OUR THINKING
This must NOT be a conflict between beekeepers and farmers.
We have watched with concern how this issue is being positioned as some kind of conflict between commercial beekeepers and conventional cash-crop farmers... as if somehow pollination had nothing to do with farming. In fact, we believe that we are very fortunate that beekeepers have raised the alarm; they have a managed insect population which is providing important data about the alarming levels of pollinator deaths. We have no reason to believe that our wild bee populations are faring any better: it's just that no one is counting those numbers. Pollinator health - which we have mostly been able to take for granted in farming - is a critical criteria for environmental and agricultural sustainability. |
It's becoming clear that the 'mode of action' is an issue.
Insecticides work by various different "modes of action". Sometimes, the insecticide will be applied on a plant at a time when the insect is feeding. The insect ingests the applied insecticide, and is poisoned. Application windows and procedures are managed to try to prevent impact on people, soil and even other beneficial insects.
Sometimes an insecticide will be "fogged" and the insect is killed by contact with the insecticide, even if it hasn't ingested the insecticide.
Neonicotinoids, however, work by a "systemic" mode of action. This means that the plant actually takes up the compound, so that the compound is present throughout the plant. In some respects, this makes it an attractive pesticide by conventional measures. It can be less toxic to mammals or humans handling the compounds, for example. And it is also highly effective.
Neonicotinoids go by several different brand names and are available for both home gardeners and for large-scale agricultural use. They are commonly used as a seed treatment, designed to protect the plants against damaging insects (and thereby boost plant health and yield).
Bee deaths seem to occur primarily in two windows in the crop season: planting and pollination.
It seems that the seed coating is causing problems - sickness or death -- in bees and other pollinators.
But the more disturbing finding, in our minds, is the bee deaths that are occurring during the time that the plants are being pollinated. One beekeeper told us that "a beautiful field of yellow canola flowers will open... and the bees don't make it back". The very characteristics that make neonicotinoids so effective - that systemic mode of action -- unfortunately also means that the compound can be present in the pollen; studies of bee kills show that bees are being impacted during the pollination window.
We believe that this fact -- the systemic mode of action of neonicotinoids - is a critical factor to consider in developing a policy to protect bees and farming.
Directing our action where it can make a difference.
Pesticides are approved for registration in Canada by Health Canada: under the PMRA, which subjects pesticides to a stringent review process, and provides conditions of registration which provide guidelines and rules for handling, storage, and application.
Often, if a problem emerges after registration, the PMRA will suggest "risk mitigation" measures designed to safeguard the human population, or to protect adjacent crops, reduce the amount of pesticide required, or to minimize the persistence of the pesticide in the environment, for example. In fact, they have done so, recently, with neonicotinoids: suggesting changes to planting procedures and reformulations of seed coatings to prevent airborne contamination, for example.
There is some question about whether these risk mitigation procedures will be effective, however. If the problem is the systemic mode of action - and any effective compound is present in the growing plant - these conventional risk mitigation proposals may not address the problem.
Our view is that review criteria and even testing methodologies may not yet be well adapted to this relatively new class of insecticides, and that the widespread adoption of these compounds means that pollinator health must become a much more prominent criteria in the review process.
Thus, our resolution does not call for an outright ban on neonicotinoids, but rather calls for the suspension of the PMRA registration of neonicotinoid-based compounds in Canada, until these new criteria can be addressed.
We believe, in fact, that it is in the best interests of farm organizations and the agrochemical industry to support this suspension - since the public is not inclined to make distinctions between pesticide categories, and the industry at large could suffer harm to its reputation.
Insecticides work by various different "modes of action". Sometimes, the insecticide will be applied on a plant at a time when the insect is feeding. The insect ingests the applied insecticide, and is poisoned. Application windows and procedures are managed to try to prevent impact on people, soil and even other beneficial insects.
Sometimes an insecticide will be "fogged" and the insect is killed by contact with the insecticide, even if it hasn't ingested the insecticide.
Neonicotinoids, however, work by a "systemic" mode of action. This means that the plant actually takes up the compound, so that the compound is present throughout the plant. In some respects, this makes it an attractive pesticide by conventional measures. It can be less toxic to mammals or humans handling the compounds, for example. And it is also highly effective.
Neonicotinoids go by several different brand names and are available for both home gardeners and for large-scale agricultural use. They are commonly used as a seed treatment, designed to protect the plants against damaging insects (and thereby boost plant health and yield).
Bee deaths seem to occur primarily in two windows in the crop season: planting and pollination.
It seems that the seed coating is causing problems - sickness or death -- in bees and other pollinators.
But the more disturbing finding, in our minds, is the bee deaths that are occurring during the time that the plants are being pollinated. One beekeeper told us that "a beautiful field of yellow canola flowers will open... and the bees don't make it back". The very characteristics that make neonicotinoids so effective - that systemic mode of action -- unfortunately also means that the compound can be present in the pollen; studies of bee kills show that bees are being impacted during the pollination window.
We believe that this fact -- the systemic mode of action of neonicotinoids - is a critical factor to consider in developing a policy to protect bees and farming.
Directing our action where it can make a difference.
Pesticides are approved for registration in Canada by Health Canada: under the PMRA, which subjects pesticides to a stringent review process, and provides conditions of registration which provide guidelines and rules for handling, storage, and application.
Often, if a problem emerges after registration, the PMRA will suggest "risk mitigation" measures designed to safeguard the human population, or to protect adjacent crops, reduce the amount of pesticide required, or to minimize the persistence of the pesticide in the environment, for example. In fact, they have done so, recently, with neonicotinoids: suggesting changes to planting procedures and reformulations of seed coatings to prevent airborne contamination, for example.
There is some question about whether these risk mitigation procedures will be effective, however. If the problem is the systemic mode of action - and any effective compound is present in the growing plant - these conventional risk mitigation proposals may not address the problem.
Our view is that review criteria and even testing methodologies may not yet be well adapted to this relatively new class of insecticides, and that the widespread adoption of these compounds means that pollinator health must become a much more prominent criteria in the review process.
Thus, our resolution does not call for an outright ban on neonicotinoids, but rather calls for the suspension of the PMRA registration of neonicotinoid-based compounds in Canada, until these new criteria can be addressed.
We believe, in fact, that it is in the best interests of farm organizations and the agrochemical industry to support this suspension - since the public is not inclined to make distinctions between pesticide categories, and the industry at large could suffer harm to its reputation.
LEGAL DISCLAIMER: These comments are provided to offer some 'plain language' explanations of our understanding of the issue of neonicotinoids and their impacts. Please consult documented research for accurate information on these compounds.