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Response to Rock's Rhetoric on Pesticide Reform

October 7, 2000

Dear Honourable Minister,

Please accept my thanks for your October 2nd, 2000 response to my letter (08/04/2000) addressed to Prime Minister Chretien. You will remember that this letter outlined my grave concerns over the lack of sweeping and profound legislation governing the registration, use, application, health/environmental ramifications of pesticides in Canada.

I sincerely appreciate the time and consideration given to this response. Your communication, however, raises further and considerable issues with respect to the ways in which you propose to remedy these very serious problems.

Let me begin by examining the current legislation you cited in your letter, the Pest Control Products Act.

For decades, this Act has allowed the manufacture, sale and application of hundreds, if not thousands of pesticide chemicals, many of which are proven to have disastrous effects on human health and the environment. The following list offers examples of some of these pesticide classes and the health risks they pose (sources included):

Organochlorines, including DDT and Lindane - still an approved pest control formulation under the PCPA, are being linked to estrogen-related cancers and breast cancer. {1, 2}
Organophosphates, insecticides such as Malthion and Chlorpyrifos - recently banned in the U.S., are linked to neurological diseases/disorders, and some cancers{3,4,5,6,7,8}.
Pyrethroids, including many 'off the shelf' retail insecticides, are implicated in Breast cancer, neurological disorders and other mutations at the cellular level. {10, 11, 12}
Phenoxy class chemicals, including 2,4-D (the most commonly used herbicide in Canada), have most recently been linked to soft tissue sarcomas like non-Hodgkins lymphoma {13, 14, 15}.
All are examples of pesticides that, although perfectly legal under the PCPA, can result in fatal illness - especially among children.

These are but a few examples of the vast number of chemicals that the PCPA has approved for manufacture, sale and application on crops for human consumption, on greenspaces where human contact is inevitable and, in some cases, application directly on the human body (children included) for eradication of so-called pests.

As you well know, Honourable Minister, this is the proverbial tip of the iceberg.

This legislation did not take into account what effects the so-called Maximum Levels of Residue (allowable levels based on health impact on the average adult male) would have on young children, no less the unborn child.

Since this Act lacked the mechanism to require assessment of a complete pesticide formulation, it did and does not take into account the effects of inert ingredients on human health, nor does it allow overall toxicity assessment of a formulation after inert ingredients have been combined with active ingredients .

The Act also neglects to consider the synergistic effects of pesticides. This is to say, what potentialities might exist when these chemicals accidentally (or otherwise) combine with other substances in the environment or in the body. As found in some studies, this can result in new and highly toxic solutions. This phenomenon is exemplified by a British study {9} that demonstrated how traces of Carbaryl (a carbamate class pesticide), combine with nitrites (common food additives) in the stomach to result in a highly mutagenic substance.

The PCPA does not consider what effects on human beings, especially young children, may result from the combined exposure to a variety of these chemicals over short, medium and long terms. Furthermore, it neglects to protect Canadians from the potential effects of pesticide residue buildup over years of exposure.

The Act does not provide for new phenomena such as the rise of pesticide resistance among certain species of insects and weeds; the dramatic eradication of flora and fauna due to their sensitivity to these toxins; the impact of pesticides on ground water and soil. As more and more farmers apportion parcels of their land for sale to developers

of residential homes, there is now an ever-growing problem of pesticide drift impacting the occupants of these neighbouring residences. It should be noted that a majority of these homes are owned or occupied by young families, so the effect of drift on small children will prove to be a very significant health concern.

Finally, the legislation lacks a mechanism to protect Canadians from other potentialities such as been found by researchers at the University of Manitoba who have discovered that certain pesticides actually promote the growth of bacterial strains such as Salmonella and E-coli on fruit and vegetable crops.

I dredge up these many profound PCPA oversights and blunders as testament that there is an overwhelming and urgent need for serious, profound, sweeping and thoughtful change to this Act in order to ensure the health of Canadians both now and for generations to come.

Your predecessors, the authors of the original Pest Control Products Act, showed either a tremendous lack of appreciation or a treasonous neglect of this tenet. You well know, as Minister of Health, that their horrifically flawed legislation has resulted in a dramatic and ongoing impact on the health of generations of Canadians and on species and natural habitat (many of which have been forever extinguished) which are defenseless to the irresponsible politics of a few reprehensible Ministers.

Beyond the PCPA issue, there are no viable incentive programs to help farmers make the transition from highly questionable traditional practices to health/eco friendly organic methods. Though organic farms are typically as profitable (if not moreso) than traditional operations, they incur great expense in making the jump to organic practices. This includes a 3 year waiting period before organic certification can be awarded, a period in which harvests are, at best, minimal. I realize this last point falls out of your departmental purview, but in the words of Pierre Trudeau, (a Liberal Prime Minister responsible for profound Cabinet reform), "each Cabinet member must share the collective responsibility for all decisions, not just the ones that affect the particular department of which he or she is in charge."

It is, therefore, incumbent upon you and your government to introduce revised legislation that, first and foremost, will protect the health of Canadians, especially Canadian children.

Again, in the words of that venerable Liberal, respected Prime Minister and devout Canadian, Pierre Elliot Trudeau, "Each of us shares a common desire: to turn over to our children a world safer than the one we inhabit... that in the years to come we will be able to face our children and assure them that we did not lack the courage to face these difficult questions, did not lack the stamina to pursue the correct solutions." So as a Canadian desperate to aid in building a safer, greener Canada, I submit to you that the health of my 3 year old daughter, Kira, and all young Canadians, now rests in your hands. Please do the right thing and pursue the correct solutions. Please ensure that their young lives are not jeopardized by the very food they eat, the water they drink or the parks in which they play.

I thank you for your time and consideration of these issues and respectfully ask, Honourable Minister, that you inform me of your plans to remedy these most grave concerns.

With respect,

Bernard R. Frazer, Director CanadiansAgainstPesticides
cc: PM. Jean Chretien, David Anderson, Lyle Van Clief, Charles Caccia


1) "Organochlorine compounds and estrogen-related cancers in women" by Hans-Olov Adami et al., Department of Cancer Epidemiology, Uppsala University, Uppsala, Sweden (Cancer Causes and Control 6:551-566 1995)

2)"Organochlorine compounds in relation to breast cancer, endometrial cancer, and endometriosis: an assessment of the biological and epidemiological evidence" by Ulf Ahlborg et al., Institute of Environmental Medicine, Karolinska Institute, Stockholm, Sweden (Crit Rev Toxicol 25:463-531 1995)

3)"Epidemiological characteristics of childhood acute lymphocytic leukemia" - Buckley J.D. et al 1994 - Leukemia 8(5):856-864

4) "Estrogenic Potential of Certain Pyrethroid Compounds in the MCF-7 Human Breast Carcinoma Cell Line." Vera Go et al., Environmental Health Perspectives 107 (3), March 1999, pp. 173-177.

5) "Acute and Reversible Parkinsonism Due to Organophosphate Pesticide Intoxication: Five Cases." Mohit H. Bhatt et al., Neurology 52(7), April 22, 1999, pp. 1467-1471.

6))"Overexposed: Organophosphate Insecticides in Children's Food" Environmental Working Group report, January 29, 1998- Richard Wiles et al

7)"Neurobehavioral effects of prenatal exposure to the organophosphate diazinon in mice" Spyker JM, Avery DL. Journal of Toxicology and Environmental Health 1977:9891002.

8)"Epidemiological study of the relationships between exposure to organophosphate pesticides and indices of chronic peripheral neuropathy, and neuropsychological abnormalities in sheep farmers and dippers" Institute of Occupational Medicine, May 1999. Copies of the report available from Fintan Hurley, Director of Research Quality, +44 (0)131 667 5131

9) Elespuru, R., Lijinski, W., and Setlow, J.K. 1974. Nature (London). 247:386-387

10)"Cytogenic effects of permethrin in cultured human lymphocytes." Barrueco C, Herrera A, Caballo C, de la Pena E. Mutagenesis. 1992;7;433-437.

11)"Cytotoxicity, cytogenotoxicity, and allergenicity tests on certain pyrethroids" Hoellinger H, Lecorsier A, SoMier M, Leger C, Do-Cao-Thang, and Nguyen-Hoang-Nam.rug Chem Toxicol. 1987;10:291-310.

12), "Estrogenic Potential of Certain Pyrethroid Compounds in the MCF-7 Human Breast Carcinoma Cell Line." Vera Go et al. Environmental Health Perspectives 107 (3), March 1999, pp. 173-177.

13). "Malignant lymphomaand exposure to chemicals, especially organic solvents, chlorophenols and phenoxy acids: a case-control study". Hardell, L., M. Eriksson, P. Lenner, and E. Lundgren. 1981. British. Journal of Cancer. 43:169-176

14)"Determination of chlorinated dibenzo-p-dioxin contaminants in 2,4-D products by gaschromatography-mass spectrometric techniques". Cochrane, W. P., J. Singh, W. Miles, and B. Wakeford. 1981 J. Chromatogr. 217:289-299

15)"Home Pesticide Use and Childhood Cancer" - Leiss, Savitz 1995 American Journal of Public Health 85:249-252