b'Greg Bartley is director of crop protection &Nevin Rosaasen is sustainability andLindsay Noad serves as director general of crop quality for Pulse Canada. government relations lead for the Alberta Pulsetransformation for the PMRA. Growers Commission.Beekeepers Commission, Alberta Canola, Alberta Pulsesomething the PMRA itself says is a long time coming.Growers, Alberta Seed Growers, Alberta Sugar BeetAs weve heard from many of our stakeholders, theres Growers, Alberta Wheat Commission and the Potatoa feeling out there that PMRA needs to do a better job of Growers of Alberta. communicating the decisions that were making. People The project also has the support of Results Drivenarent questioning the decisions necessarily, but rather Agriculture Research, Canadian Agricultural Partnership,they are wondering what data and information has gone Bayer, Syngenta, BASF and Corteva Agriscience. into PMRA making a review or re-evaluation decision, Its at the tail end of the second year of its three-yearsays Lindsay Noad, director general of transformation for running time, and Rosaasen is hoping to either extendthe PMRA. it or have the PMRA pick it up after the three years areCurrently, our pesticide use data is based on what we complete. The project is looking specifically at Albertasget as part of our own review process, but were working agricultural wetlands and looking for traces of pesticidevery closely with our stakeholders to see where we might runoff to help inform the PMRA transformation process,be able to get more data about how pesticides are being including its review of the Pest Control Products Act.used, and where. The Pest Control Products Act received royal assent in Need for Real-World Data December of 2002 and came into force in June 2006. All According to Greg Bartley, director of crop protection &pesticides manufactured, imported, distributed or used crop quality for Pulse Canada, the study will provide thein Canada must be registered by the PMRA or otherwise PMRA with valuable data far superior to the modelledauthorized under the Pest Control Products Act to ensure estimates often used to determine pesticide risk.they meet Canadian health and environmental standards, Better real-world data will help PMRA to carry outbear the Canadian label and can be used safely and effec-risk assessments that result in more realistic exposuretively according to label directions. scenarios. In the past, we have seen the review of certainThe Act requires all pest control products be re-evalu-active ingredients or pesticides where the PMRA hasated on a 15-year cycle and gives Canadas health minister relied on model data. Any time you rely on model data,the authority to remove a pesticide from the market if the the estimated exposure scenarios are ultra conservative,risks associated with the product are not acceptable. Bartley says.Over the past two decades, several reviews of the Act The challenge when you have a conservative esti- have been carried out and resulted in several key recom-mate is you really over-estimate risk level, and decisionsmendations from stakeholders, namely support for:are based on a risk level that is actually a lot higher thanProcess modernization, including a new pro-whatever pesticide levels are potentially present in theposed approach for continuous oversight of pesticides and environment. This could conceivably result in the cancel- how it improves the regulatory model overall;lation of a product that growers rely on.A re-evaluation system that ensures resources are If regulators are able to use real-world data, it offersavailable to manage pesticides that present the greatest them a realistic picture of how pesticides are being used.risk to human health and the environment; andThis will help PMRA refine their risk assessments andGreater openness, transparency, and accessibil-decide whether the risk posed by a certain product isity of processes to ensure that more meaningful and acceptable and whether to maintain its registration informed input can be provided into the decision-making 6GERMINATION.CANOVEMBER 2022'