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Ministry of Agriculture, Food and Rural Affairs

Pest Control Products for
Specialty Crops

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.

Growers must be certified through the Grower Pesticide Safety Course in order to buy and use Class 2 and 3 pest control products on their farms. They do not require this certification to use Class 4, 5, 6 or 7 pest control products. For information about certification for growers and training for assistants to growers, visit the Ontario Pesticide Education Program website at www.opep.ca or call 1-800-652-8573.

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. The Organic Materials Review Institute (OMRI) in the United States provides a list of inputs, including pest control products, which may be organically acceptable and serves as a guide for potential products. However different certifying bodies use different methods for determining acceptability of inputs, so 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 OMAF and MRA 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.

For the purpose of establishing MRLs when registering pest control products, the PMRA places crops into crop groups. A crop group is a grouping of plant species based on botany and taxonomy (for example plant families), as well as on how the crops are produced. A subset of crops within this list are designated as being representative of the whole group. Residue data gathered for these "representative crops" is used to establish an MRL for the entire crop group, allowing products to be registered on all crops in that group without having to generate data on every single crop. So, for example, if acceptable data is gathered on carrot, potato, radish and sugarbeet - the representative commodities for Crop Group 1: the Root and Tuber Vegetables Group - then it may be possible to achieve a Crop Group 1 registration. The product could then be applied to all commodities in the group, including ginseng, sweet potato, Jerusalem artichoke, daikon radish and salsify.

Crop Groups are often further divided into smaller, and more closely related subgroups. A pest control product may be registered on a subgroup, rather than the entire crop group. A product registered only on Crop Subgroup 1C - the Tuberous and Corm Vegetables subgroup - could be applied to any crop in this subgroup, including Jerusalem artichoke, potato and sweet potato. However it could not be applied to ginseng, daikon radish and salsify, which are in Crop Subgroup 1A - the Root Vegetables Subgroup.

Since 2002 the PMRA, together with several other countries, has been updating and expanding existing crop groups to incorporate additional crops. This process is still on-going, and not all crop groups have been evaluated as of October 2012, however several new Crop Groups have been approved. For example, Crop Group 8, the Fruiting Vegetables (except Cucurbits) Group, originally included only six crops - eggplant, groundcherry, pepino, pepper, tomatillo and tomato. In 2008, a new Fruiting Vegetables crop group was proposed and in 2010 a new crop group, called Crop Group 8-10 was established, which includes 21 different crops, including okra, goji berry and garden huckleberry. It is important to be aware that to use a product on one of these new crops, a label must indicate the new crop group number in order to apply it to the expanded crop list. If it has only the old crop group number, it can only be applied to the original crop group list.

To facilitate interpretation, each crop profile included in this resource indicates what crop group and subgroup the crop belongs to, if any. A complete list of all crops included in both original and revised crop groups can be found at the following link on Health Canada's website: http://www.hc-sc.gc.ca/cps-spc/pest/part/protect-proteger/food-nourriture/rccg-gcpcr-eng.php.

Putting it all together

While it would be helpful if all product labels were exactly the same, and clearly indicated what crops a given product is registered on there is, unfortunately, considerable variation in how pest control product labels list the crops they are registered on. What follows are some general tips on how to determine what products are acceptable for use on a given specialty crop.

  • To determine what crop group a specialty crop belongs to, consult its profile or the list on the Health Canada web site (http://www.hc-sc.gc.ca/cps-spc/pest/part/protect-proteger/food-nourriture/rccg-gcpcr-eng.php). Note that many specialty crops have different names - for example bitter melon is also called foo gwa, balsam pear, bitter gourd or fwa-kwa. Not all of these names are included in crop group tables, which typically include the Latin or species name, and the most frequently used common name.
  • Only products labelled for the specific crop or the crop group or subgroup in which it is included can be used on a particular crop. Pest control products registered on a entire crop group are registered on all crops and subgroups within that crop group number (e.g. pest control products registered on Crop Group 1 - Root and Tuber Vegetables are registered on all crops listed under subgroups 1A, 1B, 1C, and 1D). Pest control products registered on a specific subgroup are registered only on crops within that subgroup and not the entire crop group (e.g. products registered on subgroup 1A can not be applied to crops in subgroup 1B).
  • Not all crops within a family are included in a crop group. For example mousemelon, Melothira scabra, is in the Cucurbit family, but is not included in the list of crops for Crop Group 9, Cucurbit Vegetables Group.
  • If a product label lists an old crop group (e.g. Crop Group 8), it cannot be applied to crops included only in the new crop group (e.g. goji or okra, which are included in Crop Group 8-10 but not 8).
  • It is important to remember that not all products have a crop group registration and products registered on one crop are not necessarily registered on all members of its crop group. For example, there are a number of products registered to control downy mildew on conventional cucumbers. Some of these products are registered on all of Crop Group 9, the Cucurbit Vegetables group and can be applied to any of the specialty cucurbits included in this crop group. Others only list cucumbers and/or melons on the label and these cannot be applied to other crops in the Cucurbit Vegetables group.
  • The same plant may fall into different crop groups or subgroups, depending on how it is used or produced. For example, parsley sold as fresh leaves is in Crop Group 4, the Leafy Vegetables Group, but when the leaves are sold dried it falls in Crop Group 19, the Herbs and Spices Group. Dill is in Subgroup 19A when it is being grown for its leaves (dillweed), but in 19B when it is grown for seed production.

Accurately determining which pest control products are registered on a particular specialty crop can be a time consuming and confusing task, but one that is worth doing. Remember that the label is the law, and the grower or applicator is ultimately responsible for ensuring that they are adhering properly to it. When in doubt, refer to the resources listed below for assistance in understanding pest control product regulations, certification and licensing. For assistance in interpreting labels, consult an OMAF and MRA specialist.

  • Inside front cover of most OMAF and MRA production guides
  • Pest Management Regulatory Agency (PMRA) website: www.pmra-arla.gc.ca
  • PMRA Pest Management Information Service: 1-800-267-6315 (from within Canada) or 1-613-736-3799 (from outside Canada)
  • Ontario Ministry of the Environment (MOE) website: www.ontario.ca/environment
  • Regional MOE Pesticides Specialist
  • Ontario Ministry of Agriculture and Food (OMAF) website: www.ontario.ca/omafra
  • OMAF and MRA Crop or IPM specialists
  • Ontario Pesticide Education Program (University of Guelph, Ridgetown Campus) website: www.opep.ca
  • Ontario Pesticide Training & Certification website:www.ontariopesticide.com/index.cfm/home-page