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—