Health Canada on Wednesday announced its special review decisions on the risks to aquatic bug life from the use of clothianidin and thiamethoxam, both pesticides and seed treatments from the neonicotinoid (“neonic”) class.

The health department launched a special review of the neonics in 2016, leading to a 2018 preliminary decision calling for a phased-in ban on outdoor use of the chemicals. However, it said Wednesday it would instead be “updating” some of the products’ registered uses and introducing “additional mitigation measures and restrictions” on uses that remain registered.

Clothianidin is an active ingredient in ag chem products including BASF’s Titan and Poncho, Bayer’s Prosper, Emesto and Sepresto and Valent’s Nipsit, Clutch and Arena. Thiamethoxam, meanwhile, is marketed by Syngenta under brands including Helix, Cruiser and Actara, among others.

For thiamethoxam, Health Canada will cancel the chemical’s uses in soil drench application on potato crops and foliar application on lowbush blueberries. For clothianidin, in-furrow application on potato crops and seed treatment for field-sown leafy vegetables and bunching onion will be cancelled.

Among changes in label use for clothianidin, new or revised spray buffer zones will be put in effect around freshwater habitats, plus:

• maximum seed treatment rates for field corn will be cut to 150 grams of active ingredient (g.a.i.) per 100 kg of seed, which cancels its use on corn rootworm;
• maximum seed treatment rate per year per hectare (ha) on vegetables is limited to 100 g a.i., limiting the planting rates for broccoli, bulb onion, carrot, cabbage, cucumber and leek;
• foliar use on cucurbits is cut to a single application of 70 g a.i./ha per season, cancelling its use for brown marmorated stink bug;
• foliar use on potatoes is reduced to a single application of 52.5 g a.i./ha per season;
• foliar use on turf is cut to a single application of 125 g a.i./ha per season, cancelling its use against hairy chinch bug, annual bluegrass weevil, bluegrass billbug and European crane fly; and
• greenhouse seed treatment use for onion maggot and seed corn maggot on bulb onions will be cancelled, “as these are only pests found in field production.”

New or revised spray buffer zones will also be required around freshwater and terrestrial habitats for use of thiamethoxam, among other restrictions including:

• a lower maximum seed treatment rate for field corn (including seed corn production), at 200 g.a.i./100 kg of seed, thus cancelling its use also against corn rootworm;
• a lower maximum seed treatment rate for soybean, at 30 g a.i./100 kg of seed, cancelling uses against bean leaf beetle, European chafer, soybean aphid and wireworm;
• lower soil drench and in-furrow rates for leafy vegetables, at 90 g a.i./ha, cancelling those uses against cabbage looper, beet armyworm, corn earworm and fall armyworm;
• lower soil drench and in-furrow rate for brassica vegetables, at 90 g a.i./ha, cancelling uses against dipteran leafminers, cabbage looper, diamondback moth, imported cabbageworm, thrips, beet armyworm, corn earworm, fall armyworm and yellowstriped armyworm;
• a lower limit of one foliar application per year on dry shelled bean, potato and soybean;
• one foliar application per year against all pests on celeriac and for pepper weevil on peppers;
• for use against stink bug, tarnished plant bug and brown marmorated stink bug in fruiting vegetables, a limit of one application at the top application rate (52.5 g a.i./ha) per year;
• one foliar application per year on cranberry; and
• a requirement to hold flood water for 30 days for cranberries that require flooding.

Health Canada said its scientists “have reviewed a large body of scientific information and concluded that a complete ban on neonicotinoid pesticides is not warranted,” and the new mitigation actions “will address the risks posed to aquatic insects.”

Revised labels reflecting the new rules must be in place “no later than 24 months from today,” Health Canada said, while “a small number of uses for which there are no suitable alternatives will continue for an additional 24 months.”

New information collected during the reviews “allowed the department to determine that some uses do not pose a risk to aquatic insects, while other uses do pose risks of concern,” Health Canada said.

During its consultations in 2018, “concerns were identified by Health Canada from available scientific information that these two pesticides are frequently being detected in aquatic environments in Canada at concentrations that may pose a risk to aquatic insects,” among them important food sources for fish, birds and other animals.

But from that point, “more than 47,000” comments were received, along with several new scientific papers plus new studies and water monitoring data from product registrants, provinces, academia and other regulatory authorities.

The final special review decisions in both cases were delayed until now from last fall’s target dates “due to the unprecedented volume of information received during consultation and the challenges of the COVID-19 pandemic,” Health Canada said Wednesday.

Health Canada has scheduled webinars in English and French for April 15 to provide an overview of the special review decisions. The registration deadline for those webinars is April 12.

‘Not convinced’

Canola grower groups on Wednesday cheered the new final decision, which they said found that current use of the two products, including seed treatment, by canola farmers “does not pose an unacceptable risk to aquatic invertebrates.”

“This is great news for canola farmers as it maintains our ability to protect the canola crop at its earliest stages of development,” Mike Ammeter, chair of the Canadian Canola Growers Association (CCGA), said in a release.

“Flea beetles can dramatically reduce stand viability if not controlled early and maintaining access to these products is important for the environmental and economic sustainability of the crop.”

CropLife Canada, which represents plant biotech and ag chem companies, was also “pleased” with many aspects of the final review.

However, CropLife CEO Pierre Petelle said in a statement Wednesday, “unfortunately, in some cases — specifically in the horticulture sector — many important uses of these products will be restricted, and in some cases, removed entirely” which “may jeopardize the viability of certain types of production in Canada.”

Overall, though, Petelle said it’s “encouraging to see science prevail as (Health Canada’s Pest Management Regulatory Agency) has changed its recommendations from what appeared in the proposed decision from 2018.”

Neonic product registrants and other stakeholders “provided PMRA with significant amounts of additional high-quality data during the consultation period, which appears to have helped the agency make a more informed, risk-based decision based on the best available real-world data.”

Environmental groups, meanwhile, were less than pleased with PMRA stepping off its 2018 position.

“It is outrageous that Canada’s pesticide regulator is not delivering on its own proposed ban on neonics. European countries stopped using these chemicals years ago,” Beatrice Olivastri, CEO of Friends of the Earth Canada, said in a release Wednesday. “These neonics posed unacceptable risks four years ago, so what happened to make them safe today?”

“We are not convinced that tinkering with label restrictions will be effective in reducing concentrations of neonics in the environment,” Charlotte Dawe, a campaigner with the Wilderness Committee, said in the same release. “Certainly it will be less effective than the originally proposed ban.”

Health Canada said Wednesday it also plans to release a final re-evaluation decision for another neonic, imidacloprid, later this year, and is “in the final stages” of completing that review. — Glacier FarmMedia Network

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BASF says it is two years away from launching its new cereal seed treatment, Teraxxa, on both sides of the Canada-U.S. border.

The seed treatment will introduce a new chemistry to the market. Teraxxa will be a Group 30 pesticide and promises to actually kill wireworms, rather than current seed treatments that only discourage feeding.

“The current products are mainly neonicotinoid based and they really don’t do a good job killing wireworms,” Manitoba Agriculture entomologist John Gavloski said. “They kind of make them sick and they don’t feed during the vulnerable stages, but then later on the wireworms do recover and they resume feeding. So that’s the difference of this product. It actually kills them. So you’ve basically knocked the population way back for the next year, which is good.”

For the first time growers can control wireworm, rather than manage it. And the new product is an alternative to neonic chemistry to boot.

Teraxxa’s active ingredient, broflanilide, affects the nervous system of the wireworm, causing overstimulation and death, Chris Hewitt, seed treatment brand manager with BASF said. The result, according to the company, is rapid mortality to wireworms on contact and therefore active population control.

“In effect, it’s lights out on wireworm,” Hewitt said.

At the moment, the product is only slated for registration in cereals, primarily oats, barley and wheat, he added.

The product promises to break the life cycle of the wireworm, which can survive in the soil for multiple years and, until now, has been a challenge to fight once a population is established.

The seed treatment will also be outfitted against seed and soil-borne diseases.

“We’ve been working on this for a while both in Canada and the U.S. and we see this as a great new tool in the tool box for growers to make use of,” Hewitt said. “It’ll also include our broad-spectrum fungicide products.”

The product will be co-formulated with Insure Cereal FX4, a fungicide targeted to soil-based pathogens and seedling diseases in barley, oats and wheat.

Teraxxa alone will also be made available for mixing, Hewitt added.

Teraxxa will be one of the first new seed treatments put out by BASF since folding in Bayer’s seeds portfolio. The two agri-chemical giants closed a deal in August last year, which saw BASF absorb assets shed by Bayer as part of its deal to acquire Monsanto.

BASF suddenly got access to Bayer’s variety development and breeding assets, seed treatments, some of its pesticide projects and a new digital farming arm, Xarvio.

The company expects to see over 39 new products come to market by 2025, including a list of new seed treatment products.

Dodging the neonic debate

The Group 30 pesticide flies under the radar when it comes to public backlash against neonicotinoids. The group of pesticides have taken a reputational hit for their accused impact to aquatic insects and pollinators, leading to much tighter restrictions in places like Europe. The European Union banned three of those chemistries — clothianidin, imidacloprid, and thiamethoxam — for field crops in 2018.

Those three chemistries have also come under review from Health Canada’s Pest Management Regulatory Agency (PMRA). The product dodged the worst of the possible restrictions during a review on its impact on pollinators earlier this year, but is still waiting a review on its impact on aquatic insects, something that could still limit use or remove it entirely from the farmer’s tool box.

BASF inherited clothianidin-based seed treatment Poncho in the deal with Bayer. As a non-neonicotinoid, however, Teraxxa will dodge those regulatory worries.

Gavloski welcomed the addition of a non-neonic wireworm control option, given the looming spectre of neonicotinoid review.

“As far as the neonics go, I think the review is going to continue regardless of this product coming on the market. If anything, it provides a reasonable alternative to the neonics, so we wouldn’t be left in a void with a lot of crops if they were to be phased out. The timing of it is good given what’s happening,” he said.

He has not seen any work on Teraxxa’s potential impact to pollinators or aquatic insect species, he said, although he suspects there would be limited risk to pollinators unless the seeder throws off excessive dust to bring the seed treatment in contact with those pollinators.

BASF hopes to register the product next year for commercial launch in 2021.

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The research comes as Health Canada places new limits on the use of three key neonicotinoids while it decides whether to impose a full phase-out of the chemicals.

Neonics are the most commonly used insecticides in Canada, but they have also been linked to honeybee colony collapses.

“When bee colonies began to collapse years ago, it became clear there wasn’t just one factor involved,” said Nuria Morfin Ramirez, who completed the research as part of her PhD. “We were interested in whether there was an interaction between two of the main stressors that affect bees: varroa mites and a neurotoxic insecticide, clothianidin.”

The study revealed that when honeybees are infected with varroa mites and then regularly exposed to low doses of a commonly used neonicotinoid called clothianidin, their self-grooming behaviour drops off.

Without that self-grooming, bees are susceptible to mites that can also carry viruses that can quickly kill, said Morfin Ramirez.

The mites kill bees by slowly feeding off their blood and body fat, and can also transmit deformed wing virus. One of the only ways bees can protect themselves is to groom aggressively and brush the mites off.

“What we found was a complicated interaction between the mite and the pesticide that decreased the proportion of bees that groomed intensively, and affected genes associated with neurodegenerative processes,” Morfin Ramirez said.

The study concluded that reducing stressors on bee colonies was key to reducing colony mortality.

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Producers will still have access to most imidacloprid, clothianidin and thiamethoxam uses following the April 11 ruling.

In 2016, the federal government announced plans to phase out imidacloprid over three to five years, based on unacceptable risks to aquatic insects.

Proposed crackdowns on clothianidin and thiamethoxam, which Health Canada found posed a similar risk, quickly followed. Both pesticides were also slated to be phased out.

Health Canada later separated the debate between aquatic insect and pollinator risk.

The resulting stream of 2017 and 2018 proposals — based around pollinator risk — gave a more lenient tone.

Why it matters: Three neonicotinoid pesticides have final decisions from Health Canada, and both beekeepers and crop growers seem happy, but another round of decisions with heavier consequences is yet to come.

Health Canada proposed to cancel clothianidin for strawberry and orchard use and limit application on crops like melon and squash, but left other agricultural uses largely unchanged.

Thiamethoxam was slated for cancellation on foliar application in orchards and soil use for berries, melons, squash and fruiting vegetables — as well as a ban on foliar spray on berries, legumes and fruiting vegetables during bloom.

Imidacloprid, meanwhile, would be cancelled for some foliar applications (pome fruit, some tree nuts, most small berries and fruit) and soil uses (legumes, herbs, berries), but maintained its use for strawberries and potato, except during bloom. All three had added label requirements for cereal or legume seed treatments.

Those decisions largely echoed Health Canada’s final word on pollinator risk on April 11. The April decisions will have no impact on canola growers or seed treatment in potatoes, and foliar application in potatoes will still be allowed, although not while plants are in bloom. Thiamethoxam and imidacloprid, likewise, will still be allowed for seed treatment in soybeans and peas, although not for foliar treatment during bloom and thiamethoxam is limited to foliar use after soybeans are done blooming.

“Bloom is a little bit of a hazy term with potatoes,” Leonard Rossnagel, a retired potato agronomist and previous director with the Manitoba Seed Potato Growers Association, said, pointing to varietal differences in bloom.

Very few neonicotinoids are sprayed on a growing crop of potatoes anyway, he said.

Manitoba’s beekeepers say they’re happy canola growers skirted restrictions.

“One of our fears was that canola growers were not going to be planting as much canola,” Manitoba Beekeepers Association president Mark Friesen said. “That’s always a concern. This won’t be a hindrance to them.”

“Not to say that we don’t want to see less pesticides on a crop,” he added. “We always want to see less pesticides on a crop.”

The beekeeping association also praised new changes in application timing.

There’s little pollination impact between bees and potatoes, according to Friesen.

“That being said, potatoes are the No. 1 overspray risk for crops in Manitoba and other areas,” he said, although he noted that improved practices have limited bee loss on potatoes.

Other shoe?

Growers aren’t celebrating just yet.

While final, Health Canada has said that the April 11 decisions are based only on risk to pollinators and are separate from risk to aquatic insects, one of the main concerns that prompted the proposed phase-out in 2016.

Decisions based on aquatic insect risk are expected in January 2020.

“These final decisions will not replace the pollinator decisions announced on April 11, 2019,” Health Canada said in an emailed statement. “If mitigation is required (e.g. cancellation of uses or restrictions to applications), it will be in addition to the cancellations and changes required to protect pollinators.”

Those 2020 decisions may yet curb most agricultural use of those chemicals. The department released proposed changes based on aquatic insect risk in August 2018. Those changes would cancel all outdoor crop use of thiamethoxam and clothianidin. Health Canada has said imidacloprid is also still up for cancellation for most agricultural uses, based on aquatic insect risk.

“Until that decision comes through, I don’t think the industry is breathing too much of a sigh of relief,” Rossnagel said. “We might call this one a hurdle.”

Impact so far

The debate over imidacloprid is unlikely to hobble the potato industry, Rossnagel said. The chemistry has become unpopular in potato use, although clothianidin and thiamethoxam are widely used as seed treatments.

Both are key in Colorado potato beetle control, something that has been of increasing concern in Manitoba, although producers have noted resistance issues with those chemistries.

Manitoba’s U-pick, fruit and vegetable farms may be harder hit by the April 11 decisions. Health Canada maintained its proposal to cancel foliar use in apple orchards for all three pesticides, as well as soil use for many berry crops and fruiting vegetables. The changes also cancelled foliar application of clothianidin in strawberries, and banned foliar use for many crops during bloom.

The decision will impact vegetable and fruit growers, the Canadian Horticultural Council says. It added that it will be working with growers during Health Canada’s two-year transition period.

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There will be no new significant restrictions beyond those announced last year, Health Canada said April 10 in its final decision on its review of clothianidin, imidacloprid and thiameth­oxam.

The department said it will proceed with cancelling some uses of the products and setting rules on the timing of applications as proposed in 2017 and 2018. However, permitting them for treatment of crop seeds and greenhouse vegetables “… is not expected to pose unacceptable risks to bees and other pollinators.”

The re-evaluations of the three products by the Pesticide Management Regulatory Agency (PMRA) considered hundreds of scientific studies, from both manufacturers and published literature. Can­cellations and new restrictions will be implemented over a two- to three-year period,

Pierre Petelle, CropLife Canada president and CEO, said the decision amounted to a reaffirmation of the safety of the products for seed treatment and many other uses.

“PMRA’s re-evaluation decision confirms that in the vast majority of cases, neonics can be used effectively by farmers without unnecessary risk to pollinators,” he said.

He added the products have improved agricultural sustainability and limit exposure to non-target organisms through precise applications onto the seed.

However, he added, many farmers, particularly in the horticulture sector will be severely impacted by the restrictions that are coming. “In many cases, there are no viable alternatives to neonics to control certain insect pests and removing neonics for growing certain horticulture crops like apples and cherries may jeopardize the viability of certain types of fruit and vegetable production in Canada,” he said.

The Canadian Horticultural Council, which represents fruit and vegetable growers, said farmers are aware of the importance of pollinators.

“Growers do not make decisions that would hurt their pollinators,” the organization said in a statement, noting it would work with members to ease the transition period. Most uses on root and tuber vegetables, including potatoes, remain unchanged.

Most changes will come into effect over the next two years while in some cases an additional year is being granted to find workable alternatives to treating pests, CHC said.

It is also watching the general re-evaluation of imidacloprid, and the aquatic invertebrate special reviews of clothianidin and thiamethoxam due out in the next year.

In 2014, Health Canada implemented risk mitigation measures to help protect bees and other pollinators from exposure to neonicotinoid-contaminated dust that occurs from planting treated seeds. With these risk mitigation measures in place, the number of bee incidents in 2014, 2015 and 2016 were 70 to 80 per cent lower than in 2013.

There has been a continued decline in the number of incidents reported during planting in 2017 and 2018.

“Other factors such as favourable weather conditions might have contributed to the reduction in bee incidents, including deaths,” Health Canada said.

As for population declines in pollinators, “no single factor has been identified as the cause,” the department said in 2018. “The available science suggests that multiple factors acting in combination may be at play, including loss of habitat and food sources, diseases, viruses and pests, and pesticide exposure.” Health Canada is examining the information collected in an attempt to answer these questions.

The Canadian Federation of Agriculture said PMRA’s approach to clothianidin and thiamethoxan showed major flaws in the re-evaluation and special review process.

“Decisions are increasingly based on overly conservative assumptions and under strict timetables and do not reflect what is happening in the field,” CFA said. “These assumptions put Canadian growers at risk of losing valuable tools to address disease and insect pressures – tools that our international competitors will continue to access.”

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Health Canada said as much Thursday as it released its final re-evaluation decisions for three neonic pesticides — re-evaluations dealing specifically with the products’ potential impacts on bees and other pollinators.

The department’s assessments of the three neonics — clothianidin, imidacloprid and thiamethoxam — show “varying effects on bees and other pollinators from exposure to each of these pesticides.”

For those reasons, Health Canada said, its final decision calls for outright cancellation of some uses of the three neonics, mainly affecting the horticulture and tree fruit sectors.

For some other uses, the department plans to change conditions of use, such as “restricting the timing of application” and adding new “label statements” for uses such as cereal seed treatments.

Uses such as canola seed treatments and on greenhouse vegetables “are not expected to pose unacceptable risks to bees and other pollinators,” the agency said Thursday.

Crop protection industry group CropLife Canada hailed much of Health Canada’s announcement Thursday, saying it “affirm(s) the safety of neonics as a seed treatment and for many other uses.”

The department’s decision “confirms that in the vast majority of cases, neonics can be used effectively by farmers without unnecessary risk to pollinators,” CropLife CEO Pierre Petelle said in a statement via email.

Grain Farmers of Ontario CEO Barry Senft, in a separate statement, noted growers in that province “take several steps to protect pollinators on their farms and (Health Canada’s) decision shows that these efforts are working, as is the regulatory system that works to protect human health and the environment.”

Health Canada has been re-evaluating the three neonics since 2012 to” address growing concerns around bee health” and issued proposed decisions for clothianidin, imidacloprid and thiamethoxam in December 2017, May 2018 and December 2017, respectively.

Neonic seed treatments, Petelle said, “represent an incredible innovation that has improved agricultural sustainability and limited exposure to non-target organisms due to the very precise application of the product on the seed.”

However, he warned, the planned new restrictions and cancellations Health Canada announced Thursday will leave many growers, particularly in the hort sector, “severely impacted.”

In many cases, he said, for those growers, “there are no viable alternatives… to control certain insect pests and removing neonics for growing certain horticulture crops like apples and cherries may jeopardize the viability of certain types of fruit and vegetable production in Canada.”

The decisions

For clothianidin, Health Canada’s final pollinator decision will cancel foliar application on orchard trees and strawberries and on municipal, industrial and residential turf sites. It also limits the number of foliar applications on cucurbit vegetables to one per season.

Also, “additional label statements” will be required for clothianidin seed treatment of cereal crops.

For imidacloprid, the final pollinator decision will cancel foliar application to pome fruit, stone fruit, certain tree nuts with “high pollinator attractiveness,” lavender and rosemary. It will also cancel soil application on legume, fruiting, and cucurbit vegetables when grown outdoors; herbs harvested after bloom; small fruit and berries (caneberry; bushberry; low-growing berry; berry and small fruit vine excluding grapes); and ornamentals that are “attractive to pollinators and planted outside.”

The department would also prohibit foliar spraying of imidacloprid before or during bloom on fruiting vegetables, herbs that are harvested after bloom, legume vegetables (broad beans, fava beans andVicia faba), berry crops (with renovation after harvest for woody berries), and tree nuts apart from those with high pollinator attractiveness.

Also, additional label statements will be required for imidacloprid seed treatment of cereal and legume crops.

For thiamethoxam, Health Canada proposes to cancel foliar and soil application on ornamental crops “that will result in pollinator exposure” — in other words, crops that are planted outdoors and attractive to pollinators. It will also cancel soil application for berry crops, cucurbit crops and fruiting vegetables, and foliar application to orchard trees.

Health Canada will also prohibit spraying of thiamethoxam before or during bloom in foliar application on legume and outdoor fruiting vegetables, and on berry crops, with “renovation required” for woody berries. Foliar application on sweet potato and potato would not be allowed during bloom.

Also, “additional label statements” for thiamethoxam will be required for seed treatments of cereal and legume crops.

Risks ‘not imminent’

Health Canada proposes to put all the above risk mitigation measures in place over a 24-month period. “The risks identified (to pollinators) are not considered imminent because they are not expected to cause irreversible harm over this period,” the department said.

Members of the public have 60 days from the final decisions’ publication date to file any notices of objection, Health Canada said.

The department also noted Thursday it already put risk mitigation measures in place in 2014 to help protect bees and other pollinators from exposure to neonic-laden dust kicked up during planting of treated seeds.

With the risk mitigation measures in place from 2014 onward, Health Canada said Thursday, the number of bee incidents in 2014, 2015 and 2016 were 70-80 per cent lower than in 2013. Further decline was seen in the number of incidents reported during planting in 2017 and 2018.

Health Canada on Thursday also granted that “other factors” such as favourable weather conditions might have also contributed to the reduction in bee “incidents” and bee deaths in the crop years since 2014.

Phase-outs still proposed

All this said, the agency’s final pollinator re-evaluation decisions have no bearing on Health Canada’s separate ongoing evaluations of the “potential risks to aquatic insects” from the use of neonics.

Final decisions on those evaluations are expected at the end of this year, Health Canada said Thursday — but the department also reiterated that current research shows neonics are “detected frequently in waterbodies at levels that could be harmful to certain aquatic organisms.”

Health Canada in 2016 proposed a phase-out of most uses of imidacloprid over three to five years after a routine re-evaluation by its Pest Management Regulatory Agency (PMRA) found imidacloprid showing up at levels harmful to certain aquatic insect populations such as mayflies and midges — a “critical food source” for fish, birds and other animals.

Special reviews for both clothianidin and thiamethoxam were announced in the wake of those findings on imidacloprid. Those reviews, released last summer, found both pesticides being measured at levels harmful to aquatic insects.

As a result, Health Canada also proposed last summer to cancel all outdoor (that is, non-greenhouse) agricultural and turf uses for clothianidin, and all outdoor agricultural and ornamental uses for thiamethoxam, over three to five years, depending on availability of alternatives.

In Canada, clothianidin is marketed by Bayer as insecticides and seed treatments under brand names including Poncho, Prosper, Titan and Sepresto and by Nufarm as NipsIt.

Thiamethoxam products include Cruiser and Helix, marketed by Syngenta, while imidacloprid is sold mainly by Bayer under brands such as Admire, Gaucho, Concept and Intercept. — Glacier FarmMedia Network

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As it happens, the re-evaluation of pesticides is a legal requirement and it was during a periodic routine re-evaluation that the Pest Management Regulatory Agency (PMRA) discovered new information about neonics. The concern over possible consequences to human health and the environment eventually led to the proposal to ban them.

The federal legislation that governs these products is the Pest Control Products Act (PCPA), overseeing pesticide registration and re-evaluations, according to Pratisara Bajracharya, Manitoba Agriculture’s pesticide minor use and regulatory specialist.

Speaking to the Manitoba Agronomist’s Conference earlier this winter she explained that under the PCPA, every product is re-evaluated every 15 years.

“It ensures that the current standards for environment safety and human health is preserved or are met, and it incorporates any new information that may be available since the product was registered or last re-evaluated,” Bajracharya said.

“These re-evaluations take into account those factors and make necessary changes on pesticide product labels.”

There are six steps to the re-evaluation process and it’s not speedy. The first four phases involve collecting information, scientific assessment, a decision proposal and update assessment and can take up to four years to complete. The last two stages, final decision and implementation, can take an additional two to three years.

“As soon as PMRA comes out with a decision, there’s still product in the market so it doesn’t automatically vanish,” says Bajracharya. “In order to allow that product to gradually be phased out, PMRA normally allows two to three years from the time the final decision is made to when the product is actually allowed to be used for the last time in Canada.”

Reviewing the science

At the information collection stage, PMRA contacts various stakeholders to gather any new information about the product or its use. Probably the most important step is the science assessment, which looks at the data, including existing scientific literature from other jurisdictions and regulatory agencies.

“A few examples of risk assessment could be dietary risk — so residue in food — or a risk from any concentration of the pesticide being found in drinking water, or in environmental situations where it may be doing a pollinator assessment or an aquatic invertebrate assessment like we saw in the case of neonicotinoids,” says Bajracharya.

The proposed decision stage takes all this data and if a problem has been identified, will propose changes to mitigate the risk, such as additional label requirements or discontinuation of a product. As an example, PMRA came out with a proposed decision to discontinue or phase out the neonic insecticide imidacloprod (often used as a seed treatment) due to a threat to pollinators and aquatic insects. A 90-day public consultation period follows the publishing of the proposed decision.

“At this stage when consultation is happening on a final document, you can only comment with significant scientific data,” says Bajracharya. “At this stage, if you do not like PMRA’s decision they probably won’t listen to you unless you have solid scientific information to support your claim.”

Neonics under the microscope

Over the past years, three different neonic products commonly used in Manitoba and Canada have been proposed for discontinuation: imidacloprid, thiamethoxam and clothianidin, and another, acetamiprid is currently being re-evaluated.

“With neonicotinoid re-evaluations, it began with imidacloprid, it was a cyclical re-evaluation and started as a pollinator issue. But with more study, it was found that seed treatments were perhaps safe if used according to the label direction and with proper mitigation measures in place, but that was not the case for foliar applications,” says Bajracharya. “However, another risk was identified. PMRA said it was finding imidacloprid at concentrations that were toxic to aquatic invertebrates.”

That triggered special reviews for clothianidin and thiamethoxam specifically for aquatic invertebrate assessments.

The 15-year-cycle re-evaluations are mandated by PMRA but special reviews only happen when a particular risk is identified in an OECD country or through PMRA’s other evaluations, so this is how special reviews for clothianidin and thiamethoxam were initiated.

The imidacloprid re-evaluation was largely based upon data from Eastern Canada, and the concern at the time was that the use patterns in Eastern versus Western Canada were different and for different crops.

“We use more seed treatments in our crops versus more foliar applications in the East,” said Bajracharya. “So, there were concerns that all of these neonicotinoid products may be discontinued or proposed to be discontinued.”

In 2017 and 2018 the Province of Manitoba conducted a water quality monitoring program and submitted the data to PMRA.

“We were finding that there were detections for neonics but not an alarming level of incidences from what PMRA was proposing as thresholds,” said Bajracharya.

Despite the new data, PMRA’s proposal continues to be discontinuation of neonics.

“PMRA has said that it does not think that the risks to aquatic invertebrate posed by the neonicotinoid insecticides at the current level at which they’re being detected in water is acceptable,” said Bajracharya. “Unfortunately, 2017 and 2018 were dry years in Manitoba and all across the Prairies, so PMRA felt like it did not adequately represent the environmental conditions in the Prairies and honestly, when you’re talking about Prairies, there aren’t a lot of risk mitigation measures, and the mitigation measures that exist, we don’t really know if they work at this point. So, these are some of the reasons why (neonics are) currently being proposed to be discontinued.”

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They’ve signalled their intention to grill Health Canada and the Pesticide Management Regulatory Agency (PMRA) over their plans to eliminate the use of clothianidin and thiamethoxam over the next three to five years because they pose a threat to aquatic insects.

Consultations with government officials are to run until the end of November and could become even sharper if Health Canada goes ahead with its scheduled announcement later this month it will proceed with a phase-out of imidacloprid, the third neonic registered for use in Canada because it’s a danger to aquatic insects and pollinators.

“Sustainable production and science-based decisions about risk are the foundation of our industry,” said Brian Innes, vice-president of public affairs for the Canola Council of Canada. Clothianidin and thiamethoxam “are very important for our growers, and without viable alternatives, the ban will significantly impact the canola sector.”

The council is concerned about the loss of these two neonics because it would lead to lower yields and increase the risks for growers from flea beetles. A study published in 2017 based on European growers’ experience without these products showed that growers faced an increased risk of insect damage, had lower yields and, as a result, seeded less canola.

“With more than 22 million acres of canola in Canada in 2018, banning these plant protection tools would have a dramatic impact,” the council said. “These products have been responsibly used by canola producers as a seed treatment to control pests as part of their integrated pest management programs.”

The Canadian Horticulture Council said it was disappointed “to be potentially losing two valuable crop protection tools, leaving many growers with limited options. We hope that the PMRA will use real-use data when making its final decision, and that it will consider growers’ critical need for safe, effective crop protection products that allow them to offer locally produced quality fruit and vegetables for Canadian consumers.”

Pulse Canada said it will take its concerns about a lack of alternatives into the consultations while Grain Growers of Canada has said it will comment further on the phase-out when it has completed its review of the mid-August announcement.

Pierre Petelle, CropLife Canada president and CEO, said, “There are some alternatives available for some crop/pest combinations, but not alternatives for all of them. We haven’t had an opportunity to review to provide more details, but it’s essential that farmers have a variety of tools to help them manage pest pressures.

“Pesticides are registered to address specific pest problems and when it comes to insects, they may only be effective on certain phases of the insect’s life cycle and/or under specific crop and climate conditions,” he said. “Furthermore, from a product stewardship perspective, having only one tool to manage a pest could lead to issues with resistance.

“This is why we advocate for farmers to have many tools in their tool box and why our members invest significantly into research and development of new products. Our concern is that these investments into research and development could be jeopardized in the future if such a modern class of insecticides with extremely low toxicity to humans and animals is not passing the PMRA’s assessment.”

When asked about agriculture concerns about the lack of alternatives to the two neonics, Health Canada said seven products were registered for most uses of clothianidin and thiamethoxam. It is currently consulting stakeholders on the suitability of these registered alternatives to these neonicotinoids. Agriculture and Agri-Food Canada’s multi-stakeholder forum is also examining available alternatives.

The final decision will consider what to do “if no suitable alternatives to the use exist, as long as the human health and environmental risks, as well as value of the pesticide, are considered to be acceptable,” Health Canada said.

While the introduction of best management practices during the planting of corn and soybeans in Ontario, which is where the controversy over neonics began, has greatly reduced bee deaths, the department said it’s not convinced BMPs would correct the threat to aquatic insects.

It considered data for the 2017 season submitted by the Environmental Monitoring Working Group in its reviews of clothianidin and thiamethoxam, along with monitoring data available from other sources. They included “reports on potential risk mitigation measures such as methods for spray drift reduction and the use of vegetative filter strips to help reduce run-off into water bodies. These were also considered in the assessment of the special reviews.

“While other options are available, at this time, we do not have sufficient evidence that these proposed measures for the continued use of clothianidin and thiamethoxam will be sufficiently protective of aquatic insects.”

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Health Canada’s Pest Management Regulatory Agency (PMRA) is proposing that two neonicotinoid pesticides, clothianidin and thiamethoxam, be phased out over the next three to five years.

Following special reviews, PMRA found that the pesticides are harmful to aquatic insects which are a major source of food for fish, birds and other animals.

The chemicals are widely used as seed treatments for the majority of canola grown in Western Canada. While the impact on bees is often mentioned in discussions on neonics, PMRA itself came out with a proposed decision in 2017 noting that the neonicotinoid seed treatments don’t negatively hurt pollinators, including bees.

“These seed treatments are used on canola to prevent the young plants from being eaten by flea beetles,” said Brian Innes, vice-president of public affairs with the Canola Council of Canada.

“We’re concerned about not having these products will have a significant impact on the canola industry,” said Innes adding “it will mean increased risks and reduced yields.”

It can be very hard to predict when the insect when flea beetles will strike a field and individual fields can be lost in as little as 36 hours, according to Innes. While foliar chemical applications are an option, the small window makes control difficult.

“If we remove the neonicotinoids, it forces people to use other alternatives,” said John Gavloski, extension entomologist with Manitoba Agriculture. There are trade-offs with other pesticides, he said, making it hard to determine the eventual impact on crop production.

Diamides are a group of chemicals that can also be used as a seed treatment against flea beetles, he said. They are not as water-soluble as neonicotinoids — which comes with its own pros and cons.

The lower water solubility of diamides means they are slower to react. However, with neonicotinoids, a rain right after planting can wash away much of the seed treatment, which would not be the case with diamides.

Gavloski said more chemical options were also being researched and should be available for the market soon.

While more tools could take the place of neonicotinoids, “we’re very concerned as a canola industry, because any tool that’s taken away from farmers has a negative impact on their ability to produce canola and manage their risk,” said Innes.

Small impacts on yields could lead to hundreds of millions of dollars of losses in the bigger picture, he said.

There is a 90-day window of comment on the PMRA proposals, and Innes said the Canola Council will review the decision to make sure all of the available information was taken into account.

“We as a canola industry very much value a science-based review process,” he said.

— Phil Franz-Warkentin writes for Commodity News Service Canada, a Glacier FarmMedia company specializing in grain and commodity market reporting. Follow him at @PhilFW on Twitter.

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PMRA officials on Wednesday announced 90-day consultation periods on its decisions for both clothianidin and thiamethoxam, following “special reviews” which found both substances being measured at levels harmful to aquatic insects.

Clothianidin, under its current conditional registration, is marketed by Bayer in Canada as insecticides and seed treatments under brand names including Poncho, Prosper, Titan and Sepresto and by Nufarm as NipsIt. Thiamethoxam’s conditional registration covers products such as Cruiser and Helix, marketed by Syngenta.

PMRA proposes to cancel all outdoor agricultural and turf uses for clothianidin, and all outdoor (non-greenhouse) agricultural and ornamental uses for thiamethoxam, over three to five years, depending on availability of alternatives.

Scott Kirby, director general of PMRA’s environmental assessment directorate, said on a conference call with reporters Wednesday that most affected products would be phased out over the shorter period as alternatives are available.

Final special review decisions are to be announced at the end of next year, Health Canada said, and “will take into consideration any comments or new information received during the consultation period.”

Special reviews for both neonics were announced in November 2016 in the wake of PMRA’s routine re-evaluation of the third major neonic, imidacloprid, sold mainly by Bayer under brands such as Admire, Gaucho, Concept and Intercept.

Through that re-evaluation, Health Canada said it found imidacloprid being measured at levels harmful to certain aquatic insect populations such as mayflies and midges — a “critical food source” for fish, birds and other animals. The department thus proposed to phase out most uses of imidacloprid over three to five years.

Special reviews, Health Canada said, are launched based on “reasonable grounds to believe that the health or environmental risks, or the value (including effectiveness), of a pesticide is unacceptable.”

An environmental assessment of clothianidin showed that, in aquatic environments in Canada, the product is being measured at concentrations that are harmful to aquatic insects and most outdoor uses of clothianidin in Canada thus are “not sustainable.”

Modelling results from a risk assessment for thiamethoxam showed a “minimal acute risk to freshwater invertebrates” but found exposure on a “chronic basis” poses a risk to those species, Health Canada said.

However, the agency deemed the risks to aquatic invertebrates from greenhouse uses of thiamethoxam to be “acceptable” and plans to allow the chemical’s continued registration for greenhouse uses, “provided wastewater mitigation instructions on product labels are followed.”

For both neonics, PMRA said it will consider any “alternate risk management proposals” put forward during the comment period, “provided that they can achieve acceptable levels in the environment within the same timeframe.”

PMRA had proposed in late 2017 to grant three-year extensions to the registrations for both products, pending the outcome of the special review, while also phasing out certain specific uses of the products to reduce risk to pollinators. Final decisions relating to the pollinator evaluation are expected at the end of this year, Kirby said.

Grain Growers of Canada, in a separate statement Wednesday, said it plans to further review PMRA’s proposed decisions.

Meanwhile, GGC president Jeff Nielsen said, the group is concerned that PMRA’s re-evaluation process “is focused on publishing proposed decisions as fast as possible,” which appears to limit the agency’s ability to ensure “all relevant information” is available.

The focus on speed, he said, also “prevents (PMRA) from engaging farmers so that we can fully understand the issues they raise, which would allow us to provide the PMRA with the information required to refine these decisions.”

Both products “are very important for our growers, and without viable alternatives, the ban will significantly impact the canola sector,” Brian Innes, vice-president of public affairs for the Canola Council of Canada, said in a separate release.

The council, which said it will also “thoroughly review” the PMRA proposal, on Wednesday cited a 2017 study of European growers’ experience without neonics, showing increased risk of insect damage, lower yields and, as a result, fewer canola acres.

“With more than 22 million acres of canola in Canada in 2018, banning these plant protection tools would have a dramatic impact,” the council said.

CropLife Canada, representing the crop protection industry, said it found the PMRA proposal “especially disappointing and confusing to many, given that earlier this year the PMRA released a seemingly contradictory proposed decision validating the safety of both of these products to pollinators as seed treatments, which is one of their primary uses.”

CropLife CEO Pierre Petelle said Wednesday the organization will also review the PMRA’s proposals and data, “correct any misinterpretation of the data and provide comments to address any information gaps identified.”

The Reuters news agency on Wednesday quoted a Syngenta Canada spokesperson as saying the company is disappointed with the decision and believes the PMRA did not consider all relevant information. Reuters also quoted a Bayer spokesperson as saying the company believes clothianidin has a “favourable environmental profile.” — Glacier FarmMedia Network

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