A proposed change to tank-mix labelling requirements makes little sense and would unnecessarily hurt farmers, say grain groups.
“Our biggest concern with this regulatory proposal is that it would take immediate effect… and could make some current tank mixes that are being used illegal, for all intents and purposes,” said Shannon Sereda, government relations and policy manager for Alberta Wheat and Alberta Barley.
“It could potentially make unavailable to farmers certain mixes that they’re using on a regular basis.”
The two commissions, along with the Grain Growers of Canada, have sounded an alarm with the Pest Management Regulatory Agency (PMRA) about a proposed regulation that states “if a label contains no guidance related to tank mixing, then tank mixes will not be permitted.”
That’s not the way the current guidelines have worked since they were brought into effect in 2009, said Sereda. Under those guidelines, farmers could use unlabelled tank mixes of pest control products within the registered use pattern for each tank-mix partner.
If that were to change under the new proposal, she said, producers would have less flexible pest control options and have to make more passes in a field.
“Tank mixes are widely used in cereals,” said Sereda. “It provides some flexibility for farmers to be able to use products in a mix.”
And going through a regulatory process to amend the labels would not only be costly, but lengthy.
“Our concern, of course, is that the PMRA is already very backlogged and under-resourced when it comes to the existing and cyclical re-evaluation process that’s in place,” she said.
“We worry about how long it would take for any labelling amendment to actually take effect and what kind of resources it would draw away from the PMRA.”
And the concern is not because farmers don’t see the value the agency provides as a regulator, she added.
“(Farmers) understand the need to adhere to a science-based approach because our reputation is staked on the safety of our grains.”
But the proposed change appears to be administrative rather than based on any specific safety concerns.
“Farmers have been using these products for over a decade now under the existing guidelines, and there hasn’t been any risk or safety concerns identified,” said Sereda.
“Their role as a regulator is around risk to the environment and to human health, and in this case, it doesn’t appear that there has been any detection of risk for the usage of these tank mixes. It’s simply a novel interpretation of legislation that hasn’t changed in many years.
“We worry that they maybe don’t understand the implications of this fully.”
That view was echoed by Grain Growers of Canada president Jeff Nielsen in his letter to the agency.
“Until now, the PMRA’s interpretation of the Pest Control Products Act has allowed the use of tank mixes that are not specifically excluded on approved labels, as long as the directions on each individual label are otherwise followed,” the Olds-area producer wrote. “This has stood the test of time and should be reaffirmed.”
The PMRA should reconsider the proposed changes and adhere to the guidelines that have been in place since 2009, said Sereda.
“That’s consistent with other jurisdictions — the U.S. allows flexible labelling on registered tank-mix partners as well. So we’d like to see the guidelines stay in place.”
Farmers who are concerned about the proposed changes should contact their MLAs and MPs, she said.
“We have raised the issue with our provincial minister as well, and we’ll continue to monitor and investigate what the potential implications could be,” she said. “But at this point, we don’t really have any timelines on when the decision is going to be made.”