Getting the Protection Right: Submission on Bill 64 - Banning the Sale and Use of Cosmetic Pesticides
Summary of Recommendations
1. RNAO strongly supports the ban on the use and sale of pesticides for cosmetic purposes.
2. RNAO recommends use of the precautionary principle in developing the list of banned or allowed substances. RNAO further recommends employing an “inclusion list” of allowed substances, which would be more protective than a list of banned substances. An efficient and precautionary process for adding or removing substances from lists must be specified.
3. RNAO strongly supports province-wide coverage, with protection for all Ontarians, whether they live in built-up areas or in rural or remote areas.
4. RNAO supports exemptions for public health (as determined by the Medical Officer of Health), but is opposed to other exemptions such as that for golf courses.
5. RNAO is particularly concerned about the exemption for “other prescribed uses”, with those uses to be prescribed by regulation. RNAO strongly recommends that the clause exempting other prescribed uses be removed.
6. RNAO strongly urges complete removal of the clause rendering municipal pesticide bylaws inoperative. Ontario must preserve municipalities’ rights to take protective legislative measures against pesticides that go beyond those delivered by the province. Municipalities have been key partners in protecting citizens from pesticides, and they must remain partners.
7. RNAO supports the timely implementation of this legislation for the 2008 growing season, and it urges that sufficient resources are allocated for education and enforcement.