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Agriculture committee  Most of our models are specific to predicting concentrations in water bodies, and those models have been developed in concert with the U.S. EPA. Over the course of the years, these models have been refined. There's been what they call science advisory panels that have been held to validate some of those models, and they are models that are being used jointly.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  We haven't entered those discussions yet in terms of the potential impact of whatever alternatives are being proposed. However, I committed at the multi-stakeholder forum that once we identify alternatives, especially in light of the concern from beekeepers about the impact those pesticides might have, we would work with them to help them decide which ones were more bee friendly.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  If I understand your question correctly, the answer would be no. The PMRA has no research and monitoring mandate, so we don't actually do any testing. That's either left to the registrants, if we require data from them, or it can be generated through some of the departments that do have a research mandate, such as Agriculture Canada, Environment Canada—

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  We came to that conclusion based on our scientific assessment. We had over a hundred studies submitted by the registrants. We looked at over 200 studies by academics that were in the open literature. We also reviewed the regulatory decisions of the EPA, FSA, FDA, and the Department of Agriculture in the U.S.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  The Morrissey data is not pivotal to the imidacloprid decision in indicating risk at this time. The more pivotal pieces of information are from Ontario and Quebec. The Morrissey data comes largely from areas where the other two neonics are used more extensively—that would be thiamethoxam and clothianidin—and that information will figure in our special reviews of those two chemicals.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  If the science says that they should be treated differently, they will be. With respect to imidacloprid, in Morrissey's study the issue is to what extent imidacloprid was used in that area. If there's not a lot of use, you don't expect to see a lot of detects and lot of high concentration.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  Right now the special reviews are ongoing. We're considering all the available information. At this stage I'm not ready to pronounce as to whether or not the risks are acceptable or not. I will say that we are meeting monthly with the multi-stakeholder forum, and we're updating them on the progress of our special reviews.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  I would just add that there was information submitted from most of the regions, including the west. Some of it was Environment Canada data, some of it was provincial data, and some of it was academic data from Dr. Morrissey. As I said, a lot of that data is missing some of that ancillary information that would make it useful.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  I would say that agricultural producers have to make decisions based on the pests that they have, and they make them, so I can't really speak to whether or not they're overusing them.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  We have no real-world data in terms of impacts actually in the environment. We virtually never do. That's not something we normally receive. The information that we have is what we're basing our assessment on. I just want to make sure we understand that the onus is on the registrant to provide us with the information to demonstrate that the risks are acceptable.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  I'd just like to make it clear that the decision was not political. The decision was driven by science. That's how we make our decisions. As Mr. Aucoin pointed out with the pollinator assessments, there was a lot of pressure to deregister the chemical based on the impacts on pollinators.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  With respect to the water monitoring data, all the water monitoring data was considered. We received quite an extensive amount from across the country, more than we would normally have for a normal re-evaluation. Much of the information was lacking what we call ancillary data, which is data about where the site was, what was cropped around it, and whether the pesticide was used in those areas, so that information is of limited use in making a risk assessment decision.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  Absolutely, because—

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  The thresholds are set based on the available data. Over the course of time, since imidacloprid has been registered, there have been many toxicity studies conducted that feed the information to develop thresholds. The more, what we call, “toxicity end points” you have, the more they feed into the development of thresholds.

March 7th, 2017Committee meeting

Scott Kirby

Agriculture committee  Sorry...?

March 7th, 2017Committee meeting

Scott Kirby