October 2, 2020
Tank Mix Submission to PMRA
September 30, 2020
Pest Management Regulatory Agency (PMRA)
2720 Riverside Drive
Ottawa, Ontario, K1A 0K9
Address Locator: 6607D
Via email: email@example.com
To whom it may concern,
The Grain Growers of Canada (GGC) believe that our nation must lay a strong foundation to support economic recovery in the years ahead. To truly unleash the agri-food sector as an economic driver, Canada must do more to remove non-science-based and unnecessary regulatory impediments to innovation and competitiveness.
PMRA’s PRO2020-01 proposal on tank mix labelling which indicates that “if a label contains no guidance related to tank mixing, then tank mixes are not permitted” is a reversal of PMRA’s long-standing 2009 guidance authorizing the use of tank mixes that do not have specific labels. It appears to be administrative in nature, and not based on specific safety concerns as identified by PMRA.
GGC strongly believes that this would needlessly increase regulations at a time when the Government of Canada (GoC) has made commitments to do the opposite, and when the Canadian grain value chain has made clear that GoC needs to remove, not increase, barriers to innovation and competitiveness as it looks to the agriculture sector for post-COVID economic recovery.
Until now, the PMRA’s interpretation of the Pest Control Products Act has allowed the use of tank mixes that are not specifically excluded on approved labels, as long as the directions on each individual label are otherwise followed. This has stood the test of time and should be reaffirmed. PMRA’s current approach is fit for purpose and sufficient when label amendments are necessary.
This proposal would increase farmers’ environmental impact and hurt their competitiveness. The current tank mix regime has allowed farmers to combine the application of a variety of inputs. This has reduced time-spent in field during the spring, summer, and fall. Changing the current regime will increase the number of passes required over a field, leading to higher rates of tillage and disease. Associated greenhouse gas emissions will increase due to higher fuel usage and the release of sequestered carbon. Competitiveness will suffer as operating margins will come under further pressure.
There also appears to be a high likelihood that PRO2020-01 will divert PMRA resources away from the priorities that the Canadian grain value chain has identified in previous consultations including proposed re-evaluation changes, additional resources for PMRA, and a national water monitoring program to inform those decisions.
In addition to making it harder for farmers to use technologies with a history of safe use, the Canadian grain value chain is concerned that the proposal adds new regulations without improving safety, is being advanced with unworkable timelines, and will work at cross-purposes to other PMRA initiatives to reduce existing burdens on PMRA’s internal resources.
In summary, this proposal is not in alignment with the broader GoC approach to reducing regulatory burden. The proposed changes are also not in alignment with US regulations through the EPA, putting Canadian farmers at a disadvantage to American counterparts, and increasing our own environmental impact. If it is absolutely necessary for PMRA to move forward with the proposal for internal administrative purposes, then this must allow sufficient time for submissions, approvals of necessary label amendments, and capacity-building and education throughout Canada’s grain value chain.
Jeff Nielsen, Chair
Grain Growers of Canada