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Please Comment on McGuinty’s Cosmetic Pesticide Ban Regulations

The Provincial government has just released the final list of products that will be banned under its Cosmetic Pesticide Ban Act.

Here is the website to view the information that has been proposed.

http://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTA0OTk2&statusId=MTU3MjYz&language=en

Essentially, after reading all the details:

1. there will be no products available to effectively and economically control weeds in lawns.
2. there will not be effective and economical methods to control white grubs.
3. there will not be an effective way to control crabgrass once it has sprouted.
4. there will not be effective products to control weeds and grasses that sprout up in your driveways and patios.

Turf King-Hamilton does not support the draft Regulations as currently written.

• The regulations do not allow solutions that will prevent the destruction of Ontario's lawns and landscapes from damaging pest infestations.

• The regulations do not create a level playing field. Dual use products will be available on the retail shelf.

Damaging Insect Infestations

• Viable, effective alternative solutions do not exist to control the wide range of insect pests threatening our green spaces. If they exist, what are they?

• While some may argue that a few weeds in a lawn are deemed cosmetic and the use of a traditional herbicide to control them is non-essential, there can be no argument that denies that damaging insect infestations risk the destruction of our lawns and landscapes, and goes beyond being cosmetic.

SOLUTIONS

1. Provide Regulations to allow the prescribed use, by licensed professionals, of two otherwise banned pesticides on the Class 9 list.

• Granular Merit containing Imidacloprid (for grub control). Granular Merit is less toxic than table salt.

• Deltamethrin (for chinch bug and sod webworm control)

This prescribed use would be conditional upon requirements as outlined in the Landscape Ontario document “Prescribed Use Compliance Criteria and Protocols” previously submitted to the Ministry of Environment. These conditions include:

- IPM Accreditation (similar to what the draft Regulations outline for golf courses) and the operational requirements associated with it.

- Insect infestations must exceed threshold levels, as currently outlined by Ministry of Agriculture Food and Rural Affairs, before the Class 9 pesticide can be considered for use.

2. Remove pyrethrins from the Class 9 banned list.

• Pyrethrins are currently exempt under all Ontario pesticide by-laws.

3. Remove products that are on Health Canada's Reduced Risk list from the Class 9 banned list.

• Inclusion of Health Reduced Risk products on the Ontario banned list will be a road block to the future development and introduction of reduced risk products in Ontario.

• This legislation must provide clear criteria, and not an arbitrary decision framework. This legislation must not hinder the development of low risk, alternative products. As currently written, it will.

4. Allow for a phase-in of Section 17 of the Regulations (Class 9 banned list).

• Given that Regulations will not be finalized until well into the New Year, a phasing-in period of at least one year is required to allow business to plan, price and market.

• Allowing a phase-in will prevent the needless environmental impact of pesticide waste disposal. The Health Canada amendment of pesticide labeling customarily involves a reasonable phase-in period to allow products with expired labels to be used accordingly. Municipal pesticide by-laws typically involve a phase-in period.

• The availability or development of alternative products requires a phase-in period.

Here is the website to submit your comment. Please do so before December 22/2008

Ideally, put your comments in your own words as that will carry more weight.

I will tell you that when the legislation was first proposed, many people sent in a form comment that simply said they were opposed. So the government said this many people agreed with the proposed legislation and ignored the numerically smaller but detailed comments of those who opposed it. So, it is better to comment with your opposition (even if it is a form reply) than to do nothing.

http://www.ebr.gov.on.ca/ERS-WEB-External/searchComment.do?actionType=add¬iceId=MTA0OTk2&statusId=MTU3MjYz¬iceHeaderIdString=MTA0OTk2

Recommended comments.

• I am a homeowner and voter in the municipality of ___________
• I oppose the removal of Merit insecticide as a tool to prevent damage to my lawn from insects such as white grubs.
• I oppose the removal of 2,4-D herbicide products used to prevent weed damage to my lawn and to potentially lower my property value.
• Licensed and IPM trained Companies should be allowed to treat when infestations occur.
• What happened to the 3 year phase in promised when the bill was announced? Delay implementation at least until the spring of 2010.
• A further phase-in period for Class 9 pesticides (banned ingredients)
• The addition to Class 11 (certain biopesticides and naturally occurring pesticides) of anything classified as a Reduced Risk Pesticide by the PMRA

If you have any questions please feel free to email me at This e-mail address is being protected from spambots. You need JavaScript enabled to view it. or call me at 905.318.6677. Visit our website .

Note on Merit Granular Grub Preventer

How are you to keep up the value of our homes when there will not be any effective means to control insects on your lawn. This does not make sense. Lawn care companies cannot use Merit to prevent grubs from damaging your lawn. Granular Merit for lawns contains 0.5% Imidacloprid. and it is not allowed to be used on the lawn.

See http://pr-rp.pmra-arla.gc.ca/PR_SOL/pr_web.ve1?p_ukid=10856 for details.

In the meantime, on page 30 of the list of pesticides in Class 6 , (That class of pesticides that can be sold to anyone by anyone, see the Table in section 95 of the draft legislation ) contains a number of cat and dog flea products that contain the same Imidacloprid. Guess what the concentration is in the Flea product - 9.1% imidacloprid.

Directions on the label warning children to refrain from touching the pet until the product dries? But after that you can pet that cat immediately. No warning sign to keep off for 48 hours??

Where is the consistency? Merit 0.5 granular should be on the list of allowed products. It is less toxic than table salt.

(Merit granular LD50 is 4820mg/kg) http://www.bayeres.ca/Products/Lawn-Care/MERIT/Labels-and-MSDS/Merit-0-5G-MSDS-2006-(1).aspx

Table salt LD 50 is 3000 mg/kg (lower LD50 = more poisonous)

See http://www.ene.gov.on.ca/envision/env_reg/er/documents/2008/Pesticides010-5080/010-5080%206.pdf

Copied from page 30

275. 25127 BAYER ADVANTAGE 55 FLEA ADULTICIDE FOR DOGS 11-25 KG IMIDACLOPRID

276. 25128 BAYER ADVANTAGE 9 FLEA ADULTICIDE FOR CATS & KITTENS 4KG & UNDER IMIDACLOPRID

277. 25129 BAYER ADVANTAGE 18 FLEA ADULTICIDE FOR CATS OVER 4 KG IMIDACLOPRID

278. 25130 BAYER ADVANTAGE 10 FLEA ADULTICIDE FOR DOGS & PUPPIES 4.5 KG AND UNDER IMIDACLOPRID

279. 25131 BAYER ADVANTAGE 100 FLEA ADULTICIDE FOR DOGS OVER 25 KG IMIDACLOPRID

280. 25132 BAYER ADVANTAGE 20 FLEA ADULTICIDE FOR DOGS 4.6-11 KG IMIDACLOPRID

News Release http://www.ene.gov.on.ca/en/news/2008/110701.php

For immediate release November 7, 2008

TAKING NEXT STEPS IN PESTICIDE BAN

McGuinty Government Asks Ontarians To Comment On Ban Details

NEWS

The province is asking Ontarians to comment on the specifics of its cosmetic pesticides ban.

In particular, the public is being asked to comment on:

• the proposed lists of pesticides (products and ingredients) banned for use and banned or restricted for sale,

• the rules for pesticide use on golf courses,

• the exceptions to the ban for public health or safety reasons.

A draft regulation containing the specifics is posted on the Environmental Registry at www.ebr.gov.on.ca (#010-5080), and can also be found on the ministry's website at www.ene.gov.on.ca/en/land/pesticides/index.php . Comments will be accepted until December 22, 2008. The government will consider all comments before finalizing the regulation, expected to occur in spring 2009.

QUICK FACTS

• The Cosmetic Pesticides Ban Act, passed in June, amended the Pesticides Act, which sets out the rules for the transportation, storage and disposal of pesticides..

“The easiest thing to find on God's green earth is someone to tell you all the things you cannot do.”
Richard M. DeVos