A Letter to the PMRA About Seed Treatments

You may not have heard much about this, as it has had minimal news coverage, but the PMRA is planning on phasing out imidicloprid, a neonicotinoid insecticide we use for combating early-season insect pests. There are a number of similar products out there,
and together, they help us protect our crops from a variety of difficult to control insects. Why are they phasing out this one?

“Robust environmental monitoring from several areas of intense agricultural activity in Ontario and Quebec further support these findings as imidacloprid is detected frequently in surface water at levels well above concentrations that may result in toxic effects to insects.”

The reality is that their data-set is far from “robust”. They did not use data from Western Canada, stating this:

“Although robust monitoring data are not available for all regions in Canada…it is anticipated that elevated levels may be found in many agricultural areas where there is a high volume of use.”

The statistics in putting this data set together are staggeringly weak and highly presumptuous. We have a different climate, different crops, and a different ecological environment. This is the precautionary principle at its finest – prevent any possible harm without considering the risks of not allowing the product to be used. Without neonics, we DSC_0703will be forced into using less effective, potentially more toxic insecticides that are prone to pest resistance.

If neonics truly were causing serious harm, I would be alright with phasing them out; but the data set the PMRA is using is very weak, and the methodology used is a poor reflection of sound science. If you want to read their report, you can find it here.

The Grain Growers of Canada have produced an excellent letter to send to the PMRA, asking “farmers to express their comments to PMRA as part of the official consultation and amplify our industry’s collective request to see data from the 2017 crop included in the review.”

The deadline to submit is midnight tonight. We need to work together to try and make the PMRA realize how important science-based policy is to us – and how important it is that we have access to all the tools we need for integrated pest management.

This is the letter that I sent this morning. The Grain Growers of Canada wrote most of it; I only added the second last paragraph. I commend the organization for the work they have done to put this together.

March 23, 2017

Pest Management Regulatory Agency
Health Canada
2720 Riverside Drive
Ottawa, Ontario
Address Locator: 6606D2
K1A 0K9

PMRA.publications@hc-sc.gc.ca

Re: Proposed Re-evaluation Decision PRVD2016-20, imidacloprid

Dear Pest Management Regulatory Agency:

I am writing to you today, as a Canadian grain farmer, to express my concern with your agency’s proposed re-evaluation decision of imidacloprid. This product has been in use in Canada for over 20 years and I personally rely on it on my farm as a safe and effective method of managing pests.

I support and rely on Canada’s internationally respected regulatory system where registration and re-evaluation decisions are risk-based and grounded on sound science. As such, I am concerned that the decision to phase-out imidacloprid was not based on a credible and thorough risk assessment given the limited data sets considered by the PMRA in its proposed decision. These data sets do not reflect the potential risk across the varied Canadian agricultural landscape.

Canadian farmers use imidacloprid and other neonicotinoid seed treatments prudently as part of an integrated pest management approach. As food producers, our access to varied chemistries, tools and methods to control pest outbreaks is becoming more limited. This variety is crucial to having adaptability on our farms to limit pest resistance and risks to profits, the environment, and consumers.

On my farm, we work hard to utilize an integrated pest management approach, and we are extremely careful about potential off-target impacts from our crop protection products. We need these products to profitably produce food in an environmentally sustainable manner. Phasing out neonicotinoid products, such as imidicloprid, will remove our best protection against in-season insects. If we do not have access to these products, we may be forced to use older, less effective chemistries that, in some cases, are considerably more toxic (and therefore dangerous) to use; this puts me, my family, and my employees at risk. Moreover, these alternative products are prone to pest resistance, which will further stress the long-term sustainability of my farm.

Considering all the factors that directly impact me, as a farmer, I respectfully request that the PMRA adjust its timelines for the final decision on imidacloprid to allow relevant data to be generated and analyzed from the 2017 growing season. This will allow the PMRA to make the best possible science-based decision for farmers and all Canadians.

Sincerely,

Jake Leguee

Again, click here to go the Grain Growers website to download their letter. Don’t wait – it must be submitted before midnight tonight!

Advertisements