Update on Consultation Responses to PMRA Proposed Re-evaluation Decisions
The CHC Crop Protection Advisory Committee (CPAC) continues to respond to the PMRA proposed re-evaluation decisions that have significant impact on fresh fruit and vegetable producers. The PMRA decisions propose either the discontinuation of all uses or severe limitations of remaining uses. Of particular concern is the proposal to discontinue or limit the use of essentially all multi-site mode-of-action fungicides that are essential to managing pathogen resistance in a sustainable disease management system.
CPAC responses focus on providing information to address incorrect assumptions regarding how growers use the products under re-evaluation that the PMRA has made in their risk assessment that led to the proposed decisions. In the case of the amended proposed decision for chlorothalonil (Bravo), an extensive grower survey of product use was conducted and summarized information was submitted to the PMRA. Recent responses to re-evaluation consultations include:
- methomyl, PRVD2016-02 (Lannate Insecticide) – Proposed discontinuation of all uses, April 14;
- thiram, PRVD2016-07 (Thiram Fungicide and vegetable seed treatments) – Proposed discontinuation of all uses, May 27;
- ziram PRVD2016-06 (Ziram Fungicide) – Proposed discontinuation of all uses, May 27;
- ferbam PRVD2016-05 (Ferbam Fungicide) – Proposed discontinuation of all uses, May 27;
- chlorothalonil REV2016-06 (Bravo and Edge Fungicides) – Proposed discontinuation of many vegetable, berry and tree fruit uses and limitations on remaining uses, June 10.
A response to the PMRA proposed decision to discontinuation all uses of ipropdione (Rovral Fungicide) is currently being prepared for submission by the July 15 deadline.
The PMRA has also proposed to discontinue many captan uses including some vegetable, berry, grape and tree fruit uses, and to restrict use on other crops. A grower survey of captan uses (Captan, Maestro, Supra Captan Fungicides) is currently being prepared and will be distributed to grower organizations during the last week of June. Results of this survey will be submitted to the PMRA for use in the revision of risk assessments.
In addition, CPAC submitted a response on May 31 to the PMRA consultation on PRO2016-02, Management of the Pesticide Re-evaluation Process. This response provided comment on the inclusion of grower and other stakeholder input at the early stages of the re-evaluation process, to avoid the situation which growers are now facing with proposed re-evaluation decisions that are based on risk assessments conducted with incomplete or inaccurate information.