Thank you for the generous question.
We put forward a number of recommendations in the context of Health Canada's consultations last year on the targeted review of the act. I'd highlight three that are particularly relevant for this topic. Maybe I'll go to four.
One is to revise the requirements under the act for cumulative risk assessment. Currently, it's scoped very narrowly and requires a cumulative risk assessment only in the case of risk to human health.
When the PMRA assessed risks to pollinators from neonics, they were assessed independently, without any review of their cumulative effects on bee health or other pollinators, even though the science is well-established that they have both aggregate and synergistic effects.
I wanted to highlight our recommendation to regulate treated seeds under the Pest Control Products Act as pesticides. Outside Quebec, this is where we see a widespread use of neonics. Therefore, it is an important factor in environmental levels of the pesticide.
I want to mention that in Quebec, new restrictions were put in place by the provincial government that require an agronomist to certify a need for treated seeds for neonics in general. However, with respect to treated seeds, this has resulted in an almost complete reduction of the use of treated corn and soy seeds, which demonstrates the lack of necessity of these products that are nevertheless being used prophylactically and harming the environment.
Finally, require an assessment of species at risk, including the threatened bee species and their habitats, specifically within the assessments of pesticides.
If I can add on to the fourth, it would be for a full implementation of the new target seven, under the global biodiversity framework, under which Canada has committed to reducing pesticide risks by 50%.