Good Morning Councillors, Mr. Mayor and all other Concerned Residents of Winnipeg.  Thank you once again for the opportunity to be heard in these chambers.  You will find the presentation I am about to make on the web at crowinc.org and I have requested that you be given a direct link to it from your agenda, so that you may, at anytime, read it and access the sources upon which it is based.

When registering last week to speak before this Council, I was asked to declare either support or opposition to the proposed Mosquito Control policy.  That was difficult. I must state clearly that while we are declaring support for some of the recommendations on which you will vote later today, we have serious reservations.  It is these concerns and others raised by yourselves last week at your EPC meeting which I bring to your attention now, along with information to fill in some gaps in your decision making ability which became evident during your revisiting of the buffer zone question.  Finally, I will conclude with some recomendations on behalf of Concerned Residents of Winnipeg, Inc.

Last April, the City of Winnipeg advertised for a new Entomologist.  You were seeking someone to "ensure an ecological approach to pest suppression initiatives."  Following public outcry and demands for reliable information, on July 21st of last year this Council began the process of making a decision to study the efficiency and safety of malathion, among other questions.  When the new entomologist arrived on the scene in September, he was commissioned with the task of finding answers to those questions and reporting back to you with his recommendations.

We are happy to acknowledge the first recommendation of that report which is to reduce the city's reliance on residential fogging and chemical pesticides for larviciding. It is optimistic to read of strategies to encourage the return of predator populations and particularly hopeful to hear of plans for the discontinued use of Dursban, or chlorpyrifos, for larviciding.

This council requested (Motion 580, p 2 & 3) to learn what research has been conducted on the efficiency and safety of malathion.  Sadly, the response to that question is this, "Based on the regulations of the Federal Pesticide Management Regulatory Agency (PMRA) this report recommends that Malathion continues to be the primary mosquito adulticide used in the event that residential fogging is required within Winnipeg. "(sic)  Leaving Malathion in the toolbox as an option for adulticiding, as Robin Faye pointed out last week to the Executive Policy Committee, "will fatally undermine the progress made by the other, newer tactics in the overall plan."

We recognize that the proposed AFA guidelines offer more flexibility to the Entomologist and the department and more ways to avoid spraying, which is an improvement over the autocratic and unreasonable guidelines that were followed last summer, but it is not good enough.  The fact is, you are still leaving the door open for political pressure to fog.  You sought and found an expert knowledgable in "insect control strategies related to the reduction of urban risk to health."  You were quite right to have done that; in fact, you have a duty to reduce the urban risk to health caused by pesticides.  

We are pleased to know that the Executive Policy Committee shares a concern which has been frequently brought to CROW's attention from concerned residents all over Winnipeg, and some of you may have read about this in the papers.  Councillor Clement raised the issue of the "vigilante" behavior of some residents who purchase and use fogging guns with malicious intent; a perfect illustration of the need for a non-essential pesticide use ban in Winnipeg.  We are so grateful to know that this Council finally recognizes and acknowledges the enormous problem caused by private, untrained citizens who fail to follow label directions and safety precautions.  Innocent people have been victimized, vandalized, abused, threatened and bullied with pesticides for years in Winnipeg and that must stop.  Everyone has the right to a buffer zone.  Everyone has the right to breathe. 

I am also personally grateful to you, Councillor Clement, because I believe you clarified the reason for this Council's previous poor judgement on this issue when you said, "we have to assume that we can trust the decisions of the PMRA (Health Canada); we have to assume they've done all the checks and balances."  Now I understand.  There appears to be some critical information missing from your ability to make a reasonable decision on this issue.  You may actually believe that these chemicals are not harmful.  Here are some facts that you and a lot of other people may not know about how pesticides are regulated, registered and marketed in Canada:

• PMRA works for "the client"  (no, not the Canadian public, the pesticide manufacturers)
• PMRA does no testing of any products themselves; all test results are provided by pesticide manufacturers
• Testing is done on only the "active" ingredient; not the entire formulation, not the so-called inerts or formulants, and sometimes (as is currently the case with the proposed re-registration of 2,4-D) not even the actual form that is used in the product)
• Only single acute exposure limits are considered in registration decisions, usually of single white males; testing of combinations of chemicals is never considered; testing of repeated low-dosage exposures is not considered (see Toxin and the Truth About Pesticides)
• Immune system dysfunction, neurological, cognitive and behavioral effects, reproductive dysfunctions and chronic disease are not required information
• Most tests are done on animals, such as rats which have been shown to have detoxifying abilities not found in humans.  It would be unethical to test pesticides on humans because we know they are toxic.  (In fact, they are the only chemicals deliberately designed to be toxic.)  Herein lies the difficulty in 'proving' causal relationships.
• PMRA is unable to identify either the names or the numbers of pesticides wich are no longer registered for use in Canada.  Products are supposed to be reviewed every 5 years.  Companies sometimes voluntarily pull their products off the market rather than submit new research requirements.  Other times, products fail to meet newer safety standards.  (Does this mean they were safe when we used them before?  No, it means now we know they were never safe to begin with.)

The Sierra Club of Canada explains it further in the Truth About Pesticides, "Although pesticides used and sold in Canada are registered, this does not mean they are safe. Even the federal government regulators do not claim that registration equals safety. Pesticides are not tested in combination, although their synergistic effects may be amplified as much as 1000 times. While pesticides produce acute and long-term health effects, toxicity experiments (done on healthy animals) measure and account for only the acute effects. The pesticides that are deemed acceptable for use as a result of these tests do not take into account the possible chronic effects."

The House of Commons Standing Committee on Environment and Sustainable Development recommends that PMRA incorporate cumulative and aggregate risks and the possible interaction between pesticides into their evaluation and, more specifically, in the determination of maximum residue limits and that cumulative and aggregate risks be defined.

If we could assume that Health Canada is keeping us safe, then doctors would not be allowed to accept gifts from the pharmaceutical/pesticide industry, and drugs in this country, like pesticides, could and would be monitored adequately once they were on the market, and Canada would have in place a system for adverse pesticide effects reporting.  The 1982 report of the Clean Environment Commission of Manitoba states that it was okay for the City of Winnipeg to aerially spray with Baygon in 1981, for the same reason that you are using now, because PMRA said we can.   Twenty-one babies were still-born following that spraying (Cities Under Siege).  Baygon is now one of those chemicals that PMRA is unable to name because it is no longer registered for use in Canada.  But one can still buy it Honduras.  Do you think that makes it safe? (click here te see pesticides and birth defects)

In Misrepresentations from the Industry (written for the Sierra Club of Canada), Patricia Running-Horan quotes the  Report of the Commissioner of the Environment and Sustainable Development in which the Environment Commissioner demonstrates we are not being adequately protected by our government from the toxicity of chemicals being liberally doused in our yards, in our air and into our water systems.  The Commissioner noted that of the 405 active ingredients (not entire products) mandated for re-testing, only 17 have been re-evaluated against current health and environmental standards.  (That report was released in 2003.  My request to learn how many products have been re-evaluated as of today remains unanswered.)  I will leave this Council with a copy of the article and the Commissioner's report which begins with point 1.1 "...the federal government is not adequately ensuring that many pesticides used in Canada meet current standards for protecting health..."

Paddy Running-Horan explains another point critical to your decision-making process.  All guarantees of safety from the industry are always qualified by the statement "if used according to label directions."  Well, let us see how we ought to be dressing ourselves to prepare for exposure to Malathion according to the City of Winnipeg Insecticide Labels and Material Safety Data Sheets:  NIOSH/NSHA approved respirator, chemical safety glasses, chemical resistant gloves, coveralls; Avoid breathing vapours, contact with eyes, skin and clothing." 

To keep this weapon, Malathion, in the toolbox based on only the PMRA's evaluation of its risks and to continue to "assume" that PMRA is protecting us can, at best, be called naive.  I call it negligent.  You are creating a human health hazard in an expensive and failing effort to "control" a pest.  A nuisance.  A bother.  It does not make sense.

Concerned Residents of Winnipeg recommend that this Council chose to make human health a priority.  It is incumbent on you to practice the Precautionary Principle in matters that affect urban health.  The Standing Committee on Environment and Sustainable Development explains, "Appropriate preventative measures are to be taken where there is reason to believe that a pesticide is likely to cause harm, even when there is no conclusive evidence to prove a causal relation between the pesticide and its effects."

Furthermore, we recommend that this Council lead by example and adopt a non-essential pesticide ban.  CROW, Inc. would be happy to help any Councillor research the best of the 70+ bans which are now protecting people across Canada.  Better yet would be to enter into negotiations with the province to institute a Provincial Pesticide Code such as this one recently adopted in Quebec, where Malathion will not be permitted as of 2006.

It is no longer good enough to claim ignorance of the consequences of continued pesticide use.  And please know that  making jokes about how foggy your brains have become is really not that funny, although it may explain some of your previous decisions.  Malathion is an organophosphate nerve toxin.  Organophosphates interfere with the body's ability to send and retrieve messages.  This means that brain functions are hindered.  Acetylcholinesterase becomes overstimulated at nerve endings (p 34, EPA Recognition and Management of Pesticide Poisonings) and interferes with nerve impulse transmission from nerve fibers to smooth and skeletal muscle cells, glandular cells, and autonomic ganglia, as well as within the central nervous system.  You will hear more about toxic effects from Dr. Gary Podolsky who has agreed to speak to you after I am finished.

We acknowledge the point made by the Entomologist that language is critical.  Members and volunteers for CROW will be advised of the request to use the wording 'pupal and larval development site' instead of 'mosquito breeding grounds.'  To assist the people of Winnipeg shift away from the expectation that the City can eliminate all their bug  problems, we recommend that you consider changing "Insect Control Branch" to something like "Insect Management Branch." Furthermore, we request and recommend that you refer to us as "Buffer Registrants" not "anti-pesticide registrants."  We are fighting for something.  Section 7 of the Canadian Charter of Rights and Freedoms guarantees us "the right to life, liberty and security of the person and the right not to be deprived thereof."  A desire to eliminate a nuisance, even if it's on the part of a majority of citizens, cannot supercede the right of those who need clean air.  We all have a right to breathe.

It is time to end the denial.  You must support this recommendation to phase out the use of chemical pesticides.  Just as importantly, though, you must change your own behavior.  Lead by example.  This summer when constituents call, demanding their dose of poison, you will need to encourage them to have patience, to adjust their expectations, to take safe personal precautions, and to look around for pupal and larval development sites in their own back yard.  Please, let the man do what you hired him to do and don't tie his hands behind his back with the PMRA's apron strings (or should I say purse strings?).

Thank you very much.

Glenda Whiteman
Executive Director