and get started.

J. Doherty:My name is Jacquie Doherty. I am the president of the IPMA of Western Canada, and with me today is Paul Visentin. He's a director of our association. I'll just give you a little background. My husband and I own and have owned for the last 23 years a lawn care company in Kamloops, and Paul and his wife have a lawn care company in Cranbrook. So we'll proceed. Oh, just to mention quickly. I woke up yesterday morning with a very sore throat, so bear with me if I'm gulping back water.

Our association was established in 1983 as the Environmental Standards Association and over the years has evolved into the Integrated Environmental Plant Management Association of Western Canada. Our main focus is our annual educational conference held at the end of January in Kelowna. We represent professional certified pesticide applicators in B.C., Alberta, Saskatchewan and Manitoba.


Although we have members throughout western Canada, we are here today to represent our B.C. members and their clients, as they will be the ones affected by the recommendations of this committee. Why we're here today: to provide input to the committee regarding cosmetic pesticides and the impact a ban would have on our industry and also on B.C. landscapes. Pesticides are not cosmetic. They are applied to help protect our landscapes from the damage caused by insects, weeds and disease. Insecticides, herbicides and fungicides are used very selectively and only when necessary to protect the health of our lawns, trees and ornamentals in our urban landscapes. First and foremost, pesticides are not used primarily for aesthetic reasons. They are tools that help to ensure a healthy landscape. The use of these products protects our landscapes as valuable ecologically important areas. Residential landscapes are tremendous economic assets as well as vital green spaces that enhance our community's beauty and overall healthy state.Some of the benefits of a well-maintained landscape: a thick, healthy lawn prevents soil erosion; trees and lawns cool and clean the air we breathe; a lawn filters surface water and returns it back to the water table; healthy green spaces reduce noise pollution; a nicely landscaped yard adds value to our property —they say as much as 25 percent; and attractive landscapes are pleasing to the eye, and they make us feel good.


According to Dr. James D. Lu, medical health officer of Vancouver Coastal: "The aesthetics of urban landscapes has public health value. Appealing and well-kept neighbourhoods increase the public sense of safety and increase outdoor activities in neighbourhoods." Of course, that's what we're all striving for — safe, healthy communities.On December 31, 2004, B.C. passed the Integrated Pest Management Act. B.C. was the first jurisdiction in North America to require the use of integrated pest management, or IPM, on all public and private land by commercial pesticide applicators. Because of B.C.'s forward thinking, we have the most modern and sustainable approach to managing pests in a way that minimizes economic, health and environmental risks.IPM is a method of combining biological, cultural, physical and chemical tools to maintain landscapes. When it comes to pesticide safety, we believe you should rely on our federal regulatory system. Health Canada's PMRA and its 350 highly qualified scientists are the experts to be relied upon. We trust Health Canada and its label instructions for the safety of pesticides. We believe in a science-based approach to the registration and use of pesticides.I know we've heard some comments about what's happening in Ontario. I wanted to touch on the Ontario cosmetic pesticide ban, which came into effect on April 22, 2009. This is a photo taken of the Queensway in Toronto on July 28, 2010. No, those are not ornamental plants. Those are actually weeds that are probably four to five feet high, growing along the roadway.According to Cheryl Machan of the Professional Lawn Care Association of Ontario — and that's called PLCAO for short — the ban has had a devastating effect on the lawn care industry. Since the ban was enacted, half the lawn care companies have closed their doors. Companies that are left have lost 30 to 50 percent of their customers. Businesses servicing commercial properties have losses of 50 to 75 percent. They expect the one- and two-truck operations will disappear within the next year.One company, for example, had six trucks running full-time, six days a week, and is now down to three trucks operating only on a part-time basis.I also spoke with Steve Tschanz from Landscape Ontario. He said that this season alone gross revenues of companies are down an average of 30 percent. Profit margins have dropped to 5 to 10 percent from the original 25 to 30 percent, mostly due to the cost of the alternative products and the limited availability of those products. New products are costing approximately 20 times more than the traditional products used. Besides their exorbitant costs, the alternative products are proving to be not very effective.

Landscape Ontario also recently did a survey of their lawn care operators. These are just some of the statements that they received: "We're just barely hanging on. In a year or two we won't exist." "None of my clients are willing to pay $90 per application for a weed control on a small lawn. I have lost all











Integrating Emerging Technologies into Chemical Safety Assessment

The Expert Panel on the Integrated Testing of Pesticides







The controversy over pesticide use in BC has been driven by environmental activists demanding to know every detail of harm or risk that may come from a product. The BC NDP party has for years tried to introduce legislation to eliminate pesticides in BC regardless of the science from credible pesticide research experts. The NDP, Wildsight, Suzuki Foundation and  others joined the Canadian Cancer Society (CCS) in the misguided belief that pesticide use is tied to an unknown risk. They stake their claim on opinion polls that are skewed to get a desired result. While these groups continue their anti-pesticide campaign Health Canada has been working to improve their testing strategies by commissioning an expert panel chaired by Dr Len Ritter to review the testing strategies used on chemical safety assessment.

“Recent estimates suggest that toxicity data are lacking for 87 per cent of chemicals on the market (reviewed in Hartung, 2009). While the toxicological base supporting the safety of some chemicals, such as pesticide active ingredients, is extensive and has contributed significantly to our understanding of the toxicology of these products, on a practical level it cannot be applied to the tens of thousands of chemicals that regulatory agencies worldwide must now categorize. Consequently, there is a significant gap between expectation and capacity in toxicity testing, and an urgent need for new approaches that are more predictive, more reliable, faster, less expensive, and that provide mechanism-based, chemical-specific toxicity information in order to better inform human health risk assessment. 

In May 2009, the Pest Management Regulatory Agency (PMRA) of Health Canada asked the Council of Canadian Academies to appoint an expert panel to answer the following question: “What is the scientific status of the use of integrated testing strategies in the human and environmental regulatory risk assessment of pesticides?” Although a complete set of alternative methods that could replace the entire current testing paradigm does not yet exist, the state of the science is evolving rapidly, and the Panel expects to see a global evolution toward the use of integrated testing strategies in decision-making, with the anticipation that this will better inform decisions for both data-rich chemicals and data-poor chemicals, over the next two to 10 years. The Panel expects that the regulatory deployment of Integrated Approaches to Testing and Assessment (IATA) will vary depending on the types of chemicals and the nature of the decision-making process that the data are intended to inform.  

The potential risks associated with exposure to pesticides are already a particular worry for many people, and adoption of new IATA strategies in regulatory processes are almost certain to further underscore and exacerbate these concerns. Regulators must recognize the need to engage the public in meaningful dialogue in order to provide assurance that the new IATA approaches seek to reduce overall uncertainties in the assessment of chemical risk. Moreover, that these changes will provide more reliable assessments of potential risks to human health and the environment, rather than to simply streamline processes and sacrifice safety for social or economic benefits.” 











I doubt this will allay the fears of the NDP, environmentalists and NGO's that benefit from the fear and misinformation they continue to produce on the pesticide issue. It reaffirms that Health Canada is a world class agency on testing strategies and their expertise should be taken into account when making decisions on pesticide bans. The municipalities and provinces that banned cosmetic pesticides never invited Health Canada staff to speak to the safety issue which speaks volumes of their lack of due diligence. BC is the only province that went through an exhaustive review that included all sides of the debate including Health Canada. Christy Clark should endorse the recommendations brought forward by the pesticide review committee and put an end to the controversy in BC. The NDP have already stated they will follow public opinion, the CCS and environmentalists in making public policy on this and other contentious issues.  We can only hope that the credible science of Health Canada’s experts such as Dr Ritter will prevail and put an end to the anti-pesticide movement in BC.


To review the complete report click here  
Paul Visentin





 
Why the Precautionary Principle dictates that pesticides not be prohibited     

By John J. Holland
Communications Director
Integrated Environmental Plant Management Association of Western Canada

Anti-pesticide activists have used (or, more accurately, misused) the Precautionary Principle as one of their main tools for convincing governments to enact pesticide prohibitions. What has either been overlooked or ignored is that this much misunderstood principle—when used in its fullest sense—weighs in favour of maintaining the use of pesticides, whether agricultural or “cosmetic.”The most widely accepted version of the Precautionary Principle is the Rio Declaration of 1992. It was proclaimed as “Principle 15” at the United Nations Conference on Environment and Development, which took place in Rio de Janeiro from June 03 to 14, 1992. Principle 15 states:

“Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”

It must first be noted that there is no such thing as “full scientific certainty”—one cannot prove a negative. It is impossible to prove scientifically that pesticides—or any substance, including water­—could never harm anything or anyone under any circumstances. There is also no proof of “environmental degradation” caused by what are erroneously termed “cosmetic” pesticides.

Of interest here are the words of Sir Colin Berry, a professor at the University of London, England:

“The objectives of safe management of our environment depend on caution—the taking of heed, precaution­—and the exhibition of prudent foresight. But they cannot include an indemnity—an assurance that no one will come to harm from any action.” — Sir Colin Berry, “Risk, Science and Society,” speech given at London’s Royal Institution, 2001
Pesticides and the Precautionary Principle: Dr. Keith Solomon, an internationally respected toxicologist, has received awards for his work in North America, South America, Europe, and at the United Nations. He teaches toxicology at both the undergraduate and graduate level at the University of Guelph. Dr. Solomon has authored or co-authored hundreds of research articles and books, serves on several advisory committees on matters related to environmental toxicology and risk assessment of pesticides and other substances in Canada, the U.S.A., Europe, and for the United Nations Environmental Program. He is also the chair of the board of directors for the Canadian Network of Toxicology Centres.

States Dr. Solomon:

“Landscape and garden use of pesticides does not qualify for consideration under the precautionary principle. They are not serious, they are selective to pests, have low toxicity to non-target organisms, and are well understood. Their use is not widespread, less than 2 per cent of all active pesticide ingredients used in Canada are for landscape uses and the land area to which they are applied is small...

“The effects of these pesticides are not irreversible. There is rapid recovery through reinvasion and weed seeds and most need to be used at least once per season.” — Dr. Keith Solomon, Question and Answers about Landscape and Garden Pesticides, March 27, 2007.

Precautionary Principle Misunderstanding: It is of value to note that many of the anti-pesticide organizations (including even the Canadian Cancer Society)..... to read the full article
click here










QUESTIONS AND ANSWERS ABOUT LANDSCAPE AND GARDEN PESTICIDES 
Keith Solomon, Centre for Toxicology and Department of Environmental Biology,
University of Guelph, Guelph, ON, N1G 2W1, Canada
March 27, 2007 
The emotional argument concerning so-called “cosmetic use” of pesticides in landscapes and gardens has been a controversial topic for many years. Extremist views on both sides have dominated the discussion and the public, which has the right to expect factual information, has instead been besieged by headlines and reports which have little basis in scientific fact. These Questions and Answers address some of these issues. 
Q. What are pesticides? 
A. By law, pesticides are substances or things that control or mitigate pests. The definition of a pesticide is very broad; more than 700 pesticides are registered for control of pests such as insects, diseases, weeds, and rodents. These substances have a wide spectrum of chemical and biological properties and are used in agriculture and forestry, in urban and marine environments, and for protection of human health. Even swimming pool chemicals are classed as pesticides as are the naturally occurring pesticides such as pyrethrins, rotenone, and biological control agents favored by organic growers. What they have in common is that they cause effects in target organisms (pests). Not all pesticides are the same, some are very toxic to non-target organisms, some essentially innocuous. 
Q. Are pesticides tested before being put on the market? 
A. Yes, to be registered, extensive testing is required. These data, current, as well as historical, are reviewed and re-reviewed on a regular basis in Canada (Pest Management Regulatory Agency), USA (Environmental Protection Agency), European Union, and other jurisdictions (FAO, WHO). This process is similar to that for drugs and food additives, except that pesticide testing also addresses environmental fate and effects. Some may take exception to the fact that the testing is paid for by industry but this is appropriate as they benefit from the sales of the substances. Testing must be done under Good Laboratory Practice guidelines and must be subjected to Quality Assurance before it is acceptable. 
Q. What tests are done on pesticides? 
A. Pesticides are tested for effects in mammals and in the environment. In mammals, tests include those that address acute effects such as oral and inhalation toxicity, dermal toxicity, skin irritation, sensitization, and eye irritation. Longer-term studies include subchronic oral or inhalation toxicity and lifetime oral toxicity (cancer and other effects). Additional tests include metabolism and excretion, mutagenicity and genotoxicity, teratology (birth defects), and reproduction (multigenerational effects). Environmental testing includes acute aquatic toxicity tests in fish, algae, plants, and invertebrates, terrestrial tests in birds, and beneficial organisms (bees). Chronic tests include life cycle and developmental tests in fish and invertebrates. Special tests include environmental fate and dissipation and field tests (microcosms). 
Q. How are the test data used to assess risks to pesticides? 
A. Regulators use the precautionary approach to set guidelines for exposure of humans and the environment to pesticides. The results of laboratory tests, usually the doses or exposures that cause no effects in the test organism are used to set a maximum short-term or long-term exposure for human s or the environment. The exposure from the laboratory tests is divided by several uncertainty (safety) factors when extrapolating to humans and the environment. These factors are multiplied together and range from 100 to 1000-X. In other words, the acceptable exposure for a human will be 100-1000-X less than the dose that causes no effect in the most sensitive test animal.
Q. Is the pesticide registration system in Canada stringent? 
A. Yes, the pesticide registration process in Canada has always been stringent. Registration of pesticides in Canada is the responsibility of the Federal Government. The Pest Management Regulatory Agency has a staff of more than 300 highly trained specialists who intensively evaluate pesticides submitted for safety and effectiveness before allowing registration. The PMRA was established in 1995 to centralize a task that had previously been done by several Departmental Units and Interdepartmental Committees. Some believe that Canada had very lax pesticide regulatory requirements prior to the establishment of the PMRA. That is completely incorrect. Canada has had one of the strongest regulatory systems in the world for many years. The formation of the PMRA was primarily an administrative change — Canadian requirements for registration were strict prior to the formation of the PMRA and they have remained strict since that time. 
Q. Are pesticides controlled at the provincial level? 
A. Yes, in most provinces, pesticides have long been subject to further review and control under the local regulation. In Ontario, for example, this is done by Ministry Scientists and the Ontario Pesticides Advisory Committee, a group of highly qualified environmental scientists, medical doctors, pest management specialists, and private individuals who report to the Minister of the Environment for Ontario. This committee is responsible for classifying pesticides for use in Ontario. The Ministry of Agriculture, Ministry of the Environment, and other ministries publish recommendations for pest control and monitor use. Thus, before a pesticide is registered and recommended for use in Canada, it is subject to intensive evaluation by highly trained specialists at both levels of government. The Canadian system is as stringent, if not more so than that of the EPA in the United States, the MAFF in Great Britain, or the European Council in the EU.
Q. Is municipal regulation of pesticides needed? 
A. Municipal regulation of pesticides is not needed. Considering the intensive review carried out at federal and provincial levels, a third level of government need not be involved. Federal and provincial agencies are staffed with highly trained specialists. Beyond that, what can municipalities, only a few of which have pest management specialists on staff, contribute? A case in point is the ban on tobacco smoking in public places by municipalities. Cities do not seek to ban and restrict smoking because of the diligent work of local committees – they do it because research and risk assessment by Health Canada (and other regulatory agencies) have shown that smoking causes lung cancer and a host of other diseases. These same agencies review and assess pesticides and approve their use in Canada, the USA, and many other countries. Why do we choose to believe these agencies when it comes to smoking but not when it comes to pesticides? 
Q. Will municipal regulation of pesticide use work? 
A. Draconian plans to virtually eliminate pesticide use simply will not work. While some pests can be suppressed by non-chemical methods of control, many others cannot. Homeowners will quickly realize that some pesticide use is necessary to suppress lawn and garden pests and they will ignore the by-law. The obvious unfairness of the system will further promote non-compliance. This will not be difficult to do since pesticides registered in Canada will still be legally available. 
Q. Are pest problems in gardens serious? 
A. Pests can be a real problem, even in home gardens. Most people today have little idea of the large number of pest species that exist. For example, in Ontario, over 100 species of insects have been identified as pests of vegetable crops. There are dozens  of pest species which attack other urban horticultural crops. Not all are present at epidemic levels all the time; however, management techniques must be in place to cope with an outbreak when it occurs. Pests can cause damage very quickly, they will not conveniently wait around for a city inspector to give a permit, neither do they punch a time clock and not damage gardens over weekends. Restricting the use an application of pesticides in domestic situations may result in costly damage to ornamental and other garden plants. 
Q. What quantities and kinds of pesticides are used for home gardens and landscape pest control?
A. Compared to the total use of pesticides in Canada, only a small percentage (2-5%) is used for landscape and home gardens. Most of these (80%) are herbicides, such as 2,4-D and related phenoxys, glyphosate, and some insecticides. Fungicides are also important in golf-course maintenance. 
Q. Are landscape and home-use pesticides the same as those used in agriculture? 
A. Landscape and home-use pesticides do not include most of the pesticides used in agriculture. Generally, home use products have lesser toxicity to mammals and other non-target organisms, small persistence, and little mobility in the environment. They are only sold in small quantities and often in sealed direct-application packages. Most agricultural pesticides cannot be purchased or applied by a homeowner, they may only be applied by people who have had training and are licensed or certified to apply these products. 
Q. Do landscape pesticides build-up in the environment and in humans? 
A. No, if they did, they would not be allowed for use. For example, the herbicide 2,4-D has a half-life in soils of about 2 weeks and no persistence beyond season of use. It has low mobility, is not bioconcentrated into organisms, is not bioaccumulated over time, and not biomagnified up the food-chain. Another common urban and landscape pesticide is glyphosate, which is biologically non-persistent, immobile, not bioconcentrated, not bioaccumulated, and not biomagnified. 
Q. Have exposures to pesticides such as 2,4-D been measured in home-owners? 
A. Yes, extensive studies have been done on this topic. The conclusions of these were that: Homeowner and professional applicator exposure well below regulatory guidelines, protective clothing reduced exposure under all conditions of use, applicator exposure was caused by spills and contact with spray, no or very small exposures occurred in bystanders to home or professional applicators, and reentry exposures were small but a 24-48 hours re-entry period will further reduce them to essentially negligible amounts. 
Q. Do pesticides cause cancer in adults and children? 
A. This is a topic of much discussion, much of which was precipitated by a report of the Ontario College of Family Physicians (OCFP), a small team mainly composed of family physicians and graduate students, but with epidemiological expertise. They reviewed the literature on the human health effects of pesticides published in the period 1992- 2003 to upgrade their brochures and educational programs on the impact of pesticides on public health. On the basis of reviews of studies conducted with agricultural, not homeowner pesticides, they concluded that: Many of the studies showed statistically significant positive associations between pesticide exposure and solid tumors, non- Hodgkin’s lymphoma (NHL), leukemia, as well as consistent effects linking pesticide exposure to disorders of the nervous system. This report has not yet been published in the scientific literature but was reviewed by two disinterested groups in the UK. The UK Advisory Committee on Pesticides (ACP) remarked on the failure of the study to take account of all or even most of the relevant epidemiological evidence, and the biases inherent in the way in which material was picked out for inclusion. There was inadequate attention to exposure characteristics and relevant toxicology when interpreting reported associations. The study was superficial in the synthesis of evidence, which inadequately explored the impact of the strengths and weaknesses of individual studies. Overall, the ACP concluded that the report does not raise any new concerns about pesticide safety that were not already being addressed, and does not indicate any need for additional regulatory action in the UK. Another independent review of the OFCP study was conducted by Dr Michael Burr, University of Wales College of Medicine at the request of the UK Royal Commission on Environmental Pollution. He concluded that the authors had insufficiently addressed the issue of publication bias, and the review seemed to over-interpret the findings, given the limitations of the relevant studies. He also stated that strong conclusions were being drawn from evidence that was of rather weak quality and that concluded that it was difficult to assess the likelihood and strength of causal effects in the various associations reported. Given these independent comments, the conclusions of the OCFP report should be treated with great caution. 
Q. Are cancer rates in Canada increasing?
A. Incidence of cancer must be considered in relation to increasing population and increasing age of the population. The latter is particularly important as it is known that cancer incidence increases with age and that the Canadian population is now longer-live than ever before. Despite claims such as those by the Canadian Institute for Child Health that childhood cancer has increased 25%, this is not supported by data in National Cancer Institute of Canada’s databases, the official source of this information. Increases other than those associated with better and earlier diagnosis have not been noted by the U.S. National Cancer Institute either. Based on information from the National Cancer Institute of Canada, age-adjusted cancer incidence rates in Canada have remained constant or decreased for all major form of cancer. Breast and prostate cancer rates have increased, most probably as a result of better diagnosis and/or changes in lifestyle. Lung cancer has decreased in men and increased in women, a direct result of changing patterns of tobacco smoking. The Canadian Cancer Society has stated that “is very concerned about the use of potentially carcinogenic (cancer-causing) substances for the purpose of enhancing the appearance of, for example, private gardens and lawns as well as parks, recreational facilities and golf courses (ornamental use)”. The go on further to state that “Since ornamental use of pesticides has no countervailing health benefit and has the potential to cause harm, we call for a ban on the use of pesticides on lawns and gardens”. The reason for their recommendation is primarily that they do not perceive a value to the aesthetic use of pesticides. In other publications, they have supported the use of pesticides in the production of inexpensive and healthy food. These views do not consider the countervailing risks of alternatives and are based on value judgments. 
Q. Why can we not use epidemiology studies in humans to link pesticides to cancer and other diseases? 
A. Epidemiology studies, while conducted on the organisms of interest (humans), are, for the most part, seriously hampered by lack of good historical or current data on exposures as these are not measured analytically in the subjects. For this reason, surrogates for pesticide exposure are used, such as use of pesticides, area sprayed, years of application, money spent on pesticides, or amount of pesticide applied. These have been shown to be unreliable indicators of exposures and call all epidemiology studies with pesticides into question. 
Q. Why not apply the precautionary principle to regulating pesticides? 
A. The precautionary approach is already used in the regulation of pesticides so the application of the precautionary principle is redundant. Besides, the precautionary principle is used for issues of greater significance. The precautionary principle was first used by Swedish EPA in 1969 and was ratified in the Maastricht treaty of the European Union in 1992 and first applied in Principle15 of the 1992 Rio Declaration onEnvironment and Development. It is applied where there are threats of serious or irreversible damage; lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation. It was applied to ozone-depleting gases such as the CFCs, methyl bromide, etc., which have been banned or restricted under the Montreal Protocol of 1987.Landscape and garden use of pesticides does not qualify for consideration under theprecautionary principle. They are not serious, they are selective to pests, have low toxicity to non-target organisms, and are well understood. Their use is not widespread, less than 2% of all active pesticide ingredients used in Canada are for landscape uses and the land area to which they are applied is small (less than 1% of total land area for landscape uses and less than 10% for one or more applications in all uses). The effects of these pesticides are not irreversible. There is rapid recovery through reinvasion and weed seeds and most need to be used at least once per season.
Q. Are there alternatives to the use of pesticides only? 
A. Yes, there are better ways to manage pests than to only use pesticides. Modern pest management programs are built around the concept of Integrated Pest Management (IPM) using a combination of non-chemical and chemical pest control methods. While chemicals are an important component of IPM programs, it is sensible to use them only when necessary. For example, in 1987 Ontario initiated a 15 year program aimed at reducing agricultural pesticide use by 50%, while still achieving effective pest control. This program, involving research and extension specialists, grower organizations, and the chemical industry has, been a remarkable success. Urban landscape pest managers also can use IPM and there is no question that chemical use could be reduced substantially with significant savings in cost for chemicals. Cities could organize a positive, progressive effort to develop an urban pest management program modeled after the provincial agricultural pesticide reduction project. This can be achieved through a cooperative effort involving the city, academia, the pest management industry, and end users. This would involve education and community effort but would be less costly than the alternative.
Q. Should cities ban the use of pesticides in urban and landscape environments? 
A. No, not for toxicological or health reasons. However, if they wish to do this for political reasons, that is their legal right; however, they should at the very least be honest enough to admit it. It is also important to consider the countervailing risks of not controlling pests and the costs and the risks of the alternatives. Pesticides should always be used properly and, by all means, use Integrated Pest Management to reduce use but keep all the tools of pest management, including pesticides, in the box.



Scared to Death: How ChemophobiaThreatens Public Health
Presented by: The American Council on Science and Health
January 2011 by Jon Entin
Dr. Elizabeth Whelan, President of the American Council on Science and Health, warns that, "over the last several years the level of fear, misinformation and media hype  surrounding the use of safe chemicals in everyday, household products has swelled to a level which we feel must be addressed in detail before this situation gets even further out of hand," This position paper addresses scientific realities and dispels many of the unfounded fears regarding the safe use of chemicals. The report refers to those fears as chemophobia -- literally, an irrational fear of chemicals. Unlike many ACSH position papers, Scared to Death is not written by a scientist or team of scientists but by a journalist. Jon Entine is a science journalist who is a fellow at the American Enterprise Institute (AEI). More often than not, I find myself in disagreement with the AEI and I have felt that much Mr. Entine has written on his favorite subject of human genetics has overestimated the power of genetic determinism. This report, however, offers a well resoned analysis and debunking of a lot of silly pseudoscience that has been widely disseminated on the internet and through the mainstream media. .... To read the full article CLICK HERE

Pesticides & Health: Myths vs. Realities

Will we avert a crisis of food supply shortage? This question continues to loom large although population growth rate has tempered considerably, compared to projections 30 years ago. But several years ago, as food prices seemed to be on the verge of skyrocketing, owing to rapid increases in grain prices, we arguably got a taste of the future. When you consider uncertainty about climate variability and land use changes as well, we seem always on a precipice of doing with less rather than more.... To read the full article CLICK HERE

No basis for pesticide bans
By Leonard Ritter

Appeared in the National Post Newspaper, June 2001.

Cancer ranks among the most pervasive diseases of the western world. In a recent report, the Canadian Cancer Society estimates that Canada will experience over 134,000 new cases of cancer and over 65,000 cancer related deaths in 2001. Breast cancer, one of the most commonly diagnosed cancers in women of the western world, will affect almost 20,000 Canadian women in 2001, a new case diagnosed just about every 30 minutes in this country alone. All of us, whether women or men, will be affected by this disease, either as we receive the news of a diagnosis and begin to anticipate the horrors that will follow, or through supporting our wives, daughters, mothers and friends as they face the ordeal that lies ahead. Allegations about the causes and risk factors for cancer must always be treated seriously and the scientific community must remain vigilant in searching out and thoroughly studying possible cause-and-effect relationships. For decades, pesticides have attracted attention as possible cancer-causing agents. Allegations that pesticide exposure increases the risk of developing specific types of cancer, .... to read the full article click here

 
 
 
 
 

 

 
 

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