The CHC Crop Protection Advisory Committee submitted a response to the Pest Management Regulatory Agency (PMRA) Proposed Re-evaluation Decision for Captan (PRVD2016-13) on July 29, 2016. This response was based on the results of grower surveys that were distributed through the provincial CHC member organizations. Surveys were conducted in five crop sectors: pome fruit, tender fruit, berries, grapes and vegetables & potatoes. Information regarding captan use including applications rates, number of applications, timing of applications, post-application field activities and the use of personal protective equipment was gathered.

The response from growers was excellent with over three hundred surveys returned. The summarized survey data was provided to the PMRA with the request that this information be used to revise their risk assessments based on actual grower use of captan rather than on the unrealistic assumptions PMRA used in the original risk assessments. The use of grower survey data in the risk assessments should result in more favourable outcomes and reverse the proposed re-evaluation to discontinue most uses of captan in Canada.

The response to the captan consultation was the final response to the seven (7) PMRA proposed re-evaluation decisions for multi-site-mode-of-action (Group-M) fungicides published over the past three years. All proposed decisions either proposed discontinuation of all uses (mancozeb, metiram, ferbam, ziram, thiram) or the discontinuation of most uses and significant restriction on the limited remaining uses (chlorothalonil, captan). The devastating outcome of these proposed decisions, if not amended based on consultation, would be that growers would have no practical options to control resistant pathogen populations where already present or to prevent the development of resistance where is does not currently exist.