Re-evaluations and special reviews of registered pesticides in Canada

According to ‘2019–2020 Annual Report’ published recently by the Canadian Pest Management Regulatory Agency (PMRA), over the 10-year period between 2009 and 2019, the increase of the number of registered pest control products from 5700 to 7600 also represents an increase in post-market activity workload.

Once a pesticide has been granted registration status, it becomes subject to a system of post-market risk management controls under the Pest Control Products Act. This includes re-evaluations and special reviews of registered pesticides, compliance and enforcement activities, and reporting of health and environmental incidents.

Re-evaluation and special review programs

Under the Pest Control Products Act, registered pesticides currently available on the market are subject to re-evaluations, which are initiated 15 years after the most recent registration decision, at the latest. Pesticides registered after 1995 are referred to in the re-evaluation context as ‘cyclical pesticides’.

Pesticides registered prior to 1995 are referred to as ‘older pesticides’, and when the re-evaluation program was established, there were 401 of these older pesticides.

As of March 31, 2020, 387 of the original 401 were complete, with public consultations on the remaining 14 complete or imminent. The re-evaluation of older pesticides was scheduled to be completed by the end of 2020; however, delays due to the COVID-19 pandemic may affect the timing of some final decisions. In general, these remaining older pesticides are complex re-evaluations based on their large use patterns, and require large volumes of scientific data, and in some cases data that may be complex to generate.

Under the re-evaluation program, new methodologies, data, and scientific approaches are incorporated into the assessments to ensure that registered pesticides continue to meet modern standards for health and environmental protection, and have value.

Special reviews are another mechanism used under the Pest Control Products Act to determine the continued acceptability of registered pesticides. Unlike a re-evaluation, the intent of a special review is to address the specifically identified aspect(s) of concern, and may be triggered when:

• there are reasonable grounds to believe that the health or environmental risks of the product are, or its value is, unacceptable; or
• an OECD member country prohibits all uses of an active ingredient for health or environmental reasons.

The scope of a special review is narrower than a re-evaluation and it only evaluates the aspect(s) of concern that triggered the special review. In 2019, the Pest Control Products Act was amended to clarify that an identified aspect(s) of concern that would otherwise prompt a new special review can also be addressed through an ongoing re-evaluation or special review, reducing the need to duplicate work that is already being done.

Five-year re-evaluation and special review work plan

As part of its commitment to improve transparency, PMRA is publishing interim updates to its five-year Pest Management Regulatory Agency Re-evaluation and Special Review Work Plan 2019–2024 (Re-evaluation Note REV2019-05 and later). This work plan includes the target timelines to publish proposed and final decisions for ongoing re-evaluations and special reviews, as well as the list of anticipated re-evaluation initiations in the next five years.

In 2019–2020, PMRA made good progress on the re-evaluation of older pesticides, supported by additional temporary resources. Completing these large and complex re-evaluations will continue to be a priority, acknowledging that workload continues to increase as new re-evaluations and special reviews are initiated every year. As of March 31, 2020, 118 re-evaluations and special reviews are underway with a requirement to initiate 36 new re-evaluations later in 2020–2021.

Over the past five years, PMRA has completed an average of 25 final decisions per year for re-evaluations and special reviews. Though this is an improvement over previous years, workload continues to increase significantly as new re-evaluations and special reviews are initiated. Based on the projected number of re-evaluation initiations for the next five years, along with the average number of final decisions made per year, work on hand will grow significantly. The Program Renewal section in this Annual Report describes how PMRA is working to address this challenge.

Outreach and stakeholder engagement in re-evaluation and special review programs

PMRA has increased outreach efforts with global regulators such as the United States Environmental Protection Agency, the Australian Pesticides and Veterinary Medicines Authority and the European Food Safety Authority, to build awareness and potential opportunities for post-market collaboration.

PMRA continued its work to provide stakeholders with an opportunity for improved collaboration during re-evaluations. A unit has been dedicated to promote understanding of PMRA’s re-evaluation process and risk assessments. To this end, the unit has been giving presentations to stakeholders and responding to information requests. In addition, work has begun on exploring options to obtain pesticide use information with a goal of collecting the information needed before a re-evaluation begins.