Protecting Public Health and the Environment

The Need for a Pesticide Reduction Bylaw in Urban Settings

A Policy Proposal for Regina Prepared by Pascal Bongyu, B.Sc., MPH Candidate for the Saskatchewan Environmental Society (SES) Canadian Cancer Society (CCS) Lung Association of Saskatchewan (LAS)

P r o t e c t i n g P u b

TABLE OF CONTENTS
EXECUTIVE SUMMARY 1 1. INTRODUCTION.. 1

1.1. General context... 1 1.2. Decision request...... 2 1.3. Problem definition....... 3 1.3.1. Statistics on cosmetic pesticide use 3 1.3.2. Determinants of cosmetic pesticide use 6 1.3.3. City of Regina response to cosmetic pesticide use.......... 7 2. 2.1. 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 3. JUSTIFICATION FOR A PESTICIDE REDUCTION BYLAW... 7 Risk to human health 7 Risk to environment 10 Response from different jurisdictions to cosmetic pesticides. 12 Weaknesses in pesticide regulation. 13 Precautionary principle 14 Public support. 15 Government priority. 16 POLICY ANALYSIS. 16

3.1. Policy alternatives.. 16 3.1.1. Public education and awareness.. 17 3.1.2. Bylaw for vulnerable populations... 18 3.1.3. City-wide bylaw... 18 3.2. Criteria for comparing policy alternatives.. 19 3.3. Comparison of policy alternatives 19 3.3.1. Effectiveness. 19 3.3.2. Cost. 20 3.3.3. Economics. 21 3.3.4. Environmental implications.. 21 3.3.5. Social implications... 22 3.3.6. Implications for the City of Regina. 23 3.3.7. Implications for the provincial government of Saskatchewan. 24 3.3.8. Implications for the federal government 24 3.3.9. Legislative and legal considerations..25 3.5. Conclusion.. 26 3.6. Recommendations 27 4. REFERENCES.. 29 5. APPENDICES.. 34

P r o t e c t i n g P u b l i c

EXECUTIVE SUMMARY The use of cosmetic pesticides in urban areas is detrimental to human health, contributes to environmental contamination and threatens sustainability. In light of the foregoing effects, environmental scientists, public health researchers, clinicians and both the private and the public sectors have expressed concerns, calling for action from the government. 171 municipalities and 5 provinces have responded by enacting pesticide reduction bylaws and legislation respectively which is benefitting close to 24 million Canadians from unwanted exposure to synthetic lawn and garden pesticides. Paradoxically, there is neither legislation in Saskatchewan nor a bylaw in Regina despite the fact that both jurisdictions recorded the highest household use of pesticides in garden and lawns in Canada. As the evidence linking pesticides and illnesses grows, and based on the precautionary principle, a decision to reconsider and enact a bylaw is being requested from the City of Regina because it has the authority and responsibility to adopt such a bylaw restricting cosmetic pesticide use. This report suggests three policy options, namely: public education and awareness; a bylaw for vulnerable populations; and a city-wide bylaw. Policy alternative three, a city-wide bylaw was chosen as the preferred policy option because it has proven to be a more effective method of reducing cosmetic pesticide use in urban areas, it is socially desirable, ecologically viable and the benefits of a city-wide bylaw outweigh the cost. 1. INTRODUCTION 1.1. GENERAL CONTEXT A pesticide is any substance or mixture of substances, designated in the regulation that are intended, sold or represented for use in preventing,

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destroying, repelling or mitigating a pest (Saskatchewan PCPA, 1978). The term includes insecticides (which kill insects), herbicides (which kill plants), fungicides (which kill fungi and molds), and rodenticides (which kill rodents) (Friis, 2010). Cosmetic pesticides are those used for lawn, garden and landscape applications regarded as non-essential for aesthetic appearances only and not related to the growing of food, agriculturally economical gain or any health benefits (Cole et al., 2011). Synthetic pesticides were developed in the 20th century, mainly for use in warfare a historical reality that underlines their toxicity. Their use has broadened and now a wide spectrum of pesticides has become omnipresent in our environment (Arya, 2005). This has led to increased scrutiny of pesticides as the Canadian public becomes increasingly aware of their negative impacts on human health and the environment (Gallant et al., 2007). A significant question for health and environmental policy is how society should regulate pesticide use to ensure their most effective utility while at the same time minimizing the hazards and risk to public health and the environment. (Friis, 2010). 1.2. DECISION REQUEST The use of cosmetic pesticides in urban areas for lawn, garden and non agricultural landscaping applications is detrimental to human health, contributes to environmental contamination and threatens sustainability (Cole et al., 2011). A pesticide reduction bylaw is therefore necessary to protect the population of Regina as well as the environment from the negative impacts of pesticide use. The decision to reconsider and enact a pesticide bylaw is being requested from the Municipality of Regina because it is the level of government closest to the citizens of Regina, with authority to pass bylaws restricting or eliminating the use of cosmetic pesticides.
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The responsibility to restrict pesticide use by Canadian municipalities was upheld by the Supreme Court in 2001 and following the pronouncement, the Federal Pest Management Regulatory Agency (PMRA) also acknowledged the role of municipalities in regulating pesticide use (Cole et al., 2011). 1.3. PROBLEM DEFINITION 1.3.1. Statistics on cosmetic pesticide use

The prairie province of Saskatchewan is the greatest user of pesticides in Canada, accounting for an estimated 36% of total Canadian sales (Brimble et al., 2005). An overview of the percentage of pesticides sales in different Canadian provinces is presented in Figure 1 below. Figure 1: Percent Pesticides Sales by Province, 2001

(Source: Adapted from Presentation by Cessna JA on Public Health and Agricultural Rural Ecosystem. Water Quality. The National Water Research Institute, Saskatoon. Accessed March 2012) Simultaneously, cosmetic pesticide use has been on the rise in Saskatchewan since 1994 (see Table 1).

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Table 1: Households that used pesticides on their lawn or garden, by province, 1994 and 2005
Provinces Used pesticides 1994 2005 Pesticide users,1 2005 Pesticides applied as part of a regular maintenance schedule2 percent 48 Pesticides applied when a problem arose2

Newfoundland and 9 21 51 Labrador Prince Edward 12 14 48 53 Island Nova Scotia 19 18 50 50 New Brunswick 20 17 45 48 Quebec 30 15 55 40 Ontario 34 34 58 42 Manitoba 30 44 41 59 Saskatchewan 37 43 42 57 Alberta 36 39 48 53 British Columbia 30 29 45 55 Canada 31 29 52 47 1. As a percentage of households with a lawn or garden. 2. Some respondents specified a frequency of application other than "part of a regular maintenance schedule" or "when problems arose." This proportion is not included here so some row totals may be less than 100 percent. In addition, some respondents specified both frequencies of application so some row totals may exceed 100 percent.

Source: Lynch M. F., Hofmann N., 2007 In fact, Saskatchewan had the highest household use of pesticides in garden and lawns in Canada with 37% use in 1994 and 46% in 2007 compared to a national average of 31% and 25% respectively (Statistics Canada, 2007, 2009). Similarly, the city of Regina was among the top three cities (including Winnipeg and Saskatoon) for pesticide use with almost half of households using pesticides on their lawns and gardens (Statistics Canada, 2007). Although the agriculture sector is generally the largest user of pesticides by volume, the domestic sector is often the most intense user (i.e., kg active ingredient/hectare) (Brimble et al., 2005). An overview of the intensity of

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pesticide use in different sectors is presented in Figure 2 below. Figure 2: Pesticide use intensity by sector

(Source: Adapted from Presentation by Lalita A. Bharadwaj on Public Health Agricultural Rural Ecosystem. Pesticides. College of Nursing University of Saskatchewan) This use is significant because a large proportion of the population lives in cities and towns, and neighbors are exposed to each others practices. An American survey found that lawns treated with pesticides in Chicago averaged 9 kilograms per hectare per year while soya bean farmers used 2 kilograms per

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hectare per year (Parliament of Canada, 2000). A similar study in Alberta found approximately the same results in which domestic use was almost four times the intensity of agricultural use (Pesticide Use in Alberta, 1998). In 1998, the agriculture sector used 7,589 tons active ingredients and home and garden only used 72 tons active ingredients (Pesticide Use in Alberta, 1998). However the intensity of the agricultural use was only 0.8 kg ai/hectare while home and garden was 3.1 kg ai/hectare (Pesticide Use in Alberta, 1998). It is therefore evident that pesticide use is more intense in urban centers putting the population at greater risk of exposure to cosmetic pesticides. 1.3.2. Determinants of cosmetic pesticide use

Homeowner use of cosmetic pesticides is influenced by a multi-faceted mixture of social and environmental determinants including socioeconomic status, aesthetic beliefs, attitudes about neighborhood culture or home values, and a desire to avoid conflict with neighbors. This makes it challenging to influence at an individual level (Cole et al., 2011). Intensive consumer marketing of both the ideal of the perfect lawn and of the need for pesticides to achieve it have fostered deeply-entrenched behaviors, neighborhood norms and even municipal ordinances requiring certain standards of lawn and garden care (Cole et al., 2011). In Canadian surveys, prior to bylaw activity, approximately one third to one half of homeowners maintaining lawns and gardens reported using pesticides. Similarly, many lawn care and landscaping companies apply pesticides routinely as part of their service packages offered to clients to maintain weed- and insect-free lawns (Cole et al., 2011).

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1.3.3.

City of Regina response to cosmetic pesticide use

The paradox is that neither a provincial nor a municipal bylaw has been enacted in the province of Saskatchewan nor the City of Regina despite the fact that household pesticide use in both jurisdictions is one of the highest in Canada (Statistics Canada 2007; 2009). In the past, the City of Regina considered a bylaw restricting the use of cosmetic pesticides but rejected the idea in favor of Integrated Pest Management (IPM) and the establishment of Pesticide Advisory Committee (PAC) from key community stakeholders: Regina Health District, Citizen Member, Industry, Administration, School Boards, and Regina Urban Environment Advisory Council (City of Regina, 2002). The PAC had the responsibility of advising the Administration on pesticide matters such as: public education and awareness, city policy, procedures and methods, research and evaluation of alternatives to pesticides, monitoring community behavior and attitudes towards the use of pesticides (City of Regina, 2002). Recently, three parks (Gordon Park, Al Pickard Park, Queen Elizabeth II Court) have been designated as pesticide-free with the intention of reducing reliance on herbicides over the next three to five years (City of Regina, 2012). 2. JUSTIFICATION FOR A PESTICIDE REDUCTION BYLAW SURVEY It is becoming increasingly clear that the use of cosmetic pesticides in a manner not strictly controlled exposes the environment and all its inhabitants to chemicals that have health effects which are serious in consequence. 2.1. RISK TO HUMAN HEALTH The acute health effects of pesticides, including neurological, gastrointestinal, dermatological, respiratory manifestations (see Table 2) and

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even heart block, coma and death, are primarily linked to acetylcholine blockade (Arya, 2005). Worldwide, approximately 3,000,000 people suffer from pesticide poisoning annually, with 200,000 deaths mainly due to accidental exposure or intentional ingestion (Arya, 2005). In Canada, there are over 6,000 cases of pesticide poisoning yearly, although experts say that the actual figure is probably much higher (West Coast Environmental Law, 2006). Table 2: Effects of acute pesticide poisoning on different organs ORGANS Eyes Skin Nervous system Respiratory system Cardiovascular system Gastrointestinal tract SYMPTOMS OF ILLNESS Tearing, irritation, conjunctivitis Rash, blistering, burns, sweating, contact dermatitis, jaundice Headache, dizziness, mood disturbances, depression, stupor, muscle twitching, lack of coordination, seizures, paralysis, loss of consciousness, coma Sore throat, runny nose, cough, pulmonary edema, difficulty breathing, respiratory failure Cardiac arrhythmias Nausea, vomiting, diarrhea, abdominal pain

(Source: Adapted from a report prepared for the David Suzuki Foundation. Healthy Environment, Healthy Canadians Series. By David R. Boyd. Available at www.davidsuzuki.org/publications/.../DSF-pesticide-poisoning.pdf. Accessed February, 2012) Low but constant exposure levels may lead to long-term and chronic health impairment such as cancer (e.g. non-Hodgkins lymphoma, childhood leukemia, and breast cancer), reproductive problems (e.g. sperm abnormalities, birth defects), neurological disorders (e.g. Parkinsons disease, Alzheimers disease), organ damage and interference with the human hormone system (Arya, 2005). In 2004, the Ontario College of Family Physicians conducted a scientific literature review (30 high quality reviews and over 250 primary research studies) on the evidence linking pesticides to cancer and concluded that there is a

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statistically significant association between pesticide exposure and certain types of cancer (See Table 3) (Arya, 2005). Table 3: Chronic effects of exposure to pesticides PESTICIDES Triazine herbicides The herbicide 2,4D Phenoxy herbicides and carbamates The herbicides Glyphosate and glufosinate Fungicide Pesticides ASSOCIATED ADVERSE HEALTH EFFECT Increase breast cancer risk Linked to nonHodgkins lymphoma. Increase lung cancer risk Linked to congenital malformations in developing fetuses

Exposure had positive association with dermatitis.

Increase the childs risk of developing childhood acute lymphocytic. Leukemia through exposure during pregnancy Pyrethrin insecticides Associated with increased risk of Parkinsons disease and chromosomal abnormalities Longterm exposure to Associated with diseases such as Parkinsons disease, Glyphosatte and Alzheimers disease, Amyotrophic lateral sclerosis (ALS) glufosinate pesticide use. (Source: Adapted from Arya N. 2005. Pesticides and Human Health. Why Public Health Officials Should Support a Ban on Non-essential Residential Use. Canadian Journal of Public Health. Volume 96, NO. 2. March-April 2005) Everyone faces the risk of hazards resulting from exposure to pesticides but certain groups are more vulnerable to the effects of pesticides than others. Infants and children are particularly at risk due to their undeveloped immune systems, more permeable skin and behaviors (such as crawling on the lawn and putting objects in their mouths) (Arya, 2005). Pregnant women are a special risk group, evidenced by forty studies pooled in a meta-analysis which found that the risk of a child developing lymphoma or leukemia increased significantly when the mother was exposed
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to pesticides during pregnancy (Legislative Session, 2011). Another meta-analysis (Bailey, 2010) looking at home use of pesticides found a link between increased risk of childhood leukemia with pest-control treatments during pregnancy and early childhood years. Furthermore, a study of a large cohort of children in New York City which examined effects of pesticides (measured in urine of the pregnant mothers) on neurodevelopment of children over a number of years, showed some deficits in mental development following organophosphate exposure during pregnancy in newborns, babies of 12 months and children at six to nine years old (Vakil, 2004). These studies underscore the importance of protecting pregnant women from the harmful effects of pesticides in order to protect the fetus and young child and add to the evidence linking pesticides to childhood leukemia. Those who have multiple chemical sensitivities are also susceptible to pesticides. Statistics Canada recently reported that 2.4% of Canadians, more than 640,000 people, suffer from doctor diagnosed multiple chemical sensitivities (Arya, 2005). Chronic neurological diseases among the elderly (Parkinsons disease, amyotrophic lateral sclerosis, and Alzheimers disease), related to long-term pesticide exposure are incurable, which highlights the importance of prevention by reducing lifetime pesticide exposure (Ontario College of Family Physicians, 2011). 2.2. RISK TO THE ENVIRONMENT Once released into the environment, the fate of pesticides is affected by different processes, namely, transfer (adsorption, volatilization, spray drift, runoff, leaching, absorption and crop removal), and degradation (microbial, chemical, and photodegradation). Through the foregoing processes, not all of the applied chemical reaches the target site resulting in wasted chemical, reduction in pest

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control and more chance of damage to plants and soil and water pollution (Atmospheric Fate and Impact of Pesticides, 2007). The greatest potential for unintended adverse effects of pesticides is through contamination of the earth's hydrologic systems which supports human life, aquatic life and related food chains. Water is one of the primary media in which pesticides are transported from application areas to other locations in the environment (see Figure 2) (United States Geological Survey, 2007). Figure 2: Pesticide transport in the environment

(Source: Presence and levels of priority pesticides in selected Canadian aquatic ecosystems. Available at http://www.ec.gc.ca/Publications/default.asp?lang=En&xml=FAFE8474-C36046CC-81AB-30565982E897. Accessed February, 2012) In fact, groundwater tests have revealed that drinking water may contain residues of up to 39 different pesticides (Arya, 2005). Pesticides entering the aquatic system have been shown to harm salmon by causing changes in their reproductive and sexual characteristics (transgendering of fish species), weakening their immune systems, and

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changing their survival behaviors (Ewing, 1999). Depending on their chemical properties, pesticides can enter the organism, bio-accumulate in food chains and consequently influence human health (Pesticide Action Network, 2010). There has been a decline in bee populations by one-third in the past few years as a result of increasing pesticide concentrations in honeycombs. Bees play a critical role in the pollination of crops, and thus a threat to bee colonies can potentially affect entire ecosystems with severe implications for human food supplies, of which over 30% depend on pollination by bees (Environmental Law Center, 2010). Even though soil microorganisms are characterized by fast flexibility and adaptability to changed environmental conditions, the application of pesticides, especially long term, can cause significant irreversible changes in their population. Inhibition of species (earthworm, nematodes, mites, microarthropods) which provide key processes (decomposition, infiltration, reducing run-off reduction of organic compounds), can have a significant impact on the functioning of whole terrestrial ecosystems because all plants and animals that eat those plants, including humans, rely upon these organisms for sustenance (Pesticide Action Network, 2010). The use of pesticides results in several negative effects in the environment that cannot be ignored, considering the fact that the ecosystem provides goods and services that support human life and economic well-being. It is vital that measures restricting the use of cosmetic/non-essential pesticides are adopted to preserve and protect the environment from contamination and depletion. 2.3. RESPONSE FROM DIFFERENT JURISDICTIONS TO COSMETIC PESTICIDES In light of the widespread use of pesticides coupled with the potential health and environmental effects, environmental scientists, public health

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researchers, clinicians, the private and the public sectors have expressed concerns, calling for action from the government (Cole et al., 2011). Municipalities and provinces across Canada have responded by adopting pesticide reduction bylaws. Quebec was the first province in Canada where a municipality (Hudson) enacted a pesticide reduction bylaw, and the first province (2003) to enact provincial legislation banning the non-essential use of pesticides in all municipalities. Other municipalities have followed the lead of Hudson, evidenced by 171 bylaws across Canada, with additional ten pesticide bylaws pending adoption and the enactment of provincial legislation in Ontario (2009), Prince Edward Island (2010), Nova Scotia (2010), New Brunswick and Newfoundland and Labrador (2011) (The Coalition for a Healthy Ottawa (TCHO), 2010). It is worth noting that in none of the aforementioned jurisdictions was cosmetic pesticide use higher than in Saskatchewan or Regina. Yet they all adopted a pesticide bylaw which has led to a decrease in cosmetic pesticide use. Because of the bylaws enacted thus far, close to 24 million Canadians are now benefiting from enhanced protection from unwanted exposure to synthetic lawn and garden pesticides (TCHO, 2010). 2.4. WEAKNESS IN PESTICIDE REGULATION Although pesticide use is regulated in Canada (see Appendix 1), it has become clear over the past decade that government approval of a pesticide is no guarantee of safety (Arya, 2005). First and foremost, section 18 of the Pest Control Products Regulations (PCPR) states that registration must be denied where the use of a pesticide would lead to an unacceptable risk of harm to human health, plants, animals or the environment. Yet there is no standard definition of unacceptable risk in the Act or regulation (Vanhouwe, 2004). Secondly, studies generally measure
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only

short-term

effects

and

extrapolate, but do not measure long-term/chronic effects and additive or multiplicative effects of pesticides that are often present together in the same commercial products (Arya, 2005). Thirdly, testing does not take into account the fact that children have developing immune and neurological systems which may not react in the same way as those of adults and special considerations of the most vulnerable individuals in our society are not accounted for by current methods of testing, which impacts the accuracy of the risk assessment (Arya, 2005). In addition, while active ingredients are tested, other components such as formulants, stickers, spreaders, emulsifiers and solvents are not (Arya, 2005). Many of these, such as toluene or benzene, are known carcinogens (Arya, 2005). Moreover most pesticides were registered long before extra safety factors and present analytical methods were in place; many have not been reevaluated for decades. About 6,000 pesticides were registered by the 1969 Pest Control Product Act (PCPA) administered by Agriculture Canada before the Pest Management Regulatory Agency (PMRA). The vast majority have not been re-tested (Arya 2005). In summary, the deficiencies outlined above put human health and the environment at risk and thus lend support to the argument that cosmetic pesticide use in urban areas should be reduced through a municipal bylaw. 2.5. PRECAUTIONARY PRINCIPLE While there may be uncertainty as to the risks, it is prudent for decision makers to err on the side of prevention and take protective measures even when full scientific certainty is not conclusive, as stipulated in the precautionary principle, which states: preventive anticipatory measures should be taken when an activity raises threats of harm to the environment, wildlife, or human health,
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even if some cause and effect relationships are not fully established (Friis, 2010). There is extensive scientific evidence on the serious negative health and environmental impacts from the use of cosmetic pesticides, making it a case that merits the application of the precautionary principle. Thus, a municipal bylaw restricting the use of pesticides for cosmetic purposes does not seem unreasonable when human and environmental health is weighed against the desire for a pretty lawn. 2.6. PUBLIC SUPPORT In view of the national debate on the use of cosmetic pesticides, there is a growing list of organizations calling for a bylaw to reduce the needless risks from lawn and garden pesticides. Some leading non-governmental organizations and health groups (Canadian Association of Physicians for the Environment, the Canadian Medical Association, Ontario College of Family Physicians, Registered Nurses Association of Ontario, Canadian Nurses Association, Canadian Public Health Association) have been active in working to reduce the cosmetic use of pesticides as well as offering real alternatives to Canadians so they can enjoy green lawns without using dangerous chemicals (Arya, 2005). In this regard, the Canadian Cancer Society in Saskatchewan conducted a survey to gauge public attitudes among 44% of household using pesticides. Based on the survey, 60% of Saskatchewan residents supported restricting and sale of cosmetic pesticides, while 69% were in favor of phasing out cosmetic use of pesticides (Canadian Cancer Society, 2011). In 2003, studies showed that pesticide use was not a top-of-mind issue for Regina residents at that time. However the fact that 38% of homeowners used less pesticide than they did previously reflects a concern for the issue and a willingness to change (City of Regina, 2003). Furthermore, approximately 51% of residents support reductions in pesticide use by the City and one of the themes
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identified by respondents following the public review of a 2002 report on pesticides was a general dissatisfaction with maintaining the status quo. The question is, which policy option best addresses the issue of cosmetic pesticides in the city of Regina. 2.7. GOVERNMENT PRIORITY The City of Regina has been supportive of a pesticide-free park as is shown by the recommendation of the Community and Protective Services Committee to extend the pesticide-free designation of Gordon and Al Pickard Parks and Queen Elizabeth II Court (City Hall Grounds) which originally were designated to be pesticide-free beginning May 2010 on a one-year pilot project (City of Regina, 2012). In addition, the Enviromental Advisory Committee at its September 1, 2011 meeting adopted a resolution to form working group on the issue of becoming pesticide-free based on a report from the City of Reginas Community and Protective Services Committee concerning the status of pesticide-free park spaces as well as presentations from Canadian Cancer Society and the Saskatchewan Environmental Society. At the request of the CPSC, the Environmental Advisory Committee presented possible recommendations and adopted a resolution to provide further information to support the proposed recommendations, as well as possible implementation timelines (City of Regina, 2012). 3. POLICY ANALYSIS 3.1. POLICY ALTERNATIVES Scientists are well aware of the evidence linking cosmetic pesticide use to environmental contamination and different diseases such as cancer, reproductive effects and neurological disorders (Sanborn et al, 2004). Most of
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these diseases are not curable, which highlights the importance of prevention by reducing exposure to non-essential pesticide especially in Regina, which is one of the top three cities for pesticide use (Ontario College of Family Physicians (OCFP), 2012; Statistics Canada, 2007). Bringing to mind the precautionary principle, it is essential that the City of Regina adopt programs and policies that restrict the use of pesticides for cosmetic purposes in Regina. This document summarizes the benefits of decreasing cosmetic pesticides entering the environment and reducing the risk to public health, while at the same time presenting the public with a range of viable alternatives for sustainable landscape management. In the City of Regina, there is neither a pesticide reduction bylaw nor an education program to address the issue of cosmetic pesticide usage. One of the themes identified by respondents following the public review of the report on pesticides was a general dissatisfaction with maintaining the status quo. Given the fact that the current trend in communities throughout Europe and North America, including Canada, is finding the best way to limit the use of pesticides through bylaws or education, doing nothing is an option which will not be considered in this policy analysis. 3.1.1. Alternative 1: Public education and awareness

This policy option utilizes the principles of community-based social marketing during different phases of an education and awareness campaign. Using social marketing techniques to create effective education and outreach campaigns is essential because new knowledge in itself does not always translate into changed behavior. Social marketing techniques can help target the specific behavior that needs changing, identify the barriers that need to be overcome and provide the tools to support the desired behavior (Kassirer et al., 2004). The goals of the public education campaign would be to inform the Regina public about health and environmental risks involved in using cosmetic
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pesticides, to provide information on alternatives to pesticides and to help households transform their behaviors in reducing their use of pesticides (Saskatchewan Environmental Society, 2011). 3.1.2. Alternative 2: Bylaw for vulnerable populations

This policy option involves restriction of pesticide use on properties containing schools, day-care centers, senior citizens residences, hospitals and homes of people with medically proven sensitivities (Real Alternatives to Toxins in the Environment (RATE), 2011). The bylaw focuses on vulnerable populations such as pregnant mothers, fetuses, children, the chronically ill, the elderly, pets and the pesticide sensitive. The aforementioned groups are especially vulnerable for reasons ranging from undeveloped immune systems, more permeable skin and behaviors (children), closeness to the ground where pesticide concentrations are highest, direct exposure of chemically sensitive parts (pets) to compromised immune systems (elderly, chronically ill) (Arya, 2005; RATE, 2011). 3.1.3. Alternative 3: City-wide bylaw In this policy option, a bylaw is introduced in

The City of Regina currently has no bylaws regarding restrictions on cosmetic use of pesticides. conjunction with a comprehensive educational program. It is believed that in a typical jurisdiction, residents will support a residential pesticide use bylaw if education on alternatives is provided, and that this will lead to reduced pesticide use (Montagnese et al., 2007). This alternative would incorporate four components; education, implementation, enforcement and permitting. The first phase involves an education program to inform the Regina public about health and environmental risks involved in using cosmetic pesticides, provision of information on alternatives to pesticides and increasing public awareness of the impending bylaw and its facets. This can be achieved by
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applying the principles of community based social marketing. The second phase would comprise implementation and enforcement of a bylaw and the introduction of a permit system which allows the use of pesticides in exceptional situations where the pest infestation threatens the integrity of sensitive ecosystems, poses a serious economic loss to an owner or occupier of land, or to control the spread of invasive species or noxious weeds (District of Saanich, 2010). 3.2. CRITERIA FOR COMPARING POLICY ALTERNATIVES To determine the best policy alternative for the City of Regina, each policy option was evaluated based on: 1) Effectiveness, 2) Cost, 3) Economics, 4) Environmental implications, 5) Social implications, 6) Implications for the local government, 7) Implications for the provincial government, 8) Implications for the federal government, 9) Legislative and legal implications. 3.3. COMPARISON OF POLICY ALTERNATIVES 3.3.1. Effectiveness By providing the Regina public with information about health and environmental risks of cosmetic pesticides as well as information on alternatives, it is reasonable to expect that (like other health-related campaigns such as smoking or drinking and driving), a percentage of the population will modify their behavior to produce the desired outcome of reduced cosmetic pesticide use (MacLatchy, 2003). However, it is unlikely that this method alone will be sufficient to create a majority change in behavior (Montagnese et al., 2007). Bylaws restricting the use of cosmetic pesticides may prove to be a quicker and more effective method of reducing cosmetic pesticide use in urban areas because bylaws are mandatory and would motivate behavior change rapidly among residents and lawn care professionals (Kassirer et al., 2004; Cole et al., 2004 ).
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According to the Canadian Centre for Pollution Prevention, only those communities that adopted a bylaw in conjunction with educational programs, achieved reductions of 51% to 90% in comparison to low reductions of 10 to 24% in pesticide use where only education and outreach programs were used (Montagnese et al, 2007). In terms of effectiveness, a city-wide bylaw has a major advantage relative to education and awareness policy. Restricting the use of cosmetic pesticides for those who are susceptible will not produce the same results as a bylaw that applies to entire population. 3.3.2. Cost

There are cost implications for the City of Regina in all three policy options. Estimated budget for public education would consist of development of a communication plan, advertising and promotion, workshops and possible municipal administrative support (Kassirer et al., 2004). The cost estimate from the Canadian Centre for Pollution Prevention to implement an education program appears to be in the order of $CD 0.13 to $0.24 per person per year (Kassirer et al., 2004). Using the above range per person per year would result in a budget of CD$27,372 to $50,533 based on the current population of Regina which stands at 210,556 (National Post News, 2012). Budget estimates for a city-wide bylaw, would consist of elements mentioned in public education above including cost for drafting, implementation, permit review process, and enforcement (Kassirer et al., 2004). The cost to implement a city-wide bylaw appears to be in the order of $CD 0.50-$1.00 per person per year (Kassirer et al, 2004). Using the range above would result in a budget of CD$105,278 to $ 210,556 based on the current population of Regina. Regarding cost, education and awareness policy is less expensive than a city- wide bylaw.
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It is logical to infer that the cost for a bylaw focusing on the vulnerable population would lie between the cost for the education and awareness policy and a city- wide bylaw. 3.3.3. Economics

At the onset, a bylaw will have an impact on the lawn and garden care industry with some loss in business as consumers change their deeplyentrenched behaviors and attitudes and choose not to use pesticides for cosmetic purposes. This loss may be offset by consumers seeking firms to undertake alternative lawn and garden care services and retailers who sell alternative consumer products (MacLatchy, 2003). In reality, bylaws have benefitted landscape industries as shown in many jurisdictions. Since Halifax introduced a bylaw banning pesticides, the number of lawn care companies in the City increased from 118 to 180, according to Statistics Canada. The number of employees increased as well. In Toronto, from 2001 to 2006, the number of landscaping and lawn care sector businesses located in the City of Toronto grew each year, with an overall 30 percent increase during the period, similar to the increases in companies located anywhere in the Greater Toronto Area (36%) and across Ontario (32%)(Cole et al., 2004). With a transition period, companies will be given time to adjust to the new reality, diversify and develop products that respond to consumer demands (Cole et al., 2004). It is evident that a bylaw will have a positive effect on businesses that offer alternatives to pesticides. 3.3.4. Environmental implications

As the Regina public becomes more aware of the negative impacts of cosmetic pesticide use, they would be encouraged to explore environmentally friendly alternatives and practice proactive landscape maintenance, which in turn will reduce pollution of soil, surface and ground water. However, as already
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noted, education programs are not as successful as a bylaw combined with education. Consequently, the education and awareness policy will have some positive environmental effect while a bylaw brings the highest level of benefit from pollution reduction. Ontario's Ministry of Environment monitored 10 urban streams and creeks pre and post 2009 ban regulations and found a greater than 70% drop in the three most commonly used lawn pesticides (2,4-D, Dicamba, Mecoprop) (Todd, 2011). Also, phosphorus levels in the Huron River dropped an average of 28 percent after Ann Arbor adopted an ordinance in 2006 that curtailed the use of phosphorus on lawns (Flanigan, 2009). 3.3.5. Social implications

All three policy options have the potential to increase public awareness of the negative impacts of cosmetic pesticide use through education. Education through social marketing can be a potent force to motivate behavior change in which homeowners are able to reduce the use of cosmetic pesticides. This can stimulate the lawn and landscape industry to produce and market green products that are environmentally benign. On the other hand, a public information campaign aimed at reducing pesticide use may precipitate a counter campaign from the pesticide industry and applicators, just like the tobacco industry efforts to inhibit anti-tobacco media efforts. The resulting conflicting information can create confusion and might weaken efforts to influence the public to reduce pesticide applications for cosmetic purposes. With respect to both bylaws, the impact of a counter campaign will be minimal due to the mandatory nature of the both policy options compared to the education and awareness policy which is voluntary. It is worth noting that the predisposing (knowledge, attitudes, values,
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beliefs,

and

perceived

needs),

enabling

(availability,

accessibility

and

affordability of resources, skills, money, time, facilities, law), and reinforcing (peer influences, influences from other significant people such as health professionals, parents and teachers, law enforcement and the media, and campaign from pesticide industry) factors can either be barriers or facilitators for cosmetic pesticide use (Stevenson et al., 1997). Regarding the former, all three policy options have the potential to positively influence the aforementioned factors through education. However, both bylaws have a greater impact due to their mandatory nature. 3.3.6. Implications for the City of Regina

Adoption of a pesticide reduction bylaw presents some challenges regarding enforcement, as enforcement officers would require training in pesticide products and how they are labeled. As well, training would be required in pest management, soil sampling procedures and protocols, and horticultural principles in order to effectively enforce the bylaw as well as helping to inform residents regarding alternative uses to pesticides. In addition, it is likely that pesticides will be applied in the evening hours and on weekends when bylaw enforcement staff are not available. Furthermore, the passage of a bylaw will obviously result in an increase in calls/complaints to the City Hall (McHarg, 2007). To overcome this hurdle, steps should be taken to increase hours of service for enforcement in the initial year of the bylaw, which will have an impact on cost. On a positive note, bylaws reflect strong municipal leadership and can create a sense of civic pride and improve the image of the municipality and raise its profile as a community that cares about the health of its citizens and the environment.

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3.3.7.

Implications for the provincial government of Saskatchewan

Since the province delegates the power of municipalities, conflicts may arise when the City of Regina enacts a bylaw in areas already governed by provincial legislation (Vanhouwe, 2004). In Saskatchewan, the Pest Control Act may affect municipal powers. Section 4 provides that every person shall take measures to destroy, control and prevent the spread of all pests on any land or other premises owned, occupied or controlled by him (Vanhouwe, 2004). The focus of the legislation is the control of pests. However, if sustainable alternative measures are made available, conflict should be avoided. Municipal experiences with bylaw implementation were also important drivers for provincial legislation, prompting bans in Quebec, Ontario, Prince Edward Island, Nova Scotia and New Brunswick (Cole et al., 2004). A pesticide reduction bylaw in Regina might have the same impact across the rest of the province and pave the way for broad acceptance by the provincial government. This may lead to a provincial ban on sale and use of cosmetic pesticides, which in turn will protect all Saskatchewan citizens. A provincial ban supersedes local municipal pesticides bylaws to create one clear, transparent and understandable set of rules across the province rather than having multidimensional bylaws across the province. The benefits of a provincial approach to education includes the recognition that purchasing pesticides and the impacts associated with their use, crosses municipal boundaries. Exploring a provincial-wide approach to implement a public education campaign with neighboring municipalities could also help to reduce cost. 3.3.8. Implications for the federal government

Following recommendations by the House of Commons Standing Committee on Environment and Sustainable Development, Health Canada revised the Pesticide Products Act in 2002 but did not restrict products used for
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cosmetic purposes. Instead they deferred to the Supreme Courts decision granting municipalities the authority to restrict cosmetic pesticide use (MacLatchy, 2003). A pesticide reduction bylaw in Regina will increase attention to this public health issue and may contribute to the momentum that encourages the federal government to restrict products used for cosmetic purposes. Given the fact that many studies are now linking the use of pesticides to different diseases, especially among the vulnerable population, a pesticide reduction bylaw in Regina for the vulnerable population will focus attention on this public health issue. This may encourage the federal government to adopt the recommendations of the House of Commons regarding research on protecting vulnerable groups. These recommendations involved legal recognition of multiple chemical sensitivity syndromes. These recommendations may also encourage further funding of Health Canada and its government partners so that they can assess the relevance of existing research protocols involving vulnerable population groups, draft new protocols where necessary and pursue current research on the impact of pesticides on human health (particularly on vulnerable groups). This would prioritize the protection of the environment and human health, especially that of all vulnerable population groups and ensure legal protection, through the new Pest Control Act, for such groups (fetuses, children, seniors, women, persons suffering from multiple chemical sensitivity or in poor health, and professional users of pesticides) (Parliament of Canada, 2000). 3.3.9. Legislative and legal implications

There are no legal implications regarding policy option 1 (public education and awareness). There are also no legal implications with respect to a bylaw since they are consistent with the Supreme Court decision of 2001 in which the right of municipalities to enact bylaws to protect the health and wellPage 25

being of its citizens was upheld (Montagnese et al., 2007). 3.4. CONCLUSION The main goal of this policy analysis was to determine the best policy option which can be implemented to reduce the use of cosmetic pesticides in the City of Regina. The following conclusions can be drawn. In general, policy alternative three (city-wide bylaw) would be the most effective alternative, followed by policy option two (bylaw for vulnerable populations) and policy option 1 (public education and awareness). An education and awareness program would accrue the lowest cost, but would be the least effective alternative because it provides no implications for the local, provincial or federal government as well as no legislative or legal consideration. A city-wide bylaw would be the best policy alternative in terms of effectiveness, economics, environmental and social implications, but would accrue the most cost. Because it could have a positive impact on the provincial as well as federal government, a city-wide bylaw would be a valuable implement. Community education based on social marketing is an essential education model in changing deeply-rooted behaviors and attitudes towards cosmetic pesticide use. However, a bylaw supported by education is a quicker and more effective method of protecting human health and the environment. A bylaw for vulnerable populations is essential in protecting Reginas environment but does not address community-wide risk of exposure to cosmetic pesticide usage. With policy option three (city-wide bylaw), reduction of cosmetic pesticides can be achieved to the greatest extent and can therefore be seen as a pollution prevention strategy. Policy option one (public education and awareness) is the least expensive
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of all three options. However based on the analysis above, the benefits achieved from a city-wide bylaw outweigh the cost. All three policy options contribute to increased awareness of the negative impact of cosmetic pesticide use to human health and the environment as well as viable alternatives. See Appendix 2 for a succinct comparison of the policy alternatives in regards to the aforementioned evaluators. 3.5. RECOMMENDATIONS Mindful of the importance of protecting human health and the environment as stipulated in the precautionary principle, it is recommended that a pesticide reduction city-wide bylaw is enacted to minimize the negative impacts stemming from the use of cosmetic or non-essential pesticide consumption in the City of Regina. This policy option is the most sustainable amongst option 1 and option 2. It is socially more desirable, ecologically more viable and it is cost effective for achieving greatest results compared to policy options 1 and 2. In order to be most effective, it is suggested that the bylaw should be supported by an educational component that will facilitate change in deeply rooted behaviors and attitudes towards the use of pesticides in lawns and gardens, as well as inform the public on viable alternatives. A bylaw is only as good as its enforcement, education and permitting systems. Therefore, a comprehensive bylaw that incorporates the different substantive parts (the definitions of terms used within the act, the prohibition proper, general and specific exceptions to the prohibition, the rules by which exceptions are governed, and finally the penalty for contravention of the bylaw) should be enacted (Metcalf, 2011). By enacting a bylaw, the use of pesticides can be regulated to ensure their
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most effective utility while at the same time minimizing the hazards and risk to public health and the environment. The bylaw can, from a public health perspective, be seen as primary prevention because it reduces exposure to cosmetic pesticides. Reducing pesticides in the environment, can therefore, be a prudent cautionary action, particularly when good alternative approaches to cosmetic pesticides are available.

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4. REFERENCES Arya N. Pesticides and Human Health. Why Public Health Officials Should Support a Ban on Non-essential Residential Use. Canadian Journal of Public Health. 2005. Volume 96, NO. 2. March-April 2005. Atmospheric Fate and Impact of Pesticides. 2007. Available at http://www.eraorleans.org/AFIP/UK/pesticides.html. Accessed April, 2012. Brimble et al., 2005. Pesticide Utilization in Canada: A Compilation of Current Sales and Use Data. Environment Canada, Ottawa. Canadian Cancer Society. British Columbia and Yukon. Making the Case. U Turn for Change. 2011. Available at: http://www.cancer.ca/british%20columbiayukon/how%20you%20can%20 help/bc-take%20action/~/media/CCS/British%20ColumbiaYukon/Files%20Accessed March, 2012. City of Regina. Environment Advisory Committee (EAC-12-14). 2012. Available at www.regina.ca/opencms/.../committee...committee/.../eac12-14.pdf. Accessed April 2012. City of Regina. 2012. Pesticides-Free Park. Available at: http://www.regina.ca/residents/parks/find-field-park/pesticidefree_parks/. Accessed April, 2012. City of Regina. Pest Management Recommendations. 2003. Available at: http://www.regina.ca/opencms/export/sites/regina.ca/residents/parks/. media/pdf/ipm_recommendations_report.pdf. Accessed April, 2012. City of Regina. 2002. Reports on Pesticides. Available at: http://www.regina.ca/opencms/export/sites/regina.ca/residents/parks/. media/pdf/pesticides_report.pdf. Accessed April, 2012 Cole et al. Environmental Health: A Global Access Science Source. 10:74, 2011. Journal Article. Research Support, Non-U.S. Government. District of Saanich. Pesticide Reduction. 2010. Available at http://www.saanich.ca/living/natural/pesticide.html. Accessed March, 2012.
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Environmental Law Centre. University of Victoria. 2010. Submissions on Restricting Cosmetic Pesticide Use in British Columbia. Available at www.elc.uvic.ca/press/.../ELC-Submission-Cosmetic-Pesticides.pdf. Accessed March, 2012. European Union. European Union Policy for a sustainable use of pesticides. 2007. The story behind the Strategy. Available at http://ec.europa.eu/environment/ppps/pdf/pesticides_en.pdf. Accessed February, 2012 Ewing RD. Diminishing Returns: Salmon Decline and Pesticides, Oregon Pesticide Education Network. 1999. Available at: http://www.pcffa.org/salpest.pdf. Accessed March, 2012. Flanigan NR. Water Quality Improves after lawn Fertilizer Ban, Study Shows. 2009. Available at: http://ns.umich.edu/new/releases/7272. Accessed March, 2012. Friis RH. Essentials of Environmental Health. 2nd Edition. Sudbury, MA. Pesticides and Other Organic Chemicals. 2007; 7:141-145 Harrison et al. Report of the City of Charlottetown Cosmetic Pesticide ad- hoc Committee. 2007. Available at: http://www.city.charlottetown.pe.ca/.../PesticideCommitteeReportJuly20 07. Accessed February, 2012. Kassirer et al. The Impact of By-Laws and Public Education Programs on Reducing the Cosmetic / Non-Essential, Residential Use of Pesticides: A Best Practices Review. 2004. The Canadian Centre for Pollution Prevention and Cullbridge Marketing and Communications. Available at http://www.c2p2online.com/documents/Jay_Kassirer.pdf. Accessed February, 2012. Legislative Session: Fourth Session, 39th Parliament. Special Committee on Cosmetic Pesticides. Legislative Session, 2011. Available at: http://www.leg.bc.ca/cmt/39thparl/session4/cp/hansard/S11107p.htm#5:1415. Accessed May, 2012.
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MacLatchy P. Potential Municipal Strategies for Reducing Cosmetic Pesticide Use. 2003. City of Kingston. Report to Council No.: 03-120. Available at hwww.cityofkingston.ca/pdf/environment/pesticides.pdf. Accessed February, 2012. McHarg T. Implications of Implementing a Pesticide ByLaw. 2007. The Corporation of the Town OF Milton. Available at: http://www.milton.ca/MeetingDocuments/Council/agendas2007/rpts200 7/ES-039-07%20Pesticides%20By-Law%20Implications.pdf. Accessed March, 2012. Metcalf J. Legislating Pesticide Reduction in Saskatoon. A Report and Draft Bylaw Prepared for the Saskatchewan Environmental Society (SES) Pesticide Committee. 2011. Accessed February, 2012. Montagnese et al. Pesticides Use: Bylaw or Education Policy Research Review. 2007. Available at: http://www.simcoemuskokahealth.org/.../Pesticides_Use_Lit_Review.sflb. Accessed February, 2012. National Post News. 2012. Canadian Census 2011. Available at http://news.nationalpost.com/2012/02/08/canada-census-2011-canadasleads-g8-in-growth-population-hits-33-5-million/. Accessed April, 2012. Ontario College of Family Physicians. Implications of the Review of the Family Physicians. Available at: http://www.ocfp.on.ca/docs/pesticides-pap. Accessed February 2012 Pesticide Action Network Europe. 2010. Environmental Effects of Pesticides. An Impression of Recent Scientific Literature. Available at: www.paneurope.info/.../pesticides/.../Pesticides%20and%20environ. Accessed February, 2012. Parliament of Canada, 2000. House of Commons Committee. Pesticides in the Environment. Increasing Levels of Pesticides in the Urban Environment. Available at: http://www.parl.gc.ca/HousePublications/Publication.aspx?DocId= 1031697&Language=E&Mode=1&Parl=36&Ses=2&File=66 Accessed
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March 2012. Pesticide Control Product (Saskatchewan) Act 1978. An Act to Regulate and Control the Use, Distribution and handling of Pesticides. Available at: http://www.sarm.ca/assets/File/PREP_docs/Pest%20Control%20Products%2 0(Saskatchewan)%20Act.pdf. Accessed February 2012. Pesticide Use in Alberta.1998. Available at: http://environment.gov.ab.ca/info/library/7469.pdf Alberta Environment. Accessed March, 2012. Real Alternatives to Toxins in the Environment (RATE). 2011. Comparison of NS Provincial Pesticide Regulation and HRMs Bylaw P-800. Accessed February, 2012. Sanborn et al. Systematic Review of Pesticide Human Health Effects. Ontario College of Family Physicians. 2004. Available at: www.ocfp.on.ca/docs/publications/pesticides-literature-review.pdf. Accessed February, 2012. Saskatchewan Environmental Society (SES). 2011 Pesticide Reduction Project. Final report. Accessed February, 2012. Statistics Canada, 2007, EnviroStats, volume 1, number 2, "Canadian lawns and gardens: Where are they the 'greenest'?," catalogue number 16-002-XWE. Statistics Canada, 2009, Households and the Environment Survey 2007. Catalogue No. 11 526-XIE. Statistics Canada, 2008, Households and the Environment Survey 2006. Catalogue No. 11 526-XIE Stevenson et al. The Precede-Proceed Model: Application to Planning a Child Pedestrian Injury Prevention Program. 1997. Available at: injuryprevention.bmj.com/content/3/4/282.full.pdf. Accessed March, 2012. Todd A. Pesticide Concentrations in Ontarios Urban Streams One Year after the Cosmetic Pesticides Ban IPM Symposium January 10, 2011. Ontario Ministry of the Environment. Available at www.landscapeontario.com/.../1295274330.MOE_Update_-_Aaron. Accessed February, 2012.
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The Coalition for a Healthy Ottawa. Available at: http://www.flora.org/healthyottawa/news-flash.htm. Accessed February, 2012 United States Geological Survey. Pesticide in Ground Water. 2007. Available at: http://water.usgs.gov/nawqa/pnsp/pubs/fs244-95/gw_1.html. Accessed February, 2012 Vakil C. Pesticides and Health for British Columbia Special Committee on Cosmetic Pesticides. 2004. Available at: www.leg.bc.ca/pesticidescommittee/.../CAPE_Presentation.pdf. Accessed February, 2012. Vanhouwe C. Pesticide Bylaw Research. 2004. Saskatchewan Eco Network. Accessed February, 2012 West Coast Environmental Law. 2006. Pesticides and Your Health. Available at http://www.tenants.bc.ca/ckfinder/userfiles/files/Pesticides%20and%20yo ur%20Health%20-%20English.pdf. Accessed March, 2012.

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5. APPENDICES APPENDIX 1: Distribution of Principal Pesticide Regulation Responsibilities in Canada FEDERAL (PEST MANAGEMENT PROVINCIAL/TERROTORIAL MUNICIPAL REGULATORY AGENCY OF HEALTH CANADA) Pesticide registration and Regulation for the Bylaws for re-evaluation transportation, sale, municipal and in Human health and safety use, storage and some cases private assessment of pesticides disposal of pesticides and residential Environmental impact Training, certification, lands assessment of pesticides and licensing of Value (efficacy) applicators and assessment of pesticides vendors Alternative strategies for Spills and accidents pest management Permits and use Compliance and restrictions enforcement of Pest Compliance and Control Products Act(PCP enforcement Act) and regulation (Source: Pest Management Regulatory Agency (PMRA) homepage on internet. Fact sheet on the regulation of Pesticides in Canada. Available athttp://www.simcoemuskokahealth.org/.../Pesticides_Use_Lit_Review.sflb. Accessed February, 2012)

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APPENDIX 2: Summary of comparison of policy alternatives

POLICY ALTERNATIVES POLICY Effectiveness

Policy option 1: Public education and awareness

Cost

Low to marginal reduction (1024% and <10%) in pesticide use Low compared to policy option 2 and 3 because there is no enforcement cost. Cost lies between $CD 0.13 to $0.24 per person per year Effects at onset but off set by movement towards industries with green products Less reduction in pollution because it takes time to change deeply-rooted behaviors and attitudes since education program is voluntary Increase public awareness on negative impact of cosmetic pesticides and alternatives

Policy option 2: bylaw for vulnerable populations

Medium reduction in pesticide use

Policy option 3: City-wide bylaw

Large reduction (51-90%)in pesticide High cost compared to policy option 1 since bylaw focuses on entire population. Cost lies between $CD 0.50-$1.00 per person per year Some effect at onset of bylaw but long- term benefits as companies diversify to suit clients demands High reduction in pollution because bylaw will motivate behavior change since it is mandatory

Medium since bylaw focuses on vulnerable population rather than the entire population Some effects at onset but long-term benefits as companies diversify to suit clients demands Contributes to pollution reduction

Economics

Environmental implications

Social implications

Increase public awareness on negative impacts of cosmetic pesticides, alternatives as well as bylaws. Improve quality of life for vulnerable population

Increase public awareness on negative impact of pesticides, alternatives as well as bylaws. Improve quality of life for all by reducing exposure to cosmetic pesticides

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Implications for the City of Regina

Not applicable to policy option 1

Present challenge in enforcing bylaw (training of enforcement officers in pest management and soil sampling ) Conflict of interest if bylaw is enacted in areas governed by provincial legislation Might lead to adoption of recommendation from the house of commons(legal recognition of multiple chemical sensitivity legal protection of vulnerable groups) Supreme Court of Canada upheld the municipalitys right to enact by-laws. Thus no legal implications

Present challenge in enforcing bylaw (training of enforcement officers in pest management and soil sampling)

Provincial implications Federal implications

Not applicable to policy option 1 Not applicable to policy option 1

Conflict of interest if bylaw is enacted in areas governed by provincial legislation Might lead to adoption of recommendations from the house of commons ( legal recognition of multiple chemical sensitivity legal protection of vulnerable groups) Supreme Court of Canada upheld the municipalitys right to enact bylaws. Thus no legal implications

Legislative and legal implications

Not applicable to policy option 1

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