We should all be concerned about how the Pest Management Regulatory Agency is handling the re-evaluation of the insecticide imidacloprid.
The PMRA is currently gathering feedback, but it plans to phase out the product starting this November.
The PMRA’s approach is worrisome on a scale much larger than this one chemistry. Crop protection companies need a predictable, science-based regulatory environment or they’ll take their investment elsewhere. Canada is becoming a difficult jurisdiction for them to do business.
Imidacloprid is used largely as a seed treatment for a wide range of crops to control pests such as wireworms, flea beetles and various aphids and weevils. Trade names include Gaucho, Sombrero and Stress Shield.
The class of chemistry known as neonicotinoids is already under attack by the Ontario government because of linkages with bee losses. Canada and the United States are collaborating on the re-evaluation of neonicotinoids, including imidacloprid, to assess potential risks to pollinators. However, the decision to phase out imidacloprid relates to aquatic insects.
The PMRA’s re-evaluation is based largely on the chemical exceeding tolerance levels in water monitoring studies at sites in Ontario and Quebec where there was intense agricultural activity, both outdoors and in greenhouses. The levels were above the threshold of risk for certain aquatic invertebrate species — mayflies and midges.
Industry sources say the thresholds are set very conservatively, and the chemical may not be at levels affecting those aquatic insects in the real world. As well, the chemical may not pose any risk in the vast majority of the country. There just isn’t enough water monitoring to know.
It would seem to make sense to examine the pattern of use in the areas where tolerances were exceeded rather than yanking the product off the market. Unfortunately, the PMRA is rejecting that approach as unworkable.
The product is currently acceptable for use in many Organization for Economic Co-operation and Development countries, including Australia, New Zealand and the United States. There’s time to study the situation and get the decisions right.
According to industry sources intimately familiar with this file, the PMRA changed the aquatic toxicity endpoints for imidacloprid without notifying the registrant. The registrant had no opportunity to respond or to generate additional data. There was no consultation.
If imidacloprid is pulled from the market, producers are likely to respond by using more foliar sprays with older more potentially damaging active ingredients.
No doubt the PMRA is being besieged with submissions from environmental activists who would ban all crop protection products if they could. Farmers, farm organizations and industry have made their voices heard. The deadline for feedback is March 23.
If the PMRA maintains its hard line, industry will conclude that the competiveness of Canadian agriculture is being compromised by decisions that have questionable health and environmental benefits. Where the PMRA once worked with the industry employing open dialogue, the actions of the agency have become increasingly unpredictable.
Industry believes a national water monitoring program should be established for future re-evaluations. It’s in everyone’s best interests to have strong data from across the country on which to base decisions, but a field puddle that disappears in a week shouldn’t be considered an aquatic environment.
In the short term, industry is asking that the current process for pesticide re-evaluations be revised to ensure sufficient time for stakeholder engagement. If the PMRA refuses that simple request, it will place a chill on Canadian investment plans by crop protection companies.