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I call the meeting to order.
Bienvenue, tout le monde. Welcome, everyone, to the Standing Committee on Agriculture and Agri-Food. Pursuant to Standing Order 108(2), we are continuing our study of the PMRA decision concerning the neonicotinoid insecticide imidacloprid.
I want to welcome the members. I think Mr. Shields is replacing Mr. Anderson. Welcome, Mr. Shields.
Also Mr. Maguire should be joining us shortly.
I want to thank the panel for being here with us today. We have Mr. Craig Hunter with the Ontario Fruit and Vegetable Growers' Association. From the Ontario Greenhouse Vegetable Growers, we have Ms. Justine Taylor, science and government relations manager. From the David Suzuki Foundation, we have Lisa Gue, senior researcher and analyst, science and policy unit, Ottawa. From Équiterre, we have Annie Bérubé, director of government relations.
Welcome, all of you. I understand we have 10 minutes per team.
Mr. Hunter, you will make your opening statement first, for up to 10 minutes. Thank you.
:
Chairman Finnigan, Co-Chair Brosseau, and members of the committee, thank you very much for this opportunity today.
After almost 30 years with the Ontario Ministry of Agriculture, 18 years working for the Ontario Fruit and Vegetable Growers' Association dealing with pesticide issues, and more than 20 years as a member of the Ontario Pesticides Advisory Committee, I'm here today to share my experiences with pesticides. I'm here to represent the 2,500 fruit and vegetable growers across Ontario and more than 10,000 across Canada.
Growers are Canada's prime environmentalists. They live on the land, not in city apartments. They raise their families there and drink the water from the wells on their land. They no-till their land. They plant grass waterways and buffer strips. They do not want to spoil that land. They, in fact, want to pass it along in better condition to their children, for the next generation. They know what their environment is because they live in it every day.
Growers of fruits and vegetable crops across Ontario and Canada have been using imidacloprid since 1995, starting first with an emergency use on potatoes when every other registered insecticide had failed due to pest resistance.
Over the next 20 years, growers came to rely on this chemistry for a wide array of crops and for many insect species. In fact, an emergency use was just granted this past fall, a few weeks before the PMRA decision came out, and this was to control a new invasive species called brown marmorated stink bug, which can attack over 200 crops. I've seen it destroy 100% of an apple crop and a peach crop in Pennsylvania, which is pretty close to Ontario, so I know how devastating this insect can be.
If all the currently labelled uses are lost, it will be an enormous task to register effective and suitable alternative chemistries for the over 200 crops and multiple insect species that it controls. Although there are currently some registered alternatives for many of these pests, imidacloprid is the product of choice. As a result, a single application of imidacloprid may need to be replaced with three or even four applications of other products. You lose one, and then you have three or four alternatives each time you have to control pests.
Most of the other registered products have shortcomings that effectively preclude their use in commercial production systems. Even after 22 seasons of use, resistance to imidacloprid has not been an issue here. Many of the alternatives, on the other hand, need to be broad-spectrum products in a pesticide rotation program to prevent the pests from developing resistance. Imidacloprid has done this very well to date.
Since all horticulture is considered minor use, the pressure on Agriculture Canada's minor use program could be way beyond current capacity. None of our horticultural crops attract the research investment needed to register pesticides directly from the registrants. That's why we have the program. Even worse, many other products still face re-evaluation. Until they are reapproved, nobody wants to invest in their future, only to face double jeopardy.
I have many other comments on what I feel about the review, how it was done, the lack of time for meaningful input into the process, the lack of time to conduct new research to question some of the conclusions made by the PMRA, and their undue haste to publish a final decision by December of this year, nine months after our final comments are in. That's a full 12 months earlier than most of the re-evaluations over the past several years.
We have great concern that the 2015-2016 monitoring data, which was not included in making their decision, shows very different—in fact, lower—residue numbers in those same locations. This has not been taken into account.
Mesocosm studies that were rejected by the PMRA for various reasons need to be looked at again. What we call the weight of evidence shows up to 25 times less toxicity in the real environment as compared to pristine studies done in a laboratory. Perhaps a whole new look at the data used to condemn imidacloprid is warranted.
I also have concern that just last week Environment Canada announced they will not be conducting any further monitoring in these locations, even though they’ve expressed concern. This needs further consideration as well.
Just to close, bird counts done at Point Pelee have shown an increase in birds, and especially in fish feeders, and fishing quotas in Lake Erie have been rising. The fishing industry, in fact, has shifted down to the west end of the lake, so if there was really a problem, these would be the indicators, in my mind. This tells me a different story from the one portrayed by the PMRA in their proposal. Maybe if there is time later, I could add to the discussion.
I'll turn it over to Justine.
Thank you again for this opportunity to present to you today.
We represent over 200 greenhouse vegetable growers across the province, responsible for nearly 2,900 acres of greenhouse tomatoes, peppers, and cucumbers. The greenhouse vegetable sector is one of the fastest-growing parts of Ontario agriculture. With over $820 million in farm gate sales, a contribution of over 12,000 jobs to the workforce, and a consistent track record of growth, the sector is a valuable contributor to Ontario's economy. In fact, in 2015 alone our farmers contributed an estimated $1.4 billion to the Ontario economy.
I would like to add some additional comments from the perspective of Ontario’s greenhouse growers. Let me start by saying that our members, like most farmers, endeavour to be stewards of the land and strive to minimize their environmental impacts. lmidacloprid is used for the control of aphids and whiteflies in the greenhouse, and is only registered to be used once a season. Even then it is used sparingly and in alignment with biological control agents.
Biological control agents are beneficial insects that are introduced to the greenhouse to control unwanted pests and greatly reduce the need for pesticides. Results from a recent Canadian Horticulture Council survey indicated that 76% of respondents use imidacloprid as a tool to control outbreaks when other methods have failed. This product, like many neonics, when needed, plays a vital role in controlling unwanted pests as part of an integrated pest management, or IPM, program. A successful IPM program relies on a number of tools, including biological controls, cultural practices, monitoring, and, when appropriate, responsible chemical use.
It is clear that the increase in global trade and the impacts of a changing climate will increase our exposure to invasive pests and diseases. Therefore, it is critical to ensure the appropriate tools are available to combat these new pressures. In the greenhouse environment, the potential for pesticides to escape into the environment is mitigated through the same measures put in place to address phosphorus reduction targets under the Canada-Ontario Agreement on Great Lakes Water Quality and Ecosystem Health. Currently over 90% of Ontario's greenhouse vegetable sector uses recirculation, whereby excess feedwater is captured and treated before being returned to the crop. In addition, the greenhouse sector, in collaboration with the provincial government, has developed a set of tools to address any feedwater that must be removed from the greenhouse environment.
Lastly, Ontario's greenhouse farmers have been looking, and continue to look, for new products that support an effective IPM program. The last few years have seen growers transition towards products that are softer on biocontrols. We expect this trend will continue, and to this end a promising new product has been identified through the minor use pesticides program that may further offset imidacloprid use. This project was selected as a joint Canada-United States minor use project.
The importance of a harmonized review process cannot be overstated, as it ensures a level playing field with our largest trading partner to the south. It is our belief that given the relatively low availability of viable alternative products, the potential for the development of resistance, and the need to remain competitive with the U.S., the removal of imidacloprid as a tool for pest management would be ill-advised.
We thank you for your time and look forward to your questions
:
Thank you, Mr. Chair. I appreciate the opportunity to appear today before you.
The David Suzuki Foundation is a registered Canadian charity, founded in 1990. The foundation believes we must protect biodiversity and Canadians' right to live in a healthy environment. These twin imperatives drive our long-standing work to strengthen pesticide regulation in Canada.
I've asked my colleague from Équiterre to join me this morning, as our two organizations collaborate closely in our work on pesticides.
I will review the ecological concerns that lead us to call for a ban on neonicotinoid insecticides, and then Annie will speak briefly to the PMRA's decision-making process and the issue of alternatives to neonics.
First let me state for the record that the David Suzuki Foundation and Équiterre agree with the PMRA's conclusion that imidacloprid poses unacceptable risks to the environment and should be phased out of use in Canada. In our view, the PMRA assessment underestimates the risks to terrestrial organisms and human health. Better addressing these aspects would only reinforce the conclusion that the continued use of imidacloprid is not sustainable. We therefore encourage Health Canada to cancel the main uses of imidacloprid, as proposed, and shorten the phase-out period. The proposed decision offers no justification for delaying action for three to five years, and this delay will needlessly prolong identified environmental risks.
Just a few months before the PMRA issued its proposed decision on imidacloprid, France adopted legislation to ban all neonicotinoids by September 2018. We recommend that Canada match the French timeline.
The evidence of harm from neonics demands urgent action.
The Task Force on Systemic Pesticides, a group of 29 independent scientists convened by the International Union for Conservation of Nature, has conducted the most comprehensive systematic review to date of the environmental impacts of neonics. The study analyzed more than 1,000 published scientific studies, and it concluded that the large-scale prophylactic use of neonics is having significant unintended ecological consequences. This ground-breaking review pointed to evidence of harm to aquatic and terrestrial invertebrates, pollinator insects, and birds, and to cascading effects that threaten whole ecosystems.
The task force published its findings in January 2015 in the peer-reviewed journal Environmental Science and Pollution Research. This publication in fact foreshadowed the PMRA's more recent conclusions, stating, and I quote:
The combination of persistence...and solubility in water has led to large scale contamination of, and the potential for accumulation in, soils and sediments, ground and surface water and treated and non-treated vegetation.
As you heard on Tuesday, the PMRA's assessment confirms that concentrations of imidacloprid in aquatic environments in Canada may pose acute and chronic risks to invertebrates when considering both modelled environmental concentrations and available monitoring data. Aquatic insects are a crucial link in the food chain in marine and freshwater environments. The PMRA notes that modelled concentrations are typically considered to be higher than actual environmental concentrations, but in the case of imidacloprid, the modelled estimates cannot be assumed to be conservative because actual monitoring data overlap with the range of surface water concentrations predicted in the models. Morever, it is generally accepted that monitoring data likely underestimate actual exposure, as sampling typically does not capture peak concentrations.
With respect to bees, which I gather will be the focus for the next panel today, the task force review found clear evidence that neonics pose a serious risk of harm, including sublethal effects on navigation, learning, foraging, longevity, resistance to disease, and reproduction. A separate review of post-2013 studies that has just been published confirmed these findings, and I will provide the committee with a copy of that paper.
The PMRA re-evaluation of imidacloprid does not consider risks to pollinators, which are being assessed separately. Nevertheless, phasing out imidacloprid will dramatically reduce pollinators' exposure to this chemical. We view this as a significant side benefit of the proposed decision, not least because of the importance of pollination to agriculture and food security.
The task force assessment also found evidence of harm to earthworms and other terrestrial invertebrates, and aquatic invertebrates. It also found the potential for population-level harm to birds exposed to neonic-treated seeds.
The registrants' claim on Tuesday that Canada's decision on imidacloprid has been made in haste is nothing short of fantastical. North American regulators have been slow to respond to the evidence of ecological risks, with the first tentative regulatory restrictions in Ontario taking effect only last year.
As you know, the European Union has prohibited the use of neonics on flowering crops since 2013. This policy is currently under review and may be extended to cover other uses. Italy banned neonic seed treatments in 2008 and, as I mentioned previously, France will ban all neonics starting next year. By joining leading jurisdictions at last in the shift away from neonics, Canada can be at the forefront of a movement towards mainstreaming more sustainable agricultural practices.
Before I conclude, I would like to draw the committee's attention to a report on the effects of pesticides on the right to food, which was tabled on Tuesday by the United Nations special rapporteur on the right to food. The report describes our current dependence on pesticides as a global human rights concern and notes:
The pesticide industry’s efforts to influence policymakers and regulators have obstructed reforms and paralysed global pesticide restrictions globally.
The special rapporteur is calling for a new global treaty to regulate and phase out the use of dangerous pesticides in farming, including neonics, and move towards sustainable agricultural practices. We believe Canada could and should be a leader in this transition.
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Good morning. Thank you for the opportunity to share some of our ideas on sustainable agriculture in Canada.
Equiterre is an environmental advocacy group that has been active since 1993 and has offices in Montreal, Quebec City, and Ottawa. Its mission is to put forward concrete solutions to speed up the transition to a society where citizens, organizations, and governments make ecologically and socially fair choices.
Today, we would like to reiterate our support for the Minister of Health's recommendation to eliminate the use of imidacloprid in agriculture. We would add, however, that the risks associated with the pesticide are so harmful that it should be eliminated more quickly than the proposed time time frame.
Of concern to us is the importance of preserving the credibility of the pesticide re-evaluation process undertaken by PMRA scientists, as well as the independence of the Minister of Health's decision on this matter. The decision cannot be subject to any interference. Every stakeholder, including Equiterre, had a chance to submit comments during the consultation period. Why, then, give a public platform to a limited few stakeholders who have a clear commercial interest in the continued sale of the product in Canada?
We therefore urge the committee to expand the scope of the study to include the product's impact on ecosystems and human health, as my colleague Ms. Gue mentioned. Furthermore, the committee should take into account the knowledge and expertise currently available in Canada underlying alternatives to the agricultural use of imidacloprid.
We also have some concerns over the lack of transparency around the PMRA decision-making process. There is room for improvement in that regard.
In our view, it is especially crucial that PMRA demonstrate how its decision-making process takes into account independent scientific research, recent data such as the findings of academic researchers, and the data from provincial environmental protection agencies and Health Canada.
We are troubled, as well, by PMRA's dependence on how studies are conducted and taken into consideration. There is no way for researchers or the public to access data provided by manufacturers.
It is urgent that alternatives to the agricultural use of imidacloprid and other neonicotinoids in Canada be considered. On Tuesday, we learned that Agriculture and Agri-Food Canada had set up working groups to support the phase-out of the use of imidacloprid by farmers in Canada.
The work and recommendations of those working groups should be transparent. The groups should include agricultural stakeholders who have already implemented monitoring methods to prevent insect and pest infestations, as well as effective integrated pest management practices to prevent the unnecessary use of neonicotinoids. It is essential that the working groups not limit their efforts to the commercialization of other synthetic pesticides as the only solution.
Moreover, the working groups responsible for identifying alternatives must include stakeholders from Canada's organic farming sector who already grow corn, soybeans, potatoes, and a variety of other crops without the use of imidacloprid. The integrity of organic farming is threatened by environmental neonicotinoid contamination, which means the sector has an important part to play in the discussions.
I would like to quickly draw your attention to a few studies that raise doubts about the efficacy of many neonicotinoid uses in relation to farm yields and pest control. Take, for example, the field research—
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Sometimes I'm right, sometimes I'm wrong, and occasionally I'm left. Thank you.
PMRA sent out a proposal last year for a new approach to doing these reviews. Most of the stakeholders agreed with that new approach, and they did too. They listened to our comments, and they've now put online a new way to do these kinds of things.
The new way means that they talk to stakeholders at the beginning of their process. They get information from growers and other users to understand how we're using it, where we're using it, what the rates are, what the problems are, and so on, at the beginning.
Then during the two years, usually, or more that they take to do their review, if issues have been flagged at the beginning, we then have a two-year process with all the stakeholders to conduct research, to do further evaluations, to gather more data, to help them along the way. That's denied to us in this instance. This is done the old way.
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More information, more transparency is important.
[Translation]
First, I'd like to thank our witnesses for contributing to our study today.
We have already spent two hours on this issue. We've heard from officials from Health Canada and Agriculture and Agri-Food Canada, as well as from multinationals in the pharmaceutical industry. We are now beginning the second half of our study.
This is not a black and white issue; it's extremely complex. I thoroughly appreciated your presentation, Ms. Bérubé. I think we need more time to make sure we consult all the experts. I, myself, am not an expert. I'm not a researcher, but we have to respect PMRA's decision because it is based on science. I am eager to read all the reports you mentioned, and it may be beneficial for the committee to invite other experts like Ms. Labrie.
I read an interesting article in Le Devoir yesterday about the study and the UN special rapporteur. In June, Quebec's commissioner of sustainable development determined that the province's ministry of sustainable development, the environment and the fight against climate change was not adequately monitoring the use of pesticides in the province. I believe the government of Quebec had pledged to reduce the use of pesticides by 25% by 2020-21. Clearly, we have some work to do.
Could you discuss the importance of conducting an in-depth study and ensuring that the committee, the agriculture working group, calls for more transparency? Furthermore, we should also hear from other organic farming groups on the reduction of pesticide use.
I have spoken to the researchers at the University of Guelph and I've spoken to some of the industry reps, and they were concerned that they weren't involved in the process. It sounds as if there is a new process that's being introduced, and maybe that's something that might find its way into our discussion as we review our testimony to see what we can recommend going forward.
We're acting as members of Parliament, trying to represent ideas as best we can, trying to get as much balance as possible into our conversations, but sometimes we see these wildly divergent pieces of information. For example, the HFFA research that was released from the EU in January indicated that after two years of banning neonics in the EU, 912,000 tonnes of oilseed would have to be produced somewhere else in the market because of diminishing yields.
Ms. Bérubé, you mentioned that in your research, there wasn't a change in yields. What we've heard is that there is up to a 30% change in yields between using treated versus non-treated seeds. How do we—
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Speaking for Ontario, we have wildly divergent views here, so for members of Parliament it is difficult for us to say anything other than that we have some reports that we hope the PMRA is taking into consideration in making decisions.
Another one is the amount of water being used. The gap in the EU is 2.8 billion cubic metres of water. More water is needed because non-treated seeds versus treated seeds are being used, and 533,000 hectares of land has to be incorporated to make up for the gap in productivity. It puts enormous pressure on the agricultural community to try to produce more with less land when the land isn't available, yet the EU is trying to find 533,000 hectares to replace it.
Clearly there are some economic consequences. I know that's not part of the scope of PMRA, but it's definitely something that we're concerned with as we're trying to support the agricultural community in Canada.
Mr. Hunter, on the review process, could you comment on economic versus scientific? You mentioned the stewardship of your organization. It's very shocking that we don't produce more seeds in Canada. Why wouldn't we do that, and what's the economic result if we go a different route from the rest of the world?
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We will take our seats as soon as we can and get going.
Welcome to our panel for our second hour on the PMRA decision concerning neonic insecticides. With us here for the second hour, from the Canadian Honey Council, is Rod Scarlett, executive director. Welcome, Mr. Scarlett.
From the Grain Farmers of Ontario, we have Mr. Mark Brock, chairman. Welcome, Mr. Brock.
[Translation]
Pierre Giovenazzo teaches apiculture science at the Centre de recherche en sciences animales de Deschambault, at Université Laval.
Welcome, Mr. Giovenazzo.
You will each have 10 minutes.
That said, I must first put a motion to the committee.
[English]
We need to pass this motion regarding the title of our study for the U.S. visit. It's basically just the same title that we will use right through, so it could read like this:
That the committee undertake a study related to Canada-United States Cooperation in Agriculture.
Are we okay with that title?
[Translation]
We have a consensus, then. Thank you everyone.
We will now proceed with the presentations.
Would you care to start, Mr. Giovenazzo.
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Thank you for inviting me. This gives me an opportunity to share not just my personal view, but also the view of the beekeeping stakeholders I represent in Quebec and Canada.
I'll begin by telling you about the Centre de recherche en sciences animales de Deschambault, or CRSAD, and Canada's apiculture problem. I will also discuss the subject of the committee's study, the imidacloprid re-evaluation.
CRSAD's mission is to carry out animal science research and development. Our work is not limited to bees; we study all farm animals.
CRSAD is unique in its innovative approach to supporting animal science research and in its diverse areas of activity.
CRSAD keeps 300 bee colonies for the sole purpose of apiculture research.
CRSAD works with Université Laval, where I am a professor and teaching leadership chair in apiculture science. The centre also partners with other universities and even the private sector to carry out apiculture research.
We have published results in the following areas of research: genetic selection; productive colonies adapted to the Quebec climate; bee reproduction; the condition and fertility of queens and males; nutrient requirements, which are now extremely important; bee disease and parasitosis; pollination services; colony development dynamics; and the impact of pesticides on honeybee colonies.
Canada's beekeeping challenge is interesting for two reasons, which I will explain.
Right now, in Quebec and Canada, we are seeing a pretty remarkable rise in pollination services; bees are needed. A Government of Canada study released last year estimated the value of honeybee pollination to crops at approximately $2 billion. That is the economic value of honeybees to Canada's agricultural sector, be it blueberry, cranberry, or apple production, or even canola in Alberta.
Despite that, bee colonies have been suffering significant losses for 10 years, with annual mortality rates of between 20% and 25% in the winter and nearly 20% in the summer. The industry is experiencing tremendous losses in productivity.
In spite of these yearly losses, Canada's beekeeping industry is growing, which seems somewhat contradictory. With more colonies than before, the industry is experiencing rather sizable growth. Quebec, for example, now has around 60,000 colonies, versus the 35,000 it had 10 years ago. The growth has been fairly swift despite reduced biodiversity and expanding farmland. That is the context bees are evolving in.
To support this growth, Canada imports packaged bees, including queens, from a variety of countries. Since 2011, queen imports have gone up 92%, with colony imports rising 66%. That means our beekeeping industry cannot sustain itself. That is an important point to keep in mind.
I will now turn my focus to the decision to phase out imidacloprid.
Bees are truly the sentinels of the environment. A single colony can have 20,000 bees flying around and coming into contact with all kinds of flowers. They harvest the environment.
Beekeepers operate in agricultural areas, which receive pesticide and pest control treatments. Bees have to cope with that reality. It's important to realize that we are dealing with the environment of bees. Pesticides fight against insects, but bees are insects. There is clearly a problem.
The first message I want to convey is that the bee industry and agricultural industry must work together when new products enter the market.
A good collaborative approach helped to change planting methods. A problem was identified, and everyone worked together to solve it. The planting method was changed to reduce the use of imidacloprid dust, which helped lessen the impact on the bees. It was a good collaborative effort in the industry. This is the proper way to work.
I also want to talk about the unreasonable use of coated seeds. Integrated pest management was mentioned earlier. It doesn't consist only of using organic pesticides. It's a strategy that enables us to use all the tools available, including synthetic pesticides. However, the use of coated seeds in prophylaxis, or as a preventive measure, isn't integrated pest management. The heavy use of coated seeds is likely a problem. An adjustment must be made to avoid the excessive use of these seeds.
I'll finish by saying that, even if we measure the levels of sub-lethal effects resulting from these products, we must realize that the effects aren't sub-lethal all the time. It depends on the bee's health, parasites and potential diseases. A pesticide in the environment at a sub-lethal level could have a lethal effect if the pesticide reaches a sick bee or is associated with other pest control products found in the environment, especially if other synergistic products are present.
I'm a member of the Table filière apicole du Québec. We're concerned about the phase-out of this pesticide, because it means that another product or other products such as those mentioned earlier will enter the market. We're very concerned about this because we'll likely need to study the impact of these new products on bees. We'll need to use federal funding to conduct new research. It's unfortunate, because the funding is currently needed to conduct apiculture research and to advance knowledge in the field, and not to verify whether a pesticide is harmful.
I conduct apiculture research, and I want this industry to grow. I don't want to study pesticides, but the dynamics of a bee population, the queens and their fertility. This will move our bee industry forward. We're always very concerned about new products.
Thank you.
:
Thank you, Mr. Chairman and members of the committee, for this opportunity to provide our comments on the PMRA's proposed decision on imidacloprid.
My name is Mark Brock. I'm chairman of Grain Farmers of Ontario. I operate a farm, in partnership with my wife Sandy, in Hensall, Ontario, where we grow corn, soybeans, and wheat in rotation. We also raise livestock.
The Grain Farmers of Ontario is the largest commodity organization in Ontario, and represents 28,000 barley, corn, oat, soybean, and wheat producers. Our farmer-members cover six million acres of farmland across the province, generate over $2.5 billion in farm gate receipts, and are responsible for over 40,000 jobs in the province.
Neonics like imidacloprid are tools our farmer-members use to protect their crops from insect damage. Insects can cause many problems with our crops. They can starve a plant of the nutrients that it needs to grow; they can kill a plant, reducing our overall yield; and they can cause severe damage that will render a plant not suitable for our high-value export markets.
Some insects live below the soil and feed on the roots of the plants, and some insects fly in and eat the leaves or fruit off the plants. Neonics are primarily used as a coating on the seed, commonly called a seed treatment, which protects the seeds underground and during germination and provides some protection from leaf-eating insects during early growth.
Seed treatments are a very effective method of delivery, and the system for coating the seeds ensures the health and safety of our farmer-members. The seeds are coated in a factory before delivery to the farm, so farmers have limited exposure to the pesticide. In the past, before neonics were introduced, products were applied by the farmer in the field, increasing the health risk to the farmer. Today's modern system provides the farmer with pre-coated corn and soybean seeds so that both the seed and the pesticide are planted together. This results in less pesticide required to do its job because it is put directly on the seed, protecting it, rather than spread in the soil. This is an isolated, targeted approach to crop protection.
Seed treatments are an important tool for us in our environmental and sustainable practices. Many grain and oilseed producers have adopted no-till systems that reduce greenhouse gas emissions on the farm. Many of us also plant cover crops that improve soil health and reduce the runoff of phosphorus into the Great Lakes and tributaries.
These types of farm practices would not be possible without tools like neonic seed treatments. Cover crops and no-till results in increased insect populations that flourish in the undisturbed soil. The seed treatment allows farmers to protect each individual plant from these insects that grow in that environment. If not for seed treatments, many farmers would be less likely to plant cover crops or practice no-till because their crops could not withstand the insect damage.
Today there are no alternatives in the marketplace or in the technology pipeline that provide the same level of protection and safety for our farmer-members. Last year there was an introduction of a similar product into the marketplace, but it’s not available for soybeans, nor does it cover the same array of insects that the three neonics do. It is also being sold at four times the cost of the neonic seed treatment, even though it provides less protection. We have seen some Ontario farmers transition to this product, but we do not have enough years of experience to know what its weaknesses are and what it will or will not be effective against.
Neonics remain an important product for us, and they are products our competitors in the U.S. have access to. The Conference Board of Canada determined that the impact of not having access to neonic seed treatments would cost $600 million annually to corn and soybean farmers in Ontario alone. This number does not take into account the costs of other crops, but does include the cost of using alternative products.
It is important that our farmer-members have a tool box of technology to choose from, not only to deal with pest and disease pressures that we face, but to also remain competitive with international markets that have access to these products.
Our farmer-members have a long history of adjusting our practices when risks are identified, and we appreciate the working relationship we have with our regulators to figure out risk mitigation solutions. An example of this is the action the industry took to address the issues that arose a few years ago with bee health. PMRA identified the risks to bee health, and we adopted new practices to protect bees in the very next growing season. To date, it has proven to be successful, and honeybee populations have been improving since these new practices have been instituted.
Access to technologies like neonics is essential for our farmer-members to grow sustainably and to compete in the international marketplace. We look to PMRA to assess the safety of these products, and, if possible, we would prefer the opportunity to adjust practices to mitigate risks than rather than see products phased out. The phase-out of products limits the tool box that our members can access and can put a chill on future investments in Canadian agriculture.
We appreciate the establishment of the neonics forum chaired by AAFC. This forum has been established to address the issues that have arisen from the proposed decision on imidacloprid and is also looking at the special reviews on clothianidin and thiamethoxam. The staff at AAFC, PMRA, and Environment Canada have dedicated time and expertise to this process, along with academia and other interested parties. We are hopeful that it will result in a national protocol for environmental monitoring and risk mitigation opportunities that can be adopted by farmers.
Our farmer-members understand and take very seriously the responsibility to protect our environment, including Canada's air, water, and soil, and the ecosystems that thrive there. We are stewards of the land. The time we spend on our fields gives us a unique understanding of the environment and the different ecosystems. We know the decisions we make in our fields impact the environment. We are invested in the environment, not just because it is the right thing to do but also because our livelihood depends on it. That is why we support the PMRA in fulfilling its mandate to protect Canadians and the environment from unacceptable risks posed by pest control products.
We are committed to working with the government and other stakeholders to address environmental concerns and implement strategies that are environmentally responsible. Aquatic invertebrates are integral to the health of wetlands, creeks, and streams across Canada. We are committed to reducing risk and ensuring aquatic invertebrates continue to thrive in our ecosystems. To reduce the risk to aquatic invertebrates we must first understand the risks, and we rely on the PMRA to conduct credible and thorough risk assessments to identify unacceptable risks. We believe the work the forum completes on risk mitigation, environmental monitoring, and alternatives is valuable.
We are hopeful that the work of the forum will lead to a risk assessment that can be narrowed down through this coming season with a more robust environmental monitoring system in place, and we hope that this work will ultimately provide an opportunity to maintain access to these vital crop protection products for our farmer-members if the right mitigation is implemented to address these risks. If they cannot be managed, we are committed to working with government and stakeholders on an orderly phase-out of the products if the risk is too unacceptable.
We would like to thank you for the opportunity to speak to you today, and I am open to any questions that you may have.
:
Mr. Chair, members of the committee, on behalf of the Canadian Honey Council I'm pleased to have the opportunity to contribute to your study of PMRA's recent proposed decision on imidacloprid.
The Canadian Honey Council represents more than 9,000 beekeepers across Canada, who manage more than 750,000 colonies. Their contribution to the Canadian agricultural industry exceeds $4.5 billion. Beekeepers and farmers have a mutually beneficial relationship, as beekeepers are often dependent on landowners for yard placement, while farmers get the benefit of increased pollination of their crops, resulting in greater yields.
As many of you are aware, the status of bee health in Canada has been and continues to be at the forefront of attention in the public arena. Contrary to many preconceived notions, the numbers of managed bee colonies in Canada have been steadily increasing despite the pressures of pests, pathogens, reduced or changing habitat, and pesticide exposure. Indeed, the latest Statistics Canada numbers indicate a record number of colonies in Canada in 2016. Those numbers can be a little deceiving, as increased numbers are driven not only by economics but by and through the hard work of beekeepers, often at increased expense.
The co-operative work that industry and governments have done to mitigate the risk of pesticide exposure to the honeybee population is commendable. The work of the Agriculture and Agri-Food Canada Bee Health Roundtable is a shining example of this co-operative effort.
The Canadian Honey Council has from the very beginning maintained that the Pest Management Regulatory Agency should be the scientific barometer upon which policy and action are based. To a very large extent, the actions that have been taken with regard to mitigating pesticide exposure of honeybees have been quite successful, particularly those related to exposure from coated seeds. Certainly questions remain, particularly those related to some foliar sprays and long-term cumulative exposure impact, especially to neonics, but on the whole, work by government, equipment manufacturers, life science companies, seed companies, farm associations, and beekeepers themselves has been very admirable.
The Canadian Honey Council cannot comment on the scientific basis for the planned phase-out of imidacloprid, since the basis for the decision was made independent of honeybees. Indeed, in their preliminary pollinator-specific assessment for imidacloprid, the PMRA indicated that the potential risk to bees can be mitigated.
What we can comment on and what we do have a concern about is the potential impact that alternative products the farmers will have available to them may have on honeybees. If the alternatives are old chemistries with limited impact assessments done on pollinators, they may prove more harmful to honeybees and other beneficial insects than the current situation.
We understand the PMRA has not analyzed potential impacts of the adoption of all alternative products on bee health. Options that become available to farmers must be economical as well as provide a risk mitigation strategy acceptable to both the user and the beekeeper. It does no one any good if the replacement products are either too expensive but pollinator-friendly or cheap but creative of high risks to pollinators.
Comprehensive and comparative pollinator assessments of alternative products, in particular those with older chemistries, should be conducted now to ensure that the proposed risk mitigation approach does not create more problems than it solves.
The Canadian Honey Council has tried to work from the premise that co-operative solutions result in co-operative wins. With PMRA proposing a phase-out of of imidacloprid, we need to ensure that the “what next” genuinely is better for all stakeholders.
Thank you.
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The losses vary, so to speak.
In recent years, things have been going much better in Canada, where losses are under 20%. However, losses in certain provinces, such as Manitoba and Ontario, have exceeded 30% in the past five years. The losses aren't equal across the country or from year to year.
In the past three years, the winter mortality rate appears to have lowered. This rate is the easiest to measure. We compare the number of bees that enter the hive in the fall with the number that leave the following year. In the summer, it's very difficult to manage. The estimates are always slightly less accurate.
To answer your question, on average, the losses have exceeded 20% in the past ten years. I think the winter mortality rate in Canada is 24%.
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Good question. One of the goals of the Canadian beekeeping industry and the Canadian Honey Council, in Quebec and all provinces, is to move toward self-sufficiency, which is currently inconceivable.
For example, if 20% of the bees have died by May, to compensate for the losses, bees must be purchased from places abroad, such as California, Chile, New Zealand and Australia. Queens are imported to replace the deceased queens, and 1.5-kg packages of bees are imported. At this time, the packages are mainly from New Zealand.
That's how beekeepers quickly rebuild colonies. Then, in June and July, beekeepers can increase the number of bees when the colonies become stronger. They can create splits, which are called “nucs”. That way, they can increase the swarms. I can tell you that things are moving these days, because bees are needed.
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I really appreciate your question.
We were part of the process and are involved in the process. Really, when I step back and look at the situation as a whole, I think that when we bump into these issues around concern about the products that farmers use within the environment, we do put a lot of value on the environment. We want to mitigate as much risk as possible. This forum that was created with AFC had the dialogue and the input and broke it out into looking at risk mitigation, environmental monitoring, and alternatives. I think it was an excellent process to have these discussions around risk mitigation.
I get concerned when there's a request to have a product removed from the marketplace. I think we would lean toward the bee example we had within Ontario. In that case we were able to make some adjustments to our management practices and reduce the impact to bees. I think that's a model example that we could use going forward: before a product is taken away from the marketplace, we have this ability to look at the risk and get to a point where the risk to society around the products we use is acceptable. We're using those products with society's trust in that respect.
As they open up this consultation period, I think it would be nice to have this opportunity before decisions are made. That way we can have a really clear path forward and get to where we can feel okay as a society that we accept this risk—with input from primary producers like us—and we can go forward with consumer trust on the issue.
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I think there is even a broader perspective within the seed treatments. What happened was that the regulation that was put in place required us to prove a need for the use of neonic-treated seed through soil-testing protocols. We had to find so many bugs in a site in order to prove that we needed the use of it. That has come fully into effect for this planting season, with a kind of third party auditing system that's going to start next year.
Beyond that, I think farmers in Ontario identified the risk and decided they wanted to take steps towards that. We wanted to do it in a non-regulated manner. The government decided that regulation was one path they wanted to take, so they did it.
With regard to expanding adoption of cover crops, I plant sunflowers and buckwheat after winter wheat, and it's just loaded with wild pollinators and whatever other pollinators are out there.
Those are some of the strategies that producers are using on their own initiative. We're not singularly focused just on seed treatments; we're looking at the broader environmental impacts on our farms and looking at the risk. It's naive to think we aren't having some impact on the environment. Our job is to minimize it or get it to a point where it's at an acceptable level that society is okay with.
Sometimes I think we argue with society about what that level is, and I think we have to have a broader debate about that. However, those are some of the strategies that are in place.
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From my standpoint as a farmer, it's hard for me to really understand the review process, to a certain degree, at PMRA. From my standpoint and from our organization's standpoint, we are looking at the registrants to understand what that process is and we want to make sure there's time available for them.
As I said before, I think there needs to be that collective approach in the review process, especially if PMRA identifies some areas they're concerned about, so that we can have some dialogue around that and not be caught off guard or find the industry scrambling to come up with some of the information that's required.
When we look at some of this work that needs to be done, it's going to have to happen over this growing season. We're going to need some time to figure out where the hot spots are, where it's coming from, and how we can take steps to mitigate that. It's a long-term and thoughtful process. At the end of the day, as a producer, I don't want to see us drift towards that European, hazard-based regulatory system. I very much appreciate the system we have in Canada, which is science-based and risk-based. I think right now we're bumping into that issue of what is acceptable risk, but some good solid consultation could help that process.