Submission to Pest Management Regulatory Agency Regarding Proposed Ban of Ban Clothianidin and Thiamethoxam

November 13, 2018

Pest Management Regulatory Agency, Publication Section

Health Canada

2720 Riverside Drive

Ottawa, Ontario

Address Locator: 6607D  K1A 0K9

Email: PMRA.publications@hc-sc.gc.ca

Dear Pest Management Regulatory Agency:

The Manitoba Canola Growers Association (MCGA) appreciate the opportunity to respectfully submit written comments on the Pest Management Regulatory Agency’s (PMRA) Proposed Special Review Decision published in PSRD2018-01, Special Review of Clothianidin Risk to Aquatic Invertebrates: Proposed Decision for Consultation and the same published in PSRD2018-02, Special Review of Thiamethoxam Risk to Aquatic Invertebrates: Proposed Decision for Consultation.

MCGA represents upwards of 8,500 canola farmers in Manitoba. We are committed to helping our members maximize their net income through sustainable production of canola. MCGA is deeply concerned that the proposed decisions regarding neonicotinoid seed treatments, such as clothianidin and thiamethoxam, will have a significant detrimental impact on the sustainability of canola production in Manitoba.

MCGA is supportive of the PMRA’s mandate and recognizes the important role the agency plays in ensuring the safety of regulated pest-control products for both human health and the environment. A science-based regulatory process is the foundation upon which the Canadian canola industry was built. Empowering farmers with a suite of proven safe and effective tools to protect their crops is paramount to their continued ability to produce the canola that contributes $26.7 billion to the Canadian economy annually, and supports 250,000 jobs across the country.

Growers rely on the use of neonicotinoids in seed treatments to increase their productivity and their cost effectiveness through targeted protection against damages caused by pests, including flea beetles – a devastating pest of canola. It has been scientifically proven that, in the absence of a predictive model for flea beetle population management, using treated seed on most production acres is the only effective way of preventing widespread crop losses. Treated seed provides economic and environmental benefits, requiring less fossil fuel and pesticide use compared to the alternative of foliar spraying, reducing tillage, diminishing crop losses, and providing the ability to target specific pests while protecting other beneficial organisms that may be present in the field.

The proposed ban on clothianidin and thiamethoxam seed treatments could result in higher rates of foliar insecticide applications. This is never the first choice for our growers who are always looking for more targeted, more effective and less invasive pest control options.

If the PMRA moves ahead with a ban on both clothianidin and thiamethoxam, such a decision will also impact growers’ ability to compete effectively on a global scale. With more than 90% of the canola produced in Canada exported to markets around the world, it will hinder the agriculture sector’s ability to reach the Government of Canada’s goal of $75 billion in exports by 2025.

Farmers and our industry rely on a PMRA that has adequate information and resources to undertake its mandate and prevent unacceptable risks to people and the environment related to the use of pest control products. A regulatory system that is predicable, transparent and science-based, providing an environment for companies developing crop inputs to do business in Canada and providing confidence in our export markets that the products used are safe, is essential to our industry.

Canadians expect their government to make decisions to help protect their safety and the environment, and it is critical for a regulatory agency such as PMRA to make decisions that are grounded in science and supported by strong and irrefutable scientific evidence. Ensuring that all relevant data have been considered, and that proper consultations have taken place with key stakeholders, will strengthen confidence in the PMRA and its mandate.

It is our understanding that the PMRA’s proposed decision does not adequately consider monitoring evidence of aquatic invertebrates, and that the PMRA itself acknowledges in the consultation documents the existence of uncertainty in their assessment review of the risk of both thiamethoxam and clothianidin, specifically relating to the choice of endpoints, exposure estimation, modelling, and monitoring.

We urge the PMRA to re-evaluate its decision to ban both clothianidin and thiamethoxam until conclusive data on the impacts of neonicotinoids on aquatic invertebrates are considered. We would urge the PMRA to provide a cost-benefit analysis considering the economic and environmental impacts in the absence of a viable alternative. We would also ask that the PMRA engage directly with agricultural stakeholders to determine if appropriate and effective risk mitigation strategies could be put in place as an alternative to a full ban, and that future re-evaluation decisions by the PMRA include such consultations at the preliminary stage of the review.

Thank you for consideration of this submission. Canola growers and the canola industry are committed to the highest standard of human health and environmental safety. We believe strongly that the PMRA needs access to the best available science; that it must embrace timely consultation with industry stakeholders; that it must consider the impact on a sector’s competitiveness; and that it must pursue harmonization of efforts with other pest management regulators, particularly the U.S. EPA.

We look forward to your response to our concerns.

Sincerely,

Charles Fossay

President

Manitoba Canola Growers Association

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