I'm itching to answer this question. The precautionary principle only applies as a matter of law where a certain threshold is reached. This is codified in numerous international conventions. It's where there's a risk of serious irreparable harm; it's not every single time if every scrap of data isn't there or we can't act. In the context of neonics and admitted critical data gaps about toxicity impacts on bees, we would say that threshold was reached.
I also wanted to make one point of distinction between our views and those of the Sierra Club on the precautionary principle. Maybe it's a point that only an environmental litigator would love, but in our view, the agency is already legally required to make its registration decisions consistent with the precautionary principle. We say that's the case as a result of the Supreme Court of Canada's decision in the Hudson and Spraytech case a decade ago.
While we don't disagree that maybe including an umbrella reference to the precautionary principle in the act would be appropriate, we would view that simply as a codification of the existing state of affairs.