Agriculture Committee on March 9th, 2017

[Pierre Giovenazzo, Professor, Sciences apicoles, Centre de recherche en sciences animales de Deschambault, Université Laval, As an Individual]

Thank you for inviting me. This gives me an opportunity to share not just my personal view, but also the view of the beekeeping stakeholders I represent in Quebec and Canada.

I'll begin by telling you about the Centre de recherche en sciences animales de Deschambault, or CRSAD, and Canada's apiculture problem. I will also discuss the subject of the committee's study, the imidacloprid re-evaluation.

CRSAD's mission is to carry out animal science research and development. Our work is not limited to bees; we study all farm animals.

CRSAD is unique in its innovative approach to supporting animal science research and in its diverse areas of activity.

CRSAD keeps 300 bee colonies for the sole purpose of apiculture research.

CRSAD works with Université Laval, where I am a professor and teaching leadership chair in apiculture science. The centre also partners with other universities and even the private sector to carry out apiculture research.

We have published results in the following areas of research: genetic selection; productive colonies adapted to the Quebec climate; bee reproduction; the condition and fertility of queens and males; nutrient requirements, which are now extremely important; bee disease and parasitosis; pollination services; colony development dynamics; and the impact of pesticides on honeybee colonies.

Canada's beekeeping challenge is interesting for two reasons, which I will explain.

Right now, in Quebec and Canada, we are seeing a pretty remarkable rise in pollination services; bees are needed. A Government of Canada study released last year estimated the value of honeybee pollination to crops at approximately $2 billion. That is the economic value of honeybees to Canada's agricultural sector, be it blueberry, cranberry, or apple production, or even canola in Alberta.

Despite that, bee colonies have been suffering significant losses for 10 years, with annual mortality rates of between 20% and 25% in the winter and nearly 20% in the summer. The industry is experiencing tremendous losses in productivity.

In spite of these yearly losses, Canada's beekeeping industry is growing, which seems somewhat contradictory. With more colonies than before, the industry is experiencing rather sizable growth. Quebec, for example, now has around 60,000 colonies, versus the 35,000 it had 10 years ago. The growth has been fairly swift despite reduced biodiversity and expanding farmland. That is the context bees are evolving in.

To support this growth, Canada imports packaged bees, including queens, from a variety of countries. Since 2011, queen imports have gone up 92%, with colony imports rising 66%. That means our beekeeping industry cannot sustain itself. That is an important point to keep in mind.

I will now turn my focus to the decision to phase out imidacloprid.

Bees are truly the sentinels of the environment. A single colony can have 20,000 bees flying around and coming into contact with all kinds of flowers. They harvest the environment.

Beekeepers operate in agricultural areas, which receive pesticide and pest control treatments. Bees have to cope with that reality. It's important to realize that we are dealing with the environment of bees. Pesticides fight against insects, but bees are insects. There is clearly a problem.

The first message I want to convey is that the bee industry and agricultural industry must work together when new products enter the market.

A good collaborative approach helped to change planting methods. A problem was identified, and everyone worked together to solve it. The planting method was changed to reduce the use of imidacloprid dust, which helped lessen the impact on the bees. It was a good collaborative effort in the industry. This is the proper way to work.

I also want to talk about the unreasonable use of coated seeds. Integrated pest management was mentioned earlier. It doesn't consist only of using organic pesticides. It's a strategy that enables us to use all the tools available, including synthetic pesticides. However, the use of coated seeds in prophylaxis, or as a preventive measure, isn't integrated pest management. The heavy use of coated seeds is likely a problem. An adjustment must be made to avoid the excessive use of these seeds.

I'll finish by saying that, even if we measure the levels of sub-lethal effects resulting from these products, we must realize that the effects aren't sub-lethal all the time. It depends on the bee's health, parasites and potential diseases. A pesticide in the environment at a sub-lethal level could have a lethal effect if the pesticide reaches a sick bee or is associated with other pest control products found in the environment, especially if other synergistic products are present.

I'm a member of the Table filière apicole du Québec. We're concerned about the phase-out of this pesticide, because it means that another product or other products such as those mentioned earlier will enter the market. We're very concerned about this because we'll likely need to study the impact of these new products on bees. We'll need to use federal funding to conduct new research. It's unfortunate, because the funding is currently needed to conduct apiculture research and to advance knowledge in the field, and not to verify whether a pesticide is harmful.

I conduct apiculture research, and I want this industry to grow. I don't want to study pesticides, but the dynamics of a bee population, the queens and their fertility. This will move our bee industry forward. We're always very concerned about new products.

Thank you.

[The Chair, Liberal, Pat Finnigan]

Thank you, Mr. Giovenazzo.

Now we have Mr. Brock for 10 minutes.

[Mark Brock, Chairman, Grain Farmers of Ontario]

Thank you, Mr. Chairman and members of the committee, for this opportunity to provide our comments on the PMRA's proposed decision on imidacloprid.

My name is Mark Brock. I'm chairman of Grain Farmers of Ontario. I operate a farm, in partnership with my wife Sandy, in Hensall, Ontario, where we grow corn, soybeans, and wheat in rotation. We also raise livestock.

The Grain Farmers of Ontario is the largest commodity organization in Ontario, and represents 28,000 barley, corn, oat, soybean, and wheat producers. Our farmer-members cover six million acres of farmland across the province, generate over $2.5 billion in farm gate receipts, and are responsible for over 40,000 jobs in the province.

Neonics like imidacloprid are tools our farmer-members use to protect their crops from insect damage. Insects can cause many problems with our crops. They can starve a plant of the nutrients that it needs to grow; they can kill a plant, reducing our overall yield; and they can cause severe damage that will render a plant not suitable for our high-value export markets.

Some insects live below the soil and feed on the roots of the plants, and some insects fly in and eat the leaves or fruit off the plants. Neonics are primarily used as a coating on the seed, commonly called a seed treatment, which protects the seeds underground and during germination and provides some protection from leaf-eating insects during early growth.

Seed treatments are a very effective method of delivery, and the system for coating the seeds ensures the health and safety of our farmer-members. The seeds are coated in a factory before delivery to the farm, so farmers have limited exposure to the pesticide. In the past, before neonics were introduced, products were applied by the farmer in the field, increasing the health risk to the farmer. Today's modern system provides the farmer with pre-coated corn and soybean seeds so that both the seed and the pesticide are planted together. This results in less pesticide required to do its job because it is put directly on the seed, protecting it, rather than spread in the soil. This is an isolated, targeted approach to crop protection.

Seed treatments are an important tool for us in our environmental and sustainable practices. Many grain and oilseed producers have adopted no-till systems that reduce greenhouse gas emissions on the farm. Many of us also plant cover crops that improve soil health and reduce the runoff of phosphorus into the Great Lakes and tributaries.

These types of farm practices would not be possible without tools like neonic seed treatments. Cover crops and no-till results in increased insect populations that flourish in the undisturbed soil. The seed treatment allows farmers to protect each individual plant from these insects that grow in that environment. If not for seed treatments, many farmers would be less likely to plant cover crops or practice no-till because their crops could not withstand the insect damage.

Today there are no alternatives in the marketplace or in the technology pipeline that provide the same level of protection and safety for our farmer-members. Last year there was an introduction of a similar product into the marketplace, but it’s not available for soybeans, nor does it cover the same array of insects that the three neonics do. It is also being sold at four times the cost of the neonic seed treatment, even though it provides less protection. We have seen some Ontario farmers transition to this product, but we do not have enough years of experience to know what its weaknesses are and what it will or will not be effective against.

Neonics remain an important product for us, and they are products our competitors in the U.S. have access to. The Conference Board of Canada determined that the impact of not having access to neonic seed treatments would cost $600 million annually to corn and soybean farmers in Ontario alone. This number does not take into account the costs of other crops, but does include the cost of using alternative products.

It is important that our farmer-members have a tool box of technology to choose from, not only to deal with pest and disease pressures that we face, but to also remain competitive with international markets that have access to these products.

Our farmer-members have a long history of adjusting our practices when risks are identified, and we appreciate the working relationship we have with our regulators to figure out risk mitigation solutions. An example of this is the action the industry took to address the issues that arose a few years ago with bee health. PMRA identified the risks to bee health, and we adopted new practices to protect bees in the very next growing season. To date, it has proven to be successful, and honeybee populations have been improving since these new practices have been instituted.

Access to technologies like neonics is essential for our farmer-members to grow sustainably and to compete in the international marketplace. We look to PMRA to assess the safety of these products, and, if possible, we would prefer the opportunity to adjust practices to mitigate risks than rather than see products phased out. The phase-out of products limits the tool box that our members can access and can put a chill on future investments in Canadian agriculture.

We appreciate the establishment of the neonics forum chaired by AAFC. This forum has been established to address the issues that have arisen from the proposed decision on imidacloprid and is also looking at the special reviews on clothianidin and thiamethoxam. The staff at AAFC, PMRA, and Environment Canada have dedicated time and expertise to this process, along with academia and other interested parties. We are hopeful that it will result in a national protocol for environmental monitoring and risk mitigation opportunities that can be adopted by farmers.

Our farmer-members understand and take very seriously the responsibility to protect our environment, including Canada's air, water, and soil, and the ecosystems that thrive there. We are stewards of the land. The time we spend on our fields gives us a unique understanding of the environment and the different ecosystems. We know the decisions we make in our fields impact the environment. We are invested in the environment, not just because it is the right thing to do but also because our livelihood depends on it. That is why we support the PMRA in fulfilling its mandate to protect Canadians and the environment from unacceptable risks posed by pest control products.

We are committed to working with the government and other stakeholders to address environmental concerns and implement strategies that are environmentally responsible. Aquatic invertebrates are integral to the health of wetlands, creeks, and streams across Canada. We are committed to reducing risk and ensuring aquatic invertebrates continue to thrive in our ecosystems. To reduce the risk to aquatic invertebrates we must first understand the risks, and we rely on the PMRA to conduct credible and thorough risk assessments to identify unacceptable risks. We believe the work the forum completes on risk mitigation, environmental monitoring, and alternatives is valuable.

We are hopeful that the work of the forum will lead to a risk assessment that can be narrowed down through this coming season with a more robust environmental monitoring system in place, and we hope that this work will ultimately provide an opportunity to maintain access to these vital crop protection products for our farmer-members if the right mitigation is implemented to address these risks. If they cannot be managed, we are committed to working with government and stakeholders on an orderly phase-out of the products if the risk is too unacceptable.

We would like to thank you for the opportunity to speak to you today, and I am open to any questions that you may have.

[The Chair, Liberal, Pat Finnigan]

Thank you, Mr. Brock.

Now we will hear from the Canadian Honey Council. Mr. Rod Scarlett, you have up to 10 minutes.

[Rod Scarlett, Executive Director, Canadian Honey Council]

Mr. Chair, members of the committee, on behalf of the Canadian Honey Council I'm pleased to have the opportunity to contribute to your study of PMRA's recent proposed decision on imidacloprid.

The Canadian Honey Council represents more than 9,000 beekeepers across Canada, who manage more than 750,000 colonies. Their contribution to the Canadian agricultural industry exceeds $4.5 billion. Beekeepers and farmers have a mutually beneficial relationship, as beekeepers are often dependent on landowners for yard placement, while farmers get the benefit of increased pollination of their crops, resulting in greater yields.

As many of you are aware, the status of bee health in Canada has been and continues to be at the forefront of attention in the public arena. Contrary to many preconceived notions, the numbers of managed bee colonies in Canada have been steadily increasing despite the pressures of pests, pathogens, reduced or changing habitat, and pesticide exposure. Indeed, the latest Statistics Canada numbers indicate a record number of colonies in Canada in 2016. Those numbers can be a little deceiving, as increased numbers are driven not only by economics but by and through the hard work of beekeepers, often at increased expense.

The co-operative work that industry and governments have done to mitigate the risk of pesticide exposure to the honeybee population is commendable. The work of the Agriculture and Agri-Food Canada Bee Health Roundtable is a shining example of this co-operative effort.

The Canadian Honey Council has from the very beginning maintained that the Pest Management Regulatory Agency should be the scientific barometer upon which policy and action are based. To a very large extent, the actions that have been taken with regard to mitigating pesticide exposure of honeybees have been quite successful, particularly those related to exposure from coated seeds. Certainly questions remain, particularly those related to some foliar sprays and long-term cumulative exposure impact, especially to neonics, but on the whole, work by government, equipment manufacturers, life science companies, seed companies, farm associations, and beekeepers themselves has been very admirable.

The Canadian Honey Council cannot comment on the scientific basis for the planned phase-out of imidacloprid, since the basis for the decision was made independent of honeybees. Indeed, in their preliminary pollinator-specific assessment for imidacloprid, the PMRA indicated that the potential risk to bees can be mitigated.

What we can comment on and what we do have a concern about is the potential impact that alternative products the farmers will have available to them may have on honeybees. If the alternatives are old chemistries with limited impact assessments done on pollinators, they may prove more harmful to honeybees and other beneficial insects than the current situation.

We understand the PMRA has not analyzed potential impacts of the adoption of all alternative products on bee health. Options that become available to farmers must be economical as well as provide a risk mitigation strategy acceptable to both the user and the beekeeper. It does no one any good if the replacement products are either too expensive but pollinator-friendly or cheap but creative of high risks to pollinators.

Comprehensive and comparative pollinator assessments of alternative products, in particular those with older chemistries, should be conducted now to ensure that the proposed risk mitigation approach does not create more problems than it solves.

The Canadian Honey Council has tried to work from the premise that co-operative solutions result in co-operative wins. With PMRA proposing a phase-out of of imidacloprid, we need to ensure that the “what next” genuinely is better for all stakeholders.

Thank you.

[The Chair, Liberal, Pat Finnigan]

Thank you, Mr. Scarlett.

We'll go right into our question round.

Mr. Gourde, you have six minutes.

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

Thank you, Mr. Chair.

My question is for Mr. Giovenazzo.

In your statement, you referred to bee colony losses of 25% in the winter and 20% in the summer. Have these losses increased in the past five or six years? Are these normal losses for a colony?

[Pierre Giovenazzo]

The losses vary, so to speak.

In recent years, things have been going much better in Canada, where losses are under 20%. However, losses in certain provinces, such as Manitoba and Ontario, have exceeded 30% in the past five years. The losses aren't equal across the country or from year to year.

In the past three years, the winter mortality rate appears to have lowered. This rate is the easiest to measure. We compare the number of bees that enter the hive in the fall with the number that leave the following year. In the summer, it's very difficult to manage. The estimates are always slightly less accurate.

To answer your question, on average, the losses have exceeded 20% in the past ten years. I think the winter mortality rate in Canada is 24%.

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

Are all colonies in Canada imported? Is there a bee manufacturing industry?

[Pierre Giovenazzo]

Good question. One of the goals of the Canadian beekeeping industry and the Canadian Honey Council, in Quebec and all provinces, is to move toward self-sufficiency, which is currently inconceivable.

For example, if 20% of the bees have died by May, to compensate for the losses, bees must be purchased from places abroad, such as California, Chile, New Zealand and Australia. Queens are imported to replace the deceased queens, and 1.5-kg packages of bees are imported. At this time, the packages are mainly from New Zealand.

That's how beekeepers quickly rebuild colonies. Then, in June and July, beekeepers can increase the number of bees when the colonies become stronger. They can create splits, which are called “nucs”. That way, they can increase the swarms. I can tell you that things are moving these days, because bees are needed.

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

Are Canadian colonies similar to each other? Are they more resistant than immigrant colonies imported to the country?

[Pierre Giovenazzo]

There's a major difference. Some groups, such as CRSAD, genetically select honey bees. In these centres, bee colonies are chosen for their hardiness, meaning their overwintering survival. The colonies are selected for the spring build-up, so they can be strong for the blueberry and cranberry season. This makes a big difference when bees with other genetics are imported.

Beekeepers certainly love local genetics.

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

Would it be correct to say that bees that survive the first winter are better adapted to our Canadian climate when they're born to mothers who lived in Canada?

[Pierre Giovenazzo]

It's one of the selection principles. We first select the bees that survive the winter, obviously.

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

Are the bee colonies produced in Canada more resistant in environments where there are pesticides, as is the case in Canada?

Are the second colonies better adapted than one colony from abroad that has never been in contact with a pesticide environment?

[Pierre Giovenazzo]

Good question. There's no work on phenotypic selection, or the selection of a characteristic in order to produce bees that tolerate pesticides. I've never seen this.

However, we've observed that it's very difficult to keep bees in a strongly agricultural region, such as Montérégie, and in a region where a great deal of corn is found.

I'm not necessarily saying that pesticides are the reason. The reason is a lack of flora biodiversity.

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

Is there a link—

[Pierre Giovenazzo]

The bee nutrition issue is significant.

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

Exactly. In these regions, wouldn't it be better to establish a program in which perennials could be planted in flower beds and flowers could be planted to try to increase the flora area?

In a region where agriculture is very concentrated and where 80% of the area is covered in crops, there's no space left for flowers, apart from the space around the houses in the villages.

[Pierre Giovenazzo]

That's currently a very active research field, not only in Canada, but also in the United States, where a great deal of work is being done on agricultural land development.

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

Weren't flower fields planted in Europe to help—

[Pierre Giovenazzo]

Yes, in fallows. It's developing slowly. The right plants must also be selected. They need to bloom at all times. Bees are constantly feeding themselves. It's not as simple as it seems. We're not just talking about planting flowers in flower beds. There must be a variety of flowers that blossom all season long so that bees can feed themselves. This is much more important for the natural pollinators. The agricultural bee or the domestic bee can be fed, like livestock. We have food for bees.

Personally, I'm working on probiotics for bees, an evolving field of research. We're trying to create food products for bees. The bee lives in an agricultural environment or in an area with little flora diversity.

[The Chair, Liberal, Pat Finnigan]

Thank you, Mr. Gourde.

Mr. Peschisolido, you have six minutes.

[Joe Peschisolido, Liberal, Steveston—Richmond East, BC]

Thank you.

I'd like to welcome the witnesses. Your presentations were very, very informative.

My first questions are for Mr. Giovenazzo. Did you find the review process useful? Did you have the chance to participate?

[Pierre Giovenazzo]

I didn't have the chance to participate. I'm not a toxicologist. I'm an apiculture researcher. However, I follow what's going on at the PMRA extremely closely. I think the PMRA is a government entity that works very well. It's made up of scientists who conduct analyses, but things aren't easy. The registration process takes into account one pesticide in particular. When the process takes place in a normal environment, there's no longer only one pesticide, but a variety of pesticides.

Let's talk about my bees, for example. When a new product is introduced, as will happen after the phase-out we're addressing, the PMRA will register the product based on its toxicity. They don't look at whether the bee is sick, at what happened at that time or at whether any other products are found in the environment. These considerations are not part of the PMRA's process. It would be far too much. It goes beyond the PMRA's mandate.

That's my concern. Independent researchers will again be required to work on this issue and to verify the impact of these new products entering the market.