Does rushing decisions with poor data qualify as “sound science?”

Why is the PMRA in such a rush if the evidence against neonic seed treatments is weak and partial?

Farmers generally support using sound science as the basis for regulatory decisions on agriculture, including pesticide approvals and bans.

They support sound science being the basis of Canada’s Pest Management Regulatory Agency. In fact, I was told that Monday by the Canola Council of Canada. Most policy-involved farmers have tended to think highly of the PMRA because of this.

But what I’ve found most unsettling about the PMRA’s proposed blanket ban on two neonicotinoids, clothianidin and thiamethoxam, is the seeming rush to ban important tools for Western Canadian farmers based on data it admits is “less robust” than that for Ontario and Quebec.

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“In some areas there was much more monitoring data and it was more robust, such as in Ontario, (and) in other areas the monitoring data was not as robust, and this was the case for Western Canada,” said Scott Kirby, the PMRA’s Director-General of the Environmental Assessment Directorate.

Since the main crops using neonics out east employ them differently, in a manner generally accepted as having a higher risk of spreading into the environment, it doesn’t seem appropriate to assume the situation there can be simply plugged into assumptions about Western Canada.

I’ve also been unsettled by the PMRA’s apparent comfort with proposing a ban on products that are used on tens of millions of acres without considering the environmental consequences of the alternative chemicals and farming methods farmers will employ if they loses access to the neonics.

“We don’t do a comparative risk assessment of alternative chemicals. If they are registered, they are considered safe to use,” said Kirby. Since banning neonics will almost certainly lead to much more insecticide use, done in a way that  kills many more insects, and lead to much more machinery use, doing a comparative risk assessment would seem fitting, wouldn’t it?

Beyond those two strange elements was a third head-scratcher for me: the argument that not proving that neonic seed treatments on canola are hurting midges, mayflies and other aquatic insects can still be valid grounds for a ban if the agency believes there is a theoretical risk based on modelling.

“That information that we had available to us was not sufficient to show acceptable risk to aquatic organisms, so because of this we are proposing phasing out these chemicals,” Kirby said.

Ummm . . . So we’ve gone from needing to prove a risk to needing to prove there is not acceptable risk, when the agency admits it doesn’t have great data upon which to rely.

The PMRA still seems to be dedicated to a scientific approach and does not appear to be politicized. The PRMA media call was nicely free of spin, with Kirby seeming up-front and frank about the agency’s reasoning, both in responses to questions from urban media wondering why the PRMA wasn’t moving faster to ban and from agricultural media wondering why the agency wasn’t being more cautious. That’s reason for hope that the production of better data and analysis could cause the agency to modify its proposed bans.

But I think there are still serious questions to ask about whether something in the way PMRA operates has changed that is causing it to make decisions with inadequate data, on too-short timelines, and involving reverse onuses on approved products. Maybe it’s always been this way, but something feels weird here.

(I talk about the decision on the Between the Rows podcast this week. Listen to it here or through your favourite podcatcher.)

 

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