Agriculture Committee on March 7th, 2017

[Scott Kirby]

If I understand your question correctly, the answer would be no. The PMRA has no research and monitoring mandate, so we don't actually do any testing. That's either left to the registrants, if we require data from them, or it can be generated through some of the departments that do have a research mandate, such as Agriculture Canada, Environment Canada—

[Francis Drouin, Liberal, Glengarry—Prescott—Russell, ON]

How did PMRA come to decide that it was going to propose a ban as opposed to suggesting a mitigation strategy?

[Scott Kirby]

We came to that conclusion based on our scientific assessment. We had over a hundred studies submitted by the registrants. We looked at over 200 studies by academics that were in the open literature. We also reviewed the regulatory decisions of the EPA, FSA, FDA, and the Department of Agriculture in the U.S. Having looked at all that evidence plus the monitoring information provided to us by academics, provinces, and federal departments, we came to the conclusion that the risks were unacceptable.

[The Chair, Liberal, Pat Finnigan]

Thank you, Mr. Kirby.

Thank you, Mr. Drouin.

Now Mr. Anderson.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Thank you, Mr. Chair.

You mentioned the Morrissey study. Are you using that as one of your main datasets for western information?

[Scott Kirby]

The Morrissey data is not pivotal to the imidacloprid decision in indicating risk at this time. The more pivotal pieces of information are from Ontario and Quebec. The Morrissey data comes largely from areas where the other two neonics are used more extensively—that would be thiamethoxam and clothianidin—and that information will figure in our special reviews of those two chemicals. With respect to imidacloprid, there is some use in the area where Dr. Morrissey did her work, but it is not to the extent of the other two.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Actually, I think your summary of the data said that there's no exceedance of the acute freshwater invertebrate end point, and there are very few exceedances, I think maybe one, of any kind of chronic end point. Despite that, you're saying you're going to use that as data to encourage the cancellation of the agricultural uses across the country of that product. Why would the other neonics expect to be treated any differently?

[Scott Kirby]

If the science says that they should be treated differently, they will be. With respect to imidacloprid, in Morrissey's study the issue is to what extent imidacloprid was used in that area. If there's not a lot of use, you don't expect to see a lot of detects and lot of high concentration. If we had information that indicated that there was extensive use of imidacloprid in those areas and we still were seeing low levels, then we would consider a decision that would be based on that science.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

Looking at the science on the other products, you'd say they're below the thresholds that have been set, so you would say it looks like good data, data that would encourage the continuation of the use of that product.

[Scott Kirby]

Right now the special reviews are ongoing. We're considering all the available information. At this stage I'm not ready to pronounce as to whether or not the risks are acceptable or not. I will say that we are meeting monthly with the multi-stakeholder forum, and we're updating them on the progress of our special reviews. When we get to a point where we're able to make some preliminary determination as to whether we're seeing a good picture or a bad picture, we will let them know so that we can put measures in place to help them look for alternative strategies.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

There's a benefit of about $200 million a year to agriculture from these products. Do you do any kind of cost-benefit analysis when you're looking at your decision-making?

[Dr. Richard Aucoin]

Under our statute, our primary mandate is health of the environment. That's our fundamental mandate under the PCPA. We also are required to ensure that pesticides have value, but there is no direct cost-benefit analysis or risk-benefit comparison as part of our decision-making. Obviously, we are very cognizant of the potential value of some of these agricultural chemicals, so we can and we do put in a fair amount of effort trying to understand risk mitigation and risk management options before we proceed to, for example, phasing out a chemical. That's why, in fact, what the proposal says is that we're proposing a transition period of three to five years right now.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

What role does the precautionary principle play in this whole thing and the approach? Ms. Johnston mentioned that. Basically, the notion that some people have is that you can't do anything until you can prove there's absolutely no risk to anything. So no one moves, no one gets hurts, no one gets a benefit, nothing. What role does that play in your decision-making? It seems to be playing an increasing role in your decision-making. Is that true?

[Dr. Richard Aucoin]

No, I don't think that's accurate. In the case of all the chemicals that we re-evaluate, we don't take a different approach. We aren't taking a different approach, really, with the imidacloprid or the neonics. We use the same formula, the same sort of paradigm, when we look at this chemical as when we look at any chemical. We look at all the available information, including some modelling data. If we have information on what's being found in the environment, we use all that information.

We do take—and in the legislation we are required to take—a fairly precautionary approach. We do factor into our decision-making an understanding of where there might be uncertainty. We put in safety factors to protect human health, for example. We don't have human data, only animal data, so we are required in our legislation—and it is good science—to understand that there can be some uncertainties in the data.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

This isn't an issue of human health, is it?

[Dr. Richard Aucoin]

No. It's not. Pretty much all the human health assessment work we've done on the neonics does not show a significant health issue.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

We find ourselves in a situation whereby you're saying you're relying on science, but the science that we've been looking at says there's no direct correlation with bee kills. You're saying you're doing some other work on that. Science doesn't indicate that there's any permanent impact on water species at this point. There doesn't seem to be much information on that or whatever, yet your decision is that you're still going to ban these chemicals.

I don't see that this decision is being based on science the way it should be. I think producers out there are feeling the same way. You excluded the industry and agriculture from the discussions until you made your decision. I don't think that's a solid scientific approach to a subject or to a decision.

I've been here long enough. We've had some PMRA battles over the years, and I'm wondering what you can do to reassure us that you're paying attention to the agricultural community on these issues in ways that weren't the case in the past.

[The Chair, Liberal, Pat Finnigan]

Thank you, Mr. Anderson.

Unfortunately, I have to cut it here.

Mr. Peschisolido, you have six minutes.

[Joe Peschisolido, Liberal, Steveston—Richmond East, BC]

Mr. Chair, thank you.

I too would like to thank the witnesses for coming here to have a conversation on a very complex and multi-faceted, probably grey issue. There's no black and white, even though certain groups believe that.

Whenever you want to change something, you need an alternative. I don't remember who asked this question, but I would like to follow up with Dr. Aucoin or Mr. Kirby on the working group you have for alternatives.

Have you looked at the impact when you're switching from these pesticides, which are quite efficient when you just need one application, to other pesticides where you need more than simply one application? What would the impact be on the farming community and also on the environment?

[Scott Kirby]

We haven't entered those discussions yet in terms of the potential impact of whatever alternatives are being proposed. However, I committed at the multi-stakeholder forum that once we identify alternatives, especially in light of the concern from beekeepers about the impact those pesticides might have, we would work with them to help them decide which ones were more bee friendly.

Typically as a matter of normal business we don't do what we would call a comparative risk assessment to say that one pesticide is better than the other. If they are all registered, they are considered acceptable for use. Obviously, certain ones will have different profiles that are more favourable for different parts of the environment, and that's where I think we could help the growers with respect to looking at that risk profile.

[Joe Peschisolido, Liberal, Steveston—Richmond East, BC]

Can you follow up a little on the nature of these working groups? I believe you have at least three working groups. We can talk about the alternative part, but also the mitigation.

Have these working groups started? Who has been appearing? What have been the topics?

[Andrea Johnston]

You're correct. There are three working groups: data monitoring, which is looking at the existing data and new data that has come since the proposed decision by Health Canada; the mitigation working group, which will work closely with the data monitoring as the data monitoring should be able to pinpoint some of the crop uses, and from there the mitigation working group will assess if there are mitigation measures that could be taken into account and get to an acceptable level; and finally, the alternatives working group, which you just raised.

That work, the work plans, and any data will be submitted to PMRA before the end of the consultation period, but the work will continue past the consultation period because there's the intent of doing further data monitoring.

[Joe Peschisolido, Liberal, Steveston—Richmond East, BC]

With regard to alternatives, there are alternative pesticides, but there's also an alternative way of doing things. One of the largest sectors in agriculture has been the organic industry.

Has the organic industry been involved in this process?

[Andrea Johnston]

They haven't highlighted themselves specifically as organic producers so I'm not sure, but you're correct. That is an alternative option and a producer choice in terms of the protection methods they may want to take into account.

[Joe Peschisolido, Liberal, Steveston—Richmond East, BC]

Earlier on, Mr. Anderson talked about real-world data and I believe, Mr. Aucoin, you talked about model data, so basically you're doing an assessment on the risks. You talked about models. What models do you have? There are agencies. There are departments. In the private sector, companies have their models and there's a seal of approval through an audit process—so either KPMG, PWC, or whatever the big four are. Perhaps you can talk a little about the models you use. What is there that gives us the seal of approval? It seems as if the problem you have now is that there's a lack of trust in the process. I'm not saying it is, but it seems as if you're getting a lack of trust on both the farming side and the environmental side, and that's why we have a few folks here today.

Can you talk a bit about the model that you use, how you came about that model, and how you verify the models that you do have?