Pest Control Products for
Specialty Crops
Information in this page may be out of date and is currently being updated.
The registration of pest control products and the interpretation of pest control product labels can be a confusing and frustrating aspect of producing low acreage specialty crops. Many growers who are accustomed to larger acreage crops with multiple control options are surprised to learn how few products are registered on many specialty crops. This discovery is often made only after significant damage is noticed on the crop, when it is too late to implement non-chemical controls. This is why it is worth taking the time to research and identify pest control options prior to planting the crop in the field. Unfortunately, it is not always easy to identify which products are registered on a given crop. The following document is designed to familiarize specialty crop growers with some of the regulations around pest control products in Ontario, and provide some guidance in determining what products are registered on their crops.
USING PEST CONTROL PRODUCTS IN ONTARIO
Federal Regulation of Pest Control Products
Before a pest control product can be sold or used in Ontario, it must be registered under the federal Pest Control Products Act (PCP Act) and be classified under the provincial Pesticides Act. The Pest Management Regulatory Agency (PMRA) of Health Canada registers pest control products for use in Canada following an evaluation of scientific data to ensure that the product has merit and value. It also ensures that the human health and environmental risks associated with its proposed use are acceptable.
Any commercial product used for the purpose of controlling a pest on a crop in Canada must be registered under the PCP Act. This applies even to reduced risk and low risk products such as biopesticides and insecticidal soaps. Application of an unregistered pest control product to a crop is illegal.
Pest control product use violations can be detected by testing for residues, which are the pest control product itself and its breakdown products that remain on the plant after a pest control product application. Pest control products applied at the labelled rate will take a certain amount of time to reach levels that are determined to be safe. Very low pest control product residues are legally permitted on crops, and each pest control product has a specific amount of residue permitted, known as the maximum residue limit (or MRL). Pest control product residues above the MRL can result from not waiting the required number of days between application and harvest, or from using rates above what is approved for that crop on the product label. Surveys demonstrate that most products leave no residues and many biopesticides are exempt from the MRL requirement because they are regarded as very safe.
In Canada, some produce is randomly selected from points of sale to be tested for pest control product residues. If residues of unregistered pest control products or residues of registered products exceeding the MRL are detected, applicators or growers may face consequences including monetary fines, recall of their product and closer inspection of the farm operation's pest control product applications. For growers following a CanadaGAP On-Farm Food Safety Program, applications of unregistered pest control products results in an automatic fail during audits. Furthermore, application of an unregistered product could result in crop injury or failure due to possible phytotoxicity of the untested product against the crop.
Be aware that every country has a different system for registering pest control products, with the result that product labels can differ considerably between countries. A product may be registered on a wider variety of crops in other countries than in Canada, for different pests, at different rates, or may be registered in some countries but not in Canada. Many growers of specialty crops seek out growers or extension workers in other countries where the crop is grown on a larger scale for production information and advice. These foreign growers may use or suggest products that may not be registered on that crop in Canada. For example, many of the pest control products that are regularly used on sweet potatoes and hops in the United States are not registered on these crops in Canada, and some products used extensively by organic growers in other countries (e.g. the insecticide Neem) are not registered here.
Pest Control Product Labels
All registered pest control products have an associated product label. This is more than the just the sticker label on the product container. Pest control product labels are documents, approved during the registration process, which outline the conditions of registration. The pest control product label is a legal document. It prescribes how the pest control product can be legally used. Off-label use is prohibited. It is against the law to use the pest control product in any other way or on any other crop or pest than as specified on the label. The user is responsible for ensuring that they are complying with all directions stipulated on the most current product label.
Read the most current pest control product label thoroughly before application. The label provides important information, such as:
- Active ingredient (the ingredient that works to control the pest) and the amount of it, by weight, volume or percentage, contained in the product (known as the Guarantee).
- Trade name - the manufacturer's common name for a product. Pest control products with the same active ingredient can have multiple trade names
- Formulation - The mixture of the active with other compounds (formulants) that assist in the application, storage, safety, dispersal, etc. of the active ingredient. Typically the formulation is indicated by letters. These include:
- EC, E = emulsifiable concentrates
- WP = wettable powders
- SP, SL = soluble powder or liquid concentrate
- G, WDG = granule, water dispersible granules
- FL = flowable
- P = Pellet
- RTU = Ready-to-use
- Directions for use (rates of application, crops it can be used on, target pests, crop rotation restrictions, total number of applications, droplet size/nozzle type, application equipment, timing and ideal weather conditions)
- Personal protective equipment (PPE) - safety gear that must be worn by people who handle, transport, apply or dispose of pest control products, or sometimes, by people who must enter treated fields. Examples include, long sleeve shirts, pants, chemical resistant gloves, respirators, eye protection and others. This equipment must be worn as specified on the label.
- hazard symbols and warnings
- Restricted Entry Intervals (REI) - The REI, also referred to as Re-Entry Interval (REI), is the period of time following a pest control product application during which workers must not enter the treatment area. This allows any pest control product residue and vapours to dissipate from the treatment location (e.g., field), preventing the possibility of inadvertent pest control product exposure. The PMRA reviews each pest control product to determine whether the label should include a specific restricted entry interval. If the restricted entry interval is not stated on the label for agricultural crops, assume that the REI is 12 hours. Some pest control products have labels that carry a warning about working in treated crops and provide specific PPE requirements. Follow the label recommendations.
- Days to harvest for food crops (pre-harvest intervals, pregrazing and feeding intervals) - These intervals state the minimum time that must pass between the last pest control product application and the harvesting of the crop, or the grazing or cutting of the crop for livestock feed. If you harvest a crop before the pre-harvest interval (PHI) has passed, there may be pest control product residues in excess of the maximum residue limits (MRLs) set by PMRA. "Up to the day of harvest" means the same as 0 days PHI; however, the REI may be more restrictive (i.e., a 12-hr restricted entry interval) and must be observed for harvesting that occurs on the day of application.
- Buffer Zones - Buffer zones, or no spray areas, are areas left untreated to protect an adjacent sensitive area, such as sensitive terrestrial and aquatic habitats. Generally, a buffer zone is the downwind distance separating the point of direct pest control product application from the nearest boundary of a sensitive habitat. Leave a suitable buffer zone between the treatment area and adjacent sensitive areas. Buffer zones may vary depending on the method of application (i.e. aerial, field boom, air blast). Check the pest control product labels for buffer zone requirements.
- precautionary statements
- steps to be taken in case of an accident
- disposal
Labels for all registered pest control products are under Search Pesticide Labels on the PMRA website at www.pmra-arla.gc.ca. Ensure you have the most current label and are aware of any re-evaluation decisions.
Pest Control Product Re-evaluations
The PMRA also re-evaluates existing registered pest control products to determine whether today's health and environmental protection standards are still met when following the label directions. Outcomes of a re-evaluation can be:
- no change in the registration
- label amendments (i.e., changes to personal protective equipment requirements, restricted entry intervals and buffer zones)
- modifications to existing maximum residue limits (MRLs)
- elimination or phasing-out of certain uses or formulations
- no further acceptance of the registration
Re-evaluation decisions often result in changes to the label. Crops previously on the label may be removed, or the labelled directions may be changed, such as a reduced number of maximum applications allowed. It is the user's responsibility to ensure that they are using and abiding by the current product label. Before each growing season, it is a good idea to check the PMRA Label Search, registrant (company) websites or OMAF and MRA publications for possible changes to product labels.
Regulation of Pest Control Products in Ontario
All pest control product must be federally registered for use in Canada, however provinces and municipalities may impose further levels of regulation. The Ministry of the Environment (MOE) is responsible for regulating the sale, use, transportation, storage and disposal of pest control products in Ontario. Ontario regulates pest control products through legislation that places appropriate education, licensing and/or permit requirements on their use. All pest control products must be used in accordance with requirements under the Pesticides Act and Regulation 63/09, which are available on the e-laws website at www.e-laws.gov.on.ca or by calling Service Ontario at 1-800-668-9938 or 416-326-5300.
Before a federally registered pest control product can be sold or used in Ontario, it must be classified under the provincial Pesticides Act. The Ontario pest control product classification system consists of 11 classes. The Ontario Pesticides Advisory Committee (OPAC) is responsible for reviewing and recommending to the MOE the classification of pest control products. Pest control products are classified on the basis of their toxicity, environmental or health hazard, persistence of the active ingredient or its metabolites, concentration, usage, federal class and registration status. This classification system provides the basis for regulating the distribution, availability and use of pest control products in Ontario. Once approved by the MOE, classified products are posted on the MOE website at www.ontario.ca/environment.
Biological and Homemade Pest Control Products
Some pest control products are based on what some consider to be "alternative" active ingredients, such as microorganims or pheromones (biopesticides) or other compounds such as vinegar, oil or composted manure. Although apparently benign, commercial growers are reminded that the Pest Control Products Act governs any product applied to a crop for pest control. Biopesticides based on microorganisms are regulated by this act and must be registered for legal use in Canada. The only exceptions are invertebrate biological control agents such as parasites, predators and nematodes, which do not need to be registered by the PMRA for use.
There are many internet sites or other sources which provide "recipes" for homemade pest control products that claim to control a wide variety of pests. Preparation and use of such products may pose a number of safety risks, both personal and environmental. The PMRA's registration process involves the scientific evaluation of each product to ensure they meet health and safety standards, that the product works as claimed, and to ensure there is a product label which provides information on how to safely and effectively use the product. Homemade pest control products have not undergone this evaluation process and consequently, there is no way of knowing whether they will work as planned and/or be safe to you, your crop and the environment. For example, the preparation of homemade products may expose you to harmful toxins, or an untested homemade product may actually damage the plant you are trying to protect.
Additionally, misuse of homemade products may lead to food safety concerns on a crop if improperly prepared. For example, compost teas that are not properly manufactured may have unacceptably high levels of pathogenic bacteria.
Organic Pest Control Products
Organic growers face additional restrictions around pest control products. In addition to federal and provincial registration requirements, organic products must also be approved for use on a crop by a grower's certifying body. It is imperative for organic growers to check with their certifying body to determine whether a product is acceptable. A listing of a product as being organically acceptable does not supersede the requirement for federal registration on your crop - if the product does not list the crop on its label, it is illegal to apply it on the crop, even if it is organically acceptable.
One other important note is that not all products containing organically acceptable active ingredients are acceptable for organic use. Sometimes the products used to formulate the active ingredient are not acceptable for organic production. For example, Bacillus thuringiensis and copper are active ingredients commonly used in organic agriculture, however not all products containing these actives are acceptable for use on organic crops.
Pest Control Product Registration and Specialty Crops
The registration of pest control products in Canada is a detailed, multi-step process that can take many years. Detailed data must be provided, which is reviewed by several teams of scientists at the PMRA. Data that must be provided includes: toxicological studies to aid in the assessment of potential human health effects; residue data for setting maximum residue limits; crop tolerance studies to determine if the product has potential to harm the crop; and efficacy studies to demonstrate that the product can actually control the target pest. Collection of this data can be costly, making registration of pest control products very expensive. Consequently, it may not be economically viable for a company to register a product on a low acreage crop, where sales of the product may not support the cost of submission.
To address this, a minor use program is in place in Canada, administered by the PMRA to aid in expanding labels of products already registered on a major crop in Canada to other crops. Products which are already labelled in Canada on another major or minor crop are eligible for the User Requested Minor Use Label Expansion (URMULE) program. URMULEs can be sponsored by Agriculture and Agri-Food Canada's Pest Management Centre, grower organizations, crop specialists or other persons. All non-AAFC URMULE proposals must be reviewed and approved by a provincial minor use coordinator, who acts as a liaison between the PMRA and sponsors. More detailed information on the Minor Use program and its benefits to Ontario growers, can be found on the OMAFRA website.
Although some specialty crops are included in the Minor Use process, they must compete for limited minor use funds and resources with larger acreage horticultural crops. For this reason, specialty crops are rarely the sole target of a Minor Use Label Expansion submission. This does not mean, however, that pest control products are never registered on specialty crops.
