January 31, 2002
Regional Councillor Diane Humeniuk
Chair, Pesticide Reduction Task Force
Dear Councillor Humeniuk,
I regret that due to a prior commitment I am unable to attend this
meeting. I would like to commend the Region on its initiative to develop
a set of Guidelines, and am pleased to see that it is intended that they
will become Regional Policy.
I would also like to commend the staff for their excellent background
report, which I intend to share with my colleagues in CAPE. The review
of the health effects points to a wide range of health effects and to
weaknesses in current and past testing procedures, resulting in the
appropriate conclusion that “limitations in scientific knowledge lead to
an overall under estimation of potential adverse effects”. This in turn
makes a very strong case for the application of the precautionary
principle to our use of pesticides; the protection of the health of the
population from potential harm should be the priority concern guiding
public policy, especially with respect to non-essential use of these
toxic substances merely for aesthetic or cosmetic purposes. It would be
better if we learned to live with dandelions and spiders or other plants
and insects that we don’t like – or found other ways of managing them –
than that we be forced to live with the often unknown but potentially
health-damaging effects of pesticides.
With that in mind, I have the following comments:
- Since non-essential use of pesticides refers to the use of these
chemicals in situations that do not adversely affect public health, food
production, forestry uses or public safety, the goal should be revised
“the eventual elimination in the non-essential use of pesticides and
a substantial reduction in the essential use of pesticides on lands
owned by the Region of York”.
In other words, if the use of these hazardous substances is non-essential, why would we not apply the precautionary principle and simply eliminate their use. Where their use is essential, we should
still be able to substantailly reduce their use through IPM, and of
course we should always use reduced risk products in those situations.
In fact, the elimination of non-essential use of pesticides is stated as
a strategy in Section 3.3 of the Draft Guidelines, and should remain so.
- I would add the following to Section 3.3
(f) Using reduced risk products when a pesticide is deemed necessary
- In Section 3.5, I have no quarrel with a goal (more properly here, an
objective) of “substantially reducing the non-essential use of
pesticides by 2003”, as long as this is understood as an objective in
line with the longer range goal and strategy of eliminating their use. A
substantial reduction by 2003 would be a good first step in protecting
the health of the citizens of York Region.
Thank you for the opportunity to provide input to this process, I regret
that I was unable to be present in person.
Dr Trevor Hancock
Chair of the Board