2011 progress report: a comparison of provincial cosmetic pesticide bans

8/6/2019 2011 progress report: A comparison of provincial cosmetic pesticide bans

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2011 progress repor t: A comparison of provincial cosmetic pesticide bans

May 2011, David Suzuki Foundation and quiterre

Pesticide Free? Oui!


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CREDITS

Research and writing b Nadine Bachand and Lisa Gue

Acknowledgements:

Man people contributed to this project. The authors wish

to thank in particular: Chris Benjamin, Prin Brooks, Leanne Clare,

David Coon, Kathleen Cooper, Manon Dubois Crteau,

Gideon Foreman, Ian Hanington, Marie-ve Ro,

and Eveline Trudel-Fugre

This report would not have been possible without the generoussupport o the Salamander Foundation and the Canadian

Association o Phsicians or the Environment (cape.ca).

Design:

KAKEE design graphique responsable inc. and Guillaume Edger

ISBN 978-1-897375-38-9Canadian cataloguing in Publications Data or this book is available

through the National Librar o Canada

This report can be downloaded ree o charge at

www.davidsuzuki.org/publications

or www.equiterre.org/publications

Also available in French asCouper lherbe sous le pied des pesticides en 2011

Comparaison de lencadrement rglementaire des pesticides utiliss des ns esthtiques dans les provinces canadiennes

ISBN 978-2-922563-23-8

quiterre

2177, Masson, bureau 317 Montral, Qubec Canada H2H 1B1

Web site: www.equiterre.org

Telephone: 514 522-2000 Fax : 514 522-1227

David Suzuki Foundation

219 -2211 West 4th AvenueVancouver, British Columbia

Canada V6K 4S2

Web site: www.davidsuzuki.org

Telephone: 1-800-452-1533 Fax: 604-732-0752


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TABLE DES MATIRES

1. INTRODUCTION

2. SUMMARy OF PROVINCIAL ACTION

ON COSMETIC PESTICIDES

3. STRENGTHS AND WEAKNESSES OF PROVINCIAL

POLICy FRAMEWORKS FOR COSMETIC

PESTICIDES

4. CONCLUSION

REFERENCES

4

5

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1. Introduction

Since publication o our 2008 report Pesticide Free? Oui! An analsis o QuebecsPesticides Management Code and recommendations or eective provincial polic (quiterre

and David Suzuki Foundation), several Canadian provinces have ollowed Quebecs leadand have banned the cosmetic use o pesticides. While provincial cosmetic pesticide bansgenerall share a common purpose the protection o health and/or the environmentrom needless exposure to pesticides the approach varies considerabl rom province toprovince. In this update, we present a comparison o current provincial actions to bancosmetic pesticides and identi the most promising approaches. Building on the ndingso our earlier report, this analsis aims to bring to the attention o decision-makers thelessons learned rom recent polic innovation in this arena and highlight the best availablemodels. Our conclusions are particularl relevant or Quebec, which led the wa with the rstprovincial ban on lawn pesticides in 2003 but has now allen behind other provinces, and orBritish Columbia, where the government is considering the results o a public consultationthat avoured a provincial ban as well as or other provinces that ma consider adopting or

strengthening prohibitions on cosmetic pesticides.

The rst section o this report brie presents the approaches adopted b the veCanadian provinces that currentl restrict the use and sale o cosmetic pesticides: Quebec,Ontario, New Brunswick, Nova Scotia, and Prince Edward Island, as well as Albertas morelimited restriction on pesticide/ertilizer mixtures. We also review the process to date inBritish Columbia. We then assess the strengths and weaknesses o the dierent provincialrameworks and highlight the best models, corresponding to the recommendations madein our 2008 report.


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2. Summary of provincial action oncosmetic pesticides

Ontario

The province adopted the Cosmetic Pesticides Ban Act in June 2008 and correspondingchanges to the pesticide regulation (Ontario Regulation 63/09) took eect on April 22,2009. The regulation prohibits the use o 96 active ingredients in cosmetic pesticides orpublic and private lawns and gardens, as well as the sale o 172 products containing thesechemicals. An additional 103 mixed use products are subject to new retail restrictions.These products contain active ingredients that are banned or cosmetic use on lawns andgardens but can be used in other products or purposes beond the scope o the ban(e.g., indoor insect control) or that are permitted under an exemption or the promotiono public health and saet. The latter allows pesticides containing the active ingredientsglphosate and gluosinate, which are otherwise prohibited or cosmetic purposes, to be

used to control plants that are poisonous to the touch, such as poison iv. There is norequirement or third-part certication at the point o sale to veri that the pesticides areactuall being purchased or an exempted use. However, sel-service retail access tomixed-use products (which are generall banned or cosmetic use but still permitted oruse in certain circumstances) is prohibited and store owners are required to provideinormation about the cosmetic pesticide ban to customers who purchase them.

The exemption or the promotion o public health and saet also permits use opesticides to control animals that bite or sting, are venomous, or carr disease (includingwasps, mosquitoes and ticks) and to control plants, ungi or animals that aect publicworks and other buildings and structures. In addition, there is a limited exemption orarboriculture. In this latter case, the written opinion o a specialist must be obtained, stating

that the pesticide is necessar to maintain the health o the tree. Finall, the Ministr o NaturalResources ma authorize the use o pesticides to control invasive species, to benet aspecies o ora or auna that is native to Ontario or to protect or restore a rare ecosstem.Although there are restrictions on which pesticides can be used under the exemption orplants that are poisonous to the touch (e.g., onl glphosate and gluosinate products), thisis not the case or other exempted uses.

Gol courses are generall exempt rom the Ontario ban, but to quali or this exemptionthe must be certied in Integrated Pest Management and must submit annual reports


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disclosing the amount o each pesticide used along with plans to minimize pesticide use.The reports must be made available to the public, presented at an annual public meeting and

posted online (as o 2012).

The Ontario Ministr o the Environment maintains guidelines or classiing pesticidesunder the Cosmetic Pesticides Ban Act. Onl substances that meet proposed low-riskcriteria (see below) and those identied as reduced-risk biopesticides are allowed orcosmetic use; others will be added to the list o banned active ingredients. The sameclassication sstem applies or an new pesticide registered b the Pest ManagementRegulator Agenc (PMRA).

The Ontario provincial ban superseded municipal pesticide blaws. This means thatmunicipalities are not able to adopt tougher restrictions on pesticide use and do not have aclear role in enorcement.

Low-risk criteria1

As proposed b the PMRA, lower-risk pesticides have some or all o the ollowingcharacteristics:

Theyhaveanon-toxicmodeofaction.

Theyareoflowtoxicitytoorganismstheproductisnottargeting.

Theydonotpersistintheenvironment.

The product is used in ways that do not cause signicant exposure. For example,

the product is premixed or it is applied in a closed sstem, reducing human andenvironmental exposure.

Theyhavebeenwidelyavailabletothepublicforotherusesforsometime

1 Source: Government o Ontario, Feb. 24, 2009. Pesticide Classication Guidelines or Ontario.Available at: www.ene.gov.on.ca/environment/en/resources/STD01_076412 (accessed April 14, 2011).


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2 Source: Gouvernement du Qubec, ministre du Dveloppement durable, de lEnvironnement et des Parcs. Code degestion des pesticides. Les aits saillants. Available at: www.mddep.gouv.qc.ca/pesticides/permis/code-gestion/index.htm(accessed March 24, 2011).

Quebec

Introduced in April 2003, the Quebec Pesticides Management Code addresses the use andsale o lawn pesticides. The regulation targets 20 active ingredients that are classied ascarcinogens (including probable and possible carcinogens) b at least one o the ollowingspecied reerence agencies: the International Agenc or Research on Cancer (IARC), theU.S. Environmental Protection Agenc, the U.S. National Toxicolog Program, the CaliorniaEnvironmental Protection Agenc and the European Union. These 20 active ingredients areound in approximatel 200 lawn pesticides, which are now banned.

In determining which active ingredients would be banned, the Quebec Ministr oEnvironment (now renamed ministre du Dveloppement durable, de lEnvironnement etdes Parcs MDDEP) initiall considered other chronic eects o concern, such as endocrinedisruption. In the end, these criteria were not applied because at the time there were no

established reerence lists or chronic eects other than cancer. 2 (The European Unionspriorit list o suspected endocrine disruptors was developed more recentl.)

In principle, an active ingredient later classied as a carcinogen or endocrine disruptorshould be added to the list o banned pesticides, according to the document that outlinesthe methodolog the department used to develop the initial list. However, the PesticidesManagement Code itsel does not speci an requirement or the minister to update the listo banned pesticides, and, in act, it has remained unchanged since the Code was adoptedin 2003.

Implementation o the Code was phased in over three ears. The ban on the use opesticides on public and municipal lawns came into eect rst, in April 2003. Next, thesales ban on domestic-use pesticide-ertilizer mixtures and pesticide combination products(e.g., herbicide-insecticide mixtures) took eect in April 2004. Retail displa restrictionsprohibiting sel-service customer access to domestic pesticides containing the bannedactive ingredients have been in orce since April 2005. Finall, the sale o all domesticpesticides containing the banned active ingredients and the use o these products on privateand commercial lawns were banned in April 2006.

The Code urther restricts pesticide use inside and outside places requented b children,such as earl childhood centres, dacare centres, child drop-in centres, kindergartens andamil-run child-care acilities, as well as preschools, elementar schools and high schools.


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Onl biopesticides or 14 active ingredients considered least likel to have an toxic eects(see the box below) can be applied inside or outside these establishments. This list was

developed based on parallel requirements in the U.S. School Environmental Protection Act.

Municipalities must adhere to the Pesticides Management Code but ma also adopt morestringent restrictions on pesticide use.

Gol courses are not subject the Code but are required to submit pesticide-use reductionplans ever three ears (as o April 2006).

Nova Scotia

The Non-Essential Pesticides Control Act took eect in Nova Scotia on April 1, 2011. Thislaw prohibits the cosmetic use o pesticides on lawns and will extend to trees, shrubsand ornamental owers on April 1, 2012. The accompaning List o Allowable PesticidesRegulations sets out active ingredients that are considered to pose a lower risk to humanhealth and the environment. Nova Scotias list o allowable pesticides is based on Ontariosclassication, as well as the Canadian General Standards Boards list o allowed substancesin Organic Production Sstems. An product containing active ingredients not on the list oallowable pesticides is prohibited.

Active ingredients permitted or use inside and outside o earl childhoodcentres, elementar schools and high schools

AcetamipridBoric acidBoraxSilicon dioxide (diatomaceous earth)MethopreneOctaborate disodium tetrahdrate

Ferric phosphateInsecticidal soapSpinosad

Acetic acidMixture o capric and pelargonicHerbicidal soapSulphurCalcium sulphide or calcium polsulphideBiopesticides


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The ban applies to residential, commercial, government and institutional properties,including hospitals, long-term care acilities, schools, parks and recreational inrastructures.

It does not appl to gol courses or vegetable gardens.

There are also exemptions or the use o pesticides in specic circumstances. Pesticidescontaining the active ingredient glphosate, which are generall prohibited, can be used tocontrol plants that are poisonous to the touch, invasive plant species and plants that madamage buildings. There is also a broader exemption or the use o pesticides to controlanimals (including insects) that bite, sting, are venomous or carr diseases; ungi andanimal species that ma damage buildings; and invasive species other than plants; and orthe use o pesticides injected into outdoor trees. Although there are restrictions on whichpesticides can be used under the rst set o exemptions (e.g., onl glphosate products),this is not the case or the latter exempted uses. Neither is there an requirement orthird-part certication at the point o sale to veri that the pesticides are actuall being

purchased or an exempted use. As in Ontario, retail displa requirements prohibitsel-service consumer access to mixed-use pesticides (i.e., products generall prohibitedor cosmetic use but allowed under certain exemptions). Retailers must also supplcustomers with inormation concerning the legal exemptions allowing or the use othe pesticides.

New Brunswick and Prince Edward Island

Using existing legal authorities under the 1974 Pesticides Control Act, the New Brunswickgovernment banned the use and sale o pesticides containing 2,4-dichlorophenoxaceticacid (2,4-D) as o December 16, 2009. The ban also applies to pesticides that thegovernment considers to be misused or overused: combination products (pesticides-ertilizers mixtures), products using spra cartridges designed to be applied with a gardenhose, concentrated products requiring preparation (e.g., mixing, dilution or handling) beoreapplication, and granulated products or spraing. In all, the government banned the retailsale and use o more than 200 lawn pesticides.

Sta rom lawn-care companies must register in an Integrated Pest Management (IPM)program approved b the New Brunswick Ministr o Environment to purchase andappl commercial lawn pesticides, other than 2,4-D products (which are prohibited).To reduce blanket treatments in avour o targeted spot treatments o problem areas,


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pesticides can onl be applied on up to 50 per cent o a lawn, once per season. An exemptionis permitted or blanket treatments o so-called insect inestations i a permit amendment

rom the Ministr o Environment is obtained.

Gol courses are generall not subject to the new restrictions provided the obtain IPMaccreditation.

The provincial guidelines do not prevent the adoption o regulations at the municipal level.

The government pledged to undertake a public review o the Pesticides Control Act3 but noprocess has been announced et.

In April 1, 2010, Prince Edward Island amended its rules to match those in NewBrunswick.

Alberta

In Alberta, a ban on the use and sale o ertilizer-herbicide mixtures (so-called weed and eedproducts, most o which contain 2,4-D) took eect on Januar 1, 2010. The ban does not extendto other products containing 2,4-D. Proessional tur managers (e.g., gol courses) arealso exempt.

British Columbia

In earl 2010, the B.C. Ministr o Environment consulted the public on new statutorprotections to urther saeguard our environment rom cosmetic chemical pesticides.The Ministr o Environment received more than 8,000 submissions (including petitionsignatures), the vast majorit o which were in support o cosmetic pesticide legislation.But the government is sitting on the results o the consultation and has et to announcea decision.

3 Source : Government o New Brunswick, June 18, 2009. Province introduces lawn care pesticide ban.Available at: www.gnb.ca/cnb/news/env/2009e0865ev.htm (accessed Januar 26 2011).


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3. Strengths and weaknesses ofprovincial policy frameworks forcosmetic pesticides

On the basis o our analsis o Quebecs Pesticides Management Code, our 2008 reportPesticide Free? Oui! made the ollowing seven recommendations or eective provincialcosmetic pesticide bans:

1. Adopt the precautionary principle as the guiding principle.2. Structure the ban in reerence to a white list o reduced-risk products and biopestici-

des authorized or sale and use.3. Ensure that the provincewide ban is sufcientl stringent so that its eectiveness does

not hinge on complementar municipal blaws.4. Prohibit all cosmetic use o pesticides in landscaping not onl lawn applications.

5. Provide citizens with practical tools and encourage them to adopt new standards ortheir lawns.

6. Plan a thorough monitoring and enorcement program.7. Fund research and development o alternatives to pesticides.

Our review o subsequent developments in other provinces indicates that regulatorrameworks in Ontario and Nova Scotia are most consistent with these recommendationsand oer the best models or protecting human health and the environment rom cosmeticpesticides although there is still room or improvement.

The policies in these two provinces are the most comprehensive, in that the appl beondlawns to other aspects o landscaping and prohibit a large number o pesticides. In both

Ontario and Nova Scotia, the cosmetic pesticide ban is oriented around a credible list olower-risk products permitted or use in public and private areas.

However, it is important to note that exemptions permit the use o pesticides that aregenerall banned in Ontario and Nova Scotia, and these exempted uses are not alwaswell-controlled. There is no requirement or third-part certication at the point o sale toveri that the pesticides are actuall being purchased or an exempted use. Nova Scotiasuncontrolled exemption or the use o pesticides to control invasive species other thanplants, in particular, opens a signicant loophole or the sale and use o insecticides thatare not on the list o allowable pesticides. Although there are at least restrictions on which


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pesticides can be used under some exemptions (e.g., the exemption or the use opesticides to control plants that are poisonous to the touch extends onl to glphosateproducts), there is no parallel restriction in the case o the exemption or the o controlinvasive species other than plants.

To the extent that provincial bans on the cosmetic use o pesticides allow or exemptions,

permits should be required -- as is the case in New Brunswick when a compan seeks toappl pesticides to more than 50 per cent o a lawn to treat a so-called insect inestation.Ontario also requires the approval o specied authorities in the case o certain exempteduses; or instance, to control invasive species and to maintain the health o a tree. When anexemption is approved, residents o the surrounding area should be advised o the plannedpesticide application and warning signs should be required on the perimeter o the pesticideapplication area or a specied time beore and ater the treatment. Retailers should also berequired to maintain a record o pesticides sales or exempted uses in order to monitor andaddress possible abuse. In addition, pesticides sold under exemptions should be packagedin single-use containers.

The restrictions on pesticide use in places requented b children, under QuebecsPesticides Management Code, currentl represent the best model in terms o acomprehensive ban with onl a ew limited exemptions. However, this section o the Codeapplies onl to earl childhood centres, dacare centres, preschools, and schools, eventhough these are not the onl places where children could be exposed to pesticides.

In contrast to the Ontario and Nova Scotia regulations, cosmetic pesticide bans in Quebec(apart rom more stringent provisions or areas requented b children), New Brunswickand Alberta onl appl to lawns and exclude other elements o landscaping. As a result,active ingredients banned or use on lawns ma still be available in products marketed orcosmetic use on gardens, trees and shrubs.

Among the provinces with more comprehensive cosmetic pesticide bans, New Brunswicksapproach is the most limited, given that onl one active ingredient is banned, and onlin lawn pesticides. Albertas approach, which bans onl herbicide-ertilizer mixtures,is even weaker.

A mechanism to classi new pesticides that appear on the market is important to preventprovincial bans rom becoming outdated. In this respect, Ontario oers the best model. Theclassication o new active ingredients based on lower-risk criteria ensures that the lists opermitted and banned products are kept up to date, which ma also help to promote thedevelopment o new, lower-risk products. Nova Scotias approach is also noteworth in this


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Allow municipalities to go beyond the provincial regulations and promotea coordinated approach

The Ontario and Nova Scotia bans do not allow municipalities to urther restrictpesticide use within their territor (other than the Cit o Haliax, Nova Scotia). Quebecallows municipalities to go beond the provincial ban, but Quebecs regulation is lessstringent than those o Ontario and Nova Scotia. From our perspective, the provincialregulator ramework must be as strong as possible to protect human health and theenvironment throughout the province. Municipalities should also retain the power toinnovate to urther restrict pesticide use beond the requirements o the provincial ban.It is also important to establish a coordinated approach or inspection and enorcement.

Enforcement, awareness-raising and research and development

A comparison o public-awareness programs and enorcement activities in the variousprovinces is beond the scope o this analsis. In most cases, such an assessment wouldbe premature because provincial cosmetic pesticide policies have onl recentl beenintroduced, and in the case o Quebec, our observations have alread been noted in our2008 report. In general, however, the ollowing considerations can help to ensure eectiveimplementation:

It is important to conduct unscheduled inspections to ensure full compliance with

the ban. It is also important for governments to evaluate and report on the status of

implementation and enorcement activities, including the number and tpe o violationsand compliance trends over time.

With respect to public awareness, its important to show citizens that alternatives to

pesticides work. Conerences, lectures, workshops, demonstration sites and televisionadvertising can help to communicate this message and persuade citizens to adopt newgardening techniques.

Public education campaigns must also seek to adjust popular perceptions of what

constitutes a beautiul lawn and promote understanding o health and environmentalconsiderations.

Governments should promote research and development projects in the area of

lower-risk products.


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Summary table: Comparison of key elements of provincial cosmeticpesticide bans

Element/Province Ontario Quebec N-S N-B/PEI Alberta

White list *

Scope extends

beyond lawns

Large number of

pesticides banned ** **

Covers new active

ingredients NA NA

Includes golf courses

Addresses indoor

pesticide use *

Municipalities retain the

power to further restrict

pesticide use

* Onl or areas requented b children.**But with exemptions that are not alwas well-controlled.


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4. Conclusion

On the basis o our analsis o Quebecs Pesticides Management Code, our 2008report Pesticide Free? Oui! made recommendations to optimize provincial rameworks

or cosmetic pesticide bans. Our review o subsequent developments in other provincesindicates that regulator rameworks in Ontario and Nova Scotia are most consistent withthese recommendations and oer the best model or protecting human health and theenvironment rom cosmetic pesticides, although there is still room or improvement.

We underscore the importance o: Extendingabantoallaspectsoflandscapinginpublicandprivateareas;

Structuring the ban in reference to a crediblelistofpermitted lower-risk ingredientsand

prohibiting the sale and use o all other pesticides; Providingamechanismtoclassifynewactiveingredients;

Requiring a permit for pesticide use under exemptions. Exemptions should only be

permitted i necessar to protect public health and saet;

Gol courses are currentl excluded rom the regulations in all provinces, which should becorrected.

It is important that the provincial ramework support municipalities wishing to urtherrestrict pesticide use beond the requirements o the provincial ban, and ensure coordina-tion between provincial and municipal governments or eective implementation.

Although beond the scope o this analsis, we also stress the importance o establishingan eective monitoring and enorcement program, including unscheduled inspections andother enorcement activities, as well as promoting greater public awareness o the ban andalternatives to pesticides.

We hope that polic-makers will draw on this analsis o lessons learned and undertake toimprove on the best available models. Our conclusions are particularl relevant or Quebec,which led the wa with the rst provincial ban on lawn pesticides in 2003 but has now lostits leadership position to other provinces, and or British Columbia, where the governmentis considering the results o a public consultation that avoured a provincial ban, as wellas or other provinces that ma consider adopting or strengthening prohibitions oncosmetic pesticides.


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References

Beond Pesticides, Februar 2011, Danish Government Agrees to Reduce Pesticideson Gol Courses. Available at: www.beondpesticides.org/dailnewsblog/?p=4971

(accessed March 24, 2011).

Legislative assembl o Ontario. Loi sur linterdiction des pesticides utiliss des nsesthtiques. Available at: www.ontla.on.ca/web/bills/bills_detail.do;jsessionid=c72d607830d724ce4b357340b9ab4c0ae2b13.e3eQbNaNa3eRe3iSaxuLahuOci1nknvrkLOlQzNp65In0?locale=r&BillID=1967 (accessed March 24, 2011).

Government o Ontario. Ontario Regulation 63/09. Available at: www.e-laws.gov.on.ca/html/regs/rench/elaws_regs_090063_.htm (consulted in March 2011).

Ontario Ministr o the Environment. Pesticide Classication Guideline or Ontario.Available at: www.ene.gov.on.ca/environment/en/resources/STD01_076412

(accessed March 24, 2011).

Gouvernement du Qubec, ministre du Dveloppement durable, de lEnvironnementet des Parcs. Code de gestion des pesticides. Les aits saillants. Available at:www.mddep.gouv.qc.ca/pesticides/permis/code-gestion/index.htm(accessed March 24, 2011).

Gouvernement du Qubec, ministre de lEnvironnement. Code de gestion des pesticides.

Mthodologie pour l tablissement de la liste des ingrdients actfs interdits (Annexe 1).Available at: www.mddep.gouv.qc.ca/pesticides/permis/code-gestion/index.htm(accessed March 24, 2011).

quiterre and the David Suzuki Foundation, 2008. Couper lherbe sous le pied despesticides. Analse du Code de gestion des pesticides du Qubec et recommandationspour une rglementation provinciale efcace.

Nova Scotia Government. Website Lawns and Ornamental Gardens - Non-essentialPesticides. Pests and Pesticides. Available at: www.gov.ns.ca/nse/pests/non-essential.pesticides.asp (accessed Januar 27, 2011).


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Nova Scotia Government, BILL NO. 61, 2nd Session, 61st General Assembl, Nova Scotia,59 Elizabeth II, 2010. Non-essential Pesticides Control Act. CHAPTER 6 OF THE ACTS

OF 2010. Available at: http://nslegislature.ca/legc/sol.htm (accessed Januar 27, 2011).

Nova Scotia Government. Exceptions to Prohibitions on Non-essential PesticidesRegulations. N.S. Reg. 184/2010. Eective April 1, 2011. Available at: www.gov.ns.ca/

just/regulations/rxam-z.htm#non (accessed Januar 27, 2011).

Nova Scotia Government. List o Allowable Pesticides Regulations. N.S. Reg. 181/2010.Eective April 1, 2011. Available at: www.gov.ns.ca/just/regulations/rxam-z.htm#non(accessed Januar 27, 2011).

New Brunswick Government, June 18, 2009. Le gouvernement interdira lutilisationde pesticides dans lentretien des pelouses. Available at: www.gnb.ca/cnb/news/

env/20090865ev.htm (accessed Januar 26, 2011).

New Brunswick Government. Page Internet La gestion des pesticides au N-B - Ce quevous devez savoir. Available at: www.gnb.ca/0009/0369/0024/0006-.asp#Homeowners(accessed Januar 26, 2011).

Prince Edward Island Government. Website Restrictions on Lawn Pesticides. Available at:

www.gov.pe.ca/envengor/index.php3?number=1030236 (accessed Januar 27, 2011).

Alberta Government, Alberta Environment. Fertilizer/Herbicide Combination Products.Facts at our ngertips. Available at: environment.alberta.ca/documents/Fertilizer-Herbicide-Combination-Products-Fact-Sheet.pd (accessed in March 24, 2011).

2011 progress report: a comparison of provincial cosmetic pesticide bans

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