Off-Label Spraying: A Lose-Lose Situation

Submitted by Dustin Morton, Commercial Horticulture Specialist with Alberta Agriculture and Forestry.

Horticultural chemicals and pesticides often have the dubious distinction of being more expensive than their field crop cousins. In order to reduce costs, growers may sometimes buy and use chemicals which have the same active ingredient, but are not registered for the crop they’re being used on. This practice of “off-label” spraying is not only illegal and can result in severe fines, but can also be incredibly dangerous for your clients, your livelihood, and the environment.

Health Canada’s Pest Management Regulatory Agency (PMRA) is the sector of the federal government that is responsible for overseeing the registration and regulation of pesticides in Canada. This includes products that producers are more familiar with such as herbicides and fungicides, as well as less thought about products such as animal repellents, rodenticides, and disinfectants. These products are all rigorously tested to compile data on residue, efficacy and long term effects, all of which is reviewed by Health Canada prior to registration. Furthermore, the PMRA is the body in charge of monitoring and enforcing appropriate use of these chemicals to ensure public safety.

When reviewed by Health Canada, all chemicals have specified rates, target pests, and the crops on which they can be applied. ‘Off-label’ spraying can include spraying above the appropriate rate, or spraying the chemical for a pest that it is not registered for or on a crop not on the chemical’s label.

Throughout the year, the PMRA randomly selects growers for pesticide use inspections in order to ensure compliance. These inspections could be random ones, arising from increased incorrect spraying because of a label change, the need to update information or a neighbour’s complaint. The purpose of inspections is twofold in that they serve as a deterrent to off-label spraying but also as an educational tool to encourage growers to follow labels.

In an inspection, samples of vegetative material or soil are collected and sent away for testing. Should these come back showing incorrect use of chemicals, growers may be subject to increased monitoring, financial penalty or even prosecution under the Pest Control Products Act. If somebody producing food is found to be non-compliant, it could even result in the Canadian Food Inspection Agency (CFIA) becoming involved and product being recalled or destroyed.

No grower wants to purposefully put themselves, their clients or the environment at risk, so how to avoid the temptation of spraying off-label? When possible, avoid the need to altogether! Good scouting and appropriate record keeping allows growers to track outbreaks over time and better plan for them in their operating cycle. Furthermore, a good chemical inventory will give producers a better idea of how much they have of needed chemicals and whether they have enough to deal with problems when they come up. Adopting biological controls in their operation may also allow growers to nip some problems in the bud before they become full blown issues.

As with all chemicals, proper storage, labelling and disposal are all part and parcel in running a safe, effective operation. By being aware of the process and how best to handle these chemicals, growers can ensure they grow a safe healthy crop without running afoul of the law.