Due May 6, 2024, comment here.
https://pest-control.canada.ca/public-engagement-portal/en/forms/consultation-comment
Canada is banning animal toxicity testing by 2035, and has already banned cosmetics testing. A proposed Framework for the Pesticide Water Monitoring Program will have to utilize Non Animal Methods only, and I do not see any mention of the need to use NAMs.
Human Health Reference Values are developed by forcing laboratory animals to eat, inhale, have their skin exposed to, and their eyes burned by pesticides, to determine lethal dose and Maximum Residue Limits. These Class E tests are extremely cruel. And non human animals do not respond to pesticides in the same way as humans.
Both laboratory animals tests, in which animals are exposed up to 10 times the normal dose, and “field studies” (spraying chemicals into the environment and seeing how it harms wildlife, who are then killed and dissected) are extremely cruel. https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/policies-guidelines/risk-management-pest-control-products.html
The two year pilot project National Water Monitoring Program for Pesticides involves testing waterways twice a week at several locations across Canada.
According to this page, the pesticides are detected using a Liquid Chromatography method. Using non animal detection methods like liquid chromatography is ethical, but any additional tests in which the samples are exposed to laboratory animals are not . https://www.canada.ca/en/health-canada/services/consumer-product-safety/pesticides-pest-management/public/protecting-your-health-environment/programs-initiatives/water-monitoring-pesticides/pilot-program.html
Any guardians of companion fish will test their tank using chromatography methods only (paper strips and test tubes). They do not deliberately expose the fish to pesticides to see what happens. Bacteria and pollutants in swimming pools are also tested without animals.
Aquatic Life Referencing Values are created by testing pesticides on laboratory fish. These lethal dose tests/acute lethality tests and chronic toxicity tests are cruel and should be replaced with Non Animal Methods. No new ALRV fish tests should be conducted, and only existing data and new Non Animal Method data be used. https://www.canada.ca/en/health-canada/services/consumer-product-safety/pesticides-pest-management/public/protecting-your-health-environment/programs-initiatives/water-monitoring-pesticides/aquatic-life-reference-values.html
Please stop the “acute lethality tests” on rainbow trout, three lined stickleback, and other fish species. These tests involve pumping effluents into fish tanks about once a month, and if more than half the fish die, the experiments are repeated. Similar to Inhibiting Concentration 50% tests, and No Observed Adverse Effects Concentration.
https://www.canada.ca/en/health-canada/services/consumer-product-safety/pesticides-pest-management/public/protecting-your-health-environment/programs-initiatives/water-monitoring-pesticides/glossary.html
There are animal free ways to test for pollution. The Physicians Committee for Responsible Medicine suggests using rainbow trout cell lines instead (obtained without harming fish).
https://www.pcrm.org/news/good-science-digest/world-aquatic-animal-day
Please also end the practice of sublethal toxicity testing of effluent on baby fathead minnows, rainbow trout, and other animals. These animals are killed, dried, weighed, and preserved. Please modernize pesticide monitoring by only using Non Animal Methods. https://www.change.org/p/stop-testing-pollution-and-effluent-on-fish-and-other-animals
Please also stop lethal sampling of wild fish, birds, frogs, and other animals. Please only use humane non lethal biomonitoring methods used in human subjects.