CFA commends Health Canada’s recent decision to allow the continued use of clothianidin, imidacloprid and thiamethoxam (neonicotinoids) for use in canola seed treatment and greenhouse vegetables. Both of these uses do not pose unacceptable risk to pollinators.
It is extremely important for farmers to have timely access to new products for pest management in order to remain competitive on the global market. The Pest Management Regulatory Agency (PMRA) ensures that these products meet Canada’s strict regulatory requirements.
However, CFA feels that this decision process has highlighted major issues with the PMRA’s approach to product re-evaluations. While many farmers have critical field data that showed reduced risk from proper applications of pest products, they were unable to submit this data due to an overly strict submission window. This data is critical to show how a measured use of pest products prevent undue environmental harm.
Equal consideration of field-data and government analysis creates a balanced scientific approach that helps guide discontinuance of harmful products when unacceptable risks are detected.
The decisions also raise concern over the consideration of best-available science. Specific to these products, it is the understanding of agricultural stakeholders that eastern water data were used to estimate western exposure risks for aquatic invertebrates. The real-life cropping profiles of these species are distinct. As such, there is concern that the risk thresholds chosen were based on highly conservative laboratory data that were not consistent with real-world observations.
CFA supports the Canadian government’s recently proposed amendments to the pest product review process in Bill C-97, the Budget Implementation Act. These amendments would allow the Health Minister to determine which Special Reviews of products are triggered by decision made in other OECD countries. Currently, these reviews are triggered automatically whenever an OECD country bans a product, even if that product is already under re-evaluation. Reducing this duplication of effort should allow PMRA to focus on input provided through their Agricultural Stakeholder Engagement Unit.