Subject: PMRA proposes to harmonize domestic class pesticides: Deadline Sept 14, 2007

Health Canada is proposing changes to the way in which pesticides are classified in Canada that should smooth the way for other provinces to pass a Quebec-like policy to limit pesticide sales.  The policy proposes to harmonize domestic pesticide classification so that provinces could then pass additional restrictions on sales and marketing of pesticides - such changes could support the municipal bylaws across the country. (And they could be done in addition to any province-wide restrictions on pesticide use.) Please consider submitting comments to Health Canada by September 14, 2007 on the attached PMRA policy.

Classification Harmonization for Canada, A Proposal for Domestic Class Pesticides     
90 days     Deadline: September 14, 2007

Executive Summary

The Federal/Provincial/Territorial (FPT) Committee on Pest Management and Pesticides proposes to harmonize the existing federal and provincial classification systems for domestic class pesticides (also known as pest control products) to improve the management of pesticides across all provinces.

Currently, federal procedures for classifying products use hazard criteria as the trigger for determining if products can fall into the Domestic Class. This proposal would retain the existing procedure, but add a further subdivision of Domestic Class products. Using the criteria described below, products will be placed into two separate groups: 1) those that are suitable for unrestricted domestic sale, and 2) those for which the purchase will be controlled by a vendor.

Products which are appropriate for unrestricted domestic sale (i.e., the “Self-Select” category, or SS) are typically in a Ready-to-Use formulation and packaged in smaller sized containers; products which are appropriate for controlled sale by a vendor (i.e., “Controlled Purchase” category, or CP) typically require mixing or dilution and/or are packaged in larger sizes (i.e., greater than 1 kg or 1L). This categorization will advise provincial regulators which products will require additional controls (i.e., CP products) under appropriate provincial regulations.

The subdivision of Domestic class products into two categories will guide users towards risk reduction by identifying products that can be used with the least amount of exposure. Application of this classification framework at the federal level will result in clear and predictable outcomes, with better utilization of federal and provincial

Full implementation, apparent at the vendor level, will be dependent on adoption of the required regulations by the provinces. Further conditions of access of consumers to those Domestic products identified as Controlled Purchase will be determined by those provincial regulations. Consumers will continue to have direct access to Self-Select domestic products from the major product types (e.g., insecticides, herbicides, fungicides). Domestic rodenticides will be categorized as Controlled Purchase products.

Provincial restrictions on the sale of Controlled Purchase products, using a harmonized approach, will contribute to minimizing risks to the health of pesticide users and to the environment.

Forward written comments by September 14, 2007 to:
FPT Secretariat
Attention: Josée Beaudoin
Pest Management Regulatory Agency, Health Canada
Sir Charles Tupper Building
2720 Riverside Drive, A.L. 6606D1
Ottawa, Ontario
K1A 0K9

Contact Information
If you have any questions regarding this proposal please contact the FPT Secretariat at
Please visit the FPT Committee Internet website at http://www.pmraarla.
gc.ca/english/fpt/ciwg-e.html or http://www.pmra-arla.gc.ca/francais/fpt/ciwg-f.html
for electronic copies of the proposal document.


Re-evaluation of the Agricultural, Forestry, Aquatic and Industrial Site Uses of (2,4-Dichlorophenoxy)acetic Acid [2,4-D]     60 days     Deadline: August 18, 2007

Use of Uncertainty and Safety Factors in the Human Health Risk Assessment of Pesticides      
90 days      Deadline: October 22, 2007

Please forward all comments to:


Or mail to:
Pest Management Regulatory Agency
Health Canada
2720 Riverside Drive
A.L. 6605C
Ottawa, Ontario
K1A 0K9



Subject: EPA says no Special Review of 2,4-D needed

EPA says no Special Review of 2,4-D needed
Aug 9, 2007
LM Direct!

WASHINGTON, D.C. — Following its recent decision to reregister 2,4 dichloro-phenoxyacetic acid (2,4-D), the Environmental Protection Agency (EPA) yesterday announced its decision not to initiate a Special Review of 2,4-D, one of the most widely used herbicides in the United States and around the world, according to a news release received Aug. 9 from the Industry Task Force II on 2,4-D Data.

EPA’s decision states: “Because the Agency has determined that the existing data do not support a conclusion that links human cancer to 2,4-D exposure, it has decided not to initiate a Special Review of 2,4-D, 2,4-DB and 2,4-DP.”

EPA first considered Special Review for 2,4-D in 1986, and after more than 21 years of research and reregistration evaluation, the Agency was able to determine that no correlation exists between the proper use of 2,4-D and cancer.

 “Based on extensive scientific review of many epidemiology and animal studies, the Agency finds that the weight of the evidence does not support a conclusion that 2,4-D, 2,4-DB and 2,4-DP are likely human carcinogens,” according to a notice released by EPA. The herbicides 2,4-DB and 2,4-DP were also being considered for Special Review based on their similarity to 2,4-D.

“The impact of this decision should not be understated,” said Jack Dutra, executive director of the Industry Task Force II on 2,4-D Research Data. “Today EPA definitively stated that 2,4-D is not a human carcinogen when used according to label directions. This has been one of the most widely used and successful herbicides in history, and growers around the United States and the world will continue to use it with confidence.”

2,4-D is commonly applied to a variety of crops such as wheat, corn, rice, soybeans, potatoes, sugar cane, pome fruits, stone fruits and nuts. It controls invasive species in aquatic and federally protected areas, and broadleaf weeds in turf grass. An economic evaluation by the U.S. Department of Agriculture (NAPIAP Report 1-PA-96) concluded that the loss of 2,4-D would cost the U.S. economy $1.7 billion annually in higher food production and weed control expenses.

Since 1989, the Industry Task Force II on 2,4-D Research Data developed and submitted to EPA over 300 Good Laboratory Practice (GLP) toxicology, environmental and residue studies which EPA scientists reviewed to assess the herbicide’s safety under the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) and the Food Quality Protection Act (FQPA).

The Industry Task Force II will continue to develop studies required by EPA’s reregistration review of 2,4-D, most of which are being required of all pesticides.

For more information about 2,4-D visit www.24D.org or call 1-800-345-5109.

About the task force

The Industry Task Force II on 2,4-D Research Data was formed, as allowed under U.S. pesticide laws, to fund the new research required by both the U.S. Environmental Protection Agency and the Canadian Pest Management Regulatory Agency under their current pesticide re-registration/re-evaluation programs. The Task Force does not conduct any research, it simply must fund it. The actual research, under both U.S. and Canadian law, must be done by GLP qualified laboratories. The current companies making up the Task Force are Dow AgroSciences (U.S.), Nufarm Ltd. (Australia) and Agro-Gor Corp., a U.S. corporation jointly owned by Atanor, S.A. (Argentina) and PBI-Gordon Corp. (U.S.)



Subject: Mounting body of evidence links 2,4-D to various cancers

EPA Decides Not To Initiate Special Review for 2,4-D Cancer Risk

(Beyond Pesticides, August 14, 2007) In an August 8, 2007 Federal Register Notice (72 FR 44510-44511), the Environmental Protection Agency (EPA) announced its decision to not initiate a Special Review for the commonly used herbicide 2,4-D, as well as the related herbicides 2,4-DB and 2,4-DP (dichlorprop). Despite evidence to the contrary, according to the FR notice, “Based on extensive scientific review of many epidemiology and animal studies, EPA find that the weight of the evidence does not support a conclusion that 2,4-D, 2,4-DB and 2,4-DP are likely human carcinogens.”

Although a mounting body of evidence links 2,4-D to various cancers, particularly non-Hodgkin’s lymphoma, EPA has been reluctant to classify it as a carcinogen in the face of industry pressure. EPA lists the herbicide in class D for carcinogenicity. Chemicals in this class are considered to have inadequate evidence for carcinogenicity, or not enough data is available. However, the link between 2,4-D and non-Hodgkin’s lymphoma has been demonstrated in the United States, Italy, Canada, Denmark, and Sweden.

A 1986 National Cancer Institute (NCI) study found that farmers in Kansas exposed to 2,4-D for 20 or more days per year had a six-fold higher risk of developing non-Hodgkin’s lymphoma than non-farmers. The risk of cancer was higher for farmers who mixed or applied the pesticide themselves. A 1990 study published in the journal Epidemiology (Vol. 1, No. 5) found a 50% increase in non-Hodgkin’s lymphoma in farmers who handle 2,4-D. Even a manufacturer’s study submitted to EPA in 1986 linked 2,4-D to rare brain tumors.

In 1991, an NCI study found that dogs were more likely to contract canine malignant lymphoma if their owners use 2,4-D on their lawns than if owners did not use the herbicide. When 2,4-D was applied four or more times per year, dogs were twice as likely to contract lymphoma. In addition to these epidemiological studies, a laboratory study conducted by the Food and Drug Administration (FDA) found a 4% incidence of lymphoma in rats exposed to 2,4-D and no lymphoma in unexposed rats.

EPA first proposed 2,4-D for Special Review in 1986. Two years later, EPA proposed not to initiate Special Review (53 FR 9590; FRL-3353-3), because it said the literature did not support a cancer link. EPA deferred a final decision until the completion of the 2,4-D reregistration eligibility decision (RED), which occurred in 2005.

EPA uses the Pesticide Special Review process when it has reason to believe that the use of a pesticide may result in unreasonable adverse effects on people or the environment. The Special Review process usually involves intensive review of only a few or just one potential risk. The review involves evaluating existing data, acquiring new information and/or studies, assessing the identified risk and determining appropriate risk reduction measures.

Known formerly as the Rebuttable Presumption Against Registration (RPAR) process, Special Review provides a mechanism for public input into EPA’s deliberations before the Agency issues a Notice of Final Determination describing its selected regulatory action. The Special Review process determines whether some or all registrations of a particular active ingredient or ingredients meet the federal standard for registration, or whether amendment or cancellation of portions or all of the registrations is appropriate.

TAKE ACTION: Let the Bush Administration know that politics should not trump sound science. Tell EPA what you think about its decision to not initiate a Special Review for 2,4-D, despite overwhelming evidence of its carcinogenicity. Contact EPA Administrator Stephen Johnson by email or call 202-564-4700.



From: Joel Theriault [mailto:joel@whitemoose.ca]
Sent: Thursday, August 30, 2007 11:01 AM
To: 'Bob Wagner'
Subject: RE: Good news on 2,4-D

I hope the conclusion the EPA came to is correct.   But if I was a betting man, I’d say their decision  was influenced by other factors … caught by this part of the press release.
An economic evaluation by the U.S. Department of Agriculture (NAPIAP Report 1-PA-96) concluded that the loss of 2,4-D would cost the U.S. economy $1.7 billion annually in higher food production and weed control expenses.

From: Bob Wagner [mailto:bob_wagner@umenfa.maine.edu]
Sent: Friday, August 31, 2007 9:33 AM
To: 'Joel Theriault'
Subject: RE: Good news on 2,4-D

If you are cynical enough to believe that the EPA toxicologists and the independent scientific review panels from a number of other countries over the past 25 years have been driven primarily by economic concerns for the industry, then you will never be satisfied with any conclusions regarding the safety of anything.
Most everyone I know who has worked closely with the EPA on pesticide issues, however, will tell you that the EPA does not much care about the economic impact to the industry when environmental and human safety issues are involved. My confidence in the EPA comes from working directly with the independent university scientists who have done the research that corroborates the EPA’s conclusion. The only reason EPA cites the economic impacts of their decisions is that they were required to after years of not considering economics in such decisions.


Link to other discussions with Bob Wagner regarding herbicides and forestry.



From: Irene Gallagher (Division Office) [mailto:IGallagher@ONTARIO.CANCER.CA]
Sent: Thursday, September 06, 2007 4:40 PM
To: joel@whitemoose.ca
Subject: Re: The Canadian Cancer Society's position on the non-essential exposure to glyphosate and 2,4-D

Dear Mr. Theriault,
Thank you for your August 30, 2007 e-mail enquiry regarding the Canadian Cancer Society’s position on glyphosate and 2, 4-D.
The Society strongly believes that Canadians should not be exposed to known or probable cancer-causing substances at home, at work, or in their environment. Exposure should be reduced if it cannot be eliminated. Wherever possible, safer alternatives should be used.
We support the principle of Community Right to Know. We believe people have the right to know what substances in the environment they are being exposed to and how to help them make informed decisions about their health. In particular, we believe people have the right to know if they are being exposed to substances that are known or probable carcinogens. 
In the case of pesticides, the Society does not support the ornamental use of pesticides. Some substances used in pesticides are known, probably or possible carcinogens. The ornamental use of pesticides has no countervailing health benefit and has the potential to cause harm. The Society is calling for a 100% ban on the use of pesticides on private lawns and gardens as well as public parks, recreational facilities and golf courses for the purpose of enhancing their appearance.

We are aware of concerns about the potential carcinogenicity of glyphosate and 2,4-D, which are found in some pesticides.
The Society is committed to providing accurate and evidence-based information. We continue to closely monitor research on the link between pesticides and cancer.
Please do not hesitate to contact me should you have any further questions regarding the Society’s position on the use of ornamental pesticides at 800 268-8874 x 2231.
Kindest Regards,
Irene Gallagher
Manager, Public Issues
Canadian Cancer Society, Ontario Division
1639 Yonge Street
Toronto, Ontario
M4T 2W6
Tel: (416) 488-5402 press "1" ext. 2231
Fax: (416) 488-2872
Email: igallagher@ontario.cancer.ca
Every step makes a difference. Join us this fall for the Canadian Cancer Society Taking Steps Against Breast Cancer, a non-competitive, five to 10 kilometre walk taking place in communities across Ontario to raise money for important breast cancer research. Register today. Visit www.cancer.ca or call 1 888 939-3333.