Pesticides and the Cancer Society

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
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 []
Sent: June-19-12 11:14 AM
Cc: Bennett, Bill;
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 []
Sent: Friday, June 01, 2012 10:06 AM
To: Kathryn Seely
Cc: 'Bennett, Bill';
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

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 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. [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


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 Review has 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 Review in 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)  


-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 are taken 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 not a 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 superficially to 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) or 250-764-7628

2011 Legislative Session: Fourth Session, 39th Parliament
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



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