Re: ERO-019-5507 The…

Comment

Re: ERO-019-5507

The Government of Canada's information on Calcium Disodium EDTA hydrate advises that it is extremely irritating to the eyes. It stated that health impacts will be avoided when the herbicide is used according to the Label. When applying this new herbicide, people are not to be present and are to stay clear of the treated area until Indole-3-Butyric Acid dries.

This procedure will not protect any animals or insects residing in the treated zone. If Indole-3-Butyric Acid can irritate eyes, then anything living in the treated areas will be exposed. As an example, I am attaching images of chipmunks with a den in an area treated with another PMRA legal pesticide which is also listed as safe for people who stay out of the treatment zone until the chemical dries, but is known to irritate eyes. My observation was a first chipmunk with a severely irritated eye immediately after its den was sprayed, which became obviously blind after a few months, and a second chipmunk with a severly irritated eye after a subsequent spraying.

If you allow Indole-3-Butyric Acid to be applied over animal habitat, then those species will pay the price of exposure. If it's not safe for humans to be exposed directly to, then why is it acceptable to expose animals?

It's been more than a decade since Ontario enacted it's Cosmetic Pesticide regulations. In that time, Ontario has not been overrun with weeds and safer herbicides used since 2008 have promoted health for people and the environment. This proposed change to the Cosmetic Pesticide Laws is undermining the intention of the regulation.

I oppose the proposed change to allow Indole-3-Butyric Acid to be allowed under the Cosmetic Pesticide regulations.