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Spring
2018
grainswest.com29
ROP PESTS ARE LIKE PARTY CRASHERS: IF YOU
can’t get rid of them, at least limit the damage they
do. While farmers would be lost without pest control
products, they understand the need to regulate their use. But
in the drive to review new chemistries and re-evaluate existing
ones, some worry that science has taken a back seat.
Under the federal authority of the Pest Control Products
Act, the Health Canada Pest Management Regulatory Agency
(PMRA) is responsible for regulating these products.
“Our mandate is to prevent unacceptable risks to people and
the environment from the use of these products,” said André
Gagnon, media relations officer for Health Canada. “Health
Canada takes a science-based approach to decision-making
and works closely with its international counterparts to ensure
that regulations for pesticides are aligned.”
Once a product is approved for use in Canada, it is subject to
the PMRA’s re-evaluation program using internationally accepted
assessment techniques and current scientific information.
“Rigorous, science-based risk assessments are conducted
to determine if pesticides continue to meet modern standards
for human health and environmental protection while providing
value,” said Gagnon. “The result of the re-evaluation of a
pesticide can range from continued registration of all uses to
updates to use instructions on labels, to the cancellation of
all or some uses due to human health or environmental risk
concerns.”
Though few would argue against the need for a transparent,
predictable, science-based approach to pesticide review and
re-evaluation, there is growing concern that the need—at least
on the re-evaluation side—is no longer being met.
“In regard to new products, we are quite pleased with
the process,” said Pierre Petelle, president and CEO of
CropLife Canada. “The PMRA is a world leader in working on
harmonized approaches and applying the best, most modern
science to assess products.”
As a result, Petelle said innovation is encouraged and growers
gain access to the latest tools, keeping Canadian agriculture
competitive while protecting our health and environment.
But if the new-product review picture is a thing of beauty, the
re-evaluation side is where things get ugly in Petelle’s view.
“The story with re-evaluations is almost opposite to new
reviews. Instead of collaboration, the agency works in isolation
on their own timeline, making decisions that are sometimes
opposed to what the United States Environmental Protection
Agency or European agencies are doing.
“The crux of the problem is that we are not being consulted
when there are red flags or risk issues during the re-evaluation
process.” As a result, said Petelle, there is no opportunity to
provide new information about the chemicals or how products
are used. Reviewers may be using assumptions from 15 years
ago that are now out of date.
“If they reached out to industry when risk questions arose,
we could alleviate some concerns before proposed decisions
C
are published that cause angst for our members and the
entire agriculture industry. In a nutshell, we are asking for a
similar process to that used with new compounds, one that
is more collaborative and gives greater consideration to the
competiveness of Canadian agriculture.”
Organizations such as Alberta Barley, the Alberta Wheat
Commission and Alberta Pulse Growers have expressed that
collaboration was missing in a recent PMRA proposed decision
to phase out imidacloprid, which belongs to a relatively new
class of insecticides called neonics used to control a variety of
pests—especially sap-feeding insects—and root-feeding grubs.
“That decision was made with limited data and perceived
by industry as a precautionary principle, acting without ample
evidence of risk to aquatic invertebrates,” said Nevin Rosaasen,
policy and program specialist with Alberta Pulse Growers.
It’s a decision that could have far-reaching implications for
farmers. “Imidacloprid is used in a tremendous spectrum of
products including seed treatments, foliar treatments and
other uses,” said Petelle. “For example, canola growers use
imidacloprid to reduce the amount of foliar spraying over
millions of acres. Losing that ability could leave them with no
alternatives for protecting their seeds, resulting in lost crops and
expensive re-seeding.”
Many sectors are now concerned that similar compounds in
the neonic family may be headed down the same path, with
serious repercussions. They fear that moving away from these
products could necessitate the use of farm practices that carry
greater environmental impacts, such as tillage and broadleaf
foliar spraying.
“Eliminating or phasing out neonics as seed treatments
will have drastic impacts on certain crops where insect life
cycles and early seedling pressure may result in increased
use of non-selective foliar application of insecticides,” said
Rosaasen. “This crop protection application method does not
differentiate between those targeted pests and the beneficial
insects, including parasitoids, that can keep problem insect
populations in check and at thresholds that do not warrant
action to protect crops.”
While tillage was believed to be a practice that could
minimize cutworm pressure in the past, the jury is still out on
whether tilling soil kills cutworm eggs and larvae under certain
conditions. “Tillage is certainly not a sustainable pest control
practice and absolutely increases the risk of soil erosion and soil
degradation,” said Rosaasen.
Then there are the economic repercussions to consider.
“Certain crops like peas and canola may decline in acres if
neonic seed treatments are no longer available. There is no
other product on the market that can provide any suppression
of the pea leaf weevil and, should Alberta Pulse Growers lose
this control product, there will be fewer acres grown as a result.”
Another contentious re-evaluation occurred in June of
2017 regarding Matador-120EC, a contact chemical effective
against a broad spectrum of foliar pests. “Again, there was no