Here is a letter to the editor of the New York Review of Books, February 7, 2013:
“Dear Editor,
Tim Flannery in his review of the Biography of Rachel Carson makes one mistake and that concerns pesticide use reductions in Canada [“A Heroine in Defense of Nature,” NYR, November 22, 2012]. The first Canadian province to ban the ‘cosmetic’ use of specified pesticides and herbicides—i.e., for gardens and flowers, and not for commercial crops—was not Ontario (2009) but Quebec (2006).
This was the result of grassroots activity at the local, municipal level and it was backed by a national organization, the Campaign for Pesticide Reductions (CPR!), of which a leading sponsor (surprisingly perhaps) was the Canadian Labour Congress. The ban was backed by the Canadian Cancer Society, the first of many moves in the direction of cancer prevention, versus cancer treatment and research. Quebec’s move to ban the sale as well as the use of these products was a violation of the federal authority over commerce and it resulted in a challenge under the North American Trade Agreement (NAFTA, Chapter 13).
Some of Rachel Carson’s aims over pesticide use reduction could be achieved by a statute requiring the practice of Integrated Pest Management (IPM), which properly interpreted results in the avoidance, or use reduction, of synthetic organic chemical pesticides wherever possible. Canada, like most countries has not done this: pesticide registration or licensing is easy to get and once a pesticide is on the market, it is very difficult to prevent its proliferation or remove it from the environment. But unlike many Canadian environmental measures, the bans so far on the cosmetic use of pesticides are truly progressive.”
David Bennett
Former Director
Health, Safety and Environment
Canadian Labour Congress
Ottawa, Canada
The North American Trade Agreement is a free trade agreement between the United States, Canada, and Mexico. If you want to do business with the United States, you apparently are not allowed to ban the sale and use of pesticides.
San Francisco’s misnamed Integrated Pest Management policy
This seems a timely reminder of the difficulty of changing public policy regarding pesticide use. For the third year in a row, San Franciscans recently attended the annual hearing at which the city’s pesticide policy is renewed by the Environment Commission. Citizens reported the escalating use of toxic pesticides in San Francisco’s public parks by the so-called Natural Areas Program. They also repeated their annual request that pesticides considered “Most Hazardous” (Tier I) and “More Hazardous” (Tier II), not be sprayed in public parks.

Once again, the public’s request fell on deaf ears. In fact, the only changes to the city’s pesticide policy liberalized the use of pesticides by the Natural Areas Program. Milestone which had been rated “Most Hazardous” in the past has now been downgraded to Tier II. This is the pesticide that is mobile in the soil and persists in the soil for a long time. It is banned by the state of New York for sale or use because of concerns about the potential of poisoning ground water. Yet it is used in San Francisco in the watershed to Islais Creek.
Also, Garlon (Tier I) can now be sprayed without the applicator wearing a respirator, which will make it easier and more likely to be used in the future.
However, these two revisions of the city’s pesticide policy pale in comparison to the recent decision of the Recreation and Park Department with respect to promoting the use of pesticides in the city’s parks. The Recreation and Park Department recently announced that the person in charge of the Natural Areas Program is now also in charge of the Department’s pesticide use. This inappropriate decision effectively removes all pretenses that the Natural Areas Program’s use of pesticides is being monitored or supervised. The Natural Areas Program is now free to use pesticides wherever and whenever they wish.
Mr. Bennett makes a mistake in his letter to the editor. He assumes that an Integrated Pest Management policy would avoid or at least reduce pesticide use. San Francisco calls its pesticide policy an Integrated Pest Management program. That policy has obviously not reduced pesticide use in San Francisco’s parks. In fact, it seems to facilitate the use of pesticides. Pesticide use by any name is still pesticide use.