Regina PesticidePolicy

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The Need for a Pesticide Reduction Bylaw in Urban Settings

Protecting Public Health and the Environment


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TABLE OF CONTENTSEXECUTIVE SUMMARY 1

1. INTRODUCTION.. 11.1. General context... 11.2. Decision request...... 21.3. Problem definition....... 3

1.3.1.Statistics on cosmetic pesticide use31.3.2.Determinants of cosmetic pesticide use61.3.3.City of Regina response to cosmetic pesticide use.......... 7

2. JUSTIFICATION FOR A PESTICIDE REDUCTION BYLAW... 72.1. Risk to human health 72.2. Risk to environment102.3. Response from different jurisdictions to cosmetic pesticides. 122.4. Weaknesses in pesticide regulation. 132.5. Precautionary principle142.6. Public support. 152.7. Government priority. 163. POLICY ANALYSIS. 163.1. Policy alternatives.. 16

3.1.1. Public education and awareness.. 17

3.1.2. Bylaw for vulnerable populations... 183.1.3. City-wide bylaw...18

3.2. Criteria for comparing policy alternatives..193.3. Comparison of policy alternatives19


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EXECUTIVE SUMMARY

The use of cosmetic pesticides in urban areas is detrimental to human

health, contributes to environmental contamination and threatens sustainability.

In light of the foregoing effects, environmental scientists, public health

researchers, clinicians and both the private and the public sectors have

expressed concerns, calling for action from the government. 171 municipalities

and 5 provinces have responded by enacting pesticide reduction bylaws and

legislation respectively which is benefitting close to 24 million Canadians from

unwanted exposure to synthetic lawn and garden pesticides.

Paradoxically, there is neither legislation in Saskatchewan nor a bylaw in

Regina despite the fact that both jurisdictions recorded the highest household

use of pesticides in garden and lawns in Canada. As the evidence linking

pesticides and illnesses grows, and based on the precautionary principle, a

decision to reconsider and enact a bylaw is being requested from the City of

Regina because it has the authority and responsibility to adopt such a bylaw

restricting cosmetic pesticide use.This report suggests three policy options, namely: public education and

awareness; a bylaw for vulnerable populations; and a city-wide bylaw.


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destroying, repelling or mitigating a pest (Saskatchewan PCPA, 1978). The term

includes insecticides (which kill insects), herbicides (which kill plants), fungicides(which kill fungi and molds), and rodenticides (which kill rodents) (Friis, 2010).

Cosmetic pesticides are those used for lawn, garden and landscape

applications regarded as non-essential for aesthetic appearances only and

not related to the growing of food, agriculturally economical gain or any health

benefits (Cole et al., 2011).

Synthetic pesticides were developed in the 20th century, mainly for use in

warfare a historical reality that underlines their toxicity. Their use has

broadened and now a wide spectrum of pesticides has become omnipresent

in our environment (Arya, 2005). This has led to increased scrutiny of pesticides

as the Canadian public becomes increasingly aware of their negative impacts

on human health and the environment (Gallant et al., 2007).

A significant question for health and environmental policy is how society

should regulate pesticide use to ensure their most effective utility while at the

same time minimizing the hazards and risk to public health and the

environment. (Friis, 2010).


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The responsibility to restrict pesticide use by Canadian municipalities was

upheld by the Supreme Court in 2001 and following the pronouncement, theFederal Pest Management Regulatory Agency (PMRA) also acknowledged

the role of municipalities in regulating pesticide use (Cole et al., 2011).

1.3.PROBLEM DEFINITION1.3.1. Statistics on cosmetic pesticide use

The prairie province of Saskatchewan is the greatest user of pesticides in

Canada, accounting for an estimated 36% of total Canadian sales (Brimble et

al., 2005). An overview of the percentage of pesticides sales in different

Canadian provinces is presented in Figure 1 below.

Figure 1: Percent Pesticides Sales by Province, 2001


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Table 1: Households that used pesticides on their lawn or garden, by province,

1994 and 2005

Provinces Used

pesticides

Pesticide users,12005

1994 2005 Pesticides applied as part

of a regular maintenanceschedule2

Pesticides applied

when a problemarose2

percent

Newfoundland and

Labrador

9 21 48 51

Prince Edward

Island

12 14 48 53

Nova Scotia 19 18 50 50

New Brunswick 20 17 45 48Quebec 30 15 55 40

Ontario 34 34 58 42

Manitoba 30 44 41 59

Saskatchewan 37 43 42 57

Alberta 36 39 48 53British Columbia 30 29 45 55

Canada 31 29 52 471. As a percentage of households with a lawn or garden.

2. Some respondents specified a frequency of application other than "part of aregular maintenance schedule" or "when problems arose." This proportion is notincluded here so some row totals may be less than 100 percent. In addition, some

respondents specified both frequencies of application so some row totals may

exceed 100 percent.

Source: Lynch M. F., Hofmann N., 2007

In fact Saskatchewan had the highest household use of pesticides in
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pesticide use in different sectors is presented in Figure 2 below.

Figure 2: Pesticide use intensity by sector


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hectare per year (Parliament of Canada, 2000).

A similar study in Alberta found approximately the same results in whichdomestic use was almost four times the intensity of agricultural use (Pesticide Use

in Alberta, 1998). In 1998, the agriculture sector used 7,589 tons active

ingredients and home and garden only used 72 tons active ingredients

(Pesticide Use in Alberta, 1998). However the intensity of the agricultural use was

only 0.8 kg ai/hectare while home and garden was 3.1 kg ai/hectare (Pesticide

Use in Alberta, 1998). It is therefore evident that pesticide use is more intense in

urban centers putting the population at greater risk of exposure to cosmetic

pesticides.

1.3.2. Determinants of cosmetic pesticide useHomeowner use of cosmetic pesticides is influenced by a multi-faceted

mixture of social and environmental determinants including socioeconomic

status, aesthetic beliefs, attitudes about neighborhood culture or home values,

and a desire to avoid conflict with neighbors. This makes it challenging to

influence at an individual level (Cole et al., 2011).

Intensive consumer marketing of both the ideal of the perfect lawn and of


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1.3.3. City of Regina response to cosmetic pesticide useThe paradox is that neither a provincial nor a municipal bylaw has been

enacted in the province of Saskatchewan nor the City of Regina despite the

fact that household pesticide use in both jurisdictions is one of the highest in

Canada (Statistics Canada 2007; 2009).

In the past, the City of Regina considered a bylaw restricting the use of

cosmetic pesticides but rejected the idea in favor of Integrated Pest

Management (IPM) and the establishment of Pesticide Advisory Committee

(PAC) from key community stakeholders: Regina Health District, Citizen Member,

Industry, Administration, School Boards, and Regina Urban Environment Advisory

Council (City of Regina, 2002).

The PAC had the responsibility of advising the Administration on pesticide

matters such as: public education and awareness, city policy, procedures and

methods, research and evaluation of alternatives to pesticides, monitoring

community behavior and attitudes towards the use of pesticides (City of Regina,

2002).

Recently, three parks (Gordon Park, Al Pickard Park, Queen Elizabeth II

Court) have been designated as pesticide-free with the intention of reducing


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even heart block, coma and death, are primarily linked to acetylcholineblockade (Arya, 2005). Worldwide, approximately 3,000,000 people suffer frompesticide poisoning annually, with 200,000 deaths mainly due to accidental

exposure or intentional ingestion (Arya, 2005). In Canada, there are over 6,000

cases of pesticide poisoning yearly, although experts say that the actual figure is

probably much higher (West Coast Environmental Law, 2006).

Table 2: Effects of acute pesticide poisoning on different organs

ORGANS SYMPTOMS OF ILLNESS

Eyes Tearing, irritation, conjunctivitis

Skin Rash, blistering, burns, sweating, contact dermatitis,jaundice

Nervous system Headache, dizziness, mood disturbances, depression,

stupor, muscle twitching, lack of coordination,seizures, paralysis, loss of consciousness, coma

Respiratory system Sore throat, runny nose, cough, pulmonary edema,difficulty breathing, respiratory failure

Cardiovascular system Cardiac arrhythmiasGastrointestinal tract Nausea, vomiting, diarrhea, abdominal pain

(Source: Adapted from a report prepared for the David Suzuki Foundation.

Healthy Environment, Healthy Canadians Series. By David R. Boyd. Available at

www davidsuzuki org/publications/ /DSF-pesticide-poisoning pdf Accessed
http://www.davidsuzuki.org/publications/.../DSF-pesticide-poisoning.pdfhttp://www.davidsuzuki.org/publications/.../DSF-pesticide-poisoning.pdfhttp://www.davidsuzuki.org/publications/.../DSF-pesticide-poisoning.pdf


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statistically significant association between pesticide exposure and certain types

of cancer (See Table 3) (Arya, 2005).

Table 3: Chronic effects of exposure to pesticides

PESTICIDES ASSOCIATED ADVERSE HEALTH EFFECT

Triazine herbicides Increase breast cancer risk

The herbicide 2,4 D Linked to nonHodgkins lymphoma.

Phenoxy herbicides

and carbamates

Increase lung cancer risk

The herbicides

Glyphosate and

glufosinate

Linked to congenital malformations in developing fetuses

Fungicide Exposure had positive association with dermatitis.

Pesticides Increase the childs risk of developing childhood acute

lymphocytic. Leukemia through exposure during pregnancy

Pyrethrin insecticides Associated with increased risk of Parkinsons disease andchromosomal abnormalities

Long term exposure to

Glyphosatte and

glufosinate pesticideuse.

Associated with diseases such as Parkinsons disease,Alzheimers disease, Amyotrophic lateral sclerosis (ALS)


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to pesticides during pregnancy (Legislative Session, 2011).

Another meta-analysis (Bailey, 2010) looking at home use of pesticidesfound a link between increased risk of childhood leukemia with pest-control

treatments during pregnancy and early childhood years. Furthermore, a study

of a large cohort of children in New York City which examined effects of

pesticides (measured in urine of the pregnant mothers) on neurodevelopment

of children over a number of years, showed some deficits in mental

development following organophosphate exposure during pregnancy in

newborns, babies of 12 months and children at six to nine years old (Vakil,

2004).

These studies underscore the importance of protecting pregnant women

from the harmful effects of pesticides in order to protect the fetus and young

child and add to the evidence linking pesticides to childhood leukemia.

Those who have multiple chemical sensitivities are also susceptible to

pesticides. Statistics Canada recently reported that 2.4% of Canadians, more

than 640,000 people, suffer from doctor diagnosed multiple chemical

sensitivities (Arya, 2005).

Chronic neurological diseases among the elderly (Parkinsons disease,


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control and more chance of damage to plants and soil and water pollution

(Atmospheric Fate and Impact of Pesticides, 2007).The greatest potential for unintended adverse effects of pesticides is

through contamination of the earth's hydrologic systems which supports human

life, aquatic life and related food chains. Water is one of the primary media in

which pesticides are transported from application areas to other locations in the

environment (see Figure 2) (United States Geological Survey, 2007).

Figure 2: Pesticide transport in the environment


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changing their survival behaviors (Ewing, 1999). Depending on their chemical

properties, pesticides can enter the organism, bio-accumulate in food chainsand consequently influence human health (Pesticide Action Network, 2010).

There has been a decline in bee populations by one-third in the past few

years as a result of increasing pesticide concentrations in honeycombs. Bees

play a critical role in the pollination of crops, and thus a threat to bee colonies

can potentially affect entire ecosystems with severe implications for human

food supplies, of which over 30% depend on pollination by bees (Environmental

Law Center, 2010).Even though soil microorganisms are characterized by fast flexibility and

adaptability to changed environmental conditions, the application of

pesticides, especially long term, can cause significant irreversible changes in

their population. Inhibition of species (earthworm, nematodes, mites, micro-

arthropods) which provide key processes (decomposition, infiltration, reducing

run-off reduction of organic compounds), can have a significant impact on the

functioning of whole terrestrial ecosystems because all plants and animals that

eat those plants, including humans, rely upon these organisms for sustenance

(Pesticide Action Network, 2010).


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researchers, clinicians, the private and the public sectors have expressed

concerns, calling for action from the government (Cole et al., 2011).Municipalities and provinces across Canada have responded by adopting

pesticide reduction bylaws. Quebec was the first province in Canada where a

municipality (Hudson) enacted a pesticide reduction bylaw, and the first

province (2003) to enact provincial legislation banning the non-essential use of

pesticides in all municipalities.

Other municipalities have followed the lead of Hudson, evidenced by 171

bylaws across Canada, with additional ten pesticide bylaws pending adoption

and the enactment of provincial legislation in Ontario (2009), Prince Edward

Island (2010), Nova Scotia (2010), New Brunswick and Newfoundland and

Labrador (2011) (The Coalition for a Healthy Ottawa (TCHO), 2010).

It is worth noting that in none of the aforementioned jurisdictions was

cosmetic pesticide use higher than in Saskatchewan or Regina. Yet they all

adopted a pesticide bylaw which has led to a decrease in cosmetic pesticide

use. Because of the bylaws enacted thus far, close to 24 million Canadians are

now benefiting from enhanced protection from unwanted exposure to synthetic

lawn and garden pesticides (TCHO, 2010).


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extrapolate, but do not measure long-term/chronic effects and additive or

multiplicative effects of pesticides that are often present together in the samecommercial products (Arya, 2005).

Thirdly, testing does not take into account the fact that children have

developing immune and neurological systems which may not react in the same

way as those of adults and special considerations of the most vulnerable

individuals in our society are not accounted for by current methods of testing,

which impacts the accuracy of the risk assessment (Arya, 2005).

In addition, while active ingredients are tested, other components such as

formulants, stickers, spreaders, emulsifiers and solvents are not (Arya, 2005).

Many of these, such as toluene or benzene, are known carcinogens (Arya,

2005).

Moreover most pesticides were registered long before extra safety factors

and present analytical methods were in place; many have not been re-

evaluated for decades.

About 6,000 pesticides were registered by the 1969 Pest Control Product

Act (PCPA) administered by Agriculture Canada before the Pest Management

Regulatory Agency (PMRA). The vast majority have not been re-tested (Arya


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even if some cause and effect relationships are not fully established (Friis, 2010).

There is extensive scientific evidence on the serious negative health andenvironmental impacts from the use of cosmetic pesticides, making it a case

that merits the application of the precautionary principle. Thus, a municipal

bylaw restricting the use of pesticides for cosmetic purposes does not seem

unreasonable when human and environmental health is weighed against the

desire for a pretty lawn.

2.6.PUBLIC SUPPORTIn view of the national debate on the use of cosmetic pesticides, there is

a growing list of organizations calling for a bylaw to reduce the needless risks

from lawn and garden pesticides. Some leading non-governmental

organizations and health groups (Canadian Association of Physicians for the

Environment, the Canadian Medical Association, Ontario College of Family

Physicians, Registered Nurses Association of Ontario, Canadian Nurses

Association, Canadian Public Health Association) have been active in working

to reduce the cosmetic use of pesticides as well as offering real alternatives to

Canadians so they can enjoy green lawns without using dangerous chemicals


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identified by respondents following the public review of a 2002 report on

pesticides was a general dissatisfaction with maintaining the status quo. Thequestion is, which policy option best addresses the issue of cosmetic pesticides

in the city of Regina.

2.7.GOVERNMENT PRIORITYThe City of Regina has been supportive of a pesticide-free park as is

shown by the recommendation of the Community and Protective Services

Committee to extend the pesticide-free designation of Gordon and Al Pickard

Parks and Queen Elizabeth II Court (City Hall Grounds) which originally were

designated to be pesticide-free beginning May 2010 on a one-year pilot project

(City of Regina, 2012).

In addition, the Enviromental Advisory Committee at its September 1, 2011

meeting adopted a resolution to form working group on the issue of becoming

pesticide-free based on a report from the City of Reginas Community and

Protective Services Committee concerning the status of pesticide-free park

spaces as well as presentations from Canadian Cancer Society and the

Saskatchewan Environmental Society. At the request of the CPSC, the


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these diseases are not curable, which highlights the importance of prevention

by reducing exposure to non-essential pesticide especially in Regina, which isone of the top three cities for pesticide use (Ontario College of Family Physicians

(OCFP), 2012; Statistics Canada, 2007).

Bringing to mind the precautionary principle, it is essential that the City of

Regina adopt programs and policies that restrict the use of pesticides for

cosmetic purposes in Regina. This document summarizes the benefits of

decreasing cosmetic pesticides entering the environment and reducing the risk

to public health, while at the same time presenting the public with a range of

viable alternatives for sustainable landscape management.

In the City of Regina, there is neither a pesticide reduction bylaw nor an

education program to address the issue of cosmetic pesticide usage. One of

the themes identified by respondents following the public review of the report

on pesticides was a general dissatisfaction with maintaining the status quo.

Given the fact that the current trend in communities throughout Europe and

North America, including Canada, is finding the best way to limit the use of

pesticides through bylaws or education, doing nothing is an option which will

not be considered in this policy analysis.


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pesticides, to provide information on alternatives to pesticides and to help

households transform their behaviors in reducing their use of pesticides(Saskatchewan Environmental Society, 2011).

3.1.2. Alternative 2: Bylaw for vulnerable populationsThis policy option involves restriction of pesticide use on properties

containing schools, day-care centers, senior citizens residences, hospitals and

homes of people with medically proven sensitivities (Real Alternatives to Toxins in

the Environment (RATE), 2011).

The bylaw focuses on vulnerable populations such as pregnant mothers,

fetuses, children, the chronically ill, the elderly, pets and the pesticide sensitive.

The aforementioned groups are especially vulnerable for reasons ranging from

undeveloped immune systems, more permeable skin and behaviors (children), closeness to the ground where pesticide concentrations are highest, direct

exposure of chemically sensitive parts (pets) to compromised immune systems

(elderly, chronically ill) (Arya, 2005; RATE, 2011).

3.1.3. Alternative 3: City-wide bylaw


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applying the principles of community based social marketing.

The second phase would comprise implementation and enforcement of abylaw and the introduction of a permit system which allows the use of pesticides

in exceptional situations where the pest infestation threatens the integrity of

sensitive ecosystems, poses a serious economic loss to an owner or occupier of

land, or to control the spread of invasive species or noxious weeds (District of

Saanich, 2010).

3.2.CRITERIA FOR COMPARING POLICY ALTERNATIVESTo determine the best policy alternative for the City of Regina, each

policy option was evaluated based on: 1) Effectiveness, 2) Cost, 3) Economics,

4) Environmental implications, 5) Social implications, 6) Implications for the local

government, 7) Implications for the provincial government, 8) Implications for

the federal government, 9) Legislative and legal implications.

3.3.COMPARISON OF POLICY ALTERNATIVES3.3.1. Effectiveness

By providing the Regina public with information about health and

environmental risks of cosmetic pesticides as well as information on alternatives
http://www.saanich.ca/living/natural/invasive.htmlhttp://www.saanich.ca/living/natural/invasive.html


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According to the Canadian Centre for Pollution Prevention, only those

communities that adopted a bylaw in conjunction with educational programs,achieved reductions of 51% to 90% in comparison to low reductions of 10 to 24%

in pesticide use where only education and outreach programs were used

(Montagnese et al, 2007).

In terms of effectiveness, a city-wide bylaw has a major advantage

relative to education and awareness policy. Restricting the use of cosmetic

pesticides for those who are susceptible will not produce the same results as a

bylaw that applies to entire population.

3.3.2. CostThere are cost implications for the City of Regina in all three policy options.

Estimated budget for public education would consist of development of a

communication plan, advertising and promotion, workshops and possible

municipal administrative support (Kassirer et al., 2004). The cost estimate from

the Canadian Centre for Pollution Prevention to implement an education

program appears to be in the order of $CD 0.13 to $0.24 per person per year

(Kassirer et al., 2004).


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It is logical to infer that the cost for a bylaw focusing on the vulnerable

population would lie between the cost for the education and awareness policyand a city- wide bylaw.

3.3.3. EconomicsAt the onset, a bylaw will have an impact on the lawn and garden care

industry with some loss in business as consumers change their deeply-

entrenched behaviors and attitudes and choose not to use pesticides for

cosmetic purposes. This loss may be offset by consumers seeking firms to

undertake alternative lawn and garden care services and retailers who sell

alternative consumer products (MacLatchy, 2003).

In reality, bylaws have benefitted landscape industries as shown in many

jurisdictions. Since Halifax introduced a bylaw banning pesticides, the number of

lawn care companies in the City increased from 118 to 180, according to

Statistics Canada. The number of employees increased as well.

In Toronto, from 2001 to 2006, the number of landscaping and lawn care

sector businesses located in the City of Toronto grew each year, with an overall

30 percent increase during the period, similar to the increases in companies


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noted, education programs are not as successful as a bylaw combined with

education.Consequently, the education and awareness policy will have some

positive environmental effect while a bylaw brings the highest level of benefit

from pollution reduction.

Ontario's Ministry of Environment monitored 10 urban streams and creeks

pre and post 2009 ban regulations and found a greater than 70% drop in the

three most commonly used lawn pesticides (2,4-D, Dicamba, Mecoprop) (Todd,

2011).

Also, phosphorus levels in the Huron River dropped an average of 28

percent after Ann Arbor adopted an ordinance in 2006 that curtailed the use of

phosphorus on lawns (Flanigan, 2009).

3.3.5. Social implicationsAll three policy options have the potential to increase public awareness of

the negative impacts of cosmetic pesticide use through education. Education

through social marketing can be a potent force to motivate behavior change in

which homeowners are able to reduce the use of cosmetic pesticides. This can


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beliefs, and perceived needs), enabling (availability, accessibility and

affordability of resources, skills, money, time, facilities, law), and reinforcing (peerinfluences, influences from other significant people such as health professionals,

parents and teachers, law enforcement and the media, and campaign from

pesticide industry) factors can either be barriers or facilitators for cosmetic

pesticide use (Stevenson et al., 1997). Regarding the former, all three policy

options have the potential to positively influence the aforementioned factorsthrough education. However, both bylaws have a greater impact due to their

mandatory nature.

3.3.6. Implications for the City of ReginaAdoption of a pesticide reduction bylaw presents some challenges

regarding enforcement, as enforcement officers would require training in

pesticide products and how they are labeled. As well, training would be

required in pest management, soil sampling procedures and protocols, and

horticultural principles in order to effectively enforce the bylaw as well as

helping to inform residents regarding alternative uses to pesticides. In addition, it

is likely that pesticides will be applied in the evening hours and on weekends


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3.3.7. Implications for the provincial government of SaskatchewanSince the province delegates the power of municipalities, conflicts may

arise when the City of Regina enacts a bylaw in areas already governed by

provincial legislation (Vanhouwe, 2004). In Saskatchewan, the Pest Control Act

may affect municipal powers. Section 4 provides that every person shall take

measures to destroy, control and prevent the spread of all pests on any land or

other premises owned, occupied or controlled by him (Vanhouwe, 2004). Thefocus of the legislation is the control of pests. However, if sustainable alternative

measures are made available, conflict should be avoided.

Municipal experiences with bylaw implementation were also important

drivers for provincial legislation, prompting bans in Quebec, Ontario, Prince

Edward Island, Nova Scotia and New Brunswick (Cole et al., 2004). A pesticide

reduction bylaw in Regina might have the same impact across the rest of the

province and pave the way for broad acceptance by the provincial

government. This may lead to a provincial ban on sale and use of cosmetic

pesticides, which in turn will protect all Saskatchewan citizens. A provincial ban

supersedes local municipal pesticides bylaws to create one clear, transparent

and understandable set of rules across the province rather than having multi-


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cosmetic purposes. Instead they deferred to the Supreme Courts decision

granting municipalities the authority to restrict cosmetic pesticide use(MacLatchy, 2003).

A pesticide reduction bylaw in Regina will increase attention to this public

health issue and may contribute to the momentum that encourages the federal

government to restrict products used for cosmetic purposes.

Given the fact that many studies are now linking the use of pesticides todifferent diseases, especially among the vulnerable population, a pesticide

reduction bylaw in Regina for the vulnerable population will focus attention on

this public health issue. This may encourage the federal government to adopt

the recommendations of the House of Commons regarding research on

protecting vulnerable groups.

These recommendations involved legal recognition of multiple chemical

sensitivity syndromes. These recommendations may also encourage further

funding of Health Canada and its government partners so that they can assess

the relevance of existing research protocols involving vulnerable population

groups, draft new protocols where necessary and pursue current research on

the impact of pesticides on human health (particularly on vulnerable groups).


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being of its citizens was upheld (Montagnese et al., 2007).

3.4.CONCLUSION

The main goal of this policy analysis was to determine the best policy

option which can be implemented to reduce the use of cosmetic pesticides in

the City of Regina. The following conclusions can be drawn.In general, policy alternative three (city-wide bylaw) would be the most

effective alternative, followed by policy option two (bylaw for vulnerable

populations) and policy option 1 (public education and awareness). An

education and awareness program would accrue the lowest cost, but would be

the least effective alternative because it provides no implications for the local,

provincial or federal government as well as no legislative or legal consideration.

A city-wide bylaw would be the best policy alternative in terms of

effectiveness, economics, environmental and social implications, but would

accrue the most cost. Because it could have a positive impact on the provincial

as well as federal government, a city-wide bylaw would be a valuable

implement.


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of all three options. However based on the analysis above, the benefits

achieved from a city-wide bylaw outweigh the cost.All three policy options contribute to increased awareness of the negative

impact of cosmetic pesticide use to human health and the environment as well

as viable alternatives.

See Appendix 2 for a succinct comparison of the policy alternatives in regards

to the aforementioned evaluators.

3.5.RECOMMENDATIONS

Mindful of the importance of protecting human health and the

environment as stipulated in the precautionary principle, it is recommended that

a pesticide reduction city-wide bylaw is enacted to minimize the negative

impacts stemming from the use of cosmetic or non-essential pesticide

consumption in the City of Regina. This policy option is the most sustainable

amongst option 1 and option 2. It is socially more desirable, ecologically more

viable and it is cost effective for achieving greatest results compared to policy

options 1 and 2.


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most effective utility while at the same time minimizing the hazards and risk to

public health and the environment. The bylaw can, from a public healthperspective, be seen as primary prevention because it reduces exposure to

cosmetic pesticides. Reducing pesticides in the environment, can therefore, be

a prudent cautionary action, particularly when good alternative approaches to

cosmetic pesticides are available.


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4. REFERENCESArya N. Pesticides and Human Health. Why Public Health Officials Should

Support a Ban on Non-essential Residential Use. Canadian Journal of

Public Health. 2005. Volume 96, NO. 2. March-April 2005.

Atmospheric Fate and Impact of Pesticides. 2007. Available at http://www.era-orleans.org/AFIP/UK/pesticides.html. Accessed April, 2012.

Brimble et al., 2005. Pesticide Utilization in Canada: A Compilation of Current

Sales and Use Data. Environment Canada, Ottawa.

Canadian Cancer Society. British Columbia and Yukon. Making the Case. U Turn

for Change. 2011. Available at:

http://www.cancer.ca/british%20columbiayukon/how%20you%20can%20

help/bc-take%20action/~/media/CCS/British%20Columbia-

Yukon/Files%20Accessed March, 2012.

City of Regina. Environment Advisory Committee (EAC-12-14). 2012. Available at

www.regina.ca/opencms/.../committee...committee/.../eac12-14.pdf.Accessed April 2012.

City of Regina. 2012. Pesticides-Free Park. Available at:

http://www.regina.ca/residents/parks/find-field-park/pesticide-

f k / A d A il 2012


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Environmental Law Centre. University of Victoria. 2010. Submissions on Restricting

Cosmetic Pesticide Use in British Columbia. Available atwww.elc.uvic.ca/press/.../ELC-Submission-Cosmetic-Pesticides.pdf.

Accessed March, 2012.

European Union. European Union Policy for a sustainable use of pesticides. 2007.

The story behind the Strategy. Available at

http://ec.europa.eu/environment/ppps/pdf/pesticides_en.pdf. Accessed

February, 2012

Ewing RD. Diminishing Returns: Salmon Decline and Pesticides, Oregon

Pesticide Education Network. 1999. Available at:http://www.pcffa.org/salpest.pdf. Accessed March, 2012.

Flanigan NR. Water Quality Improves after lawn Fertilizer Ban, Study Shows. 2009.

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and Other Organic Chemicals. 2007; 7:141-145

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http://www.city.charlottetown.pe.ca/.../PesticideCommitteeReportJuly20


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February, 2012.

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http://www.milton.ca/MeetingDocuments/Council/agendas2007/rpts2007/ES-039-07%20Pesticides%20By-Law%20Implications.pdf. Accessed

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5. APPENDICESAPPENDIX 1: Distribution of Principal Pesticide Regulation Responsibilities inCanada

FEDERAL (PEST MANAGEMENT

REGULATORY AGENCY OF

HEALTH CANADA)

PROVINCIAL/TERROTORIAL MUNICIPAL

Pesticide registration andre-evaluation

Human health and safetyassessment of pesticides

Environmental impactassessment of pesticides

Value (efficacy)assessment of pesticides

Alternative strategies forpest management Compliance and

enforcement of Pest

Control Products Act(PCPAct) and regulation

Regulation for thetransportation, sale,use, storage and

disposal of pesticides Training, certification,

and licensing ofapplicators and

vendors

Spills and accidents Permits and use

restrictions Compliance and

enforcement

Bylaws formunicipal and insome cases private

and residentiallands

(Source: Pest Management Regulatory Agency (PMRA) homepage on internet.

Fact sheet on the regulation of Pesticides in Canada. Availableathttp://www.simcoemuskokahealth.org/.../Pesticides_Use_Lit_Review.sflb.

Accessed February, 2012)
http://www.simcoemuskokahealth.org/.../Pesticides_Use_Lit_Review.sflbhttp://www.simcoemuskokahealth.org/.../Pesticides_Use_Lit_Review.sflbhttp://www.simcoemuskokahealth.org/.../Pesticides_Use_Lit_Review.sflbhttp://www.simcoemuskokahealth.org/.../Pesticides_Use_Lit_Review.sflb


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APPENDIX 2: Summary of comparison of policy alternatives

POLICY

POLICY ALTERNATIVES

Policy option 1: Public

education and awareness

Policy option 2: bylaw for

vulnerable populations

Policy option 3: City-wide bylaw

Effectiveness Low to marginal reduction (10-24% and


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Implications for the City ofRegina

Not applicable to policyoption 1

Present challenge inenforcing bylaw (training ofenforcement officers in pestmanagement and soilsampling )

Present challenge in enforcingbylaw (training of enforcementofficers in pest management andsoil sampling)

Provincial implications Not applicable to policyoption 1

Conflict of interest if bylaw isenacted in areas governedby provincial legislation

Conflict of interest if bylaw isenacted in areas governed byprovincial legislation

Federal implications Not applicable to policyoption 1

Might lead to adoption ofrecommendation from the

house of commons(legalrecognition of multiplechemical sensitivity

legal protection of vulnerablegroups)

Might lead to adoption ofrecommendations from the house

of commons (legal recognition ofmultiple chemical sensitivitylegal protection of vulnerable

groups)

Legislative and legal

implications

Not applicable to policyoption 1

Supreme Court of Canadaupheld the municipalitys right

to enact by-laws. Thus nolegal implications

Supreme Court of Canada upheldthe municipalitys right to enact by-laws. Thus no legal implications

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