Agriculture Committee on March 7th, 2017

[Scott Kirby]

Most of our models are specific to predicting concentrations in water bodies, and those models have been developed in concert with the U.S. EPA. Over the course of the years, these models have been refined. There's been what they call science advisory panels that have been held to validate some of those models, and they are models that are being used jointly. As we've progressed from one model to the other, we've validated that the results are consistent with what we were expecting.

The models are used as an initial lower-tiered estimate of what animals or fish or insects would be exposed to, and then if those show significant risk, if we have good monitoring data, then we will turn to that to see whether or not the predicted model outcomes are similar to what we're seeing in the environment. If they are, then that validates our assumptions in terms of risk. If they're not, that's when we need to do more work to see whether or not the models are overly conservative and whether the true real-world data is actually telling us a different story.

When we have good, solid monitoring information, as far as we're concerned, that's where the bar is set. The sad thing is that we often don't have that very good, strong, robust monitoring data.

[The Chair, Liberal, Pat Finnigan]

Thank you, Mr. Kirby. Thank you, Mr. Peschisolido.

That will conclude our first hour of the panel. I want to thank Mr. Kirby and Mr. Aucoin with the PMRA, and also Ms. Johnston for appearing with us today. It's been a very interesting conversation.

We will switch. Also, I will ask Ms. Brosseau if she will chair the second hour. Unfortunately, I can't be here. Also, I'll ask if you will allow her to ask her questions because I'm creating all this disturbance, so I think it would be good if you would allow that.

Thank you so much. We'll break for a few minutes and have a new chair.

[The Vice-Chair, NDP, Ruth Ellen Brosseau]

I have the gavel. Watch out.

Hello, everyone.

We will begin the second part of our study on pesticides with the presentation by Mr. Pierre Petelle, who is the vice-president of chemistry at CropLife Canada.

Please go ahead, Mr. Petelle.

[Pierre Petelle, Vice-President, Chemistry, CropLife Canada]

Thank you, Madam Chair and members of the committee.

On behalf of CropLife Canada and its member companies, we are pleased to have the opportunity to contribute to your study of PMRA's recent proposed decision on imidacloprid.

I'm joined today by my colleague, Dr. Maria Trainer.

CropLife Canada is the commercial association that represents manufacturers, developers and distributors of plant science innovations, including crop protection products and plant biotechnology products for use in agriculture, in cities and in public health. We are committed to protecting human health and the environment and we believe in ongoing research to stimulate innovation.

Our mission is to enable the plant science industry to make the benefits of its technologies available to farmers and the public. These benefits are varied, including reliable and effective tools to help Canadian farmers feed the world and, in turn, stimulate agricultural exports and job creation, strengthen rural economies, and boost government tax revenues.

Agriculture, as Dominic Barton states in his recent report to government, is a sector of enormous potential for this country, but it requires a supportive environment in order to truly thrive. CropLife Canada believes that a predictable, science- and risk-based regulatory system for pesticides in Canada is key to this agricultural success. The protection of human health and the environment is a top priority for our industry, and we believe that our track record clearly demonstrates that. The advances that have been made in plant sciences have contributed to significantly improved human health, lower risk for farmers, and reduced environmental impact.

As an industry, we're strong proponents of the pesticide re-evaluation process, which ensures that regulatory decisions are always founded on the most current available science. This process protects Canadians, and it is one we wholeheartedly support. Protections like this in the Pest Control Products Act are part of the reason why PMRA is seen as a leader in risk-based evaluations of pesticides by regulatory bodies throughout the world.

However, PMRA has deviated from its normal process in a series of proposed re-evaluation decisions it has made in the past year, and that has been a cause for concern. Many of these proposed decisions, with imidacloprid being simply the latest, have lacked the transparency and predictability for agriculture stakeholders that we have come to expect from PMRA. We fear that these essential components are being missed as the agency rushes to meet arbitrarily imposed deadlines. Some of this appears, in our view, to be fallout from the January 2016 report of the commissioner of the environment and sustainable development, or CESD, and an overreaction to criticisms contained therein.

Our specific concern is that after a re-evaluation is initiated and potential red flags are identified, dialogue with the registrant is not being pursued. Had the PMRA initiated earlier dialogue with the registrant and other stakeholders in its re-evaluation of imidacloprid, we believe we would not be sitting before you here today.

In order to make progress on this active ingredient, there is a need to ensure that the regulator demonstrates and maintains an openness to new data and to scientific dialogue with all stakeholders, including, of course, the product registrant. Disagreements can and do exist on the interpretation of scientific data, which makes the need for an open dialogue especially urgent. Recently, we are seeing significantly less of that openness and desire for dialogue from PMRA.

It is worthwhile to contrast previous PMRA strategic plans with their present one, as that serves to exemplify some of our concerns. Previous strategic plans, from both 2003 and 2008, contained, in addition to the obvious primary mandates of human health and environmental protection, clear language about the agency's role in providing “access to pest management tools”, “timely and predictable access”, and “supporting Canadian competitiveness”, to quote just a few. This language did not lessen the importance of human health and environmental protection, but it did remind PMRA evaluators and managers that their decisions have a profound impact on agriculture and that efforts must be made to consider this in their deliberations.

The latest, 2016-21 strategic plan for PMRA contains no such language. This is a concern for us, particularly in light of the kinds of re-evaluation decisions being proposed, including the one you are studying on imidacloprid. As mentioned, the audit report from the CESD sharply criticized the PMRA on some of their re-evaluation delays. We feel that, in the haste to address this backlog, the agency is sacrificing fulsome scientific dialogue for expediency. We believe that the agency needs clear direction from the government on the interpretation of the CESD audit to ensure that decisions with clearly negative impacts on a major sector of our economy are not made in haste.

In addition to the pressure the agency faces from the audit, there has been a huge increase in activist pressure in recent years. For example, there have been increases in form letters submitted by click-and-submit sites set up by activist groups, more media attention, and even some U.S.-style lawsuits from activist groups. Surely, this is affecting workload, not to mention morale.

Is it creating a risk averse environment at the agency? We're not sure, but recent actions by the agency would suggest it could be.

Canada is and should continue to be a global leader in sustainable agriculture. That was certainly the intent of the recent report from the council of economic growth chaired by Dominic Barton. Mr. Barton sees the immense potential that Canada has to continue to increase its agricultural productivity and exports, increase agri-food production and truly take advantage of the opportunities that exist for us globally.

With its strong work at the international level, the PMRA has been a leader, which has resulted in new technologies coming to Canadian growers at the same time as their competitors in the U.S. and elsewhere. We're concerned that this commendable action on new products is being undermined by the agency's re-evaluation approach and decisions, just as the Government of Canada is looking to agriculture as an avenue for economic growth.

Our global members, some of whom are sitting here next to me, need predictability in order to invest here in Canada. Recent re-evaluation proposals are sending shock waves among our members. Our fear is that, if Canada becomes a high-risk or unpredictable market, we will miss out on new opportunities.

This is certainly not the environment envisioned by Dominic Barton and his colleagues when they wrote their report and we do not believe that this is the policy intent of the Government of Canada. This is why we're looking to this committee and the Minister of Agriculture and the Minister of Health for leadership to help ensure PMRA's re-evaluation program doesn't undo all the good work that has been done to get new products registered by, at the same time, tarnishing the reputation of approved products without first having done a thorough and transparent examination of all the data.

We need to avoid damaging the competitiveness of Canadian growers with decisions that provide questionable health and environmental protection. Specifically, agriculture stakeholders are looking for a fair scientific discussion from PMRA with potential input from external expertise on imidacloprid.

There needs to be flexibility on timing for new data on this product, so that PMRA can be certain that decisions are being based on the best possible information. We would like to see consideration given to re-evaluation process improvements as outlined earlier. We hope for a reinsertion of “enabling access” or competitiveness language in the PMRA strategic plan.

Finally, we would like to see some consideration given to the broader Canadian agriculture strategy, as articulated in the Barton report, by PMRA in its decision-making.

Thank you for your time. We look forward to your questions.

[The Vice-Chair, NDP, Ruth Ellen Brosseau]

Thank you very much, Mr. Petelle.

We will now hear from Mr. Paul Thiel, from Bayer CropScience.

You have 10 minutes, Mr. Thiel.

[Paul Thiel, Vice-President, Product Development & Regulatory Science, Bayer CropScience Inc.]

Madam Chair, members of committee, thank you for inviting me here today to share with you Bayer's view on the proposed regulatory action on imidacloprid with respect to aquatic invertebrate safety and its potential impact on segments of production agriculture in Canada.

Bayer is one of the world's leading innovative crop science companies in the area of seeds, crop protection, and non-agricultural pest control. Our company offers an outstanding range of products, including high-value seeds, innovative crop protection solutions based on chemistry and biologicals, as well as an extensive service backup for modern sustainable agriculture. Headquartered in Calgary, Bayer's crop science division employs over 450 people across Canada, as well as 200 summer students each year.

More than 60,000 grower customers adopt our technologies for many of their crop production needs, including crop protection products, seeds, and plant biotechnology.

The committee has heard much discussion on this regulatory proposal for imidacloprid, and I would like to take the opportunity to add to this important discussion. Imidacloprid is a member of the neonicotinoid insecticide family. These insecticides represent an important advancement in agricultural technology that has helped Canadian farmers increase productivity and improve competitiveness and sustainability. These products provide clear performance and environmental advantages over the older insecticides they replaced, and by effectively controlling pests they provide incremental yield benefit, are adapted to integrated pest management systems, and present a lower risk to users.

Imidacloprid has been registered in Canada since 1994, when it first received an emergency-use registration in potatoes to control Colorado potato beetle, which was resistant to most of the other registered insecticides of the time. Since that initial approval, imidacloprid products have been widely expanded to fill a need left by the loss of older pesticides that were removed from the market. Imidacloprid was also the first generation of innovative seed treatment technology with systemic activity for protection against seedling and seed insect pests. It is also used for structural control of pests such as bedbugs, and with pets in the control of fleas and ticks.

Late last year the PMRA, in its review of the dossier, stated that there was no concern related to human health; however, PMRA's proposed re-evaluation decision of imidacloprid found that in aquatic environments, exposure to imidacloprid from spray drift and from runoff may result in toxic effects to aquatic insects. On this basis, the PMRA is proposing to phase out all of the agricultural and a majority of other outdoor uses for this product over the next three to five years.

Bayer disagrees with this regulatory proposal based on potential harm to aquatic invertebrates. Bayer is of the view that it fails to adequately discern regional differences or production practices of concern, fails to adequately address potential associated mitigation options, and does not take into account higher-tier risk assessments, resulting in an overly conservative threshold value based on a single species.

Data reviewed to arrive at this proposed action include more than 11,000 water samples taken from coast to coast. Of these water samples, only a few programs were considered adequately robust, including three sampling sites in southern Ontario and one in Quebec that had levels of imidacloprid above the new proposed threshold value of 41 parts per trillion. Other sampling data that had detections below this threshold have been discounted due to the lack of ancillary information.

In their review of the registrant and published data, the PMRA has relied exclusively on laboratory data to generate the threshold values of concern, using the mayfly as the most sensitive representative species. Bayer has submitted 22 mesocosm studies as part of the dossier for the imidacloprid registration. These studies are higher-tier studies that more properly represent the aquatic invertebrate community in a natural setting, as opposed to an artificial laboratory setting. However, each of these studies was rejected by the PMRA for this assessment. Many years ago our industry moved to this type of study to better characterize risk in the natural environment; however, we now find ourselves taking a step backward to rely on more conservative laboratory data.

Bayer has had a long and collaborative relationship with the PMRA. Their role as a regulator and ours as a registrant are well understood and accepted. However, in this case, the proposal was published with no advance discussion and consideration of potential mitigation steps that may resolve any concern. The proposal to phase out many uses of imidacloprid is not supported by any monitoring evidence of the aquatic invertebrate community, or any evidence that its use has caused harm in this area.

Furthermore, with limited data, or the absence of information from many regions of Canada, this proposal is nationwide. With the lack of effective alternative products such action may result in the use of increased tillage for the control of soil-dwelling insects such as wireworm, leading to an increase in soil erosion, loss of land productivity, increased carbon emission, loss of revenue, and a reduction in sustainability metrics.

As a leader in Canadian agriculture, we understand the value of biodiversity and the role of aquatic invertebrates in the food chain. We also believe that imidacloprid, when used according to label directions, poses no undue risk to the aquatic invertebrate community and the nature that depends on these as a food source. We believe the products we develop, market, and steward represent the latest innovations in crop protection that have helped make Canadian agriculture productive, sustainable, and competitive. I look forward to answering your questions.

Thank you.

[The Vice-Chair, NDP, Ruth Ellen Brosseau]

Thank you very much, Mr. Thiel.

We will now move on to Mr. Chris Davison, from Syngenta Canada.

You have 10 minutes.

[Chris Davison, Head, Corporate Affairs, Syngenta Canada]

First, let me thank the chair, vice-chairs, and members of the committee for the opportunity to meet with you today.

By way of background, Syngenta is a leading agriculture company helping to improve global food security by enabling millions of farmers to make better use of available resources. Through world-class science and innovative crop solutions, our 28,000 people in over 90 countries are working to transform how crops are grown. The Syngenta Canada team is approximately 300 people strong, supporting products and services for the country's major crops, including wheat, barley, canola, corn, potatoes, pulses, soybeans, and specialty crops.

While the focus of your meeting today is the PMRA's proposed decision concerning the neonicotinoid imidacloprid, which is manufactured and marketed by Bayer, as just mentioned, the topic is also of critical interest to us at Syngenta, as we are the manufacturers and marketers of one of the other neonicotinoids, thiamethoxam. As well, the PMRA's proposed decision regarding imidacloprid triggered a special review of other neonics, including thiamethoxam, also with a focus on aquatic invertebrates. It is worth noting that there are currently four different re-evaluations and special reviews under way that include thiamethoxam in their remit.

We are supportive of and regularly tout Canada's rigorous and stringent regulatory system. Our system protects the health and safety of Canadians by ensuring that no products are approved that would pose an unacceptable risk to human health and the environment. Our system also ensures that products are regularly re-evaluated and reassessed to ensure they continue to meet the latest scientific standards. That being said, it is fair to say that we have some concerns with some of these current activities, which we will return to in a few minutes' time.

We are also cognizant of the fact that this committee and other bodies of the government have previously spent significant time on the subject of neonics, so we'll use the majority of our time with you here today to focus on some considerations and potential implications of the most recent regulatory actions regarding neonicotinoids.

The PMRA is very clear that before any pesticide can be registered in Canada, Health Canada must review the scientific information to make sure it has value and there are no unacceptable health or environmental concerns related to its use. The focus on value, health, and environment is clear and shared by us as registrants of these products.

With regard to thiamethoxam specifically, it is an extremely important and valuable tool for controlling various insect pests across a variety of crops. Its introduction, together with other neonics, ushered in a new era of insect control and management.

Thiamethoxam is registered for different uses on different crops as a foliar, soil-applied, and seed treatment insecticide. The majority of its use in Canada is as a seed treatment, which also brings additional value and benefits, including protection of seeds and emerging plants from insect damage during the critical first weeks of development.

From an environmental perspective, the benefits as a seed treatment include a significantly lower amount of active ingredient per acre compared with foliar and soil-applied pesticides, direct application to the seeds, reduced impact on non-target organisms, and protection from increased pest pressure associated with a range of agronomic practices, including reduced and no-till field conditions.

From an agronomic and production perspective there are also a number of other benefits, including optimizing seeding rates due to improved plant stand; minimizing the need for replants; extending the application window for in-season pesticide applications, if and when needed; supporting earlier planting practices, which helps to maximize labour and production efficiency; and complementing trait technology to manage insect pests.

Over the past several years various government, industry, and other stakeholders have undertaken work to quantify these benefits to Canadian agriculture, and while they have all employed different criteria and had a different scope for their analyses, all have confirmed the on-farm value of this class of chemistry.

Likewise, the impact of loss of or restriction of uses of these technologies has also been documented and would be expected to impact production in three main ways: yield loss or depression, quality losses, and additional need for foliar applications of insecticides, the majority of which would involve older chemistry with less favourable profiles.

The most recent action by the PMRA related to thiamethoxam, as mentioned earlier, is the special review regarding potential environmental risk to aquatic invertebrates. This special review was announced by the PMRA on November 23 and was triggered by the proposed re-evaluation decision regarding imidacloprid, which was announced the same day. To speak to this, I'm going to turn things over to my colleague Dr. Paul Hoekstra.

[Paul Hoekstra, Senior Stewardship and Policy Manager, Syngenta Canada]

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.

[Chris Davison]

Thanks, Paul.

Finally, I think it's important to situate Canadian regulatory actions, generally, and the actions that are being contemplated vis-à-vis neonics, specifically, in a somewhat broader and holistic context. To do that, I would make the following comments for consideration.

Comments have already been made about the Dominic Barton report and the opportunity for the Canadian agri-food sector. Implicit in realizing this is support for a research and innovation driven sector, inclusive of significant advancements in plant science that will help ensure we continue to make great strides in crop production for years to come. Neonics generally and thiamethoxam specifically are excellent examples of such advancements, advancements that we want to encourage and continue to bring to Canadian agriculture and Canadian farmers in order to sustain their productivity and competitiveness in a globalized economy.

Second, as part of the various evaluations and special reviews and the various actions that may or may not result from them, there is considerable speculation, and we are asked about replacements for or alternatives to neonics in the event that one or more of them were to be restricted or removed from the marketplace.

To our knowledge, there are no one-for-one replacements for this technology. While there are other active ingredients that control some of the pests on some of the crops with some of the uses that neonic products do, there are none that are as broad spectrum, that are registered for as many crops and uses, or that are as effective as neonics.

Furthermore, restrictions or removals on their uses would result in more reliance on fewer modes of action, which would increase resistance risk and, even more important, drive more use of foliar sprays based on older chemistries with risk profiles that are less favourable than neonics.

It is also critically important to keep in mind that decisions about the development of new or alternative products won't be made in Canada or just with the Canadian situation in mind. Plant science innovations, as was referenced earlier, are generally developed and registered largely on a global basis. To think that somebody or some organization would develop a Canada-specific solution does not reflect the reality of the years of intensive research, development, registration, and commercialization, and the financial resources required to do so.

Finally, as the majority of crop production agriculture in Canada is destined for export, it is critical that Canada be at the front end of the innovation and adoption curve, to keep our growers competitive and our status as one of the world's largest agricultural exporters. This need not and should not happen at the expense of or in place of human health and the environment, but in concert with it. We should be working to make sure that our regulatory system finds the right balance to achieve this.

Thank you.

[The Vice-Chair, NDP, Ruth Ellen Brosseau]

I would like to thank all the witnesses.

We will now proceed with questions and comments.

David, you have six minutes.

Thank you.

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

Thanks for being here today.

We talked before about modelling and real-world data, and that kind of thing. I just want to come back to that again. You said that Bayer had 22 studies done on aquatic invertebrates and they were rejected by the PMRA. When they were here, they talked about how they see modelling data as being important. I guess we're all aware of how unpredictable and uncertain that can be. They also talked about focus on predicting levels in water bodies with the EPA.

How does modelling and lab data and real-world data fit together, and how would you like to see that fit together in order to get a better balance in decisions such as this?

[Paul Thiel]

I think what you described are pieces of the puzzle that describe the story. We work through a series of tiered risk assessments, starting with the very most fundamental, controlled, in-lab types of studies, which give us direction as to what we should look for at the next level. Eventually you get out into the environment you're monitoring, which is the highest-tiered risk study you can possibly run.

Modelling is used to predict what you might find out there. Obviously, a model and real-world monitoring in a perfect world will match up. You'll find what you're looking for. A mesocosm study simulates the natural environment but tries to control the variables, which are numerous when you go out into a natural body such as a wetland or a stream running through an agricultural area.

In this case, all these studies were not considered in the assessment. They were deemed for whatever reason to be inadequate, although previously, I will say, they were used to grant the initial registrations.

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

It's just interesting, because they talked to us about how they were considering all the science and all the different data they could find.

It seems to me, though, that there are two parts to this. One was that these chemicals were being blamed for the bee kills. It turned out that they didn't have the impact that people thought they would have on them. Then it seems as though there has almost been an effort to shift this attention to something else, to see if we can find a place where these things are considered more toxic and then ban them. It's almost as though we're trying to find an excuse for the ban rather than doing the science to prove it, or whatever.

With the real-world data you've done on aquatic invertebrates, are you comfortable with the results and would you like them to consider that? Do you consider that to be valuable for them?

[Paul Thiel]

Yes, absolutely.

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

Okay. Maybe we can encourage them to take a look at that.

We talked a little earlier about changing thresholds and values. I think you mentioned thresholds as well. Do you participate when those values are changed? A gentleman mentioned that they've changed a number of times. How do the companies fit into that when the government decides they're going to change threshold values? Do you have any say in it?

[Paul Thiel]

Our experience has been that when the government was going to make a regulatory proposal, we had the opportunity to discuss that with them. In this case, the discussion did not take place prior to publication of the proposal.

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

That's everyone's experience.

I thought Mr. Hoekstra made a really good point, which doesn't come through in the studies actually, but detection does not equate to risk. If you read some of the studies, you'd think that the mere presence of something proves that there's an issue or whatever. It just seems that some people think this assumption is critical to banning these things.

There's a study out of Guelph that talks about more prescriptive direction, more prescriptive use of the chemicals. Would you see that as an alternative to this ban, as a useful alternative to the ban, or do you think that the chemical prescriptions are already adequate?

It's your product.

That leads into my other question: why do you expect the other chemicals to be treated differently?

First of all, can you answer the question, do we need more prescriptive directions for the use of the chemical, a bit more control on it? Would that make it acceptable, or do you think it's fine the way it is?

[Paul Thiel]

I believe the label as it stands today is fit for use. It provides adequate direction to growers. When used according to the label direction, it poses no undue risk.

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

Now the other question about why you expect—

[Chris Davison]

The PMRA has a process, but I think that's what Paul's comments were. We're looking at the methodology that's being applied in the proposed imidacloprid decision because basically a new study has been triggered also looking at aquatic invertebrates in the context of thiamethoxam.

That's why Paul made the comments he did about the areas of focus or of concern for us in terms of the methodology that's been used. That's why we're here and why we have a keen interest in the proposed decision regarding imidacloprid.

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

Do you feel the multi-stakeholder forum is being used to do some of PMRA's work for them? Is it work that should have been done ahead of time by them, or should have been done in participation with you, and now it's being passed off and it's being said, “Do you want to do this work now and prove to us A, B, and C?"

[Pierre Petelle]

I can touch on that one.

I think the process is novel. To my knowledge, it has not been done for any other consultation in my time with CropLife. Should it have been done before the publication of the proposed decision? Absolutely. I think there's a lot of good work being done there, except it's being done on a very tight timeline. Had that been done as a consultative process with the agriculture sector and the registrants, if these issues had been talked about in advance and not in this politically charged climate of a proposed ban hanging over everyone, I think it would have been much more productive.

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

Do you actually think you're going to have an impact on that ban?

[The Vice-Chair, NDP, Ruth Ellen Brosseau]

You're at almost seven minutes.

I'm being generous. I'll be good on your side, too.

Mr. Longfield.