Grainswest - Winter 2019

Winter 2019 Grains West 40 Petelle’s group advocates for regulators to be involved in decision-making to help export-dependent Canada thrive andmeet 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 FEATURE For wheat and barley farmers, there is concern that no alternatives exist for the treatment of wireworm.