WCTA Iprodione Submission to Health Canada

12.08.18-health.canada.logoJuly 11, 2016

Pest Management Regulatory Agency Health Canada

Re: Proposed re-evaluation decision (PRVD2016-09) regarding iprodione

Dear Sir or Madam:

On behalf of the Western Canada Turfgrass Association (WCTA), allow this letter to serve as our response to the proposed re-evaluation decision regarding the active ingredient, iprodione.

The WCTA is a 700+ member, not-for-profit industry organization representing professional turfgrass managers and the associated industry supply network in western Canada.  Areas under the management of these professionals include beneficial greenspace infrastructure such as golf courses, sports fields, parks and other maintained turf spaces, along with sod farms.

As a professional industry organization, the WCTA has a longstanding track record of supporting and promoting the safe use of pesticides in our work environments through proven IPM practices and close cooperation with government regulatory bodies.

• In 2002, our organization partnered with the BC Ministry of Agriculture to publish the comprehensive resource, ‘IPM Guide for Turfgrass Managers’.
• Since 2002, the WCTA has acted as an official Credit Coordinator for Pesticide Applicator Certificate ‘Continuing Education Credits’ in British Columbia, currently tracking points for over 300 individuals and designing many our annual educational offerings to include CEC’s toward maintaining an active pesticide applicator certificate.
• Our organization actively participates in the PMRA NOMULE committee helping represent the turf management industry.
• Since 2009, the WCTA has worked with the BC provincial government to craft Integrated Pest Management (IPM) legislation aimed at enhancing environmental protection.
• In 2009, the WCTA organized and chaired the national ‘Turf Industry Steering Committee’ in cooperation with the PMRA.

These ongoing efforts help ensure turf managers are well trained in all aspects of pesticide storage, handling, application and disposal, and are conscientious about choosing the appropriate product, proper equipment calibration, ensuring that applications reach target areas, and following specific label instructions with regards to the use of personal protective equipment, applying the correct rates and adhering to required re-entry intervals.

Iprodione is used extensively around the world and, although the product has had an established history of safe and effective use, the proposed amendment would completely eliminate its use.  This will have a significant negative impact on the turfgrass industry, in particular golf courses, whose business relies on the proper care and health of turf.

Based on participation, golf is the number one recreational activity in Canada with an estimated yearly participation of 5.7 – 6.0 million and direct spending of $19.7 billion.  The golf industry contributes $2.8 billion to the province of British Columbia’s GDP, $2.4 billion in Alberta, another $446 million in Saskatchewan and 104,000 jobs across the three provinces.  In addition, Swedish research from 2008 showed golfers are healthier and live longer than the average population.

Currently, there are a number of products registered for various diseases on golf courses that are either standalone or multiple active products.  These products are intended to control various summer diseases (dollar spot, brown patch, leaf spot, and anthracnose) as well as two winter diseases (grey and pink snow mould).  The multiple active ingredient products have been very effective in controlling snow moulds.

When present, summer diseases are treated monthly and usually are applied to golf greens only.  In order to prevent disease resistance, iprodione is rotated with chemistries from other fungicide groups resulting in a maximum of three summer applications.  For snow mould prevention, two fall applications are typically applied on greens and, in some cases, on tees and fairways.  Maximum application rates for summer diseases are 60 g/100m2 of active ingredient, while winter disease prevention rates of application are 52 g/100m2 of active ingredient based on the product, Trilogy.

Re-entry period for summer application is ‘once residues have dried’.  Fall applications are typically conducted after golf courses close for the winter and therefore pose no re-entry risk.  In-season post application activities where workers might handle plant material would include mowing, hole changing and turf repair.  Golfer exposure would occur as they handle equipment during the course of play.  Long-term exposure from application of iprodione is minimized because golf greens are typically mowed daily.

The WCTA considers the PMRA a valuable partner and appreciates the opportunity to present some of the concerns of our industry and membership.  If you would like to speak with us further, contact Jerry Rousseau, WCTA Executive Director at the number listed below.

Yours sincerely,

James B. (Jim) Ross
Chair – Research Committee Western Canada Turfgrass Association

Jason Pick
President Western Canada Turfgrass Association