June 10, 1998
(Environment and Labour)

1998 Aerial Spray Program for Insect Control Released from Further Environmental Assessment

The Minister of Environment and Labour, Oliver Langdon, announced today that the 1998 Aerial Spray Program for the Control of the Balsam Fir Sawfly and the Yellowheaded Spruce Sawfly has been released from further review under the Environmental Assessment Act.

On April 9, 1998, the Department of Environment and Labour received a registration document from the Department of Forest Resources and Agrifoods which detailed the department's plans to undertake an aerial spray program for parts of the western and central region of the province to control the balsam fir sawfly and the yellowheaded spruce sawfly. The document outlines, in detail, plans to apply the insecticide known as Dylox to approximately 10,000 hectares in the province. This particular spray program will complement the program the department is now developing to combat the hemlock looper using the biological insecticide Bt.

Minister Langdon said: "On the basis of expert advice and information received from provincial community health professionals, the Pest Management Regulatory Agency of Health Canada, the US Environmental Protection Agency and the World Health Organization, I am comfortable in saying that Dylox can be used safely to combat the two species of sawflies in question."

The registration document was reviewed extensively by various government departments and agencies as well as the general public. During the course of the review, questions were raised about the potential impacts of Dylox on the environment and on human health. "For this reason," said Langdon, "expert advice was sought on the use of Dylox for aerial application. The responses I received, I feel, adequately address the concerns that have been raised by the public and various government departments and agencies."

For the program to proceed, however, the Department of Forest Resources and Agrifoods must obtain the necessary licences and permits, including a Pesticides Operators Licence. This licence is required under the Pesticides Control Act administered by the Department of Environment and Labour and establishes the majority of terms and conditions for the operation of the spray program. As a minimum, the following conditions will be included: a requirement for a comprehensive communications plan and public notification program; appropriate buffer zones to ensure public health and safety; application of the Dylox spray can only take place with appropriate weather conditions; and appropriate equipment and trained personnel are to be used. Furthermore, the Department of Forest Resources and Agrifoods will be required to submit a contingency plan outlining procedures and protocols to follow in the event of a spill or similar event. This must also be approved by the department. While these are examples of the types of conditions that will be included in a Pesticides Operator Licence, all necessary measures will be put in place to ensure protection of the environment and the health and safety of the public.

Dylox has been approved for use by the Pest Management Regulatory Agency of Health Canada for a wide variety of applications since the 1970's. It has been applied to food crops, wood lots, rights-of-way, and to Christmas trees. Approval for aerial application was given by Health Canada earlier this year for one year only.

The minister stated that he feels this program is necessary to effectively deal with the severe sawfly infestations and it will be done in accordance with strict safeguards to protect the environment and public health.

Contact: Sean Kelly, (709) 729-2575.

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BACKGROUNDER ON DYLOX

What is Dylox?

Dylox is the trade name for an insecticide product containing the chemical trichlorfon as the active ingredient.

Dylox Use in North America

Dylox has been used throughout North America on a variety of field and vegetable crops to control moths, flies and other bugs. Dylox has also been used on forests, ornamental plants, tobacco and wood lands to control a variety of insect pests. Dylox is used to control certain internal and external parasites on commercially important livestock and to control flies in international public health programs.

Dylox has been registered and used in Canada since the 1970s. In 1997 Dylox was used in British Columbia, Alberta and New Brunswick primarily on rape/canola (53 per cent) and alfalfa crops (33 per cent). However, Dylox was also used on wheat (6 per cent), blueberries (6 per cent), beets (1 per cent) and Christmas trees (1 per cent).

In 1996, New Brunswick Environment authorized the aerial application of Dylox, Neemix and Cythion to approximately 200 hectares of woodlands for the purpose of controlling yellowheaded spruce sawfly.

In 1997, the Alberta Department of Agriculture sprayed 24,000 hectares of canola with Dylox. It is also used by farmers in Alberta for insect control on cattle.

The US Environmental Protection Agency has prohibited the aerial application of Dylox. However, the removal of this application statement from the label was done for economic reasons. It was not done because of unacceptable human health or environmental issues. There is not a significant market for the aerial application of Dylox in the United States; the main uses being to apply the product on the ground for turf situations. In light of the cost of keeping an aerial application statement on the product label, the manufacturer of Dylox, Bayer, voluntarily removed it from the label. In light of the voluntary withdrawal of this application, the US EPA prohibited the application of Dylox from the air.

Potential for Impacts of Dylox on the Environment and Human Health

Dylox, like any other chemical, can be harmful if the dosage or concentration is high enough. Scientific literature indicates varying levels of toxicity and impacts on humans, animals and plants, which is not uncommon. However, on balance, officials of various agencies such as, the US Environmental Protection Agency, the Pest Management Regulatory Agency of Health Canada and the World Health Organization feel that the chemical, if used properly, can have a beneficial impact on controlling unwanted pests with little or no increased risk to human health and the environment.

Possible Impacts on Bystanders

What would be the impact of a bystander being showered with the spray or drinking water that contained the chemical?

Given the anticipated concentration of the spray and the concentration of chemical that may be found in water, if indeed any should reach a water body, the exposure would be far below the levels where any noted impact would be felt or seen. For instance, with regard to dermal exposure, the body would have to be subject to a dosage a hundred times that of the spray to the full body before any impact would be noticed. With regard to drinking water, the concentration is anticipated to be about 500 times less than the level where an impact may be seen.

Does Dylox Cause Cancer?

There is no evidence that exposure to Dylox can result in the development of cancers in humans. In fact, trichlorfon, the active ingredient in Dylox, has been classified in a category of "no evidence of carcinogenicity for humans" by the World Health Organization, the Pest Management Regulatory Agency and the United Stated Environmental Protection Agency.

BACKGROUNDER - REGULATORY RESPONSIBILITIES

Regulatory Responsibilities of the Federal and Provincial Governments

Both the Provincial Government (Department of Environment and Labour) and the Federal Government (Health Canada) are involved in the regulation of pesticides. Pesticides cannot be used in Newfoundland and Labrador until both levels of government give their approval.

Health Canada (Pest Management Regulatory Agency)

Before any chemical manufacturer can begin selling a pesticide in Canada they must first submit a registration application to Health Canada (PMRA). Included with the registration application is environmental and health data that explains how the pesticide behaves in the environment. Research outlining risks to non-target organisms is included with the package. Other environmental and health data are submitted with the application. These data are required to ensure that the product will not pose an unacceptable risk to human health or the environment when used for its intended purpose. Furthermore, the need for a particular pesticide must be demonstrated.

Health Canada reviews the information once it is received from the pesticide manufacturer. If registration is granted Health Canada may require that the users follow certain restrictions, most of which are outlined on the pesticide's label. These restrictions mitigate against any identified risks to human health or the environment.

Department of Environment and Labour

The Department of Environment and Labour is responsible for ensuring that individuals using certain pesticides have received appropriate training, post-registration research and monitoring. The Department also issues pesticide licenses that further restrict pesticide use by spelling out public notification programs, spill response requirements, weather conditions under which to apply pesticides, buffer zones, etc. The provincial government ensures compliance with these activities through monitoring and enforcement.

BACKGROUNDER - REGISTRATION WITH PMRA

Emergency Registration of Dylox with PMRA

The Pest Control Products Act allows for emergency registration of a pesticide, for a period not exceeding one year, for the control of pest infestations that are potentially detrimental to public health, domestic animals, natural resources or other commercial sectors.

The Pest Management Regulatory Agency (PMRA) considers an emergency situation to be a pest outbreak which has potential to cause significant economic, environmental or health problems and for which there is no registered product or alternate control method available. An emergency registration for a pesticide is usually requested by the provincial or federal agency involved in the direct management of the pest problem and must be supported by the provincial pesticide regulatory agency. The applicant must provide information supporting the claim that an emergency situation exists, including information on the location of the infestation and the proposed area for treatment. Upon approval by the PMRA, the provincial government takes over.

The provincial government responsibilities include licenses that further restrict pesticide use by spelling out public notification programs, spill response requirements, weather conditions under which to apply pesticides, buffer zones, etc. The provincial government monitors these activities through monitoring and enforcement.

Emergency Registration of Dylox in Newfoundland and Labrador

The request for emergency registration for Dylox was made by the Newfoundland Department of Forest Resources and Agrifoods for control of a serious infestation of balsam fir sawfly in western Newfoundland. Failure to control this infestation in a 10,000 ha area of high value balsam fir stands is expected to result in growth loss and potential mortality of the trees with significant economic loss to the forest industry in western and central Newfoundland. The request for emergency registration was supported by the Newfoundland Department of Environment and Labour, the provincial pesticide regulatory agency.

The emergency registration of Dylox is for the 1998 use season only (i.e., to address to current emergency situation). Should there be an ongoing need for the use of Dylox for control of balsam fir sawfly, a regular application for registration of this use would have to be made to the PMRA for evaluation.

1998 06 10                    12:20 p.m.