A/HRC/45/12/Add.3
insufficient information available so far to assess whether or not there was a violation of the
Convention. This sentence should be constrained to just the Philippines case.
Comments from Health Canada
Para 8, last sentence, comments:
Not all chemical regulation in Canada falls under CEPA. To improve accuracy for pesticide
regulation, there should be a mention in this paragraph on the Pest Control Products Act –
and the framework it provides for the protection of human health and the environment.
Jointly managed by Health Canada and Environment and Climate Change Canada, the
Chemicals Management Plan (CMP) brings all existing federal chemical programs together
under a single strategy. This integrated approach allows the Government of Canada to address
various routes of exposure to chronic and acute hazardous substances. It also enables use of
the most appropriate management tools among a full suite of federal laws, which include the
Canadian Environmental Protection Act, 1999 (CEPA), the Canada Consumer Product
Safety Act (CCPSA), the Food and Drugs Act (F&DA), the Pest Control Products Act
(PCPA), the Fisheries Act and the Forestry Act
Para 22, last sentence, comments:
This number was compiled by the David Suzuki Foundation prior to the coming into
force of Canada’s Pest Control Products Incident Reporting Regulations in 2007.
Between 2007 and 2017, over 20 000 incidents were reported to Health Canada’s
Pest Management Regulatory Agency (PMRA), the majority of which were
domestic animal incidents of minor to moderate severity. In 2017-18, 198 human
incident reports were submitted to Health Canada’s PMRA.
https://www.canada.ca/en/health-canada/services/consumer-product-safety/reportspublications/pesticides-pest-management/corporate-plans-reports/report-pesticideincidents.html
Para 23, 1st sentence, comments:
It would be good to have a reference to further support this statement or specify which
hazardous substance is being referred to here—unless this is meant to only speak to air
pollutants (i.e. PM2.5).
Para 25, last sentence, comments:
All products currently registered and used in Canada must have acceptable risk. Special
review provisions exist where if all uses of an active ingredient are banned in an OECD
country, Health Canada must proceed with a Special Review. Also, at any time, if the
Minister of Health becomes aware of information that would indicate potential unacceptable
health or environmental risk, a Special Review can be initiated.
https://www.canada.ca/en/health-canada/services/consumer-product-safety/reportspublications/pesticides-pest-management/policies-guidelines/regulatorydirective/2014/dir2014-01-approach-special-reviews-dir2014-01.html
Para 25, 1st sentence, comments:
In reference to “unlike occupational laws”, it is unclear what occupational laws do not require
exposure to be considered or require risk assessments to be completed in Canada.
Para 30, 2nd sentence, comments:
Children and infants are considered as a specific vulnerable sub-population in the risk
assessments conducted by Health Canada for pest control products. A pest control product
will only be registered if that risk is acceptable, including the risk of Pest Control Products
used on food.
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