ontario’s proposal to enhance pollinator health -...

Ontario’s Proposal to Enhance Pollinator Health

April 18, 2015

Photo credit: www.pollinator.ca1

Introduction

• The Ontario government is concerned about declining pollinator numbers. This includes both managed bees and wild pollinators.

• The province has stated regarding the use of neonicotinoid‐insecticide treated seeds that the “long‐term sustainability of Ontario’s food system and productivity of the natural environment may be affected” (OMECC, 2015).

• This presentation focuses primarily on Ontario’s efforts to enhance pollinator health through a reduction in use of neonicotinoid‐treated corn and soybean seed.

OMECC. 2015. Pollinator Health Regulatory Discussion hosted by OMECC on April 2, 2015.

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Topics to be covered today

• Introduction • Some facts about honey bees• Pests registered for control by neonicotinoid insecticides (“neonics”)• Re‐evaluation of neonicotinoids in Canada and the USA• Ontario’s proposal on enhancing pollinator health from November 2014• OIA’s comments on this proposal• Proposed regulatory amendments to Ontario Regulation 63/09 under the Pesticides Act from March 2015• Conclusions and questions

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The value of honey bees to agriculture• Unlike other pollinators, honey bees live in colonies and can be reared as livestock.

• They produce honey, wax, propolis, royal jelly.• Orchard fruits, berries, vegetables and oilseeds depend on honey bees and other wild pollinators for pollination.

• Hives can be transported across the country to provide pollination services for various crops.

Photo credit: www.pollinator.ca 4

Crops requiring insect pollination

• Tree fruits: apples, apricots, cherries, peaches, pears, prunes• Berries: grapes, blueberries, raspberries, strawberries, cranberries

• Cucurbits: cucumbers, melons, pumpkin, squash• Oilseeds: canola, soybeans, sunflower, mustard seed• Seed production: alfalfa, canola

Data source: Agriculture and Agri‐Food Canada

Photo credit: www.pollinator.ca

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Source: CANSIM Table 001‐0007 6

0%1%0% 5%

10%

17%

20%

42%

5%

PE

NS

NB

QC

ON

MB

SK

AB

BC

Honey Production by Province 2014

Source: CANSIM Table 001‐0007

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Bees are susceptible to many threats

• Varroa mites and tracheal mites• Bacterial, fungal and viral diseases• Loss of habitat /nutrition• Weather• Pesticides• Genetics

Photo credit: Canadian Association of Professional Apiculturists

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CAPA winter mortality survey• Conducted annually since 2007• Each province administers survey• Results are tabulated to permit comparisons and evaluation of trends

• Provinces have option to ask additional questions• Ontario recorded 58% mortality following winter of 2013‐2014

Ontario winter mortality survey• Ontario beekeepers felt mortality was due to starvation, weather, chronic pesticide exposure, poor queens, unknown, weak colonies, acute pesticide exposure, other, nosema, ineffective Varroa control.

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Neonicotinoids – in Canada

• These are systemic insecticides (i.e., they move in the vascular systems of plants) which include imidacloprid (Gaucho, Stress Shield), thiamethoxam (Cruiser), clothianidin (Poncho).

• Seed treatment uses of neonicotinoids were registered as replacements for lindane primarily in late 1990s to early 2000s.

• Registered on corn for control of:o Corn rootworm, European chafer (a white grub), wireworms, seedcorn maggot, black cutworm, corn flea beetle

• Registered on soybean for control of:o Seedcorn maggot, soybean aphid, bean leaf beetle, wireworm

• Neonicotinoids not as effective as lindane vs. wireworms.• Neonicotinoids are safer to humans, other mammals, and birds, than the other insecticides they replaced including organochlorines such as lindane and the organophosphates and carbamates.

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White grubs

WirewormSeedcorn maggot

Photos courtesy T Baute. Image credits: WG ‐ Anonymous, WW ‐ T. Baute, SCM ‐ T. Cowans 11

Northern corn rootworm Western corn rootworm

Photo credits: T. Baute, OMAFRA

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Sandy knolls high risk area for white grubs in soybeans Photo courtesy T. Baute. Image credit: T. Cowans

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Corn field missing plants due to wirewormsPhoto credit: T. Baute

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Canada and USA – timetable for re‐evaluation of neonicotinoids

• Clothianidin, imidacloprid and thiamethoxam are under re‐evaluation in both countries.

• In Canada, Pest Management Regulatory Agency (PMRA) has published several updates and has committed to produce an interim report in 2015. This is to be followed by public consultation and subsequent report (possibly in 2017).

• PMRA acknowledges the need for further research on all of the factors that affect bee health.

• PMRA is working with federal and provincial partners, international regulatory agencies and other partners to assess the emerging body of scientific evidence regarding neonicotinoid insecticides and pollinators.

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Canada and USA – timetable for re‐evaluation (cont’d)

• United States Environmental Protection Agency (US EPA) began the registration review (i.e., re‐evaluation) of imidacloprid in 2009 and of remaining neonicotinoids by 2012.

• US EPA, among other refinements to ecological risk assessment, are considering potential effects of neonicotinoids on honey bees and other pollinating insects.

• Target is to complete US reviews of imidacloprid, clothianidin and thiamethoxam between 2016 and 2018, and of remaining neonicotinoids by 2019.

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Joint responsibility for pesticide regulation in Canada

• Pesticide regulation is the joint responsibility of federal and provincial governments:

oPMRA registers pesticides, and oProvincial governments classify pesticides and regulate their sale, use, transportation, storage and disposal.

• In Ontario, pesticides are classified under the Pesticides Act. Classification determines who can sell or use a pesticide and what restrictions are in place relating to its use.

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Ontario Pollinator Health

• Ontario plans to put in place an overall strategy for enhancing pollinator health.

• A discussion paper released on November 25, 2014 outlines the key elements for consideration in developing the proposed Pollinator Health Action Plan:

oBackground on pollinator health,o Taking immediate action to protect pollinators,oDeveloping a pollinator health action plan, ando Exploring the four stressors:loss of habitat and nutrition, pesticide exposure,climate change and weather, anddisease, pests and genetics.

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Ontario – November 2014 proposal for regulation of use of neonicotinoid seed treatments

• Ontario announced a two month consultation period beginning on November 25, 2014 on a proposal to reduce the use of neonicotinoid insecticide seed treatments on field corn and soybeans by an “aspirational” amount of 80% by 2017.

• Ontario proposed the requirement that neonicotinoid‐treated seed be used only on fields where it is truly needed. A new pesticide class, Class 12, would be created to regulate neonicotinoid‐treated seeds as a pesticide under the Pesticides Act.

• All of the current 11 classes are pesticides.• Ontario currently grows about 2.5 million acres of each of corn and soybeans each year.

• Nearly 100% of corn seed and about 60% of soybean seed planted in Ontario are currently treated with neonicotinoids.

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Ontario – November 2014 proposal for regulation of use of neonicotinoid seed treatments (cont’d)

• Ontario’s proposal is a response to the high winter mortality of honey bees and deaths during summer and fall observed in Ontario. This is attributed largely to exposure to contaminated dust generated during the planting of neonicotinoid‐treated corn and soybean seed.

• Ontario’s precautionary approach cites:oA recent review of 800 peer‐reviewed scientific papers by the International Union for Conservation of Nature (IUCN) Task Force on Systemic Insecticides,

oUS EPA’s conclusion that seed treatments provide negligible benefits to soybean production in most situations, and

oPMRA’s evaluation of reports of bee deaths and attribution of the majority of these to neonicotinoid use in corn‐growing regions of Ontario and Quebec in spring of 2012.

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Summary of OIA comments on Ontario’s proposal of November 2014

• The science pertaining to the impact of the use of neonicotinoid seed treatments on pollinators continues to be developed.

• There are uncertainties related to the information on which the proposed regulatory approach to their use is based.

• Risk and value assessments have not been completed by the PMRA, US EPA, and CalDPR.

• Further research is needed on value and how to accurately assess the potential for insect damage to occur.

• Western Canada, where virtually all of the approximately 20 million acres of canola planted annually is treated with a neonicotinoid insecticide seed treatment for the control of flea beetles, is not reporting bee losses to anything like the extent found in Ontario. Why is this so?

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Summary of OIA comments on Ontario proposal of November 25, 2014 (cont’d)

• We encourage that an economic evaluation of the impact of the proposed regulation be done. Ontario should assess the cost of this program so as to ensure the continuing competitiveness of Ontario's agricultural sector in comparison with other jurisdictions that do not adopt similar practices.

• We note that efforts are already being made by the farm community to reduce application rates as well as dusting‐off from corn and soybean seed at planting.

• If Ontario proceeds with the proposed regulation, we strongly encourage explicit acceptance that it is an interim measure until the science is more definitive, or five years have passed, whichever comes first.

• We encourage acceptance of the need for continued flexibility in updating this regulation.

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Regulatory amendments to Ontario Regulation 63/09 under Pesticides Act to reduce use of neonicotinoid insecticides• A draft regulation was released on March 23, 2015 along with a pollinator health action plan and regulatory discussion.

• There is a 45‐day comment period (i.e., until May 7, 2015).• This supports creation of a new Class 12 pesticide for corn and soybean seed that has been treated with imidacloprid, thiamethoxam or clothianidin.

• This regulation does not currently apply to seed of other crop species or to other insecticides.

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Proposed new requirements for the sale of treated seed

• Seed company vendors:oVendors must obtain a new Treated Seed Vendor License to sell Class 12 pesticides.

oVendors must disclose whether treated corn and soybeans are Class 12 pesticides and make seed not treated with neonicotinoids available for sale. The seed can still be treated with fungicides.

oVendors must confirm customers are trained in Integrated Pest Management (IPM).

oSales must be reported to the Ontario Ministry of the Environment and Climate Change (OMECC).

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Proposed new Requirements for the sale of treated seed (cont’d)

• Seed Sales Representatives must:o Undergo training provided by treated seed vendors and carry company identification.

o Provide to the vendor copies of documentation required to be provided by purchasers of Class 12 pesticides.

o Keep copies of the written and IPM declarations and pest assessment reports for at least 4 years.

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Proposed new requirements for the use of treated seed

• Target is 80% reduction in acres planted with neonicotinoid‐treated corn and soybean seed by 2017.

• Farmers are provided with training on pest ID and IPM methods.

• Reduced use of neonicotinoids is encouraged in 2016 planting season.

• Purchaser must demonstrate proven pest infestation or crop damage due to specified pests in order to purchase treated seed.

• Users of neonicotinoid‐treated seeds must plant them in such as manner as to reduce impact on pollinators.

• Sale of treated seed must be tracked.

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Proposed new requirements for the use of treated seed

• Integrated Pest Management (IPM) Training:o In order be allowed to plant Class 12 pesticides, a person must complete a course on their use.

oTraining will be available beginning in fall of 2015; certification will be good for five years. It will include: the importance and protection of pollinators in the ecosystem,components of IPM such as pest ID and scouting, and alternatives to pesticides, andan overview of the requirements of the regulation relating to the purchase and use of Class 12 pesticides.

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Proposed new requirements for the use of treated seed (cont’d)

• Voluntary Reduction Approach to Phasing‐in Reduced Usage:o Class 12 pesticides can be used on up to 50% of land that will be planted to corn and soybeans in 2016.

o A written declaration must be provided that the farmer will not purchase more that the maximum quantity of seed allowed.

o A pest assessment would not be required in 2016.

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• Pest Assessment:oThis is required after 2016 growing season prior to purchase of a Class 12 pesticide for planting in 2017 and future years.

oThere are two approaches to doing assessments:Soil Pest Scouting Assessment: dig holes and sample to confirm presence of grubs or wireworms in soil, or bury bags of wet flour/grain/potatoes as a bait to attract wireworms must be completed by a professional pest advisor every 3 years (an IPM‐trained farmer can do this in the other 2 years out of 3).

Crop Damage Assessment: confirms damage to:

• corn from grubs, wireworms, seedcorn maggot and corn rootworm, or

• soybeans from grubs, wireworms and seedcorn maggot. there must be at least a 15% stand loss in corn or a 30% stand loss in soybeans in affected vs. unaffected areas.

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• Pest assessment:oMust be done by a: Certified Crop Advisor (CCA), Certified Professional Agronomist (CPAg), member of the Ontario Institute of Agrologists (OIA), ora person that OMECC deems to have equivalent qualifications.

oThis person cannot derive financial benefit from manufacturing or selling a Class 12 pesticide.

oA signed report is required in order to purchase and use a Class 12 pesticide.

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Pest Assessment Reports include

• Location and acreage of farm unit, • Confirmation that Pest Assessment Guideline was followed and pest detected in numbers equal or greater than threshold in guideline,

• ID and number of pests, and a sketch showing locations where found, and

• Date of inspection, name of person performing inspection, pest assessment method used, location where Class 12 pesticide is intended for use.

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Use of Class 12 pesticide

• User must read and follow instructions on seed tag, for example:

o Minimize dust emission,o Use a dust‐reducing fluency agent if a seed flow lubricant is being used, and

o Avoid doing equipment maintenance in areas that may affect bee colonies or where bees are foraging.

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Conclusions

• In our presentation we have identified a number of factors that influence bee health and mortality. Of these, Ontario has for now focussed on regulation of neonicotinoid‐treated seed.

• We note that much work continues by farmers, industry, researchers and regulators in determining the influence of neonicotinoid‐treated seed on pollinators.

• Successful beekeeping and sustainable agricultural production will depend on continued attention to all factors affecting bee health and co‐operation by stakeholders.

• OIA is drafting comments on the proposed Regulatory Amendments to Ontario Regulation 63/09 under the Pesticides Act.

• Please send your comments to Ontario Pollinator Health. If you wish them included in a generic response from OIA please send them to [email protected] .

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Acknowledgements

We wish to thank Tracy Baute and her colleagues for providing some of the images used in this presentation.


Questions?

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The following are background slides (in case of need)


History of previous seed treatments containing lindane in North America

• Lindane is a broad spectrum organochlorine insecticide in use since the 1940s.

• US EPA began restricting its use in the 1970s.• Special review begun by Canada’s Pest Management Regulatory Agency (PMRA) in 1999.

• PMRA determined risks to human health and the environment did not meet current standards and could not be mitigated to render them acceptable.

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History of previous seed treatments containing lindane in N.A.(cont’d)

• Exposure to humans can occur through diet (food and water) and when treating or handling seeds; maximum personal protection equipment and engineering controls insufficient to mitigate risks to workers.

• Persistent in soil and water and can contaminate groundwater.

• Released as a gas from the soil; subject to atmospheric transport far from primary area of use to areas such as the Great Lakes region and the Canadian Arctic where it is deposited by the process of condensation.

• Bioconcentrates and bioaccumulates in wildlife, and biomagnifies in some animals.

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Neonicotinoids – concerns regarding bees abroad

• Early 2000s – imidacloprid use on sunflowers in France associated with losses of honeybee colonies. Losses continued despite restrictions on use of imidacloprid. Losses likely due to Varoa mites.

• In 2008 sudden losses of honey bee colonies observed in Germany, Italy and Slovenia linked to use of clothianidin on corn seed. Dust from planting with air seeders was blowing onto nearby oilseed rape on which bees were foraging, resulting in their deaths.

• Recent laboratory studies have shown subtle non‐lethal effects of neonicotinoids on bees including shortened lives, impaired memory, homing and foraging behaviour, reduced body size and numbers of new males and queens.

• It is not yet clear whether these subtle effects are also being seen in the field.

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Europe – regulatory situation• In 2013, the European Food Safety Authority (EFSA) identified “high acute risks” for bees from exposure to dust from treated seed in several crops such as corn, cereals and sunflowers, to residues in pollen and nectar in crops like oilseed rape and sunflower, and to guttation in corn.

• The European Commission (EC) restricted use of clothianidin, imidacloprid and thiamethoxam for seed treatment, soil application (granules) and foliar treatment on bee attractive plants and cereals for two years beginning Dec 1, 2013.

• The EC continues to review conditions of approval of these three neonicotinoid insecticides taking into account relevant scientific and technical developments.

• The EFSA report does not address risk management.• The EFSA also stated in 2013 that two neonicotinoids, acetamiprid and imidacloprid, may affect the developing human nervous system and has proposed changes to several toxicological reference values for these active ingredients.

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Neonicotinoids – advantages and other uses

• Safer to humans than organochlorines, organophosphates and carbamates.

• At the time they were registered, considered safer to the environment compared to alternatives, due to their targeted toxicity to insects, lower toxicity to other non‐target organisms, and low use rates.

• Have systemic activity.• Neonicotinoids are registered as seed treatments, and for foliar and soil applications, to a wide range of field crops, fruits, vegetables, greenhouse crops, turf, as a tree injection, in structures, outdoor residential areas, and in pet care products.

• Neonicotinoids have the disadvantages of long half‐lives in soil and water, and high water solubility.

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