Further to Proposed IPM Act Regulatory Changes Just Announced

By Jerry Rousseau

Regarding the BC Ministry of Environment’s proposed pesticide use regulatory change announcement circulated earlier today (October 9th, 2013), we encourage you to read the Intentions Paper carefully and submit your comments/ questions to MOE.  You are also encouraged to pass this information along to stakeholders who are not WCTA or BCGSA members.

Upon first review of the document, it appears the Ministry is targeting most if not all of the Special Committee on Cosmetic Pesticide’s list of 17 recommendations released in May of 2012.  Major regulation changes, if put into force, include:

• Home and business owners wishing to apply pesticides to private land will require similar licencing and certification as a commercial applicator unless using pesticides considered safe for use by untrained people.  In essence, MOE expects most homeowners and businesses will hire the services of a licensed company to apply pesticides considered unsafe to use without certification.

• Require notification of residents when pesticides are used on private landscaped areas.

• Remove provisions allowing uncertified applicators to apply pesticides under the supervision of certified applicators and establish an assistant applicator category that may perform some, but not all, of the duties of a certified applicator.

• Owners or managers of botanical gardens, cemeteries and golf courses on private lands will need to obtain a ‘pesticide user licence’ to apply pesticides.  Some golf courses already atone to this requirement if they are located on public land; all golf courses in BC will require this licence if the regulations are amended.  (Note that to qualify for a pesticide user licence, an applicant must employ certified pesticide applicators, have an address in British Columbia and pay a specified annual licence fee - $250 for a non-service licence and $250 to $1,000 for a service licence)

Other regulations are proposed and should be reviewed by all stakeholders including dispensers.  The implementation timeframe for the proposed revisions is relatively short with the Ministry intending to have changes enacted in two stages between 2014 and 2015.

On a highly related note:

Allied Golf Association of BC representatives will meet with the Environment Minister at 1:00pm tomorrow (October 10, 2013) in Vancouver.  This meeting had been scheduled before the announcement from MOE and was intended to discuss its suggestions for enhanced pesticide use practices within the industry.  In his Sept/Oct 2013 report, WCTA President Keith Lyall stated the following:

"Recently the Honourable Minister of the Environment, Mary Polak, a member at Redwoods Golf Course approached Doug Hawley, Redwood’s Managing Director and NGCOA Past President, and asked him what golf has done to date to meet the 17 recommendations. Needless to say, our joint Environmental Advocacy Committee met shortly after. This was our second meeting as a committee and I think we were not expecting a request from the Minister so soon, but there is no doubt that the sooner we get this nailed down, the less chance of further legislation against the golf/sportsturf industry."

The Allied Golf Association of BC's Environmental Advocacy Committee did meet in person on September 4th along with Doug Hawley, to review and ammend if necessary, the BC golf industry's list of suggestions for pesticide use practice improvements previously put forward to the Special Committee on Cosmetic Pesticides early in 2012.   

The original list was developed by the AGA-BC then titled 'Pesticide Advocacy Committee' after consultation with golf course superintendents throughout the province and with the respective boards of both the BCGSA and WCTA.  A full day of review and discussion by the 7 member committee on September 4th, which includes representation from AGA-BC, BCGSA, WCTA and CGSA, resulted in the following letter:

In response to the Special Committee on Cosmetic Pesticides recommendation #16;   ‘Ask the golf industry to develop a province-wide certification process, or to modify an existing one, that will ensure a high standard of pesticide use by all golf courses in BC, including the use of IPM principles.’

The Allied Golf Association of British Columbia (AGA - BC) offers the following options/ideas to further enhance public, employee and environmental protection relating to pesticide use in the British Columbia Golf and Sportsturf Management Industries.  We appreciate the opportunity to work with government to ensure the highest safety standards possible in registration, transportation, dispensing, storage, application and disposal of pest control products. 

Although very stringent regulations governing pesticides already exist in British Columbia, improvement is always possible and we would make the following suggestions aimed at enhancing BC golf and sportsturf management industry’s pesticide use practices:

• Mandatory pesticide applicator certification:  currently, only permit-restricted and restricted class pesticides require an applicator certificate for purchase and all uses.  The BC golf and sportsturf management industries would support enhancing applicator certificate requirements to include commercial class pesticides including pesticide applications made to private land.
• Enhanced applicator certification:  currently, the pesticide applicator certification is based on a comprehensive (3 hour) multiple choice open book test for which a 75% passing grade is required to achieve 5-year certification.  The BC golf and sportsturf management industries support this methodology but suggests enhancing applicator certificate training by mandating a practical component to the certification process.
• IPM certification:  the current BC IPM Act implemented in 2003, mandates an Integrated Plant Management approach to pest control product use.  The BC golf and sportsturf management industries support enhancing the existing framework of pesticide applicator certification to ensure a high standard of IPM principles rather than establish a separate system of IPM certification.
• Enhanced applicator recertification:  currently, a re-certification system is in place where certificate holders may renew their credentials through a system of ongoing education points rather than re-writing the test.  The BC golf and sportsturf management industry suggests that all pesticide applicators be required to satisfy ongoing education requirements as already exist and re-write the examination every 5 years in order to fully renew their pesticide applicator certificate.
• Independent classification for pesticide certification:   The BC golf and sportsturf management industries suggest creating a pesticide certification category independent of the current landscape classification. 
• Voluntary 3rd party facility accreditation:  currently, nine BC golf courses have been certified by the Audubon International Society Cooperative Sanctuary Program for Golf Courses, a voluntary environmental stewardship program with standards beyond current government regulation that apply specifically to golf courses.  Other similar programs/templates exist such as the Golf Environmental Organization (GEO) and International Standards Organization environmental achievement designation (ISO 14001).  The golf and sportsturf management industries suggest government encourages and incentivizes golf facilities to participate in a recognized environmental achievement program.
• Commitment to researching alternatives:  in partnership with government and other stakeholders, the BC golf and sportsturf management industries support a cooperative funding approach to research viable pest control alternatives. 

 The letter was ratified by the AGA-BC Board of Directors on September 11 and will be presented to Environment Minister, Mary Polak at a meeting scheduled for October 10th in Vancouver.  Representing the committee at this meeting will be Dean Piller, BCGSA President, Keith Lyall, WCTA President and Trevor Smith, AGA-BC President along with Doug Hawley acting as industry liaison.   

About AGA - BC

AGA - BC comprises all sectors of the golf industry including golf course owners (NGCOA), golf course managers (CSCM), golf professionals (PGA of BC), golf course superintendents (BCGSA), the governing body for amateur sport and players (BCGA), and the body mandated with turfgrass research and development (WCTA). 

Golf is the number one sport in Canada based on participation and is played by an estimated 812,000 resident golfers in British Columbia at over 316 golf course facilities.

The BC golf industry employs 47,000 people generating $1.08 billion in household income, $160.7 million in property and other indirect taxes and about $256.5 million in income taxes.

Golf in British Columbia generates $4.005 billion in total gross production through direct, indirect and induced spending impacts.  The total direct economic activity (total direct sales) resulting from the British Columbia’s Golf Industry is estimated at $2.01 billion. Of this total, the revenues generated directly by golf courses, and their associated facilities is estimated at $617.1 million.

For further information, please contact AGA - BC President Trevor Smith at trevor@keso.com