(This article has been translated from French.)
Health Canada has taken seven years to review the risks posed to pollinators by neonicotinoids. Given global scientific consensus on the negative impact of these pesticides on bees and other organisms, Health Canada’s recent decision to sanction their continued use makes no sense. The regulatory system is fragmented and slow, and Canadian authorities’ risk management of neonicotinoid pesticides is inadequate.
A question of survival
The United Nations has designated May 20 World Bee Day, since our very survival depends on that of the bees:
The food that we eat, such as fruits and vegetables, directly relies on pollinators. A world without pollinators would equal a world without food diversity – no blueberries, coffee, chocolate, cucumbers and so much more. . . . Pollinators such as bees, birds, and bats affect 35 percent of the world’s crop production, increasing outputs of 87 of the leading food crops worldwide, plus many plant-derived medicines. . . . Without this service, many interconnected species and processes functioning within the ecosystem would collapse.
Neonicotinoids first came into public awareness after their deadly involvement in the decline of bee colonies worldwide was revealed. Independent scientists were quick to assess their devastating effects and conclude that they represent a serious threat to biodiversity, ecosystems and global food security.
In the meantime, Canada is delivering incomplete assessments and multiple delays in an already very slow and highly fragmented re-evaluation process.
Canada drags its feet
In 2012, after receiving a high number of bee mortality incident reports coinciding with the planting periods of neonicotinoid-treated corn and soybean seeds, Health Canada’s Pest Management Regulatory Agency (PMRA) launched a process to re-evaluate neonicotinoid insecticides.
On April 11, 2019, seven years after starting the process, the PMRA announced its final re-evaluation decisions on the risks to pollinators posed by imidacloprid, thiamethoxam and clothianidin, three major neonicotinoids.
The re-evaluation downplayed the impact of coated seeds, the most widespread use of neonicotinoids in Canada and a major source of contamination. The PMRA’s conclusions on this matter run directly counter to similar assessments conducted by the European Union, which confirm the threat to bees posed by the use of neonicotinoids in any form.
The PMRA argues that its proposed risk mitigation measures make the continued registration of products that contain neonicotinoids acceptable. However, the proposed mitigation measures – that is, changes to the conditions of registration, including the prohibition of certain uses – will be implemented only on end-use product labels over a 24-month period. Few of the proposed measures apply to neonicotinoid-coated seeds.
The decision is not unlike allowing a drug with serious side-effects to become immediately available, but waiting two years before informing health professionals of the contraindications. Here, two years must elapse before pollinators in Canada can be suitably protected from the well-documented risks of this class of pesticides.
Furthermore, in 2016, the PMRA concluded that one neonicotinoid, imidacloprid, presented unacceptable risks for aquatic organisms, findings that justified a full ban on its agricultural applications within three to five years of the final decision. However, fully two-and-a-half years after completing its scientific review of imidacloprid, the PMRA continues to stall on releasing its final decision. The same applies to clothianidin and thiamethoxam, whose gradual phase-out the PMRA proposed in August 2018. The final decision for all three isn’t expected until 2020.
Despite international scientific consensus on the major threat posed by neonicotinoids to the environment and world food security, and notwithstanding the PMRA’s own conclusive findings, we must wait until 2023 or even 2025, before implementing the widely justified prohibition of these dangerous products in Canada.
Neonicotinoids in court: delays here, too
In Canada, lacking scientific data about their risks, a number of neonicotinoids were granted “conditional registration,” allowing the industry to obtain a conditional (ergo temporary) license to sell them. The PMRA renewed the conditional registration on these pesticides for 10 years without filling in the data gaps. In 2016, Canadian environmental groups contested the conditional registration in the Federal Court. However, after a series of motions by the Canadian government and pesticide manufacturers stalled the proceedings, on April 5, 2019, the court decided not to rule on the legal issues raised by the case.
This leaves us minus the answer to a fundamental question: Has the registration of neonicotinoid pesticides in Canada been illegal from the very start?
Continued use in Canada despite a European ban
While France banned the use of neonicotinoids in September 2018 and Europe did so in December 2018, Canadians must still await the final decisions and cancellation of their applications.
It is at the very least inconsistent that the PMRA authorizes the continued use of numerous neonicotinoids while continuing to review them and delay a total ban when its own scientists have found their risks for certain organisms to be unacceptable.
The Canadian government’s repeated delays in the re-evaluation of neonicotinoids come at a time where an international meta-analysis has confirmed the rapid decline of insect species worldwide, 40 percent of which are threatened with extinction in the coming decades and a further one-third of which could become endangered.
The study highlights intensive farming and recurring pesticide use as key contributing factors to the situation. Given the essential role of insects to the proper functioning of all ecosystems — they pollinate plants, recycle nutrients and serve as staple foods for other creatures — these conclusions, frankly, are alarming.
Canadians are very concerned about the harmful effects of neonicotinoids on ecosystems: since 2013, over 460,000 citizens have asked Health Canada to ban them. The demand is legitimate. In the face of persistent delays and weak proposed restrictions, how can we trust the PMRA to protect our health, food security and environment?
Additional delays in an already slow risk-evaluation process will cause irreversible ecological damage in Canada and raise serious questions on the scientific credibility and impartiality of the Canadian government’s pesticide evaluation and decision-making practices.
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