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Environmental Petition Contact Information: Kris Robinson Name of Group: Environment Hamilton Biedermann Fire Working Group Signature of Petitioner: Title of Petition: Deficiencies in Pest Control Incident Reporting System Pest Management Regulatory Agency Health Canada Relevant Act: Pest Control Products Act and Pest Control Products Incident Reporting Regulations Attachments Theÿsmeÿer, T., and D. Galbraith. 2007. July 2007 Biedermann Packaging Fire: Effects on Cootes Paradise Marsh. Internal Report. Royal Botanical Gardens. Hamilton, Ontario. Background Information: On July 26, 2007 at 1:41 am. a fire broke out at the Biedermann Packaging plant, 36 Head Street, Dundas Ontario. Biedermann Packaging is a pesticide manufacturing plant located next to Spencer Creek and adjacent to a residential neighbourhood. Douse water from the fire drained into the nearby Spencer Creek with devastating results to the environment including the death of between 5 and 15 million living organisms (including large fish) in both Spencer Creek and Cootes Paradise. Spencer Creek, the largest stream in Hamilton, empties into Cootes Paradise. The Royal Botanical Gardens describes Cootes Paradise as: Cootes Paradise Marsh is considered one of the most important waterfowl staging habitats on the lower Great Lakes and the largest nursery habitat for fish in the region. The Government of Ontario has designated Cootes Paradise as a Provincially Significant Class 1 Wetland and an Area of Natural and Scientific Interest (ANSI). It also is listed as an Environmentally Sensitive Area (ESA) in the Hamilton Region. http://www.rbg.ca/pages_sci_conserv/sci_conserv_nature2.html According the new Pest Control Products Act (June 28, 2006), registrants and applicants are required by law to report pesticide incidents as of April, 2007. The Pest Control Products Incident Reporting Regulations states: Under the PCP (section 13), registrants, a company in whose name a pesticide is registered, and applicants for the registration of a pesticide, are now required to report prescribed information (such as incidents) about their pesticides. The Regulations go on to stipulate the time frames for reporting incidents: The IRR prescribe the information received by registrants and applicants that they are required to report and the time frames within which they are to report. …human death; major incidents involving humans that occur in Canada; and major incidents in the environment are to be reported within 15 days. It is noteworthy that “moderate” environmental incidents are to be reported within one month after one month of accumulation and “minor” environmental incidents are to be reported within 2 months following a 12 month accumulation. The fire at Biedermann Packaging Inc. occurred almost 19 months ago. In a search of the Public Registry, Incident Reports, only 2 registrants reported this environmental incident: Home Hardware Stores Ltd., incident report no. 2007-5800 Active ingredients reported: warfarin Spectrum Brands IP Inc, incident report no. 2007-5823 Active ingredients reported: difethianlone, metaldehyde and chlorophacinone In both of these reports the incident is categorized as “major”. On October 31, 2007, The Royal Botanical Gardens released the Working Report: July 2007 Biedermann Packaging Fire: Effects on Cootes Paradise Marsh (attached). The raw data included in this report came directly from the investigation of the Ontario Ministry of the Environment. This report identifies 3 active ingredients believed to have caused the greatest amount of damage. The water was contaminated with a variety of materials, including among others Malathion, Carbaryl, and Diazinon. It is suspected that much of the ecosystem-level damage was caused by Diazinon. (Executive Summary) The ingredients malathion, carbaryl and diazinon are not included in the 2 reports relating to this incident. The Report goes on to describe the devastation of our local environment: During its course downstream the contaminated douse water is expected to have caused the mortality of nearly every invertebrate and small fish in the flow path. This damage to the ecosystem includes millions of aquatic invertebrates of most species, as well as millions of fry and fingerling fish hatched this year. The aquatic invertebrates form the base of the food web, necessary food for most small fish species and many bird species. (Executive Summary) Given the devastation of Spencer Creek and Cootes Paradise it is imperative that the federal agencies responsible monitor the active ingredients involved in pesticide incidents. According to the Pest Management Regulatory Agency’s website (Fact Sheet on Reporting Pesticide Incidents): The database will be regularly searched for any type of pattern related to a specific pesticide. If the result of a search indicates that there is a trend, such as multiple incidents for a particular pesticide or a serious effect, Health Canada will evaluate the information in conjunction with scientific literature. The Regulations describe the benefits of the requirement to report incidents: The Minister of Health’s mandate under the PCPA is to prevent unacceptable risks to people and the environment from the use of pesticides. It is important that PMRA has access to timely postregistration information regarding incidents related to pesticides. In order to ensure that the risks of registered pesticides continue to be acceptable, PMRA must be aware of, and must evaluate, new information that could cause their registration to be amended or cancelled. (emphasis added) The point of the incident reporting system is to monitor these pesticides for unacceptable risks. Petition Questions / Requests: These questions are directed to Health Canada and the Pest Management Regulatory Agencies and any other responsible department. 1. Why have the registrants of malathion, carbaryl and diazinon not filed an incident report? Will the appropriate department determine the responsible registrants and contact them to request that a report be filed as required by law? 2. In a search of the database, Biedermann Packaging Inc. holds a registration for the ingredient carbaryl (Registration No. 10711). Again, this ingredient was not reported as being involved in an incident. Will the appropriate department ensure that this active ingredient is included in the database as contributing to an environmental incident? 3. The reporting of pesticide incidents must be enforced if Health Canada is to use this database as a source of information to determine unacceptable risks and trends such as a serious effect of a given active ingredient. Will Health Canada or other responsible departments examine the use and incidents of malathion, carbaryl and, particularly, diazinon to determine if these active ingredients should continue to be registered, available and sold in Canada? The Objectives: 1. As the Incident Reporting system is an important mechanism for the federal departments involved to evaluate and monitor the registered ingredients, compliance must be enforced. Will the appropriate federal departments ensure that the registrants responsible for malathion, carbaryl and diazinon file an incident report immediately? 2. The three ingredients identified by the authors of the Working Report: July 2007 Biedermann Packaging Fire: Effects on Cootes Paradise Marsh, namely, malathion, carbaryl and diazinon, need to be re-evaluated in terms of their risks against their benefits. In our opinion, the risks far outweigh the benefits. Will the appropriate federal departments undertake a re-evaluation of the abovementioned active ingredients?