November 3, 2014
Pesticide Management Regulatory Agency Publications Section
Pesticide Management Regulatory Agency (PMRA)
Health Canada
2720 Riverside Drive
Ottawa, ON
K1A 0K9
Address Locator: 6604-E2
email: PMRA.publications@hc-sc.gc.ca
To the Pesticide Management Regulatory Agency:
Re: Proposed Registration Decision PRD2014 – 20, Flupyradifurone
The National Farmers Union (NFU) welcomes this opportunity to comment on the proposed registration of Flupyradifurone.
From the information provided by PMRA in relation to this consultation, we note that Flupyradifurone is similar to the neonicotinoid class of insecticides in that it attacks the nervous system of insects, it is a systemic pesticide and it is persistent in the environment. We also note that while neonicotinoids are toxic on contact as well as if ingested, Flupyradifurone is acutely toxic only if ingested.
According to PMRA, Flupyradifurone poses a risk to non-target beneficial insects, such as bees, and aquatic invertebrates when it is used as a foliar spray. When used as a seed treatment it poses a risk to birds and small mammals. Since it is toxic to a wide variety of insect pests, it will therefore, be toxic to a wide variety of non-target insect species including beneficial insects and insects that are an important component of natural ecosystems in agricultural areas.
The National Farmers Union has consistently called on the Health Canada and the PMRA to use the precautionary principle in regard to the evaluation and regulation of pesticides such as neonicotinoids. As Flupyradifurone is similar to neonicotinoids in many aspects, including its toxicity to beneficial insects,its systemic natureand its persistence in the environment, we again call upon you to use the precautionary principle in considering the registration of Flupyradifurone.
In May, 2014 the NFU made a presentation to the Senate Standing Committee on Agriculture and Forestry during their study of The Importance of Bees and Bee Health. Two of our recommendations were:
- Assess and implement integrated pest management (IPM) programs which are run in the public interest for the public good and designed to benefit farmers and both natural and agricultural ecosystems;
- In the public interest, research and widely promote alternative and ecological farming practices which do not depend on the use of chemical pesticides.
If registeration of Flupyradifurone is permitted, this would continue Health Canada’s tendency to support an agricultural system based on the use of chemical pesticides. At a time when there are serious questions about the use of neonicotinoids as a seed treatment for soybeans, PMRAappears to beprepared to register a similar pesticide for use as a seed treatment in soybeans. The registration of new pesticides does not provide support for farmers to implement integrated pest management (IPM) on their farms, and thus decrease the use of chemical insecticides.
The BY1 02960 480 FS formulation of Flupyradifurone would be registered to use as a seed treatment in soybeans to control aphids and bean leaf beetle. The Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) says that seed treatments are only an effective control for aphids in the very early vegetative stages of soybean growth – a time when aphids are rarely an issue in Ontario. They also say that entomologists in North America recommend controlling soybean aphids with foliar insecticides, but only when a threshold is reached, i.e. through an IPM monitoring program. Additionally, OMAFRA indicates that bean leaf beetles are only a potential issue in the five most southern counties of Ontario and even then, only in some fields.[1]
Instead of registering Flupyradiruone at this time,the NFU recommends that thePMRA:
- Complete its evaluation of neonicotinoid seed treatments.
- Support a move to IPM by researching and making available information on:
- pest control options that do not involve chemical pesticides;
- thresholds when pests should be controlled by chemical pesticides or other means; and
- when various pesticides are most likely to be effective (ie what seasons, what stage of crop growth crop).
- Regulate according to the precautionary principle rather than risk management.
Bees and native pollinators are an essential element of our agricultural ecosystems – without their contribution most fruits and vegetables cannot be grown. The stress, both acute and chronic, faced by bees and native pollinators has already been documented across the globe. The role of insecticides, including neonicotinoids, in the decline of essential insect species has also been identified by scientists around the world. This is a critical time to protect the health of our natural, agricultural ecosystems and to use the precautionary principle in making decisions to register new insecticides, including Flupyradifurone.
Respectfully submitted by
National Farmers UnionNovember 3, 2014
[1] http://www.omafra.gov.on.ca/english/crops/soybean-pest-assess.htm, accessed November 2, 2014
