Why Proper Implementation Matters as Much as Good Science

The Pest Management Regulatory Agency (PMRA), under Health Canada, is responsible for regulating pesticide use in Canada. Its mandate is clear: to ensure that pest control products pose minimal risk to human health and the environment. In a perfect world, this would be ideal. That mandate matters. But so does how those decisions play out on your farm. Agriculture does not operate in a vacuum. When a crop protection product is cancelled or restricted, the impact does not stop at the label. It moves through production practices, input decisions, grain handling systems, and cross-border trade. Canada’s scientific review process is respected around the world. The issue is not weak science. The issue is what happens after the science is done. Two recent examples highlight the gap between regulatory decisions and on-farm reality: the cancellation of strychnine and the re-evaluation decision regarding lambda-cyhalothrin (lambda-cy).

CASE STUDY 1: THE BAN ON STRYCHNINE

The request for emergency use of Strychnine was denied in 2026, following it being banned in 2024. In its decision, the PMRA raised concerns about environmental risks, particularly impacts on non-target wildlife. It also cited the availability of five alternative products. On paper, the transition appears straightforward: a product poses environmental risk, alternatives exist, and therefore the product is removed from the market.

But what supported the transition?

1. Were producers properly trained on how to effectively use alternative products?
2. Were integrated pest management strategies updated and disseminated?
3. Was monitoring conducted to assess whether alternatives were being used correctly and effectively?

Without education and transition planning, producers may use alternative products in the same manner as the discontinued chemistry. If alternatives are less effective per application, producers may compensate through multiple applications. Over time, that can create new environmental pressures, undermining the original goal of the decision. When a regulatory action disrupts established production practices, it should be accompanied by a coordinated action plan that includes training, stewardship, monitoring, and adaptive feedback mechanisms.

CASE STUDY 2: LAMBDA-CYHALOTHRIN AND FEED RESTRICTIONS

In 2023, the PMRA issued a re-evaluation decision for lambda-cyhalothrin that restricted its use on crops destined for animal feed. The concern was that residues could accumulate in livestock tissue and potentially affect human health. While precautionary, the decision raised significant operational concerns.

Agronomic Reality

In most crop systems, lambda-cy is applied prior to flowering and seed development. By harvest, no residues have been detected in the grain. The restriction raised questions about whether sufficient consideration was given to real-world application timing and agronomic practice.

Supply Chain Integration

The North American grain system operates as an integrated bulk handling system. Grain designated for food and feed moves through the same infrastructure. Operationally, segregating “feed-only” versus “non-feed” grain at scale is highly impractical and economically disruptive.

Moreover, the North American grain market is deeply integrated. Canada restricted lambda-cy for feed use; the United States did not. This created an enforcement paradox as U.S. producers may apply lambda-cy, move grain across the Canada-U.S. border and the same grain could ultimately be used for livestock feed in Canada.

In effect, domestic producers face regulatory constraints that may not meaningfully reduce exposure risk while potentially creating competitive disadvantages and enforcement inconsistencies.

Looking at the Bigger Picture

The question is not whether pesticide risks should be evaluated rigorously. They should be! The question is whether decisions are assessed through a full operational lens that considers:

• On-farm agronomic realities
• Adoption behaviour and producer training
• Supply chain logistics and infrastructure
• Cross-border trade integration
• Whether rules are enforceable in practice
• Competitive parity with key trading partners

A more holistic approach would integrate regulatory science with economic, operational, and trade analysis prior to final decision-making.

In practical terms, this could include:

1. Clear transition frameworks when products are cancelled.
2. Mandatory stewardship and training programs

when alternatives are introduced.

• Operational feasibility assessments before imposing use-pattern restrictions.
• Cross-jurisdictional alignment reviews, particularly with the United States.
• Post-implementation monitoring to evaluate real-world outcomes.

FINAL THOUGHT

Canada’s regulatory institutions are strong. The PMRA’s scientific integrity is not in question. However, regulatory excellence must extend beyond risk assessment to include implementation strategy. It must also work in the field, in the elevator, and in the marketplace.

When decisions account for how agriculture actually operates, they are more likely to achieve their intended outcome: protecting human health, safeguarding the environment, and keeping Canadian producers competitive.

For farmers, the difference between a sound decision and a workable one often comes down to implementation. And implementation is where policy meets the farm gate.

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