Reports and Submissions
September 8, 2023
PMRA Notice of Intent: Strengthening the regulation of pest control products in Canada
In the summer of 2023, Health Canada proposed four areas of regulatory amendments to the Pest Control Products Regulations. This included:
increased public access to confidential test data;
increased transparency for maximum residue limit (MRL) applications for imported food products;
explicit authority for the Minister of Health to require the submission of cumulative environmental effects where information and methodology are available; and
strengthened consideration of species at risk in risk assessments by giving the Minister the explicit authority to require the submission of available information on species at risk.
In response, this submission emphasizes that Canada’s science-based, regulatory framework for pesticides is among the best in the world and already addresses several of the transformation objectives proposed by Health Canada through its operation. SaskCrops remains supportive of a fully transparent process and notes that it is important that any transformative processes do not draw scarce PMRA resources away from core PMRA work making crop protection tools available to farmers.
August 4, 2023
Finance Canada’s Pre-Budget Submissions
SaskCrops continues to submit annually to Finance Canada’s federal pre-budget consultations. The SaskCrops submissions emphasize the need for the government to acknowledge Saskatchewan’s annual crop producers’ contributions to the Canadian economy, global food security, and emissions reduction. The submissions also draw attention to the need for the government to meaningfully and constructively encourage agricultural innovation through increased and accelerated investment in research that will enable primary agricultural producers to lower their carbon footprint and increase their capacity to competitively meet Canadian and global demand for their products, both of which are stated goals and targeted objectives of the government.
March 31, 2023
Agriculture and Agri-Food Canada’s Sustainable Agriculture Strategy Consultation
AAFC articulated an overarching goal of reducing absolute GHG emissions and ultimately reaching net-zero emissions by 2050, while finding ways to increase yields and economic growth. More specific concurrent and possibly conflicting targeted time frames for large increases in the value of national agricultural production and exports (which will necessarily include increases in Saskatchewan production and exports) as well as a targeted 30 per cent reduction in fertilizer emissions have been put forward. Given the short timeframes for achieving these targets (2028 and 2030 respectively), this presents significant challenges for farmers.
August 31, 2022
Agriculture and Agri-Food Canada’s Fertilizer Emissions Reduction Target Consultation
This submission, in collaboration with the Agricultural Producers Association of Saskatchewan (APAS), details three key areas of concern about AAFC’s fertilizer emissions reduction target including ‘Developing a Strategic Approach to Meeting the Fertilizer Emissions Target’, ‘Data, Reporting and Measurement’ and ‘Innovation and Transformation Opportunities’.