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Provincial consultations show 88% support for
cosmetic pesticide ban
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22 July, 2010
Last winter (from December to February 15th) the BC government held public
consultations on “new statutory protections to further safeguard our environment
from cosmetic chemical pesticides.” The response was overwhelming. As a summary
of the public comments released at the
end of March notes:
More than 8,000 comments,
signatures on petitions or
submissions were received TIP JAR
between December 2009 and Your contributions will let us keep
the end of February 2010 in sparking public discussion about
the importance of strong
response to the ministry’s environmental laws in BC and
Canada.
request for comments on the
cosmetic use of pesticides in
Click here to tip!
British Columbia. These
responses included: petitions with individual signatures (more than RECENT COMMENTS
4,000 signatures); copies of letters or e-mails sent to Members of the
NEB pipelines
Legislature (MLAs) or the Minister of Environment (about 3,000 1 week 2 days ago
individual items of correspondence); individually signed form (or Responding to Metro Vancouver
template) letters (more than 500); and responses or submissions 1 week 2 days ago
specifically addressing the consultation issues and topic areas identified Technical accuracy
1 week 2 days ago
in the consultation paper prepared by the ministry (more than 800 by e-
Sue the Metro Board
mail, fax or attached file). 2 weeks 1 hour ago
Regional Growth Strategy
For those interested, here's West Coast Environmental Law's submissions - just one of 2 weeks 22 hours ago
the more than 800 submissions discussing the issues raised in the Ministry's Re: ALR and the RGS
2 weeks 3 days ago
consultation paper.
With the extra regulations

Conservation The publicly available summary seemed incomplete. After highlighting the immense
6 weeks 4 days ago

Officer Service I have been personally

water act public interest in this consultation, the summary fails to tell us anything about how 6 weeks 4 days ago
modernization many of the respondents would like to see an outright ban on pesticides, and what Great work!
Prosperity Mine No 8 weeks 3 days ago
Response enforcement portion would prefer other alternatives. Instead the report simply talks about “many
Salmon Farming.
Enbridge respondents” said X, “while others” said Y – never giving any indication to the 9 weeks 2 days ago
Pipeline more tags Ministry of where public support lies.
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Since then – with the exception of the March summary – we’ve heard nothing. February 2011 (1)
The Environmental Law Alert Blog
However, recent communications with Ministry of Environment staff confirm that the January 2011 (4)
is made possible through the
generous support of: respondents overwhelmingly supported a ban on the cosmetic use of pesticides. December 2010 (6)

Moreover, Freedom of Information documents received by West Coast Environmental November 2010 (5)

http://wcel.org/resources/environmental-law-alert/provincial-consultations-show-88-suppo... 2/11/2011
Provincial consultations show 88% support for cosmetic pesticide ban | West Coast Envir... Page 2 of 5

CNC Repair and Sales Law show that this high level of public support for a ban was never properly October 2010 (6)

communicated to the Minister and suggest that more public pressure needs to be September 2010 (8)
The Notary Foundation
brought to bear before the government will consider a ban on cosmetic pesticides. August 2010 (10)
The Law Foundation of British July 2010 (9)
Columbia June 2010 (10)
This post will give the best information about what the province heard through its
May 2010 (6)
consultation. A companion blog post – What’s the Province thinking about pesticides?
1 2 next › last »
– will examine what the documents received suggest the province’s next steps on
pesticides might be. OTHER PAGES
Why does West Coast
Environmental Law need a blog?
High levels of public support for a cosmetic pesticide ban
My information request was aimed at finding out more about how the government was About Environmental Law Alert

analyzing the results of the public consultation. I suspected that earlier drafts of the
About the blog's authors (coming
report or separate reports, not disclosed to the public, would contain this level of soon)
analysis. Assuming that all of the relevant documents were disclosed to me, it would
Blog Roll
appear that my suspicion was wrong. The only additional analysis we received as a
result of the request is just as vague in terms of the levels of public support as the RSS Feed
public summary.
About West Coast
Environmental Law
My first draft of this post, based on the information request, suggested that the
government – by failing to evaluate the level of support for various positions taken
during the consultations – was trying to hide the high level of public support for a
pesticide ban. However, when I put that question to Bob Lucy, a Pesticide Licence
Officer with the Ministry who has been very involved in the consultations, he proved
very willing to put together some of the type of analysis I had been looking for, as well
as providing an explanation as to why no quantitative analysis has been done.

Mr. Lucy argued that the consultation process had always been intended to produce a
qualitative analysis:

We did not design the Consultation Paper to collect statistics; the

questions are open-ended and, as the paper says in its introduction,
intended to stimulate conversation and gather your input on this topic.
Providing a quantitative analysis of opinions received in response to such
a paper would not have provided any statistically relevant information.
The contractor indicated the relative frequency of the different types of
responses received by using language such as “Many respondents …” or
“Some respondents …”. Given the wide range of comments received, I
think he did an excellent job of giving an accurate summary.

With respect, “some respondents” only tells you that more than 2 expressed a view,
and at what point does “some” become “many”?

Mr. Lucy went on to clarify that:

At present there are no plans to do the quantitative analysis you

requested. The reasons for this include:

• The consultation process was not designed to be an opinion poll and

is not capable of providing statistically valid numbers.

• We were interested in people’s thoughts on how various issues could

be addressed. Campaigns both for and against a ban on the use of
cosmetic pesticides were directing people to websites where they
could submit responses without having the opportunity to review
the consultation paper. This meant that a large number of responses
did not provide the type of information for which we were looking.
• Of the responses received with answers to our specific consultation
questions, answers to individual questions mean more when taken
in the context of the entire response. Responses taken in their
entirety “tell the story” better than trying to analyse numbers.

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Provincial consultations show 88% support for cosmetic pesticide ban | West Coast Envir... Page 3 of 5

I do not disagree that qualitative analysis of the comments received is useful.

However, public consultations, while not an opinion poll, are routinely used by
government to measure the strength of public opinion on issues. In our view the
consultation summary does not give the Minister – or the public – any basis to
distinguish between the different perspectives taken.

So who said what?

Fortunately Mr. Lucy was willing to pull together some approximate figures that give
us some idea as to who responded to the public consultation and what they said.

Virtually all of the petitions received –

primarily from the Canadian Cancer
Society – supported a cosmetic
pesticide ban, as did approximately
82% of the form letters and emails
received (which includes, as I
understand it, those received by MLAs
or the Ministry of Environment).
Mr. Lucy provided a breakdown of how
the more than 800 individuals,
corporations or organizations that wrote specific responses to the Ministry’s
discussion paper were classified. 58% were identified only as members of the public.
Here's a graph showing the breakdown by type of respondent.

Mr. Lucy writes:

Of the 800 individual responses to the consultation questions, I would

guess that half were generally in favour of banning the sale and use of
pesticides for cosmetic purposes; a quarter favoured some sort of
increased regulation without implementing an actual ban and the
remaining quarter thought that no changes to pesticide regulation were
required. There were many nuances to these responses, however, and it
was not always obvious or possible to classify them as wanting a ban or
not wanting a ban.

So, based on Mr. Lucy’s approximation, of the more than 800 people who took the
time to specifically write a response to the Discussion Paper, approximately 75%
wanted some form of increased regulation of cosmetic pesticides, and about 50%
wanted a ban. However, when all responses are taken into account, approximately
88% of respondents (or 9912) favoured a pesticide ban. Only 11% (or 1206) didn’t
want any changes to the law, and a further 2% favoured increased regulation, but not
an outright ban. (Note to anyone trying to compare these figures to the 8000
comments described above: Mr. Lucy’s figures include responses received after the
February 15th consultation deadline, so a direct comparison is not possible based on
the available information).

These numbers were not

in the written material
communicated to Minister
Barry Penner to assist him
in making decisions on
whether and how to
regulate cosmetic
pesticides. Mr. Lucy was
unable to tell me whether
some of this information
was passed on to the
Minister in oral briefings,
although he did assure me
that the Minister was
aware of the high levels of public support for a pesticide ban from past polling, such as

http://wcel.org/resources/environmental-law-alert/provincial-consultations-show-88-suppo... 2/11/2011
Provincial consultations show 88% support for cosmetic pesticide ban | West Coast Envir... Page 4 of 5

the 2008 poll by the Canadian Cancer Society that confirmed that 76% of respondents
favour a cosmetic pesticide ban.

Numbers aren’t everything, of course. But surely it means something that the Ministry
of Environment was blown away by the level of public engagement in this
consultation, and that overwhelmingly the respondents were telling the government to
ban cosmetic pesticides.

The people have spoken. Will the government listen?

Related Posts:

What’s the province thinking about pesticides?

Will BC ban cosmetic pesticides?

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23 Jul08:07
On Croplife and public debate
By Andrew

Sean Holman of Public Eye has just published a blog post about Croplife Canada
(the trade association for the pesticide industry) and its efforts to lobby the BC
government against a cosmetic pesticide ban: Chem Trails. Makes for an
interesting read.

Sean and I will be discussing the province's pesticide consultations on Public Eye
Radio this Sunday (July 25th) at 8:45am. Update July 23 - this interview has
been moved forward to 8:25am.

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