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response to your correspondence re PMRA and 2,4-D Date: Tue, 17 May 2005 20:09:48 -0600 From: Al Taylor To: ECD-DCHG3 <ecd-dchg3@hc-sc.gc.ca>, Minister-Health Canada <Dosanjh.U@parl.gc.ca> CC: Ralph Goodale <Goodale.R@parl.gc.ca> References: 1 Greetings; Your statement,"The PMRA has determined, based on the available scientific information, that 2,4-D can be used safely on lawns and turf when label directions are followed" indicates that you have not bothered to read my email. You state "The United States Environmental Protection Agency's re-evaluation published in January 2005, that indicated the risks associated with 2,4-D lawn uses were acceptable." Perhaps you should read the news and know that EPA is dominated by "Bush's Monsanto Men" so relying on EPA for good science is like relying on the devil to produce good and loving people. I pointed out in my original email that the Ontario College of Family Physicians found all pesticides to be dangerous. The Canadian Cancer Society states that pesticides should not be used for cosmetic purposes. The Canadian Institute for Child Health states that children should not be exposed to pesticides like 2,4-D. The Quebec Institute of Health has lead the fight to ban pesticides, like 2,4-D, in the whole province of Quebec. All of these organizations, except Health Canada apparently, are interested in my, and everyone else's health. Human health is closely associated with the health of the environment. As the saying goes, "It is possible to have sick people in a healthy environment but it is impossible to have healthy people in a sick environment". So why does PMRA quote EPA instead of these trusted Canadian health organizations? I believe it is because PMRA is more interested in the economic health of the pesticide industry than it is in the health of Canada's environment and it's citizens. You state, "The PMRA convened a panel of independent scientific experts to review its re-evaluation of 2,4-D." Again you obviously didn't read my email, decided to ignore it, or worse you are trying to defend an indefensible position. To suggest to me, who has seen Dr. Keith Solomon defend the pesticide industry, ad infinitum, you must take me to be completely uninformed. Dr. Solomon is employed by the pesticide industry and has appeared across Canada as their mouth piece and you have the gall to tell me the PMRA panel was made up of "independent scientific experts." Give me a break! You state, "The PMRA ... would like to convey that all registered pesticides undergo a thorough science-based assessment and must meet strict health and environmental standards before being approved for use in Canada." I take it that you haven't bothered to read the 2004 Report of the Commissioner of Environment and Sustainable Development, or any of the three previous Reports. I have. If ever an organization has been found not to be carrying out it's mandate to protect the public health and the environment, it is PMRA. Making such an outlandish statement, in view of the evidence, tells me your letter is PMRA propaganda and has very little to do with science. Of course, "Risk Assessment" is not real science. It is voodoo science and nothing you say can change that fact. Finally, your answer did not deal with the Precautionary Principle (PP). I can understand your reluctance because if PMRA used the PP you would have had to ban 2,4-D. There is plenty of evidence "of harm" from 2,4-D and overwhelming evidence that "it may cause harm" that applying the PP would mean doing away with 2,4-D. I suggest PMRA read the Report of the Commissioner of the Environment and Sustainable Development and instead of protecting the economic interests of the pesticide industry PMRA start protecting the public health and the environment. It is what you are being paid to do. I expect an answer that will deal with the real issues I've raised and not some spin that tries to cover up the problems of 2,4-D. Thank you. Yours truly, Allan S. Taylor, Regina, Sask. ----------------------------------------------------------------------------------- "To sin by silence, when they should protest, makes cowards of men." Abraham Lincoln ================================================== ----- Original Message ----- From: ECD-DCHG3 To: Cc: Goodale.R@parl.gc.ca Sent: Thursday, April 28, 2005 8:01 AM Subject: In response to your correspondence Dear Mr. Taylor: Thank you for your correspondence of February 25, 2005, concerning the pesticide 2,4-D. Your member of Parliament, the Honourable Ralph Goodale, has also written on your behalf. I regret the delay in responding. As you are aware, Health Canada's Pest Management Regulatory Agency (PMRA), has conducted its re-evaluation of 2,4-D, a herbicide commonly used to control weeds on lawn and turf. The PMRA has determined based on the available scientific information, that 2,4-D can be used safely on lawns and turf when label directions are followed. This recommendation concurs with the findings of regulators in other OECD countries, the most recent being the United States Environmental Protection Agency's re-evaluation published in January 2005, that indicated the risks associated with 2,4-D lawn uses were acceptable. The PMRA convened a panel of independent scientific experts to review its re-evaluation of 2,4-D. The scientific panel supports the PMRA conclusions and proposal to continue registration of products containing 2,4-D for lawn and turf uses. Following review and consideration of comments and feedback obtained during the 60-day consultation period, the final decision will be communicated to stakeholders and the general public. The consultation period ends on April 22, 2005. The PMRA understands that the public may have concerns over domestic uses of pesticides and would like to convey that all registered pesticides undergo a thorough science-based assessment and must meet strict health and environmental standards before being approved for use in Canada. For further information on the re-evaluation of the lawn and turf uses of 2,4-D acetic acid, you may wish to visit the PMRA Web site at http://www.pmra-arla.gc.ca/english/highlights/2005221-e.html. Again, thank you for writing. Yours sincerely, Jonathan Moser Policy Advisor - B.C. & West c.c. Office of the Honourable Ralph Goodale, P.C., M.P. (See attached file: 05-002296-638.TIF) ======================================================= Dear Ralph; The Pest Management Regulatory Agency (PMRA) recently released a document that OKs the use of 2,4-D. Given the research I've done over the last three years I find the decision flies in the face of ordinary intelligence and the science. - PMRA did not mention, and worse, did not use the Precautionary Principle (PP) in making their decision. They found scientific literature that indicated there was harm, or may be harm, from the use of 2,4-D but chose to ignore the science, and by doing so ignored the PP which has been enshrined into law by our Supreme Court. - PMRA completely discounted the recent report by the Ontario College of Physicians. The report showed positive links to all pesticides and many health problems, especially to our children. They recommended that people should avoid all pesticides, not just 2,4-D, because of the numerous health problems associated with the use of pesticides. - PMRA ignored the recommendations of the Canadian Cancer Society, The Canadian Institute of Child Health, Canadian Association of Physicians for the Environment, The Canadian Public Health Association, The Medical Health Officers of Halifax, Toronto and Vancouver, The Sierra Club, Canadian Wildlife Federation, the World Wildlife Federation, The Federation of Canadian Municipalities plus the intelligence of the councils of over 60 Canadian cities and towns that have banned the use of pesticides. - PMRA appointed a Committee that had Dr. Keith Solomon on it. Dr. Solomon is a toxicologist that is employed by the pesticides industry and known Canada wide as a hired mouth piece of the pesticide industry. Given Dr. Solomon's bias it isn't surprising that PMRA came out supporting the continued use of 2,4-D. - PMRA appears to only have looked at whether or not 2,4-D causes cancer. They apparently did not assess 2,4-Ds affect on hormone development, childhood development, neurological development or whether or not 2,4-D is associated with other kinds of epidemic illnesses such as childhood asthma. - PMRA has been found wanting on the last three audits by the Commissioner for the Environment and Sustainable Development. She specifically said in Section 1.137, "The range of weaknesses raises serious questions about the overall management of the health and environmental risks associated with pesticides. AMEN! -PMRA is, and always has been, more interested in the health of the pesticide industry than in the health of Canadians or the health of our environment. This latest recommendation just proves it. Further proof is found in PMRAs decision re Mecoprop. It is de-registered because it can't meet regulations but is allowed to stay on the market, if you can imagine, until Dec 31/09. Please take up this serious health issue with the Minister of Health. He must force PMRA to adopt the PP as their guiding principle. In doing so PMRA will have to abandon the voodoo science of "risk management" and "cost benefit" analysis as it's modus operandi. Abandoning voodoo science will mean that PMRA will actually be forced to start protecting the health of Canadians and our environment which is their stated mandate. I recommend you advise the Minister of Health that if PMRA doesn't change, their budget will be reduced to $1.00 in the next budget year. I would appreciate a reply. Thank you. Yours truly, Allan S. Taylor, Regina, Sask. ------------------------------------------------------------ "What we need to match the science of human health is what the ancient Israelites called 'hocma' - the science of the heart.....the capacity to see....to feel....and then to act...as if the future depended on you." Bill Moyer |
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