July 3, 2014
Hon. Rona Ambrose, Minister of Health
Brooke Claxton Building, Tunney's Pasture
Postal Location: 0906C
Ottawa, ON K1A 0K9
Dear Minister Ambrose:
On April 22, 2014, on behalf of farmers from across Canada the National Farmers Union (NFU) sent you a letter asking you as Minister of Health to work with the Minister of Agriculture and the Minister of the Environment, along with your provincial counterparts, to implement a five-year moratorium on the use of neonicotinoid seed treatments in field crops. We would like to acknowledge the response received on July 3 from Richard Aucoin, Ph.D., Executive Director PMRA.
The NFU's December, 2013 Submission to PMRA Regarding Notice of Intent NOI2013-01: Action to Protect Bees from Exposure to Neonicotinoid Pesticides was included with the April 22 letter. On May 1, 2014 the NFU appeared before the Senate Standing Committee on Agriculture and Forestry hearing on The Importance of Bees and Bee Health. In all three submissions, we noted that in September, 2013 the Pesticide Management Regulatory Agency (PMRA) "concluded that current agricultural practices related to the use of neonicotinoid treated corn and soybean seed are not sustainable." In all three submissions, we also called on government and regulatory agencies to act in the interest of the Canadian public, in particular, in both the submission to PMRA and to the Senate Standing Committee we called for the use of precautionary principle in relation to the use of neonicotinoids in Canada.
In his response, Mr. Aucoin says that PMRA "will closely monitor scientific information and other developments related to the potential impacts of pest control products on pollinators, not only in Canada … but also in Europe". As such, we assume that Health Canada and PMRA are carefully analyzing the findings and recommendations released on June 24, 2014 by the Task Force on Systemic Pesticides – a group of global independent scientists. Their full analysis is being published in the peer reviewed Journal Environment Science and Pollution Research.
As with PMRA, one of the conclusions of the Task Force is that "the present scale of use of neonics is not sustainable." However, the approach recommended by the authors of the Task Force report is very different from the risk-management approach Health Canada through PMRA has taken in regulating the continued use of neonicotinoids. The Task Force "strongly suggests that regulatory agencies apply more precautionary principles and further tighten regulations on neonicotinoids … and start planning for a global phase-out or at least start formulating plans for a strong reduction in the global scale of use."
The National Farmers Union has already called on Canadian regulatory agencies to act in the public interest by invoking the precautionary principle in relation to neonicotinoids. The steps outlined in our April 24 letter and in our submission to the Senate Standing Committee provide the basis for a managed phase-out and strong reduction of use of neonicotinoids as seed treatment in field crops.
Once again, we are asking you as Minister of Health to work with the Minister of Agriculture, the Minister of the Environment and your provincial counterparts to take the steps necessary to phase-out and reduce the use of neonicotinoids in Canada, starting with a five-year moratorium on the use of neonicotinoid seed treatments in field crops in Ontario and Quebec while allowing farmers to apply for one-time use applications if they can demonstrate the need for the seed treatment.
We also once again call on the Canadian and provincial governments and regulatory agencies to act in the public interest by protecting bees, other pollinators, the farmers whose livelihoods rely on pollinators, and Canada's food sovereignty. In order to act in the interest of the public, governments and regulatory agencies must give serious and full consideration to research carried out by independent scientists, such as the Task Force on Systemic Pesticides, not just on the information and data provided by chemical and seed companies. And in order to fully understand the impact of neonicotinoids on Canada's agricultural and natural ecosystems, public funding must be provided to independent Canadian scientists to undertake research in the public interest.
[original signed by:]
cc: Hon. Jeff Leal, Minister of Agriculture and Rural Affairs
cc: Hon. Glen Murray, Minister of Environment and Climate Change
cc: Hon. Eric Hoskins, Minister of Health and Long-Term Care
cc: Premier Kathleen Wynne
cc: Hon. Pierre Paradis, Quebec Minister of Agriculture, Fisheries & Food
cc: Hon. Gaétan Barrette, Quebec Minister of Health
cc: Hon. David Heurtel, Quebec Minister of Sustainable Development, Environment and the Fight
against Climate Change