Pesticide regulation in Canada must be more transparent

We urge Canada’s Chief Science Advisor, Dr. Mona Nemer, to investigate the lack of transparency in the research and decision-making process that informs Canada’s pesticide regulation.

In 2015, the Commissioner of the Environment and Sustainable Development’s audit highlighted the need for Health Canada’s Pesticide Management Regulatory Agency (PMRA) to engage in more timely and consistent communication with the public. The reason provided: to ensure that pesticide end-users can make informed decisions about safety and risks. After all, pesticide regulation is about protecting our health and our environment from unacceptable risks posed by pesticides, and public trust rests upon transparency in the regulatory process as well as in the research that is used to support regulatory decisions.

Currently, the PMRA’s risk assessments are heavily supported by data that is unpublished and not peer-reviewed, despite the availability of large bodies of public, peer-reviewed studies. An over reliance on unpublished studies, some of which are, questionably, deemed Confidential Business Information (CBI), is concerning because of the lack of transparency and lack of replicability of results. 

These non-published data can only be accessed from the “Reading Room” during the 60 day public consultation period after a proposed risk assessment decision is made. The supervised Reading Room can only be accessed in Ottawa, at the expense of the person or organization requesting access. Only handwritten notes can be removed from the Reading Room. In our experience with the Reading Room materials, most of these studies are stamped CBI in their entirety, despite the fact that upon access to them, the CBI is only a few words or sentences within whole reports that can easily be eliminated from access. We therefore raise the question on the scope and definition of CBI within the context of the scientific data submitted to the PMRA.

What is not available to citizens and scientists at all are the internal scientific reviews conducted by the PMRA’s scientists, that guide their decisions on which data or scientific studies to include in their assessments. As a result of this lack of transparency, the PMRA’s process of arriving at conclusions for risk assessments is opaque.

Open Science is about transparency, accessibility, sharing and collaboration. The PMRA’s decision-making processes and the resulting pesticide regulatory decisions need to integrate these principles, so that Canadians can trust the Minister of Health, and the PMRA, that they are conducting rigorous risk assessments for the good of our health and the environment.