Blog: The Wheat Sheaf

Letter to PMRA: Response to Proposed Re-evaluation Decision for Imidacloprid

Richard Aucoin
Executive Director
Pest Management Regulatory Agency
Health Canada
2720 Riverside Drive
Ottawa, Ontario K1A 0K 

Thursday, March 23rd, 2017 

RE: Response to Proposed Re-evaluation Decision for Imidacloprid

Dear Dr. Aucoin:

The Alberta Wheat Commission (AWC) is pleased to have the opportunity to share the producers’ perspective in response to the Pest Management Regulatory Agency’s (PMRA)  decision to re-evaluate the neonicotinoid insecticide imidacloprid.  AWC has developed a reputation for demonstrating leadership and facilitating collaboration and is well-positioned to provide the producers’ perspective on policy matters.  AWC not only represents the interests of over 14,000 wheat farmers in the province of Alberta, we take advantage of every opportunity to work in partnership with other producer commissions and associations here in Alberta and across the country on issues of common interest including the role that neonicotinoid seed treatments serve as a valuable tool to cereal, pulse and oilseed production across the prairies.

Given the work that AWC has led with respect to sustainability at the provincial level with Team Alberta and the Alberta Farm Sustainability Extension Working Group as well our leadership at the national level with the National Environmental Farm Plan and the Canadian Roundtable for Sustainable Crops, we will also take this opportunity to highlight how seed treatments have enabled producers to grow crops more sustainably. 

Imidacloprid is a valuable management tool used by producers on a wide range of agricultural crops to manage pests such as pea leaf weevils and aphids as well as wireworm in wheat for which imidacloprid is the only effective management tool. Cereal producers typically treat with a fungicide-only seed treatment and utilize insecticide seed treatments only when protection against insect pests is required.

Scientific rigour is becoming increasingly important as Canada’s agriculture sector looks for ways to become more efficient and more sustainable through the adoption of new technology and innovative ways to grow more food with fewer inputs. Canada is recognized globally for its leadership in the establishment of a predictable, science-based regulatory environment - one which international investors have come to rely on. Maintaining this standard with respect to evaluation is key to encouraging the type of investment required to keep Canada’s agriculture sector competitive in the global market place.  Losing access to modern farming tools such as seed treatments including imidacloprid puts Canadian farmers at a competitive disadvantage, especially when you consider that these tools are readily available to farmers in competing jurisdictions, including the United States. 

Farmers are price takers and therefore any costs incurred by farmers cannot be passed on to our customers. If farmers continue to lose access to valuable tools such as seed treatments, pest-management will become more complex and costly. This increase in cost, coupled with a certain reduction in yields will have a negative impact on their already narrow margins. 

The PMRA’s decision with respect to imidacloprid has the potential to set a precedent for the use of similar products and this is very concerning to an industry that has come to rely on PMRA’s previous track record for employing a transparent, rigorous, science-based approach to evaluation.  It is therefore critical to ensure that PMRA is encouraged to protect the credibility of the process and not allow outside motivations to influence what must be an objective science-based approach. 

Imidacloprid is one of the most extensively studied insecticides.  As such, it has one of the largest available datasets to characterize the potential impacts on non-target organisms. According to the product registrant, Bayer, the dataset for aquatic invertebrates is comprised of more than 110 studies performed in laboratories and over 31 meso and microcosm studies.  Therefore the PMRA’s decision to undertake a regulatory phase out of this product after a re-evaluation that relied heavily on laboratory results without adequate in situ evaluation and testing is concerning.  AWC, along with a number of our industry partners, are recommending that the PMRA take the time required to evaluate additional watershed data from a variety of Canadian regions, including privately available data, prior to the issuance of the final re-evaluation decision. We also request that these concerns be addressed prior to commencing the re-evaluation process for thiamethoxam and clothianidin.

As previously mentioned, today’s producer is on the cutting edge of technology, always adopting new practices that make their farming operations more efficient and in-turn more sustainable. They are proud of their role as stewards, protecting what they have inherited and preserving and improving the land for generations to come. Canada’s cropping sector has long been part of the climate change solution. The introduction of conservation tillage has allowed Canadian farmers to significantly increase the amount of CO2 that is effectively removed from the atmosphere and stored or ‘sequestered’ in the soil. This has resulted in crop productivity increasing at twice the rate of increases in greenhouse gas emissions between 1990 and 2013. In 2000, for the first time in Canada’s history, agricultural soil sequestered more carbon than was emitted.

Imidacloprid maintains a favourable environmental profile; it has provided an effective way to manage wireworm in wheat, which prior to its advent could only be controlled through the use of spring and fall tillage, releasing previously sequestered C02 into the atmosphere, or the application of non-selective foliar treatments.  According to research conducted by the Government of Alberta, “overall, the new seed treatments are more effective, control a broader range of pests, and are much safer to use for both the applicator and the environment” (2013). 

In addition to the positive environmental impacts of modern seed treatments they are safer for farmers to handle and apply, “one key benefit is lower dose and use rates. This decreases the amount of product that needs to be used and reduces environmental exposure to the user” (Government of Alberta, 2013).

In our view, insufficient relevant data has been collected to allow for a science-based decision to be made concerning imidacloprid at this time.  Furthermore, AWC is concerned about the precedent that could be set for future reviews and the impact it will have on the sustainable management tools available to Canadian farmers.

AWC is grateful for the opportunity to provide comment as part of the Committee’s Review of this important matter and I invite you to contact our Government Relations & Policy Manager, Erin Gowriluk via email at egowriluk@albertawheat.com or telephone at 403.219.7901 should you require any additional information with respect to our submission.

Sincerely,

Kevin Auch,
AWC Chairman

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