Golf courses are known for having perfect, weed-free turf. But this perfection comes at a price. Many kinds of grass on our local golf courses are not native to Ontario – ie. Bentgrass -and require intense maintenance not only to stay green and lush but to ensure its very survival. If left unmanaged, particularly when the grass is mowed to the fairway and putting green heights, they quickly succumb to fungal diseases, insect predators, or are overtaken by weeds, local grasses, and other plants.

To maintain their pristine condition, our local golf courses use different pesticides – thirty-one “Unlisted Pesticides” (formerly known as Class 9 pesticides) were used in 2022. Unlisted Pesticides are only available to licensed professionals for which the Pesticide Act permits applications to golf courses – all are toxic to aquatic life. They are grouped into three categories: fungicides, herbicides, and insecticides. By weight applied (kg) they constitute 85%, 10%, and 5%, respectively. In many cases up to seven times the average amount used on farms based on “active ingredient (kg) per hectare”. And while pesticides are excellent at killing off targeted insects, unwanted plants, and fungus, when applied to golf course turf, pesticides will migrate to ponds, groundwater, and nearby streams and ditches. Once there they can damage the surrounding environment by killing off native aquatic and insect life, and potentially posing a danger to our drinking water.

Long term use or overuse of fungicides makes fungal diseases resistant to those chemicals. This usually forces users to apply more fungicides or even switch to other pesticides and/or pesticide “mixtures” (these are commercial products that contain more than one type of pesticide). Residual pesticides in the watershed are difficult and expensive to test and identify. Many are labelled as toxic to fish and aquatic organisms – many are also labelled as dangerous to human health.

Local Findings

There are seven golf courses in the Blue Mountain watershed: Batteaux Creek, Blue Mountain, Cranberry, Duntroon Highlands, Georgian Bay, Monterra, and Oslerbrook. There are four public and three private golf courses.

Key Data 2022

1. Total pesticide use (kg) decreased by 3% versus 2021 to 1,401 kg/yr. This slows the ~8% decrease versus 2020;
2. Fungicides are consistently the largest type of pesticide used – 85% by kg applied;
3. The top five pesticides (by active ingredient (“a.i.”)) represent about 81% of all usage; and
   1. Chlorothalonil (58%)
   2. Tebuconazole (6%)
   3. 2-4, D (6%)
   4. Propiconazole (6%)
   5. Fosetyl—Al (5%)
4. Private golf courses apply 68% of all pesticide by weight (kg)

Bees and other pollinators are adversely affected by Imidacloprid (#17 (0.32%)). It is to be phased out in 3-5 years (Health Canada (April 11, 2019)). Only GBC and Oslerbrook use this insecticide. The use of the two other neonicotinoids (Clothianidin and Thiamethoxam) has been discontinued.

The fungicides are registered by Health Canada and combat turfgrass diseases such as snow mould, dollar spot, anthracnose, leaf spot, and brown patch.

The #1 most heavily used fungicide on local golf courses (Chlorothalonil) is under re-evaluation for use or ban in several jurisdictions: EU (European Food Safety Authority), USA (EPA), and Canada (Health Canada). Local golf courses will soon need to modify their fungicide regime due to existing products being unavailable – or changes to their application may preclude further use.

The US EPA’s Pesticide Office, under the Federal Insecticide, Fungicide, and Rodenticide Act, has come under intense scrutiny in recent years. The US EPA, for example, in 2016, permitted the use of nearly 400 million pounds of pesticides that are banned in the EU, China, and Brazil.

Major Regulatory Changes in Ontario (Dec 2019)

Health Canada carefully regulates pesticide use in Canada through a program of pre-market scientific assessment, enforcement, education, and information dissemination. This is accomplished via the Pest Management Regulatory Agency (PMRA) under the Pest Control Products Act (PCPA) and Regulations. Until the PMRA approves a pesticide, it cannot be sold, imported, or used in Canada. The federal programs remain unchanged. In 2015 The Federal Commissioner for the Environment and Sustainable Development (Office of the Auditor General) issued a very unflattering audit report of the PMRA. The primary critical findings include:

1. Conditional registered pesticides allowed to be in use for lengthy periods – in many cases greater than 5 years. This means PMRA has not conducted the risk assessment in its totality;
2. Failure to confirm whether the risks to using neonicotinoids are acceptable (since 1995);
3. When re-evaluating Pesticides (required every 15 years), when required, the cumulative health effects have not been assessed;
4. The PMRA has made insufficient progress in completing the re-evaluations of older pesticides; and
5. Unreasonably long withdrawal time periods for pesticides deemed to be ineffective or dangerous to humans and the environment.

Our overall conclusion is that the PMRA has failed to meet many of its obligations under the federal PCPA. And now Ontario has jumped, perhaps recklessly, on the bandwagon.

The provinces (in Ontario it is the Ministry of Environment, Conservation and Parks (MECP)) are responsible for the education, licensing of vendors, growers, applicators, disposal, and enforcement. They may ban a pesticide and apply greater restrictions on use than the PMRA.

Somewhat controversially, the Province of Ontario recently made significant changes to our Pesticide Act and Regulations (Bill 132, Better for People, Smarter for Business Act, 2019) in December 2019. The outcome is a strict reliance on Health Canada’s PMRA, elimination of the provincially determined Class 9 Pesticide group (these were pesticides banned for “cosmetic” purposes with certain exemptions including golf courses), discontinuation of the Ontario Pesticide Advisory Committee (OPAC), and changes to the Integrated Pest Management program under regulation 63/09. Overall, the outcome is intended to standardize pesticide legislation and approval, get new pesticides faster to market, and reduce duplication within the government. However, at this early stage, it appears that we have also reduced our ability to protect aquatic life. We have, essentially, forfeited provincial control of the detailed and complex scientific considerations needed to enact and change policy pertaining to pesticide use. The new regulations under the new Pesticide Act came into law on May 1, 2020 – these determine how the Integrated Pest Management program (a third-party industry group) will affect how golf courses manage pesticide application, auditing, training, and communications to the public.

Major Regulatory Changes in Canada (June 2023)

The Government of Canada has recently demonstrated positive efforts to better manage the use of pesticides in Canada. It has begun to amend the Pest Control Products Regulations (PCPR) under the Pest Control Products Act. Health Canada has restarted the science-based process of evaluating acceptable increases to pesticide limits. The Science Advisory Committee on Pest control Products was created in January 2022 and acts as a much needed advisory role to the Pest Management Regulatory Agency.

Just recently the PMRA has introduced a new measure of pesticide levels in fresh water – the Aquatic Life Reference values (ALRV). ALRVs are pesticide concentrations in surface water below which risks to aquatic life are not expected. PMRA’s ALRVs are thresholds for individual pesticides, based on toxicity values for aquatic species, with the goal of protecting the environment. The PMRA follows internationally accepted methods to assess both long-term (chronic) and short-term (acute) risks to fish and invertebrates. The risk to aquatic vascular and non-vascular plants is also assessed using internationally accepted methods. For a given pesticide, there are up to six ALRVs, depending on the organism group and exposure duration, that form the basis of a pesticide risk assessment:

• acute fish and chronic fish
• acute invertebrates and chronic invertebrates
• aquatic vascular plants
• aquatic non-vascular plants (algae)

The BMWT is evaluating the potential option to test the Golf Course surface water discharges or ponds to determine ALRV levels for the key Unlisted Pesticides now in use. This is relatively expensive and would be done via the University of Guelph.

Challenges with Regulation, Reporting, and Testing

The Watershed Trust is concerned about the potential of pesticide impact to area streams that flow from the Blue Mountains Watershed into Georgian Bay. Although our area golf courses follow all regulatory requirements – ie. they report what they use and how much in a calendar year – the timeliness of the information makes it virtually impossible to protect aquatic life and invertebrates.

The federal and provincial water quality regulations – the Canadian Environmental Quality Guidelines (set by the Canadian Council of Ministers of the Environment (CCME)) and Provincial Water Quality Guidelines (PWQO) – establish the maximum long term concentration (mg/L) of pesticides that should exist in surface waters (streams, lakes, ponds, and groundwater). Unfortunately, for most pesticides used on golf courses, there is no limit specified.

Furthermore, for some of these pesticides, there are no laboratories in Canada that can test for their presence. Yet the Health Canada mandatory labelling on these products states that they pose a danger to human health and/or the environment. This presents quite a conundrum – Health Canada determines a pesticide is safe provided the users adhere to the prescribed application methods but in field testing of surface waters to determine actual concentrations is not possible.

For clarity, the CCME and PWQO standards do not pertain to drinking water. Health Canada stipulates the Guidelines for Canadian Drinking Water. The Ontario Safe Water Drinking Act sets similar parameters. None of the drinking water standards is intended to protect surface waters and aquatic life. Rather, and appropriately, they are legal maximum levels (expressed as a maximum concentration (mg/L)) for the municipal, town, and city water supply and treatment facilities.

The Watershed Trust’s Role

Since 2008, the Watershed Trust has been regularly conducting sampling of water runoff from area golf courses and documenting our findings. We have contacted Environment Canada as well as the Ontario Ministry of the Environment, Conservation, and Parks to voice our concerns and to present our key recommendations. We continue to communicate with federal and provincial authorities with the intention of improving the legislative framework around pesticide use and its impact on surface water quality.

You can help

You can help the Trust in its efforts by becoming a member or by making a tax-deductible donation. If you are a golfer, talk to your Golf Course Superintendent about their pesticide use – encourage them to take up more sustainable and best practice turf management practices. The golf course must provide, upon request, the prior year’s Integrated Pest Management (IPM) mandated Annual Report – Unlisted Pesticide Use. Typically, all 7 local golf courses submit the Annual Report – this is required under the Pesticide Act Reg 09/60 – via the IPM.

However, the Batteaux Creek golf course (owned by Golf North) had failed to do this for both 2021 and 2022 seasons in a timely manner. This seems to indicate weak corporate leadership in fulfilling a basic process to running a golf course in Ontario. Application of Unlisted Pesticides (UP) requires a licensed IPM Agent and Golf North, due its size, can purchase UP but chooses to not report their prior year usage by January 31 as required by provincial law.

Contact the relevant government ministers:

Office of the Hon. David Piccini (Northumberland-Peterborough South)

Email: minister.mecp@ontario.ca

Federal Minister of Environment and Climate Change:

The Honourable Steven Guilbeault (Laurier—Sainte-Marie)

Email: enviroinfo@ec.gc.ca

Toll-free: 1-800-668-6767