Pesticide Legislation, Licensing and Regulatory Compliance
Who regulates what
Two levels of government matter. Health Canada's PMRA registers pesticide products and approves the label federally, and assigns a PCP registration number. Ontario's Pesticides Act, R.S.O. 1990, c. P.11 and Ontario Regulation 63/09 govern sale, use, storage, transportation, disposal, licensing and classification inside the province. A federal registration number does not by itself authorize a use - the provincial class, your licence category and the label directions do.
O. Reg. 63/09 sorts registered products into 11 classes (Class 1 the most restricted, through domestic, commercial, agricultural and structural classes). Know that the class determines who may buy and apply the product, and that a domestic-class product bought at a hardware store is not automatically legal in a commercial or structural account.
The Act provides for exterminator licences (with categories such as structural, fumigation, wood preservation and agricultural), operator licences for businesses, and vendor licences for retail sale. A licensed applicator working for an unlicensed operator is still a compliance problem. Holders must produce their licence to an inspector on request, keep application records, give clients the required information, and work within integrated pest management.
Ontario's cosmetic pesticides ban prohibits aesthetic use of listed classes on lawns and gardens; structural, agricultural and health/safety uses remain lawful with the right licence.
Traps: confusing federal and provincial roles; assuming a domestic product is fine in a restaurant; thinking a licence covers any category or any province; forgetting the operator licence and the notice/record duties.
Rule of thumb: before every treatment ask - Is the product registered for this pest and this site? Does the cosmetic ban exempt this use? Is my licence category plus a valid operator licence in place?