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.