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What’s your secret cure for the hiccups? Do you hold your breath? Do you drink a glass of water from the side? Do you hop on one leg? 

What if you weren’t allowed to do anything and had to hope the diaphragmatic dilemma resolved itself? When we have problems, we look for solutions to solve them. It’s instinctive. But what if the solutions to your problems became unavailable? Or worse yet, illegal. 

Western Canadian farmers may experience a few hiccups of their own when it comes to protecting their crops thanks to recent decisions by Health Canada’s Pest Management Regulatory Agency (PMRA) surrounding three common neonicotinoids. 

Neonics have been commonplace for Western Canada’s farmers since the early 2000s with the introduction of imidacloprid, thiamethoxam and clothianidin, which replaced harsh and more toxic organophosphates such as lindane and diazinon, which farmers often mixed by hand. 

“When [neonics] were brought to Canada, the PMRA and other regulators fast-tracked those because they were in the process of getting rid of the organophosphates. This new class heralded a new approach and less human toxicity and they were welcomed as a great alternative to the organophosphates,” said Pierre Petelle, CEO of CropLife Canada, an Ottawa, ON-based industry group representing the world’s largest agrochemical companies within Canada. 

Imidacloprid is a neonic used extensively to combat wireworm in wheat. As with all active ingredients, it was subject to a 15-year cyclical review by the PMRA. This Nov. 23, 2016 report concluded there were concerns related to aquatic invertebrates. Its findings triggered special re-evaluations of two other common neonics— thiamethoxam and clothianidin—also based on potential risk to the health of the aquatic species. 

During the 120-day consultation period on imidacloprid, more than 46,000 comments were submitted to the government on its proposed ban. The final proposals may push for the complete revocation of all three ingredients in outdoor operations with the exception of thiamethoxam in greenhouses. 

“My concern is that not only are Canadian growers losing significant and important active ingredients, the reputation [of Canada] as a predictable scientific country to come to might erode the attractiveness for new chemistries, as well,” said Petelle. 

The publication of the imidacloprid decision was released after press time. The decisions for thiamethoxan and clothianidin are expected in January 2020. 


In January 2016, the Auditor General’s office published a report by the PMRA on its study of the government agency’s activities during fiscal year 2014/15. Julie Gelfand, Canada’s federal commissioner of the Environment and Sustainable Development, made a three-minute video to publicly lambaste the agency for various infractions in what was effectively a disciplinary report. Of the seven recommendations that came down on the PMRA, most related to correcting poor internal controls and lack of oversight. The report suggested these deficiencies resulted in lost productivity, misspent work time and in the agency falling behind on re-evaluations of critical ingredients. 

Any active ingredient becomes subject to a special review prior to its 15-year operating period if an OECD country prohibits that active ingredient due to health or environmental concerns. Today, there are still about 30 outstanding active ingredients that require PMRA re-evaluations. 

In February 2018, the European Food Safety Authority published a report about risks associated with the three neonicotinoids and their potential threat to bees, which was years in the making. Two months later, EU member states approved the European Commission’s pitch to ban all outdoor uses of the three active ingredients currently being debated in Canada. The decision came into force May 29 with a grace period that recently expired on Dec. 19, 2018. The state of affairs in Europe was perhaps spurred on by Canada’s expedited pace of re-evaluations. 

“Now, PMRA is under self-imposed deadline to get them all cleared out,” said Petelle of re-evaluations. “Whether it was dragging their heels or the complexity of some of these chemistries; now, in their haste to complete these, to clear them off their books, they’re inadvertently creating upheaval in the industry.” 

Petelle’s group advocates for regulators to be involved in decision-making to help export-dependent Canada thrive and meet its target of $75 billion in agri-food exports by 2025. “We have all this talk about increasing our exports … the regulators aren’t part of that discussion. Our ask is that if we have the Government of Canada’s commitment to increasing agricultural production, the regulators cannot be on the sidelines because they have the ability to enable or very much hamper that ability to achieve those goals,” he said. In addition, Petelle stated that the potential alternative of returning to greater foliar spraying hasn’t been considered, something he bluntly labelled “a problem.” He cited the wider sustainability issues such a return would create, such as increased fuel consumption, reduced carbon sequestration and the greater number of applications required to get results comparable to those of the neonics in question. 

However, the PMRA typically does not evaluate alternatives. The organization looks at the issue at hand and its potential effects on human health and the environment, not a farmer’s in-field practices or what they may do if that chemical is pulled off the shelf. Petelle called it “short-sighted” to not review impacts for a ban on certain chemistries but does understand the government’s predicament. “If they identify a risk issue, it’s about mitigation, not how canola or apple growers will adapt to that. That’s also part of the problem—we’re very much looking at this in isolation,” he said. 

The government has made it clear that it won’t involve industry every step of the way, despite the insistence. “I can see why the [product] registrant would want that, but the public might not be on board with that,” said Frederic Bissonnette, a spokesperson for Health Canada, regarding re-evaluations. He added the process would take even longer if corporations were involved from the outset. 

The government’s recent proposed decisions pertaining to both thiamethoxam and clothianidin were based on water monitoring samples that showed risk to aquatic invertebrates, which included midges and mayflies. Eastern Canadian data was robust and plentiful while, by comparison, almost non-existent out West, where both geography and usage differ. A lack of hard numbers is not an issue, though. When it comes to data monitoring, the PMRA utilizes quantitative data sets as well as estimated environmental concentrations or EECs, which is extrapolated data based on water modelling. The PMRA says it always uses both, when available, but prefers real data, and the weight given to the data depends on the circumstances. 

The real data came up short in Alberta due to one of the driest years in recent memory, so the EECs were used in the findings and perhaps given greater weight given the conditions. “We had to make an assumption,” said Bissonnette. 

To complicate matters further, thiamethoxam and clothianidin are similar in nature, which caused the PMRA to conclude that since “both pesticides are registered for use on many of the same crops, it is often not possible to determine whether concentrations of clothianidin measured in water are a result of the transformation of thiamethoxam, a result of the use of clothianidin as an insecticide, or a combination of the two.” Nonetheless, the recommendation was put forth to revoke both their use for agricultural operations. 

Shannon Sereda, government relations and policy manager of Alberta Barley and the Alberta Wheat Commission, decried the EECs as “super concerning.” “You’re basing a risk analysis on a study and proposing the cancellation of a product across the country, but you’re not proving that the science is rigorous in arriving at that decision, particularly the work that was done in Alberta. It’s very inconclusive,” she said. 

In 2017, an initial chronic endpoint (HC5) reference value, or maximum allowable levels, for imidacloprid was set at 41 parts per trillion (PPT) by the PMRA, and most of the agricultural industry believed that the threshold values would be similar for both clothianidin and thiamethoxam. However, the PMRA subsequently indicated HC5 reference points of 1.5 and 26 PPT, for clothianidin and thiamethoxam, respectively. The issue became clouded yet again when different reference standards were announced for the PMRA’s risk assessments on clothianidin and thiamethoxam, this time higher, to 20 and 300 PPT, respectively. 

Nevin Rosaasen is the Alberta Pulse Growers’ policy and programs specialist as well as a Saskatchewan grain farmer who is concerned with the aquatic findings. “They should consider other impactful substances to waterways and specifically those downstream from urban centres,” he said. The substances in question include medications, hormones, air source pollutants and other contaminants, most of which were found downstream of dense population zones in recent monitoring. “The data should be collected in a manner that’s common and consistent across the country. The PMRA’s work could be further harmonized with the U.S. EPA and include work sharing in special reviews or re-evaluations. We want them to come to similar conclusions using similar methods. That’s what we’re striving for.” 

For wheat and barley farmers, Sereda is concerned about wireworm and that alternatives do not exist to treat this invasive pest. “From a cereals perspective, lindane was an effective product available for the eradication of wireworm but was cancelled in 2004. Since then, there has been an anecdotal increase in wireworm, because neonics do not eradicate it. They’re a suppressant and only work to allow the plant to emerge but will not reduce the prevalence of wireworm,” she said. 

Both she and Rosaasen agree that the PMRA needs to change the process it uses to engage with stakeholders, including the creation of a draft assessment prior to a publicly proposed decision to avoid alarmist language in the public domain. As well, they’re advocates of the PMRA expanding its mandate. Aside from evaluating environmental risks, they believe it should consider economic impacts to farmers and the economy, if and when chemistries are no longer available to Canadian farmers despite remaining in use in other countries. 

Today, Alberta has surpassed Saskatchewan as the No. 1 producer and exporter of Canadian yellow peas. The increase in production has raised red flags about increasing pest prevalence, specifically the pea leaf weevil. Pulse farmers now have two suppression options: thiamethoxam and imidacloprid. If these active ingredients become unavailable, there will be no accessible products to suppress or control the weevil. There is also no product now available to farmers that is 100 per cent effective against the pest. 

“The lifecycle of pea leaf weevil is such that by the time you notice any notching in your plants, the adult weevil has laid an egg at the surface of the soil. Once the egg has hatched, the larvae begin chewing away on the nodules of pea plants,” said Rosaasen. 

What makes pea leaf weevil that much harder to control is they can fly in from adjacent fields and continue multiple life cycles during a growing season. Rosaasen describes foliar spraying for weevil as “revenge killing” that would accomplish nothing and certainly not control adult populations. To salvage a pea crop, it must become attractive enough for farmers to apply a nitrogen rescue. 

“To finish a 50-bushel pea crop, peas will need 150 pounds of actual nitrogen, which basically negates our pulse advantage,” he said. Losing not only a pulse advantage, but also a general agronomic advantage, is what these neonics in question continue to represent for western Canadian farmers. 

Despite reservations over research methods and chronic endpoints at the PMRA, both Sereda and Rosaasen side with Petelle and are eager to continue to collaborate to reform the PMRA’s decision-making process. 

“One glimmer of hope is that we are having dialogue with the PMRA. They have committed and acknowledged that the re-evaluation process needs to change. We’re engaging with them on that process. My expectation is that we’ll have a better outcome on that program in the future. The next cycle of re-evaluation—we’re hopeful and optimistic that the process will be improved, with less surprises with negative impacts for ag,” said Petelle. 

For a chemical company to bring a new active ingredient to Canadian farmers, it costs more than $300 million and takes anywhere from eight to 11 years. If the three active ingredients in question vanish, conventional farmers should hope that new research has already begun so they may have new options to protect their crops. Hiccup.


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