Questions To and Answers From the PMRA
(Pesticide Management Regulatory Agency)

Question and Answer Sets
I hope that some confusion concerning what the federal regulations allow and do not allow in regard to 'alternative materials' for control of particular pests is understandable, if not forgivable, at least for persons who have not been through pesticide use training courses. Even the advice provided on a number of provincial and municipal documents that I have viewed (for several provinces and municipalities) appears to be inconsistent with the federal regulations.

I had assumed that as insecticidal soap is listed as a permissible material in HRM's Administrative Order No. 23, it could be used on chinch bug. Kevin Brooks of Clean Nova Scotia enlightened me on this matter: in 2003 when Clean Nova Scotia was advising use of insecticidal soap to deal with the outbreaks of chinch bugs, he was told quite emphatically by a local vendor of pesticides that insecticidal soap is NOT useable for this purpose because chinch bug is NOT LISTED as one of the target pests on insecticidal soap product labels.

I then checked various PMRA documents and consulted the ELSE database and it seemed possible that even household soap - a commonly suggested alternative to pesticides for pests generally - could not be used for chinch bug control; nor could garlic or any other household material for that matter because "unless expressly exempt by regulation under the Act, all pest control products must be registered and be issued a PCP Act registration number before being permitted for sale, import or use in Canada."[1]

I posed the questions in these pages to the PMRA to (i) confirm that pesticidal soap and diatomaceous earth are NOT permitted for control of chinch; (ii) to determine if household soap is allowed (i.e. expressly exempt) and (iii) how permits might be obtained for exceptional use of alternative pesticidal materials that are not currently licensed for use against chinch bug.

To avoid any ambiguity in reporting on these issues, the questions and answers are given as posed and received. -dp

1. Pest Management Regulatory Agency Fact Sheet on The Regulation of Pesticides in Canada. Available under Consumer Information on the PMRA website. From the Introducton to this document: "Pesticides are carefully regulated in Canada through a program of premarket scientific assessment, enforcement, education and information dissemination. These activities are shared among federal, provincial/territorial and municipal governments, and are governed by various acts, regulations, guidelines, directives and bylaws. Although it is a complex process, regulators at all levels work together towards the common goal‹helping protect Canadians from any risks posed by pesticides and ensuring that pest control products do what they claim to on the label."

Page posted 5 May 2004
Edited 17 May 2004