May  21,  2007

To: The Ad-Hoc Committee on the Non-Essential Use of Cosmetic Pesticides
      City of Winnipeg,  MB


My name is Sandra Madray, from the volunteer organization - Chemical Sensitivities Manitoba, representing individuals who are affected by the medical condition – Multiple Chemical Sensitivities (MCS). I co-founded this organization with three other individuals after I became chemically sensitive. People with this medical condition experience adverse reactions after exposure to substances such as, pesticides, solvents, gasoline, fragrances, exhaust fumes, new carpets, among others. They react at levels of exposure that are generally considered safe for most people, exposure levels that probably do not affect you. Their symptoms can include cardiac irregularities, muscular pain, severe headaches, gastrointestinal problems, twitching and mental confusion.

Statistics Canada in their 2003 National Population Health Survey indicated that approximately 3% of the Canadian population had physician-diagnosed MCS (1). For Winnipeg, with a population of approximately 700,000, that theoretically translates into 21,000 people with physician-diagnosed MCS. This figures increases if non-diagnosed individuals were to be included. The 2007 report titled – ‘The Medical Perspective on Environmental Sensitivities’, commissioned by the Canadian Human Rights Commission gives more details about this medical condition. (1)

We are here today to talk about how pesticides affect people, and more specifically, people like myself, who have multiple chemical sensitivities (MCS). Our health is at great risk when we are exposed to pesticides. In fact, pesticides have been strongly implicated in the onset of some MCS  cases. (2) Such individuals become hypersensitive after repeated pesticide exposures. Other populations are risk include women of child-bearing age, babies, children, the elderly, allergy sufferers and those with respiratory ailments.
 
Before going into more details about the effects of pesticide exposure on the chemically sensitive, I would like briefly talk about pesticides in general. Chronic low-level exposure to toxins including pesticides is often ignored. However, there is increasing evidence to indicate that this type of exposure is harmful to human health. The resulting health effects include chemical sensitivities, disruption of the reproductive and immune systems, kidney dysfunction, cancer, birth defects, genetic damage, neurological, psychological and behavioural effects and blood disorders. (3) In several studies, blood and urine sample testing have indicated that we are accumulating toxic pesticides in our body. (4, 5, 6) 

And, now, to get back to the chemically sensitive. In Winnipeg, the widespread use of pesticides for lawn care and insect control from spring to fall, wreaks havoc in the lives of the chemically sensitive. While some people in the general population may not noticeably react at these exposure levels, we, the chemically sensitive, react. Showing exquisite sensitivity to pesticides, the symptoms often include cardiac irregularities, central nervous system and muscular problems, and mental confusion. By the time affected individuals recover, it is time to be bombarded with more pesticides again the next year.

I would like to draw your attention to the accommodation problems that some chemically sensitive people face after pesticide applications. They react to the residues on lawns and the pesticide drift in their homes and apartments. I know it is very difficult to understand that a neighbour spraying a lawn with pesticides could precipitate a series of reactions in the hypersensitive. Some people have to evacuate their homes or apartments for extended periods of time and relocate to safer areas outside of the city, until the pesticides have dissipated. They are sometimes forced to sleep in tents. Others have to thoroughly clean their homes after pesticide applications and some are prisoners in their homes. This all happens in Winnipeg every summer! 

Those who do not have these resources have to stay and try to cope with the barrage of pesticides as best as they can. I have been one of the ‘fortunate’ ones with chemical sensitivities. I have the emotional and financial support that allow me to deal with my health issues related to pesticide exposures. Some, who are not as fortunate, have had to sleep in cars.

The decision of what to do, where to go, turns into a nightmare for some people. The city and provincial governments do not provide safe accommodation for affected individuals. It is not a simple matter. What is defined as safe accommodation varies considerably, therefore making it very difficult to satisfy everyone’s needs. While buffer zones may offer some protection, they are not the solution.

Many issues arise from this yearly upheaval, such as loss of income, increased cost of living, reduced quality of life, and some negative health outcomes. Dealing with these problems can be overwhelming because of the lack of government recognition and support. With this disruption of life, the basic needs of affected people are not met.

Even before the 2004 Ontario College of Family Physicians (OCFP) report, a House of Commons Standing Committee on Environment and Sustainable Development report stated: "Given what is known or suspected about the harmful effects of these products and given the purely esthetic purposes they serve, the Committee favours a ban on the use of pesticides for cosmetic purposes.” (7) 
Here are some interesting quotes taken from the websites of two major Canadian health associations:
Canadian Cancer Society: “Since ornamental use of pesticides has no countervailing health benefit and has the potential to cause harm, we call for a ban on the use of pesticides on lawns and gardens.” (8)
The Lung Society: “Cosmetic pesticides can hurt the environment and human health  and….In the short term, cosmetic pesticides can be a problem for people who have multiple chemical sensitivities, or people who have lung diseases. They can set off an immediate reaction, such as an asthma attack. “(9)
There are at least 127 Canadian municipalities with pesticide bylaws limiting or restricting the cosmetic use of pesticides. Cities likes Toronto, Vancouver and Peterborough are pesticide free. It is time for the city officials here to wake up! Why are we here we are today still deliberating this issue?
Without a complete disclosure of ingredients in pesticide formulations, none of us here know exactly what all the ingredients are. This is a very contentious issue. The so-called ‘inert’ substances are not as inert as claimed. They are specifically chosen for their physical and chemicals properties within a pesticide formulation.
Also, there are hundreds of chemicals being used in these ‘cosmetic pesticide’ formulations. While we have information on the cumulative effects of some of these pesticides, it is far more difficult to look at the total concept of synergy. However, we have very persuasive arguments by the pesticide industry as to the safety of their well-intended products. One often wonders if we are, in fact, talking about the same products.
Because of the ready availability of pesticides, people assume that they are safe, government tested and approved. This is a fallacy. At present, the onus is on us, private citizens, to prove harm from the non-essential use of pesticides. Private citizens should not have the burden of this responsibility. It is time for the onus to be reversed. Industry must be more responsible corporate stakeholders. It appears that financial profit is taking greater precedence over human health and the environment. And what about the societal costs – that neglected factor?
With the evidence of harm to public health and the environment, why are we not using a  common sense approach and apply the precautionary principle? I fail to understand why the Pest Management Regulatory Agency (PRMA) and Health Canada are not taking a more proactive approach in their measures to ban the non-essential use of pesticides. Potentially toxic chemicals should not be registered when more benign solutions exist, risks are not clearly quantifiable or potential risks outweigh benefits. (10)  Some landscaping companies have seen the business opportunities in going organic and are taking advantage of it.
To quote from the Ontario College of Family Physicians 2004 Pesticides Literature Review: “Very few of our patients willingly expose themselves to harmful chemicals, but information about pesticide health effects is not common knowledge, and we are in an excellent position to make it so. Strong one-to-one messages from health care providers about the potential harm from pesticide exposure are an effective way to inform our patients. The evidence for harm is strong, and just as the public became aware of the health risks of smoking over decades of education, we now have an important role in heightening awareness of the risks of pesticide exposure.” (3)

In May 2005, there was a challenge in the Ontario Court of Appeal against Toronto's Pesticide By-law. After the court ruled in favour of the by-law, this statement was made made: "The court has reconfirmed the Supreme Court of Canada ruling that Canadian municipalities must be able to govern based on the health, welfare and interests of their communities." (11)

In conclusion, I am requesting you, as our municipal councilors, to honor that ruling. You have been charged with the responsibility of OUR public health and the environment. As you review both sides of the debate on the non-essential use of pesticides, consideration of an integral part of this review must not be forgotten: the balance between risk and benefit. Chemical Sensitivities Manitoba recommends that you have the political will to conclude a total ban on the non-essential use of pesticides along with non-compliance regulations. 

Thank you for allowing Chemical Sensitivities Manitoba the time to make this presentation.


References:
(1) Canadian Human Rights Commission. 2007 report available at:
http://www.chrc-ccdp.ca/pdf/envsensitivity_en.pdf
(2) Zeliger, HI. Toxic Effects of Chemical Mixtures. Archives of Environmental Health January 2003, Vol 58, No. 1: 23 – 29.
(3) Sandborn M, Cole D, Kerr K, Vakil C, Sanin LH, Bassil K; Ontario College of Family Physicians. Pesticides Literature Review. 2004. Available on line:
http://www.ocfp.on.ca/English/ocfp/communications/publ;ications/default.asp?s=1#EnvironmentHealth
(4) Environmental Defence – Toxic Nation Report 2005, available at:
http://www.environmentaldefence.ca/toxicnation/pollutionInYou/toxicNationReport.htm
(5) U.S. CDC National Center Environmental Health Monitoring Program – Environmental Public Health Tracking
http://www.cdc.gov/nceh/tracking
(6) Environmental Working Group – U.S. National Report on Human Exposure
http://www.ewg.org/reports/bodyburden
 (7) Canadian Federal Government, Standing Committee on Environment and Sustainable Development. Report: Pesticides: Making the Right Choice for the Protection of Health and the Environment, May 2000. Available at:
http://www.parl.gc.ca/InfoComDoc/36/2/ENVI/Studies/Reports/envi01/04-toc-e.html
(8) Canadian Cancer Society, pesticide statement:
http://www.cancer.ca/ccs/internet/standard/0,3182,3172_335143__langId-en,00.html
(9)  Lung Association of Canada:
http://www.lung.ca/protect-protegez/pollution-pollution/outdoor-exterior/pesticides-pesticides_e.php
(10) Sears M, Walker CR, van der Jagt RHC, Claman P. Pesticide Assessment: Protecting public health on the home turf. Pediatrics and Child Health. Vol 11, No. 4 April 2006: 229-234.
Abstract:  http://www.pulsus.com/Paeds/11_04/sear_ed.htm
(11) Canadian Environmental law Association (CELA): Media Release May 13, 2005. Ontario Court of Appeal Releases Pesticide Decision. View at:
http://www.cela.ca//newsevents/detail.shtml?x=2205