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.