Ontario Bee Health Working Group Report
Table of Contents
March 19, 2014
The Honourable Kathleen Wynne
As Chair of the Ontario Bee Health Working Group, I am pleased to deliver this report. We were tasked with the challenge to reduce the risks to honey bees from exposure to neonicotinoid seed treatments ahead of the spring planting in 2014. The Working Group accomplished this by identifying a range of options and then through individual and collective actions, implementing many of the options ahead of the Spring planting season.
The diverse members of the Working Group collaborated to identify and develop options for action to mitigate the risks from neonicotinoid treated corn and soybean seeds on bee health. Recognizing the complexity of the issue the Working Group generated a broad range of options to address various potential sources of risk to bees - from improving best management practices to regulatory restrictions on neonicotinoid use.
The options for action outlined in this document are accompanied by merits and considerations, as assessed by the members of the Working Group. These options were not critically evaluated within the Working Group against scientific principles. They are provided with the understanding that further development and systematic evaluation of the merits and implications of a number of options may be required prior to consideration for implementation. It is recognized that these options are not equivalent in terms of impact on either bee health or on the agricultural sector.
Working group members recognize that no single option may fully address the issue. Each option should be considered as a potential component of a suite of options available to mitigate risks to bees.
Recognizing the need to address the risks to bee health, both government and industry have moved quickly to implement many of the identified options. There was a shared sense of urgency among the Working Group members that enabled the rapid response. A table listing the current implementation status of each option is appended.
I would like to thank the members of the Bee Health Working Group for the considerable time and effort that they dedicated to the Working Group and for the respectful dialogue that took place through the identification and development of the options.
Deb Sikora Assistant Deputy Minister,
Acute bee mortality incidents have been linked to exposure to neonicotinoid insecticides in dust generated during planting of neonicotinoid treated corn and soybean seed (PMRA, 2012, 2013). In Ontario, beekeepers have reported bee mortality incidents in both 2012 and 2013. There have been significant concerns identified with potential acute and chronic impact of neonicotinoids on pollinator health.
Neonicotinoids are a group of systemic insecticides that are used in agriculture to protect crops from insect pests and have a range of application methods including soil and foliar applications and seed treatments. Alternative treatments such as organophosphate insecticides have been shown to have significant impact on non-target organisms, including humans when compared to neonicotinoid products.
In response to the reported bee mortality incidents, the Ontario Minister of Agriculture and Food established the Ontario Bee Health Working Group in July 2013 with the specific mandate to support the development and implementation of strategies to mitigate the risk to honey bees from exposure to neonicotinoid seed treatments on corn and soybeans. The thirty-three members of the Working Group represent the apiary sector, research institutions, grain growers, agri-business industry and government. The Working Group met throughout the summer and fall and identified a range of options to mitigate the risk to honey bees from neonicotinoid treated corn and soybean seeds.
Given the divergent opinions held by members on the issues associated with bee health and potential impact of neonicotinoid treated seeds, it was recognized that consensus would not be possible in all cases. All options that were identified are contained in the report, with considerations provided for each option. The thirteen options for action include improvements to growing practices and communications, environmental enhancements, technology advancements and training as well as regulatory approaches. Where consensus was reached, government and industry have collaborated extensively and taken action to implement those options.
Many of the options have already been implemented by government and industry partners as the need to reduce risks to honey bees from neonicotinoid seed treatments is recognized by all parties. Actions that have already been acted on include improvements and promotion of Best Management Practices, mandating the use of a new fluency agent and developing a bee yard/field identifier application. Further research and analysis will be required prior to implementation of a number of the identified options.
The members of the Bee Health Working Group came to a better understanding of the impact of this issue on the different stakeholders represented in the Working Group. The Working Group agreed that a multi-pronged approach to the issue offers the best opportunity to mitigate the risks to bees.
Acute bee mortality incidents have been linked to exposure to neonicotinoid insecticides in dust generated during planting of neonicotinoid treated corn and soybean seed (PMRA, 2012, 2013).
In 2012, over 50 beekeepers, representing more than 300 bee yard locations across Canada reported honey bee mortality incidents to the Pest Management Regulatory Agency (PMRA, 2013). Two hundred and forty of the impacted bee yards were located in Ontario. These incidents occurred during the spring planting of corn seed.
In the spring and summer of 2013, the PMRA continued to receive reports of honey bee mortality from beekeepers in corn and soybean growing areas of Ontario, Quebec and Manitoba. Ontario reported 319 incidents from 79 beekeepers. (See below for overall numbers of bee keepers and colonies).
The Canadian apiary sector also has concerns related to higher than average (over 15%) over-winter mortality rates that have been observed in the past decade. Overwintering losses in Ontario have fluctuated from a high of 43% in 2011 to 12% in 2012. Whether or not neonicotinoids contributed to this overwintering mortality has not been determined. Health concerns in managed bee populations are not unique to Ontario - similar problems have been facing beekeepers in other areas of the world including the United States and Europe.
Neonicotinoid insecticides have been linked to acute bee mortality incidents from exposure to drifting dust generated from corn and soybean seed planting (PMRA, 2012, 2013) and related primarily to the use of specific air planter systems. There is also concern with the potential chronic impacts on bee health from exposure to low levels of neonicotinoids in the general environment. Much attention has been paid to these issues by the media, and public sensitivity to the issue is high.
In Ontario, managed honey bee populations produce honey and also contribute to the pollination of many agricultural crops. There are approximately 3,000 registered beekeepers that manage an estimated 100,000 bee colonies in Ontario. Ontario honey bees are used for pollination services both here in Ontario and in other provinces.
High mortality rates are of concern to individual beekeeping operations and the apiary sector in general. Dead and/or weakened hives produce less honey, are less effective at pollination and are more susceptible to winter mortality. Although large bee die-offs have been observed in Ontario apiaries, they are not occurring uniformly across all operations or areas of the province - many beekeeping operations have not been affected and have been able to maintain strong and healthy bee colonies as evidenced by hive strength and honey production.
Neonicotinoids are a group of systemic insecticides that are used in agriculture to protect many crops from various insect pests. Imidacloprid, thiamethoxam, clothianidin, acetamiprid and thiacloprid are active ingredients from the neonicotinoid group that are registered for use in Canada. In Ontario, some of the first uses (1995) for these insecticides were for the control of Colorado potato beetle in potatoes and as a seed treatment for flea beetle protection in canola. Today, neonicotinoids are registered for use on most crop types and for various methods of application, including soil and foliar applications, seed treatments and tree injections. Earlier, alternative treatments such as organophosphate insecticides have been shown to have a significant impact on non-target organisms including humans when compared to the neonicotinoid products.
Over 95% of the corn acreage and between 55 and 60% of soybean acreage in Ontario is now planted with neonicotinoid-treated seed. Clothianidin (e.g., Poncho®) and thiamethoxam (e.g., Cruiser®) are common seed treatments used in corn and thiamethoxam (e.g., Cruiser Maxx®) and imidacloprid (e.g., Stress Shield 600®) are used in soybean to manage soil and early season above-ground insect pests. Neonicotinoids have become an important pest management tool in agriculture, including their use in Integrated Pest Management (IPM) programs, as they represent an effective means to control targeted insect pests during the crop production season. At this time, it is understood that there are no alternative pre-emergent seed treatments to replace the neonicotinoid seed treatments.
The Ontario Ministry of the Environment (MOE) administers the Ontario Pesticides Act - this legislation regulates the sale, use, transportation and disposal of pesticides in Ontario. The MOE is also responsible for the classification of pesticides in Ontario which determines who can use a certain pesticide and under what conditions. The MOE conducts an environmental monitoring program, testing surface water for a range of pesticides, including neonicotinoids from limited sites across the province.
The federal Pest Management Regulatory Agency (PMRA), within Health Canada administers the Pest Control Products Act (PCPA) and is responsible for the regulation of pest control products in Canada, including agricultural chemicals for use on particular crops. This is a rigorous and thorough process. The PMRA is currently evaluating reported incidents of bee mortality and has recently implemented regulatory measures to reduce the risk to bees from seed treatments. This includes the mandated use of fluency agent and new labelling requirements. The PMRA is also conducting a re-evaluation of the risks associated with all uses of neonicotinoids in Canada and has signalled its intent to review new scientific information as it becomes available and to take additional action as needed, at any time, to further protect health and the environment. The Ontario Ministry of Agriculture and Food has an apiary program which supports bee health through the administration of the Bees Act. This entails visual inspection of bee colonies for certain pests and diseases, e.g., Small Hive Beetle and American Foulbrood. The program provides information on hive management and pest identification and treatment recommendations. The Ministry works closely with industry partners to develop and promote the adoption of Best Management Practices for all aspects of crop production including those designed to minimize the risk of neonicotinoid seed treatments to pollinators during corn and soybean planting.
There are many factors that can impact bee health including: weather, nutrition, loss of habitat, exposure to pesticides, diseases and parasites (Pest Management Regulatory Agency, 2013). The international research community has been working to determine and characterize the impact of all of these factors, including neonicotinoid insecticides on bee health, for several years. The evidence from PMRA's analysis of the 2012 bee mortality incidents in Ontario found that the planting of corn seeds treated with neonicotinoids did contribute to bee mortality. Based on the incidents in 2012 and 2013, the PMRA concluded, "that the current agricultural practices related to the use of neonicotinoid treated corn and soybean seed are not sustainable."
For bees, there are different potential types of exposure to neonicotinoid insecticides from treated seeds: direct exposure to contaminated dust during planting, and exposure to product in the environment, such as in soil, pollen, nectar and water sources (e.g., presentation to the Bee Health Working Group by Dr. Valérie Fournier, December 2013).
Possible impacts of neonicotinoids on other organisms are beyond the scope of the Working Group's mandate, although it is acknowledged that if neonicotinoids affect honey bees they may also affect other pollinators, such as bumblebees, wasps, and butterflies.
The Ontario Bee Health Working Group was established by the Ontario Minister of Agriculture and Food in July 2013 with the specific mandate to support the development and implementation of strategies to mitigate the risk to honey bees from exposure to neonicotinoid seed treatments on corn and soybeans. Although neonicotinoid insecticides are used in other grain and oilseeds and many horticulture crops, the scope for this Working Group was limited to their use as seed treatments on corn and soybean seed, because of the demonstrated link to reported incidents of managed honey bee acute mortality in the apiculture sector in Ontario.
The Working Group is comprised of thirty-three members from government, research institutions and industry, including the following organizations:
The thirteen options being brought forward in this report were developed by the collective group through facilitated discussion. The Working Group did agree to a set of overarching success criteria (see appendix) that could be used to assess different options. It was also recognized that given the divergent opinions on the issues, consensus on support for options would not be possible in all cases. It was agreed that all proposed options would be referenced in the report. Voting did not take place on each option, but if there was general agreement for an option, this is noted in the discussion. Each option is meant to be considered as part of a suite of options available to mitigate risks to bees. Key merits and considerations of each option have been suggested by the members of the Working Group and are included in the report.
Implementation of many of the options has already been initiated where there was consensus across the Working Group, including early communications last fall related to access to non-insecticide treated seed.
To avoid any perceived influence on the option development process OMAF, MOE and PMRA working group members have not assessed the potential validity of any of the options. Further, the working group members were not asked to fully develop the individual options nor were the options subjected to scientific assessment within the Working Group. It was recognized that some options require further development and elaboration prior to consideration for implementation. All members were encouraged to identify options that they felt could contribute to mitigating the risk to honey bees.
Option A1 - Update Best Management Practices
The Working Group had the opportunity to review the Best Management Practices that had been developed by industry and government for growers to mitigate the risk to pollinators from exposure to neonicotinoids from seed treatments. It was agreed that additional work could be done in this area. The discussion led to the following option:
OMAF and PMRA, in partnership with researchers and affected agricultural stakeholders*:
Timing: Begin immediately and continue to update as needed.
Status: Several Best Management Practices for various production practices, including Integrated Pest Management (IPM), are already in place. The BMPs are being actively communicated by industry and government. Those related to IPM can reduce the need for insecticide use, including neonicotinoid seed treatment products. Practices will be updated to address the current known risks and efficacy of the recommended practices as new data and information becomes available.
As a separate outcome from the discussion of Best Management Practices, the Working Group identified the need to invest in additional research in support of IPM programs. The Ontario Ministry of Agriculture and Food was identified as having the primary role for developing IPM programs. The use of IPM assists growers to target pesticide treatments to their specific needs and utilizes a range of pest management tools including crop rotation, enhanced pest monitoring and non-pesticide applications. Specifically, the Working Group discussed the need for supplementary funding of research/studies on components of an Integrated Pest Management framework that may reduce the use of neonicotinoid seed treatments on corn and soybeans.
Timing: Begin immediately (with the recognition that research outcomes can be expected in a three to five-year timeframe).
Status: Research on Integrated Pest Management practices is one of the identified priority areas under the New Directions research program. Ministry funding is being directed to support the development of an IPM guide for the identification and management of soil borne insects.
The Working Group identified the need to proactively promote the availability of fungicide-only treated corn and soybean seed for 2014 on all top hybrid varieties by an immediate communiqué from OMAF, Grain Farmers of Ontario and the Canadian Seed Trade Association.
Timing: Ordering of corn and soybean seed is underway by October 1, 2013
Status: This option received broad support from the Working Group and was identified as a priority for action this past fall. Individual members actively promoted the availability of non-insecticide treated seed for the 2014 crop year. This was done through a range of communication vehicles including: media releases, articles, Ministry web site, partnership issued communiqué (OMAF, GFO, and CSTA), and staff outreach to growers. Seed companies offered an increased number of varieties of non-insecticide treated seed of the 2014 growing season.
Encourage private sector development of new technologies, through a government innovation fund, to develop seed treatments which minimize impact to bees.
The working group did not discuss what government partner would be best positioned to address this option nor estimate what level of investment would be required to support this identified need.
Timing: Begin Winter/Spring 2014
Status: The Ministry is aware of research in the area of new polymers which could potentially reduce the amount of neonicotinoids released during planting.
The Ministry of Agriculture and Food should encourage producers to use a crop rotation that reduces the need for neonicotinoid seed treatments.
Timing: Begin within six months and complete within 1 year.
Status: Crop rotation is currently part of standard BMPs that are provided to growers and is widely implemented across Ontario.
Use bee location data (with consideration of privacy/security issues) to build a single, reliable source to document the position of beeyards in Ontario. This will allow growers and custom applicators to make more informed planting and spraying decisions and mitigate the risks to bee colonies. It will also encourage improved communication between beekeepers and growers. Potential partners to develop an application to promote sharing of location would include the Ministry of Agriculture and Food, and grower and apiary organizations.
Timing: Begin work immediately to launch within a year (may require testing and further modifications)
Status: The Grain Farmers of Ontario is working with the Ontario Beekeepers' Association on the development of an application for beeyards and fields. Existing applications in use in other jurisdictions can be evaluated for their application to Ontario's needs.
Develop strategies for creating and maintaining pollinator-friendly habitats across the province.
A financial incentive program for landowners could be a component of the program to encourage the creation of pollinator friendly habitats.
Timing: Begin within one year (this option could be undertaken by a number of parties/organizations).
Status: There is an opportunity for government and industry, including the recently announced chair in pollinator conservation at the University of Guelph (December 2013), to work collaboratively on a pollinator health strategy.
Pursue research* and information gathering in partnership with equipment manufacturers and other stakeholders, toward the development and adoption of modifications for existing air planters to reduce or eliminate dust. This research could be undertaken by industry and/or government. Given most manufacturers are located outside of Ontario, this could be a multi-jurisdictional initiative.
Timing: Begin within 12 months
Status: Ministry staff are leading a collaborative effort with industry partners to increase access to air planter deflector modification kits available for growers prior to Spring (2014) planting.
Promote the development and manufacturing of air planters meeting
the International Organization for Standardization (ISO) standard
(being developed) for fugitive dust.
Timing: Begin within 6 - 12 months
Status: New ISO standards to better control fugitive dust are currently being developed by the Association of Equipment Manufacturers and are expected in 2015 for application by manufacturers in 2016.
Stakeholders continue to develop and enhance an education campaign to encourage suppliers, sellers and users to properly use the new fluency agent (currently being tested) for the 2014 planting season.
Timing: Within the next 6 months
Status: Already underway for the spring of 2014. PMRA is making use of the new fluency agent mandatory where a seed lubricant is being used (note that not all growers use a seed lubricant) and is currently working with the various stakeholders on specific implementation and labelling strategies.
The Ministry of Agriculture and Food should provide expertise and most current Best Management Practices for the Ontario Pesticide Safety Course and also distribute to course graduates. (Goal is to increase understanding of potential impacts on pollinators and mitigation strategies)
Timing: Complete by December 1, 2013
Status: This has been completed
Require grower consultation with crop consultants on appropriate rate for neonicotinoid-treated seed prior to purchase of insecticide treated seed.
Timing: Begin within 1 year
Status: Extension effort has been made to have certified crop advisors and the agricultural service industry aware of the recommended Best Management Practices.
A regulatory approach to mitigating the risk to honey bees was endorsed by some members of the Working Group. These members note that a temporary ban on the use of neonicotinoids is consistent with the precautionary approach to risk mitigation and with actions taken by several European jurisdictions. Specifically, it was felt that the Ontario government should consider banning neonicotinoid seed and foliar treatments on field crops of corn and soybeans until the Pest Management Regulatory Agency finalizes its re-evaluation. Other members identified significant impacts and risks associated with Ontario moving unilaterally to ban neonicotinoids.
Timing: Implement immediately so that it is in place for 2014.
Status: The Ontario government has indicated that any action will be guided by the best scientific data available when making recommendations to address bee health issues, and that it is looking to the PMRA, as the federal regulator of pesticides in Canada, to take a national approach to neonicotinoids. The Pest Management Regulatory Agency is expediting the re-evaluation of all uses of neonicotinoid insecticides and has implemented measures under its jurisdiction to protect pollinators until the review is complete.
The Working Group is committed to continuing to address this important issue through respectful dialogue and supportive actions. With an interest in positive bee health outcomes, it is our hope that the options for action presented in this report will serve to mitigate the risks to bees and other pollinators from the impact of neonicotinoid treated corn and soybean seed.
While consensus was not obtained on all the options outlined in this report, the members of the working group do share in the desire to reduce the impact on bees from neonicotinoid treated corn and soybean seeds. Members have come to a better understanding of the impact of this issue on the different stakeholders represented on the Working Group, and also to appreciate the complexity of addressing the situation.
The Working Group recognized that while there may be challenges to adopting all the options identified we are pleased to report that any options are already completed or well underway.
The Working Group anticipates that a multi-pronged approach to the issue offers the best opportunity to mitigate the risks to bees.
The working group will support the development and/or implementation of strategies to mitigate the risk to honey bees from exposure to neonicotinoid seed treatments on corn and soybeans, acknowledging that a crucial milestone is the 2014 planting season.
To achieve this objective, the working group will:
This group will be chaired by the Assistant Deputy Minister, Food Safety and Environment Division. The chair will be supported by a Secretariat from OMAF that will co-ordinate the agenda and organize meetings, develop and distribute minutes.
Decisions are made by discussion of the issues from multiple perspectives with an attempt to reach consensus. Given the positions of the different stakeholder groups a consensus may not always be possible on all issues; dissenting opinions may need to be recognized.
Based on Science
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