Thank you, Chris.
Madam Chair and committee, thank you for the opportunity to speak today as well.
The focus of this most recent special review is aquatic insects. With that in mind, I think it's important that we start with some brief comments about thiamethoxam and water.
First, as a systemic compound, thiamethoxam is inherently water soluble. Essentially, thiamethoxam breaks down in water into metabolites. It doesn't mean you're not able to detect thiamethoxam in water. However, it rapidly degrades through microbial action and sunlight.
It should also be emphasized that detection does not equate to risk. The presence of a pesticide, thiamethoxam or otherwise, does not in and of itself imply a safety issue, and it needs to be placed in the appropriate context based on rigorous scientific information related to various components in the ecosystem. Pesticides in water are considered, evaluated, and accounted for as part of the registration and approval process that governs the approval and use of these products.
With this in mind, we are reviewing the proposed re-evaluation decision regarding imidacloprid, and specifically, the methodology applied to it, for potential implications for the special review of thiamethoxam. While that work is still ongoing, we can provide you with an indication of a few areas of focus for us.
Regarding data quality, studies considered to be of value for ecological risk assessment should first be evaluated to determine whether their end points, the observations made in the studies, were derived with adequate scientific rigour and robustness before being used to characterize potential risk. It is not apparent to us at this time that this approach was taken in evaluating all the scientific data incorporated in the imidacloprid assessment.
A second area of interest relates to the establishment of a chronic water concentration. This is the value proposed from which the long-term impact of a pesticide is assessed. Given the limited dataset employed in the imidacloprid assessment, it is not clear that determination or derivation of a chronic concentration is scientifically supportable.
More generally, care is needed when extrapolating findings from one specific watershed or geography to an entire country. It is vital to account for differences in agricultural practices, cropping systems, product usage, and land use characteristics.
Suffice it to say, we will use the special review as another opportunity to bring all of the science to bear that supports the safe use of thiamethoxam and, as is required with the special review, all requested data has been provided to the PMRA for its consideration.
Above and beyond this, I can also tell you that other parties have assessed, and continue to assess, available data on the potential impact of thiamethoxam to aquatic life; that includes our own data and other data published in scientific literature. We believe this work is an important component of a comprehensive weight of evidence assessment regarding neonics and aquatic invertebrates and will be published in the public domain as it's completed.