Mar 312006
 

Normally I would shout and dance for joy.  Surely this is a victory.

We’ve been working on vaporooter since 2003.  (Vaporooter is a chemical mixture used to dissolve tree roots in sewer lines.) 

When you read how the Government (Health Canada,  Pest Management Regulatory Agency (PMRA)), is handling the de-registration, you will understand why there is no joy.

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CONTENTS

(1)  BRIEF STATEMENT OF ISSUE (letter to City Council, today).

(1a) COMMUNICATION OF INFORMATION TO OTHER COMMUNITIES

(2)  ELABORATION, WHAT DID THE Pest Management Regulatory Agency (PMRA) HAVE TO SAY?

(3)  CONTACT OTHER COMMUNITIES TO STOP USE OF VAPOROOTER, A DE-REGISTERED PRODUCT THAT POISONS WATER SUPPLIES.

(4)  LETTER TO “INTEGRATED PROBLEM-SOLVING OF POISONS IN WATER SUPPLY”.   (In another posting.)

(5)  PMRA HANDLING OF VAPOROOTER IS CONSISTENT WITH HANDLING OF MECOPROP AND UNACCEPTABLE.

(6)  I WILL BE IN OTTAWA NEAR END OF AUGUST, AM WORKING ON ARRANGEMENTS THAT (MIGHT?! HAH) RESULT IN MEETING WITH TONY CLEMENT, MINISTER OF HEALTH. 

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(1)  BRIEF STATEMENT OF ISSUES (letter to City Council, today.  I will be speaking at Council tonight. Started this in 2003.)

RE:  Use of Vaporooter in Sewer

(Your File No. CK. 375-1)

Dear Mayor and Councillors,

I presume you have been advised by the Administration:

Vaporooter was de-registered, effective date given is March 31, 2006 by Health Canada, Pest Management Regulatory Agency (PMRA).

Today I am calling and emailing information to upstream communities that are using Vaporooter.  I am asking those communities to stop using vapo-rooter because we are downstream from them, and receive the combined impact of the poisons put into and washed into the River by every community from Banff and Calgary right on down.

 The PMRA believes it is acceptable that they not disclose the reasons for the de-registration.

Nor do they accept responsibility for notifying the communities in Canada that vapo-rooter is de-registered.

 Respectfully submitted,

Sandra Finley

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(1a) COMMUNICATION OF INFORMATION TO OTHER COMMUNITIES 

I will be contacting communities and asking them to stop putting vaporooter down their drains because:

–  it is a de-registered product.

–  one of its two ingredients is a known carcinogen.

–  there is no known protocol for removing vaporooter from the water supply, once it gets in.

–  there is no known test available to determine whether one of the two ingredients is in the water supply.

–  the cost for one test to see if the testable ingredient is in the water is $3000 a pop.

–  scheduled once-a-year augering works just fine to remove tree roots from sewer lines until such time as old pipes can be replaced.  The problem of tree roots is associated with old infrastructure.  It is unwise to poison the water supply for a temporary problem.

High levels of disease (cancer, Parkinson’s Disease, etc.) and developmental problems are associated with the poisons we are putting into our water, air, soil and food supply.

 I will be asking the communities that are upstream from Saskatoon to stop the use of vaporooter, because it affects the health of people downstream, here in Saskatoon. 

For people whose water supply isn’t the River:  poisons seep into underground waterways.  And they evaporate, as in the case of acid rain.

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(2)  ELABORATION, WHAT DID THE Pest Management Regulatory Agency (PMRA) HAVE TO SAY?

 Vaporooter is an example used to illustrate how the system works.  It doesn’t work to protect “the commons”;  it puts industry interests first.  I have been told by the PMRA that the Government is not going to do the job of notifying communities that vaporooter is de-registered.   They have only notified the supplier. 

From my perspective: we are the ones who drink the water.  If the Government isn’t going to look after it, we will.  We aren’t useless beings.  With our networks, we can improve things.  And if we have to step in to perform the function of the PMRA, so be it.  I have stated before, in relation to the cities and towns and province (Quebec) that have banned the cosmetic use of pesticides registered by the PMRA, that the PMRA is making itself irrelevant.

 The PMRA is a hindrance to getting the job done because the mantra is “If the product is licensed by the PMRA, and if used according to label instructions, then the product is safe to use.”  The example of vaporooter once again shows the dishonesty of the statement.  Vaporooter is de-registered; it is unsafe.  The public isn’t told.  Mecoprop is another example: the industry has from 2004 until 2009, 6 years, in which to continue sale of the product. Then the registration of the product will be cancelled.  They are quietly allowed to sell off their inventory, so as to avoid any financial inconvenience. While the public is spun the mantra:

“safe if used according to label instructions”.  Different rules apply to these companies.  If the product was tainted beef, then the unsafe product would be pulled immediately from the shelves.

The failure of the regulatory system has extremely serious consequences for our own health and for the health of children in particular.  The public is maintained in a state of ignorance about the products.  You find wording such as, “The industry has agreed to …”.  Why wouldn’t they agree to have 6 years in which to get the products off the shelf?  But why should we stand stupidly by and allow our water supplies to become more and more poisoned?

We know the increase in disease rates and developmental problems.  Are we so disempowered that we won’t stand up to the Government when it serves the corporate interest?

Paul Sawatsky is the regional enforcement official for the PMRA.  For newcomers:  I phoned Connie Moase, the head of the PMRA – – spoke by phone with her, and then with Karen McCullagh who is head of Enforcement for the PMRA.  I met in person with Paul Sawatsky who is the Regional enforcement officer.  The point I made with Paul and with “Ottawa”: the problem is NOT with enforcement.  It is with licensing.  The PMRA is licensing highly poisonous products which most communities are incapable of removing from their water supplies.  This is obviously true of communities that empty their sewers into a body of water with zero treatment.  It is true of communities that only have primary treatment.  It is most likely true of communities that have secondary treatment.  It is possibly also true of the few communities in Canada that have so-called “tertiary” or third level treatment capability. 

With vaporooter there is no known test to see if one of its two chemical components is in the water supply (we know that it’s been put down the drain;  we can’t test to see if it’s in the water).

In my conversations with the PMRA, I said, “You say that vaporooter is safe, “If used according to label instructions”.  The instructions say that the water into which vaporooter goes, has to be “controlled” or “treated”.  What do you mean by “treated”?  Does it mean that the water has to go through a water treatment plant?  Or does it mean that the water has to be specifially treated for the removal of the particular chemical components?

 The answer was:  this is a question that the PMRA is now addressing.  They don’t know what their labels mean. 

It is obvious if you know a little about the actual water treatment systems we have, about the total lack of capability to test for the presence of some chemicals in the water, and the cost of testing for others ($3000 for a test for just one chemical, for example) that you cannot just release the poisons into the water and rely on the water treatment plants to remove them. 

We discovered that in the case of vaporooter, no one could come up with a protocol to remove it from the water.  “Safe if used according to label instructions?”  If the label instructions require that the water be treated, it has to be treated to specifically remove the specific poisons that were put into the water.  If that is the case, then someone who puts the poisons into a sewer line, must show me the place along the sewer line where they are catching and treating the contaminated water.  Presumeably it is at the place where the sewer line from the individual property joins the artery city sewer line.  I need to see the equipment and the protocol they use to remove these specific poisons.  But as stated, in the early work on vaporooter we searched for such a protocol.  No one was able to produce one.

Presumeably the PMRA would have produced one, if they know of one.

This is all pretty damning.  Since 2003 I have been submitting evidence to the City, calling on it to cease and desist in the use of vaporooter.  The augering out of tree roots has worked just fine for decades.  It is cost effective if you are required to address the so-called “external costs”, those such as increased healthcare and environmental costs that are borne by the society at large, not by the manufacturers of the products.

 We have communicated directly with the Government (Tony Clement, Minister of Health) and with the officials at the PMRA (Connie Moase and Karen McCullagh among others).

 So what happens? …  I phone the local official to inquire.  “What is the status of your report on vaporooter?  I will be making another presentation to City Council and would like to provide up-to-date information.”

 The official provided me with all the information I need;  I am grateful to him.  He has worked with the City and with the Company to whom the vaporooter work is contracted out locally.  His report concludes that the City and Company are in compliance with the regulations.  No laws are being broken. 

Then he mentioned that vaporooter has been de-registered, as of March 31st.

Nothing to do with this work on it.  …  Had I not phoned to ask for an update on the investigation and report, I would not have known about the de-registration.  In spite of having talked on the telephone with Connie Moase and Karen McCullagh, no one communicated that vaporooter is now de-registered. 

This is disturbing to me personally because of my involvement.  The other information provided by the official is disturbing from the perspective of what is expected in a democracy.

 The PMRA will only notify the supplier of vaporooter that it is now a de-registered product. It will not notify the towns and cities whose water supply is affected. I presume the product will remain on the market until the supplier has sold all his current stock.  (I presume based on the experience with the chemical mecoprop.) 

I asked for the reasons why vaporooter was de-registered.  And was told that the officials are under instruction not to discuss those reasons, even if they know them.

I asked:  if vaporooter is de-registered, does that mean that one or both of the chemical ingredients in vaporooter is also de-registered?  The answer is “not necessarily”.  A product can be de-registered, or ingredients can be de-registered.  The public is not privy to the reasons for de-registration.

And the officials cannot talk about it.

Paul, the official, mentioned that there can be an application to re-register vaporooter.

I said to Paul that such a system makes it impossible to fix problems.  He might know of problems or solutions to them, but because of a general gag order, he (civil servants) will feel inclined to keep mouths shut.

The PMRA is not notifying anyone, except the supplier, when the product is de-registered.  How are people to know that the product is extremely problematic;  they shouldn’t be using it if it is de-registered?  And how are we to know when an application is made to re-register the product?  Are the PMRA and the company just waiting until the heat is off?  Will a different supplier approach to register the product?  No one outside the first supplier and some people in the PMRA know that the product is de-registered … isn’t it ideal to be dealing with an ignorant public?  If no reasons are given for de-registration, how is the public to know that re-registration is justifiable?

I didn’t ask Paul, but Connie Moase, head of the PMRA needs to answer:  Upon what basis is the information kept secret from the public?  Show me the legislated justification.  Specifically why isn’t it public information?

If vaporooter is de-registered, there are no label instructions under which it can be used.  (“Safe, if used according to label instructions.”)

McGill’s is the local vendor in the Saskatoon area of vaporooter.  McGill’s supplied City Administration with a list of communities that are using vaporooter to support the argument that it’s okay to put the poison down the drain because all these other communities are doing it, too.

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(3)  CONTACT OTHER COMMUNITIES TO STOP USE OF VAPOROOTER, A DE-REGISTERED PRODUCT THAT POISONS WATER SUPPLIES.

 Will you contact your Council to see if vaporooter is used in sewer lines?

Bring them up-to-speed:  vaporooter is de-registered because it poisons the water supply.  It is obvious that no one else will be doing this for us.  It falls to us to protect our water supplies.

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(4)  LETTER TO “INTEGRATED PROBLEM-SOLVING OF POISONS IN WATER SUPPLY”.    (In another email.) 

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(5)  PMRA HANDLING OF VAPOROOTER IS CONSISTENT WITH HANDLING OF MECOPROP AND UNACCEPTABLE.

From the PMRA (2004):

 ” … In order to achieve an orderly phase-out of products containing racemic mecoprop, the registrants of the technical active ingredient have agreed to limit sales of the technical active ingredient in 2004 to a maximum of their annual average over the past five years. Beyond 2005, sales of existing end-use products in the possession of those other than the registrant as well as use of end-use product by users is permitted until 31 December 2009 when the registrations will be cancelled.”

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(6)  I WILL BE IN OTTAWA NEAR END OF AUGUST, AM WORKING ON ARRANGEMENTS THAT (MIGHT?! HAH) RESULT IN MEETING WITH TONY CLEMENT, MINISTER OF HEALTH.

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