Agriculture Committee on March 9th, 2017

[The Chair, Liberal, Pat Finnigan]

I call the meeting to order.

Bienvenue, tout le monde. Welcome, everyone, to the Standing Committee on Agriculture and Agri-Food. Pursuant to Standing Order 108(2), we are continuing our study of the PMRA decision concerning the neonicotinoid insecticide imidacloprid.

I want to welcome the members. I think Mr. Shields is replacing Mr. Anderson. Welcome, Mr. Shields.

Also Mr. Maguire should be joining us shortly.

I want to thank the panel for being here with us today. We have Mr. Craig Hunter with the Ontario Fruit and Vegetable Growers' Association. From the Ontario Greenhouse Vegetable Growers, we have Ms. Justine Taylor, science and government relations manager. From the David Suzuki Foundation, we have Lisa Gue, senior researcher and analyst, science and policy unit, Ottawa. From Équiterre, we have Annie Bérubé, director of government relations.

Welcome, all of you. I understand we have 10 minutes per team.

Mr. Hunter, you will make your opening statement first, for up to 10 minutes. Thank you.

[Craig Hunter, Expert Advisor, Pesticides, Ontario Fruit and Vegetable Growers' Association]

Chairman Finnigan, Co-Chair Brosseau, and members of the committee, thank you very much for this opportunity today.

After almost 30 years with the Ontario Ministry of Agriculture, 18 years working for the Ontario Fruit and Vegetable Growers' Association dealing with pesticide issues, and more than 20 years as a member of the Ontario Pesticides Advisory Committee, I'm here today to share my experiences with pesticides. I'm here to represent the 2,500 fruit and vegetable growers across Ontario and more than 10,000 across Canada.

Growers are Canada's prime environmentalists. They live on the land, not in city apartments. They raise their families there and drink the water from the wells on their land. They no-till their land. They plant grass waterways and buffer strips. They do not want to spoil that land. They, in fact, want to pass it along in better condition to their children, for the next generation. They know what their environment is because they live in it every day.

Growers of fruits and vegetable crops across Ontario and Canada have been using imidacloprid since 1995, starting first with an emergency use on potatoes when every other registered insecticide had failed due to pest resistance.

Over the next 20 years, growers came to rely on this chemistry for a wide array of crops and for many insect species. In fact, an emergency use was just granted this past fall, a few weeks before the PMRA decision came out, and this was to control a new invasive species called brown marmorated stink bug, which can attack over 200 crops. I've seen it destroy 100% of an apple crop and a peach crop in Pennsylvania, which is pretty close to Ontario, so I know how devastating this insect can be.

If all the currently labelled uses are lost, it will be an enormous task to register effective and suitable alternative chemistries for the over 200 crops and multiple insect species that it controls. Although there are currently some registered alternatives for many of these pests, imidacloprid is the product of choice. As a result, a single application of imidacloprid may need to be replaced with three or even four applications of other products. You lose one, and then you have three or four alternatives each time you have to control pests.

Most of the other registered products have shortcomings that effectively preclude their use in commercial production systems. Even after 22 seasons of use, resistance to imidacloprid has not been an issue here. Many of the alternatives, on the other hand, need to be broad-spectrum products in a pesticide rotation program to prevent the pests from developing resistance. Imidacloprid has done this very well to date.

Since all horticulture is considered minor use, the pressure on Agriculture Canada's minor use program could be way beyond current capacity. None of our horticultural crops attract the research investment needed to register pesticides directly from the registrants. That's why we have the program. Even worse, many other products still face re-evaluation. Until they are reapproved, nobody wants to invest in their future, only to face double jeopardy.

I have many other comments on what I feel about the review, how it was done, the lack of time for meaningful input into the process, the lack of time to conduct new research to question some of the conclusions made by the PMRA, and their undue haste to publish a final decision by December of this year, nine months after our final comments are in. That's a full 12 months earlier than most of the re-evaluations over the past several years.

We have great concern that the 2015-2016 monitoring data, which was not included in making their decision, shows very different—in fact, lower—residue numbers in those same locations. This has not been taken into account.

Mesocosm studies that were rejected by the PMRA for various reasons need to be looked at again. What we call the weight of evidence shows up to 25 times less toxicity in the real environment as compared to pristine studies done in a laboratory. Perhaps a whole new look at the data used to condemn imidacloprid is warranted.

I also have concern that just last week Environment Canada announced they will not be conducting any further monitoring in these locations, even though they’ve expressed concern. This needs further consideration as well.

Just to close, bird counts done at Point Pelee have shown an increase in birds, and especially in fish feeders, and fishing quotas in Lake Erie have been rising. The fishing industry, in fact, has shifted down to the west end of the lake, so if there was really a problem, these would be the indicators, in my mind. This tells me a different story from the one portrayed by the PMRA in their proposal. Maybe if there is time later, I could add to the discussion.

I'll turn it over to Justine.

[Justine Taylor, Science and Government Relations Manager, Ontario Greenhouse Vegetable Growers]

Thanks, Craig.

Thank you again for this opportunity to present to you today.

We represent over 200 greenhouse vegetable growers across the province, responsible for nearly 2,900 acres of greenhouse tomatoes, peppers, and cucumbers. The greenhouse vegetable sector is one of the fastest-growing parts of Ontario agriculture. With over $820 million in farm gate sales, a contribution of over 12,000 jobs to the workforce, and a consistent track record of growth, the sector is a valuable contributor to Ontario's economy. In fact, in 2015 alone our farmers contributed an estimated $1.4 billion to the Ontario economy.

I would like to add some additional comments from the perspective of Ontario’s greenhouse growers. Let me start by saying that our members, like most farmers, endeavour to be stewards of the land and strive to minimize their environmental impacts. lmidacloprid is used for the control of aphids and whiteflies in the greenhouse, and is only registered to be used once a season. Even then it is used sparingly and in alignment with biological control agents.

Biological control agents are beneficial insects that are introduced to the greenhouse to control unwanted pests and greatly reduce the need for pesticides. Results from a recent Canadian Horticulture Council survey indicated that 76% of respondents use imidacloprid as a tool to control outbreaks when other methods have failed. This product, like many neonics, when needed, plays a vital role in controlling unwanted pests as part of an integrated pest management, or IPM, program. A successful IPM program relies on a number of tools, including biological controls, cultural practices, monitoring, and, when appropriate, responsible chemical use.

It is clear that the increase in global trade and the impacts of a changing climate will increase our exposure to invasive pests and diseases. Therefore, it is critical to ensure the appropriate tools are available to combat these new pressures. In the greenhouse environment, the potential for pesticides to escape into the environment is mitigated through the same measures put in place to address phosphorus reduction targets under the Canada-Ontario Agreement on Great Lakes Water Quality and Ecosystem Health. Currently over 90% of Ontario's greenhouse vegetable sector uses recirculation, whereby excess feedwater is captured and treated before being returned to the crop. In addition, the greenhouse sector, in collaboration with the provincial government, has developed a set of tools to address any feedwater that must be removed from the greenhouse environment.

Lastly, Ontario's greenhouse farmers have been looking, and continue to look, for new products that support an effective IPM program. The last few years have seen growers transition towards products that are softer on biocontrols. We expect this trend will continue, and to this end a promising new product has been identified through the minor use pesticides program that may further offset imidacloprid use. This project was selected as a joint Canada-United States minor use project.

The importance of a harmonized review process cannot be overstated, as it ensures a level playing field with our largest trading partner to the south. It is our belief that given the relatively low availability of viable alternative products, the potential for the development of resistance, and the need to remain competitive with the U.S., the removal of imidacloprid as a tool for pest management would be ill-advised.

We thank you for your time and look forward to your questions

[The Chair, Liberal, Pat Finnigan]

Thank you very much, Ms. Taylor.

Now we'll move to the David Suzuki Foundation and Ms. Lisa Gue.

[Lisa Gue, Senior Researcher and Analyst, Science and Policy Unit, Ottawa, David Suzuki Foundation]

Thank you, Mr. Chair. I appreciate the opportunity to appear today before you.

The David Suzuki Foundation is a registered Canadian charity, founded in 1990. The foundation believes we must protect biodiversity and Canadians' right to live in a healthy environment. These twin imperatives drive our long-standing work to strengthen pesticide regulation in Canada.

I've asked my colleague from Équiterre to join me this morning, as our two organizations collaborate closely in our work on pesticides.

I will review the ecological concerns that lead us to call for a ban on neonicotinoid insecticides, and then Annie will speak briefly to the PMRA's decision-making process and the issue of alternatives to neonics.

First let me state for the record that the David Suzuki Foundation and Équiterre agree with the PMRA's conclusion that imidacloprid poses unacceptable risks to the environment and should be phased out of use in Canada. In our view, the PMRA assessment underestimates the risks to terrestrial organisms and human health. Better addressing these aspects would only reinforce the conclusion that the continued use of imidacloprid is not sustainable. We therefore encourage Health Canada to cancel the main uses of imidacloprid, as proposed, and shorten the phase-out period. The proposed decision offers no justification for delaying action for three to five years, and this delay will needlessly prolong identified environmental risks.

Just a few months before the PMRA issued its proposed decision on imidacloprid, France adopted legislation to ban all neonicotinoids by September 2018. We recommend that Canada match the French timeline.

The evidence of harm from neonics demands urgent action.

The Task Force on Systemic Pesticides, a group of 29 independent scientists convened by the International Union for Conservation of Nature, has conducted the most comprehensive systematic review to date of the environmental impacts of neonics. The study analyzed more than 1,000 published scientific studies, and it concluded that the large-scale prophylactic use of neonics is having significant unintended ecological consequences. This ground-breaking review pointed to evidence of harm to aquatic and terrestrial invertebrates, pollinator insects, and birds, and to cascading effects that threaten whole ecosystems.

The task force published its findings in January 2015 in the peer-reviewed journal Environmental Science and Pollution Research. This publication in fact foreshadowed the PMRA's more recent conclusions, stating, and I quote:

The combination of persistence...and solubility in water has led to large scale contamination of, and the potential for accumulation in, soils and sediments, ground and surface water and treated and non-treated vegetation.

As you heard on Tuesday, the PMRA's assessment confirms that concentrations of imidacloprid in aquatic environments in Canada may pose acute and chronic risks to invertebrates when considering both modelled environmental concentrations and available monitoring data. Aquatic insects are a crucial link in the food chain in marine and freshwater environments. The PMRA notes that modelled concentrations are typically considered to be higher than actual environmental concentrations, but in the case of imidacloprid, the modelled estimates cannot be assumed to be conservative because actual monitoring data overlap with the range of surface water concentrations predicted in the models. Morever, it is generally accepted that monitoring data likely underestimate actual exposure, as sampling typically does not capture peak concentrations.

With respect to bees, which I gather will be the focus for the next panel today, the task force review found clear evidence that neonics pose a serious risk of harm, including sublethal effects on navigation, learning, foraging, longevity, resistance to disease, and reproduction. A separate review of post-2013 studies that has just been published confirmed these findings, and I will provide the committee with a copy of that paper.

The PMRA re-evaluation of imidacloprid does not consider risks to pollinators, which are being assessed separately. Nevertheless, phasing out imidacloprid will dramatically reduce pollinators' exposure to this chemical. We view this as a significant side benefit of the proposed decision, not least because of the importance of pollination to agriculture and food security.

The task force assessment also found evidence of harm to earthworms and other terrestrial invertebrates, and aquatic invertebrates. It also found the potential for population-level harm to birds exposed to neonic-treated seeds.

The registrants' claim on Tuesday that Canada's decision on imidacloprid has been made in haste is nothing short of fantastical. North American regulators have been slow to respond to the evidence of ecological risks, with the first tentative regulatory restrictions in Ontario taking effect only last year.

As you know, the European Union has prohibited the use of neonics on flowering crops since 2013. This policy is currently under review and may be extended to cover other uses. Italy banned neonic seed treatments in 2008 and, as I mentioned previously, France will ban all neonics starting next year. By joining leading jurisdictions at last in the shift away from neonics, Canada can be at the forefront of a movement towards mainstreaming more sustainable agricultural practices.

Before I conclude, I would like to draw the committee's attention to a report on the effects of pesticides on the right to food, which was tabled on Tuesday by the United Nations special rapporteur on the right to food. The report describes our current dependence on pesticides as a global human rights concern and notes:

The pesticide industry’s efforts to influence policymakers and regulators have obstructed reforms and paralysed global pesticide restrictions globally.

The special rapporteur is calling for a new global treaty to regulate and phase out the use of dangerous pesticides in farming, including neonics, and move towards sustainable agricultural practices. We believe Canada could and should be a leader in this transition.

[Annie Bérubé, Director, Government Relations, Équiterre]

Good morning. Thank you for the opportunity to share some of our ideas on sustainable agriculture in Canada.

Equiterre is an environmental advocacy group that has been active since 1993 and has offices in Montreal, Quebec City, and Ottawa. Its mission is to put forward concrete solutions to speed up the transition to a society where citizens, organizations, and governments make ecologically and socially fair choices.

Today, we would like to reiterate our support for the Minister of Health's recommendation to eliminate the use of imidacloprid in agriculture. We would add, however, that the risks associated with the pesticide are so harmful that it should be eliminated more quickly than the proposed time time frame.

Of concern to us is the importance of preserving the credibility of the pesticide re-evaluation process undertaken by PMRA scientists, as well as the independence of the Minister of Health's decision on this matter. The decision cannot be subject to any interference. Every stakeholder, including Equiterre, had a chance to submit comments during the consultation period. Why, then, give a public platform to a limited few stakeholders who have a clear commercial interest in the continued sale of the product in Canada?

We therefore urge the committee to expand the scope of the study to include the product's impact on ecosystems and human health, as my colleague Ms. Gue mentioned. Furthermore, the committee should take into account the knowledge and expertise currently available in Canada underlying alternatives to the agricultural use of imidacloprid.

We also have some concerns over the lack of transparency around the PMRA decision-making process. There is room for improvement in that regard.

In our view, it is especially crucial that PMRA demonstrate how its decision-making process takes into account independent scientific research, recent data such as the findings of academic researchers, and the data from provincial environmental protection agencies and Health Canada.

We are troubled, as well, by PMRA's dependence on how studies are conducted and taken into consideration. There is no way for researchers or the public to access data provided by manufacturers.

It is urgent that alternatives to the agricultural use of imidacloprid and other neonicotinoids in Canada be considered. On Tuesday, we learned that Agriculture and Agri-Food Canada had set up working groups to support the phase-out of the use of imidacloprid by farmers in Canada.

The work and recommendations of those working groups should be transparent. The groups should include agricultural stakeholders who have already implemented monitoring methods to prevent insect and pest infestations, as well as effective integrated pest management practices to prevent the unnecessary use of neonicotinoids. It is essential that the working groups not limit their efforts to the commercialization of other synthetic pesticides as the only solution.

Moreover, the working groups responsible for identifying alternatives must include stakeholders from Canada's organic farming sector who already grow corn, soybeans, potatoes, and a variety of other crops without the use of imidacloprid. The integrity of organic farming is threatened by environmental neonicotinoid contamination, which means the sector has an important part to play in the discussions.

I would like to quickly draw your attention to a few studies that raise doubts about the efficacy of many neonicotinoid uses in relation to farm yields and pest control. Take, for example, the field research—

[The Chair, Liberal, Pat Finnigan]

Kindly wrap it up, Ms. Bérubé.

[Annie Bérubé]

I have a good punchline coming in one minute.

[The Chair, Liberal, Pat Finnigan]

Let's go for it.

[Annie Bérubé]

There have been many studies that have shown the inefficacy of certain uses of neonicotinoids in Canada. A lot of this research is coming out of Quebec, and I have a lot of those studies here that I would be happy to share with the committee.

Further to its agricultural crop health strategy, Quebec developed very effective tools to prevent the unnecessary use of neonicotinoids in Canada, including crop rotation, intercropping, and sound fertilizer and irrigation management.

In conclusion, I encourage the committee to consider, perhaps as part of a future study, the important issue of alternatives to the agricultural use of synthetic pesticides in Canada.

Thank you.

[The Chair, Liberal, Pat Finnigan]

Thank you, Ms. Bérubé.

We will now begin the question and answer portion of the meeting.

Mr. Gourde, you have six minutes.

[Jacques Gourde, Conservative, Lévis—Lotbinière, QC]

Thank you, Mr. Chair.

I'd like to thank the witnesses for being here this morning.

I'm going to start with a question about something you said at the end of your presentation, Ms. Bérubé.

Do you also have research on how those Quebec farms fared in terms of performance and productivity, research that would support the possibility of doing without these pesticides?

[Annie Bérubé]

Yes. I would refer the committee to the studies done by Quebec's Centre de recherche sur les grains, notably Dr. Labrie's research. I have all the studies here. Researchers at the centre focused mainly on farm yields and the efficacy of neonicotinoid-treated soybean seeds in keeping pests away. They found no significant difference between treated and untreated soybean seeds. Further to that research, Quebec's pesticide strategy for 2015-18 sets out financial incentives for Quebec farmers for the purchase of non-neonicotinoid-treated seeds.

The results are similar for corn. No significant difference in yields was noted with the use of neonicotinoids to keep insects and pests away from corn crops. The United States Environmental Protection Agency has also done relevant research.

[Jacques Gourde, Conservative, Lévis—Lotbinière, QC]

Are you able to submit all of those studies to the committee?

[Annie Bérubé]

Certainly.

[Jacques Gourde, Conservative, Lévis—Lotbinière, QC]

Very good.

Eliminating products already registered in Canada would set quite a precedent. Are there other products that could also be eliminated? How will the industry adapt quickly enough?

[Annie Bérubé]

We believe the solution merits a broader and more informed discussion. We have to move away from the very narrow paradigm we have now. Under that model, any time an agricultural pesticide is restricted or eliminated, the only solution is to replace it with another synthetic pesticide. That reflects a very narrow view of farm management, when we know integrated pest management methods exist. Monitoring, prevention, crop rotation, and the use of natural predators, for example, are all just as effective as synthetic pesticides.

That is what we encourage the committee to pursue. It is Agriculture and Agri-Food Canada's responsibility to support Canadian farmers early on in the decision-making process so that they are not caught off guard whenever they have to restrict the use of a pesticide in their production.

[Jacques Gourde, Conservative, Lévis—Lotbinière, QC]

Are farms with more sustainable practices in place comparable in size to other farms in Canada? Are they smaller or fairly similar?

[Annie Bérubé]

I can only comment on the situation in Quebec.

The studies I will be providing to the committee on efficacy examine multi-hectare farms, and farms with corn, soybean and potato productions. Those crops perform better because of a sustainable approach to the management of pest infestations.

[Jacques Gourde, Conservative, Lévis—Lotbinière, QC]

I am mainly interested in whether the approach works for farms between a thousand and three thousand acres, or just those with 100 or 150 acres. Farmers who adopt more sustainable practices have to do more weeding. They have to do it more often, and they have the time to do it. Larger, commercial-sized farms, however, operate under stricter time frame and temperature requirements. In Canada, or in Quebec, farmers have very narrow windows for seeding, weeding, and irrigation.

Some farmers opt for the application of products so they can cover the area in a single pass because they have such a large acreage to cover. Farmers with smaller or medium-sized operations have the flexibility to go over the field more often.

Does the research examine small and medium-sized farms or large ones?

[Annie Bérubé]

I would have to check the exact number of hectares in order to answer your question.

I encourage the committee to invite Dr. Labrie, who did the research in Quebec. She could discuss the results of her field trials in Quebec in greater detail.

[Jacques Gourde, Conservative, Lévis—Lotbinière, QC]

Very well.

In that case, can Mr. Hunter answer the question?

Do you think farms with medium-sized and large acreages would have trouble using other growing methods?

[Craig Hunter]

The Ontario potato industry has 35,000 acres, and there are about 200 growers of the main crop. The average size of a farm is hundreds of acres. When we lost all effective pesticides to control the Colorado potato beetle leading up to 1995, all we had left to control them were propane burners that went down the field hot enough to burn the feet off the beetles so they couldn't walk, and giant vacuum cleaners that went down the rows. The cost of the propane for the burners was very high, and the cost of running vacuums up and down the field twice a day is prohibitive.

In effect, we had nothing effective that worked.

[Jacques Gourde, Conservative, Lévis—Lotbinière, QC]

How much time do I have left?

[The Chair, Liberal, Pat Finnigan]

Thirty seconds. I'll give you a minute because we are losing time.