1999 Report of the Commissioner of the Environment and Sustainable Development

1999 Report—Chapter 3

Exhibit 3.9—Special Review of Carbofuran

This case study illustrates the lack of a clear process, criteria for determining what constitutes "unacceptable risk" as specified by the legislation, and timelines for the special review of pesticides.

Carbofuran is an insecticide, first registered in Canada in 1969. It is popular and economical, and is used in granular and liquid forms on a wide variety of crops. Birds are killed by carbofuran when they eat the granular form (mistaking it for dietary grit) and when they eat insects or small animals that have been exposed to carbofuran. Carbofuran is classified as extremely hazardous to humans and its application requires use of protective equipment and measures.

The Canadian Wildlife Service (CWS) first raised concerns in 1987 about the effect of carbofuran on birds, and especially the burrowing owl, an endangered species. Following deliberations, in 1989 Canadian regulators put in place mitigation measures intended to protect the burrows of burrowing owls. The use of carbofuran otherwise continued.

The CWS remained concerned about the effects of carbofuran on other birds and wildlife. There were reports of major bird kills in both Canada and the U.S. in fields that had been sprayed with carbofuran. For example, in 1984 more than 2,000 Lapland longspurs were killed after ingesting carbofuran as they were crossing the prairies at canola-seeding time.

In 1990, Agriculture Canada (responsible at the time for pesticide regulation) announced a special review of carbofuran, to be concluded in 1992. The expected completion date was subsequently moved to 1994, and then to 1995.

As part of the special review process, in 1991 the CWS completed an assessment of the effects of carbofuran on birds and other wildlife. In 1993, an Agriculture Canada report acknowledged the assessment's conclusion on the extreme hazard to wildlife, especially birds. It said that adequate mitigation of the hazard did not appear possible and that the extensive impact on birds would continue if granular formulations remained on the market. However, the Department did not withdraw approval for any of the carbofuran formulations. It debated with CWS over reductions in the use of carbofuran on a crop-by-crop and product-by-product basis.

By December 1995, the newly created Pest Management Regulatory Agency had negotiated with the manufacturer the removal of two of three granular formulations and certain uses of the liquid formulation. The PMRA required that the manufacturer conduct a bird monitoring study for the remaining granular formulation. Based on that study, the PMRA estimated that 109,000 to 958,000 birds in Canada were killed by carbofuran each year.

A decision was announced in December 1998 that all uses of carbofuran in granular formulation would be de-registered in 1999. Use of the liquid formulation on corn and other produce continues.