Submissions

The CFA has repeatedly called on the Government of Canada to ensure that the PMRA is appropriately resourced and supports measures to improve its core activities, fuel its Transformation Agenda, and reduce the backlog in product review and re-evaluation. However, the CFA wishes to express concern over the rate of the increase in the modernization of fees for pest control products, especially taking into account that this is the first of two phases, the second phase being planned for 2028 and would entail further increases.

If the Bill is to proceed, the following specific amendments to the Bill are necessary to avoid any unintended consequences for Canadian producers.

– Recommendation #1: That Section 4(2) (I) be removed to allow the Advisory Committee theflexibility to undertake its mandate and to focus its attention on pandemic prevention andpreparedness. Specifically, our concerns relate to the use of the words “regulate” and “phase out.” It is recommended this wording be removed or changed to consistently use “assess” or “summarize.”

– Recommendation #2: That the Bill include language that encourages continued support andenforcement of existing biosecurity initiatives, including industry-led initiatives.

– Recommendation #3: That the reference to “high-risk species” in Section 4 (2) (I). iv. be clearly defined.

CFA notes that the 2035 emission reduction targets must take into consideration the triple bottom-line definition of sustainability and set achievable targets informed by data and evidence.

The CFA supports the analysis and recommendations contained in the Final Report of the National Supply Chain Task Force (the Report), including the Task Force’s vision of creating a connected, resilient and efficient supply chain system in Canada. In particular, the CFA supports the Report’s conclusions that “as Canada’s trade volumes continue to increase, investment in critical infrastructure assets such as seaports, railways, highways and roads, and airports must also increase to meet demand.

CFA supports providing an immediate $8 million budget increase, with full annual inflationary increases thereafter, to the PMC.

CFA acknowledges that adjustments need to be made to comply with the findings of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP) panel. At the same time, the CFA supports the Dairy Farmers of Canada (DFC) in requesting that any changes be limited only to those that are necessary to comply with the panel and doesn’t lead to overcorrection.

CFA supports providing an immediate $8 million budget increase, with full annual inflationary increases thereafter, to the Pest Management Centre (PMC) to expand its research on alternative crop protection and Integrated Pest Management (IPM) strategies, addressing the backlog due to prolonged underfunding, and support the center’s activities.

A joint submission including CFA, which proposes an amendment to the Bill to improve animal welfare concerns.

CFA asks the Government of Canada to amend Schedule II of the Cannabis Act to exempt industrial hemp, including the whole hemp plant, all primary industrial hemp products (hemp roots, hemp stalks and branches, hempseeds, hemp leaves, and hemp flowers), and processed products derived from industrial hemp primary products from the Cannabis Act and repeal the Industrial Hemp Regulations. CFA also proposes regulatory changes to expand allowable sales and processing to whole hemp plants.

As a result, while the CFA is generally supportive of the proposed policy on continuous oversight of pesticides, we wish to highlight the following concerns over potential risks in applying the policy: Unintended impact on PMRA’s resources and core mandate; Increased confusion concerning pest management products.

CFA provides feedback on the Critical Minerals List, recommending that the list include key minerals for agriculture such as phosphorus, nitrogen, boron, copper, iron and others.
It also includes a proposal to develop a Canadian Critical Farm Input Strategy based on the Critical Minerals Strategy.

CFA recommends that adequate resources are allocated by the federal government to develop accessible laboratory methodologies to effectively detect PFAS, and to develop risk assessments to understand the impacts of PFAS in biosolids applied as fertilizers. CFA also recommends the implementation of standards for source control of PFAS in the wastewater stream, in order to limit the presence of PFAS in the environment, including in biosolids.