Ontario Bee Health Working Group Report

Table of Contents


Letter to Minister

March 19, 2014

The Honourable Kathleen Wynne
Minister of Agriculture and Food

Dear Minister:

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,
Food Safety and Environment Division Chair,
Ontario Bee Health Working Group


Executive Summary

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.


Introduction

The Problem

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.

Honey Bees in Ontario

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

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.

Partner Roles

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.

Bee Health

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).

Other Pollinators

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

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:

  • Association of Equipment Manufacturers (AEM)
  • Bayer CropScience Canada
  • Canadian Pollination Initiative
  • Canadian Seed Trade Association (CSTA)
  • CropLife Canada
  • Grain Farmers of Ontario (GFO)
  • Ontario Beekeepers' Association (OBA)
  • Ontario Federation of Agriculture (OFA)
  • University of Guelph (U of G)
  • Syngenta Canada Inc.
  • Ontario Ministry of Agriculture and Food (OMAF)
  • Ontario Ministry of the Environment (MOE)
  • Pest Management Regulatory Agency (Health Canada) (PMRA)

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.


Proposed Options for Action

Improvements to Growing Practices

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*:

  • Assess demonstrated efficacy of specific Best Management Practices (BMPs)
  • Identify gaps and required improvements to BMPs
  • Develop as a priority, dust mitigation Best Management Practices for January 2014
  • Support continuing research and extension to improve Best Management Practices for grain growers and beekeepers
  • Consider each Best Management Practice to be a "living document" and subject to further amendments based on new information.

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1Options have a letter designation as developed by the Bee Health Working Group. The options have been grouped by the type of activity.

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*stakeholders include: Ontario Federation of Agriculture, Grain Farmers of Ontario, CropLife, Ontario Beekeepers' Association, Canadian Seed Trade Association, other agencies

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.

Merits:

  • Infrastructure to disseminate best management practices is in place within OMAF.
  • Potential for success in protecting all non-target insects, not just honey bees.
  • May result in improved relationships and communication between stakeholders.
  • Would allow science and new information to be incorporated on an ongoing basis.

Considerations:

  • Funding and additional research is required to strengthen existing best management practices.
  • Would require a significant education program for farmers and beekeepers on best management practices.
  • Would rely on voluntary adoption of best management practices by farmers and beekeepers.
  • Farmers and beekeepers may incur costs when implementing new best management practices.
  • Best management practices are not likely to completely mitigate the risk to honey bees from neonicotinoids.
  • Moving away from seed treatments through an IPM recommendation could result in the need for foliar insecticide applications where insect populations exceed damage thresholds. This could pose risks to both pollinators as well as beneficial insects that control other pests in the target crop.
Option B - Invest in Integrated Pest Management (IPM) Research

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.

Merits:

  • Reduced use of neonicotinoid-treated seed.
  • Improving grower decision-making for use of pesticides.
  • Improving agricultural production as a whole.
  • Reduce pest resistance issues.
  • Better knowledge of pest pressures to support the use of non-insecticide treated seeds.
  • Opportunity to market crops that are produced using integrated pest management.

Considerations:

  • Research and education takes time - can take years to lead to improved practices.
  • Can be complex to implement integrated pest management practices.
  • Given the use of neonicotinoids is inexpensive and protects against potential yield loss due to pest pressures:
    • Adoption of improved management practices may be low.
    • Growers may be risk averse and wary of adopting IPM given limited alternatives for identified pest threats.
Option C - Promote Availability of Non-Insecticide Treated Seed

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.

Merits:

  • Increased awareness of options for fungicide-only or untreated seed for growers.
  • Potential to increase the number of varieties of non-insecticide treated seed made available to growers.
  • Supports IPM practices where applicable.

Considerations:

  • May not result in the planting of untreated seed.
  • Not all varieties of seeds will be available as non-insecticide treated.
  • Logistical challenges for seed companies to provide untreated seed.
  • Increased costs for seed companies to provide untreated seed.
  • Potential impact on yield and also on grain quality - risk to be borne by farmer.
  • Less flexibility for farmer to change varieties used at planting time, especially if returns to seed companies are restricted.
  • Replant costs may not be fully covered in the event of insect related issues where fungicide-only or untreated seed is used.
  • Use of other insecticide products later in the season may increase when untreated seeds are used; remedial action such as foliar sprays may be needed with potential non-target effects.
  • Growers need education and integrated pest management tools such as advanced field scouting to support their buying intention.
  • Non-insecticide treated seeds could be made the default option when ordering seeds
Option D - Encourage Development of New Seed Treatments

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.

Merits:

  • Additional seed treatment options improve pest resistance management by enabling farmers to rotate use of chemical families.
  • Potential to reduce environmental impacts.
  • Supports / contributes to IPM through the availability of additional tools.

Considerations:

  • Development of seed treatments is long term; 7 to 10-year time frame.
  • Costly to develop and relative efficacy cannot be predicted without long term research investment.
  • Registration of new products requires extensive process, including regulatory submissions.
  • Requires the continuation of a transparent and predictable Federal and Provincial regulatory environment to support the investment in new product development.
  • Potential for health impacts on other animals e.g., mammals, birds.
Option K - Encourage Crop Rotation

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.

Merits:

  • Reduce bee exposure to neonicotinoids from seed treatments and potentially reduce the overall pesticide load in the environment.
  • Potentially reduce the amount of neonicotinoids used across Ontario.
  • Reduction of resistance in pests.
  • Crop rotation is part of the cultural practice within an integrated pest management program.

Considerations:

  • Growers with certain pest pressures require protection every year.
  • Rotation may not be suitable for all growers or address pest pressures.
  • Short-term issues like weather may require deviation from rotation plan.
  • May result in a decrease in the use of no-till practices as more tillage may be required to address pest populations. This may have an impact on the environment in terms of potential loss of soil and negative impacts on water quality.
  • May reduce yield when seed treatments are not used due to potential delays in planting, regardless of the rotation used.

Improved Communications Between Stakeholders

Option E - Centralize and Communicate Bee Location Data

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.

Merits:

  • Helps to identify bee yards at risk both from seed treatments and foliar sprays.
  • Supports best management practices.
  • Allows/encourages increased communication between growers and beekeepers to mitigate risks to bee colonies.
  • Members suggested the potential for predictive models to be used along with a map to identify risk to bee colonies.

Considerations:

  • Privacy considerations.
  • May not increase quality of information available to farmers should beekeepers not provide the location of their bee yards.
  • Protocol and maintenance of data required.
  • Producers need to agree to share the information.
  • Information technology solution required.
  • Does not decrease environmental loading.
  • Observation by some members that the experience in United States of a similar application shows limited benefits.
  • May result in increased vandalism if the location of bee yards becomes known to the public.

Environmental Enhancements

Option F - Develop Strategy for Pollinator-Friendly Habitats

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.

Merits:

  • Larger and more diverse forage area for bees could contribute positively to bee health.
  • Increase access to better/diverse forage.
  • Environmental diversity for all insects and pollinators.
  • Could be incorporated into a tree planting or other bio-diversity program.
Considerations:
  • Need to clearly define pollinator-friendly habitat.
  • Need to assign a responsible jurisdiction (or could be initiated at the grassroots level).
  • If forage area is legume-based, there is a risk of an increase in virus transmission to crops or encouraging economically significant pests, such as the bean leaf beetle.
  • May not be sufficient to mitigate risk of drift from contaminated dust or there could be uptake into foliar plants.
  • Requires incentives for growers to increase forage acreage.
  • Reduced acreage for grain production.
  • Level of adoption may be low.
  • Contradicts best management practices related to flowering plants (if on cropland).
  • May increase weed sources.
  • Hive placement plays a role in providing forage-friendly crops (and vice versa).
  • Would require considerable coordination with beekeepers and growers.

Technical Options

Option G - Investigate Modifications for Air Planters

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.

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*under similar agronomic conditions in an Ontario context

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.

Merits:

  • Potential to reduce fugitive dust from corn and soybean planting.
  • Potential for faster adoption relative to requiring changes to new equipment.
  • There are precedents in Europe for equipment modifications, but these would not reflect Ontario growing conditions.
Considerations:
  • Modifications may affect planter performance and functionality.
  • Potential impact on equipment warranty.
  • Cost to growers might have to be offset by financial incentives.
  • Require data to show efficacy.
  • May not decrease environmental loading.
  • Challenging for growers with different types and models of planters.
  • Standards would be required.
  • May not help if the field is no-till.
  • May have to till ahead of planting.
  • Lengthy timelines to develop and test modifications and costly to manufacturers.
Option H - Promote ISO Standard for Air Planters

Promote the development and manufacturing of air planters meeting the International Organization for Standardization (ISO) standard (being developed) for fugitive dust.
Develop an incentive replacement/retrofit program for older models of planters that do not meet this standard.

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.

Merits:

  • Potential to mitigate fugitive dust.
  • Limited number of manufacturing companies to reach.

Considerations:

  • Slow implementation.
  • Long-term change dependent on turnover of industry inventory taking many years to get the current planters out of the system.
  • Many air seeders have recently been purchased in Ontario.
  • May not mitigate impacts on bee health.
  • Require data to show efficacy.
  • May not decrease environmental loading of pesticides.
Option I - Stakeholders Promote New Fluency Agent

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.

Merits:

  • Consistent with current product development focus of the agri-chemical industry
  • May reduce contaminated residue in fugitive dust.

Considerations:

  • Management of current inventory of talc and graphite lubricants; challenge to remove current talc and graphite lubricants from the distribution system (i.e. growers may be inclined to use existing purchased inventory first).
  • Disposal of current stocks of talc and graphite.
  • Users are inexperienced with fluency agent. New lubricant expected to have a comparable cost to talc when considering the amount used per seed unit (less fluency agent is required). Requires strong communication efforts early and often to be effective in this next growing season (2014).
  • Requires monitoring to demonstrate results.
  • Data to show a decrease in neonicotinoids in the dust is needed.
  • May not result in a significant reduction in environmental loading.
  • May not reduce exposure.
  • Growers may assume that this solves the entire problem.
  • May negatively affect seeding rate therefore increasing cost to grower.
  • Potential impact on planter performance.
  • New fluency agent is only manufactured by one company.

Mandatory Training

Option J - Update the Ontario Pesticide Safety Course

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

Merits:

  • Would improve knowledge of bee health at the grower and custom applicator level.
  • Could improve communication and understanding.
  • Easy and low cost to implement.

Considerations:

  • Will not reach all farmers since applying seed treatment does not require completion of the course.
  • Time lag before all course attendees are covered due to five-year rotation.
  • Long-term and ongoing rather than immediate action.
Option L - Require Grower Consultation

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.

Merits:

  • May reduce use of neonicotinoid-treated seed.
  • Need strong Integrated Pest Management program to support the potential reduction in treatment or treatment rates.

Considerations:

  • Potential development of resistance of pests to treatment if incorrect rates used.
  • Continued potential for off-label application by growers.
  • Do not have scientific knowledge to address this issue.
  • Re-evaluation process is expected to consider this and it continues to be an option for growers at any time.
  • Risk assessment required.
  • Scouting takes resources.
  • Requires data to know effective rate of application.
  • Require variable dosage depending on infestation level.

Regulatory Approaches

Option M - Consider a Temporary Ban of Neonicotinoids

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.

Merits:

  • Potential to reduce bee mortality.
  • Could improve bee health.
  • Would reduce neonicotinoids in the environment.
  • Would buy time to better assess bee health factors.
  • Could increase populations of beneficial predator insects.Ontario could be seen as a leader in addressing pollination issues.

Considerations:

  • Corn and soy growers would lose an effective pest management tool.
  • Could impact Ontario grower competitiveness as banned products would still be available to producers in other provinces and in the U.S.
  • May lead to use of alternatives with other environmental and health implications.
  • Granular insecticides have negative implications; increased cost, decreased planting efficiency, increased environmental footprint.
  • Growers may have fewer genetics as a choice for planting.
  • May have negative implications for availability of seed varieties in Ontario.
  • Potential yield loss and reduced grain quality due to increased pest damage increasing food costs.
  • May impact ability for no-till; primary and secondary tillage increases costs.
  • May not have the desired positive impact on bee health because of the use of other insecticide treatments or due to other bee health determinants.
  • Cost to grower to retrofit equipment to use different insecticides.
  • Substantial implications to some crops with only these products registered for pest control if no alternative treatment is immediately available.
  • Potential negative impact in confidence in evidence-based regulations and the current regulatory approval process.

Concluding Remarks

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.


Appendices

A. Ontario Bee Health Working Group Terms of Reference

Objective:

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:

  • act as a central forum for information sharing for affected parties and enhance their understanding of multiple perspectives related to this issue;
  • make recommendations on priority research areas to address identified research gaps or to address Ontario-specific issues;
  • report on action items to mitigate risk to bees before next year's critical planting season;
  • support the dissemination of best management practices publicly; and
  • provide expert, timely advice in guiding the government's approach to bee mortality mitigation.

Member Roles:
Working Group participants are expected to:

  • enhance their understanding of multiple perspectives related to bee health issues related to the use of pesticides;
  • ensure the views of their respective organizations/associations are represented in the discussions while contributing to the development of consensus-based recommendations for consideration by the government; and
  • request specific topics for discussion by contacting the secretariat, and possibly suggest other participants with expertise or interest in the topic to be included in the discussion.

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.

Operating Principles:

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.

Meeting frequency:
A minimum of two times per year; additional ad hoc meetings as necessary.

B. Activities of the Working Group

  • July 16 - Inaugural Meeting - Terms of Reference established
  • August 19 - Information Forum and Second Meeting - the Working Group invited speakers on a spectrum of topics related to the issue and developed an initial set of options for action
  • Last week of August - sub-groups further developed options
  • September 6 - Third Meeting - established research priorities, discussed merits and impacts of each option
  • September 25 - Fourth Meeting - drafting of options completed
  • December 12 - Fifth Meeting - discussion of draft report

C. Success Criteria

Economics
  • Beekeepers do not suffer economic losses
  • Grain farmers do not suffer economic losses
  • Ontario growers remain competitive
  • Ensure both Ontario growers and beekeepers can remain competitive in their sectors
  • Maximize income for all involved parties including beekeepers and farmers
  • Growers are able to produce a high yielding profitable crop
Bee Health
  • Major decrease in bee mortalities in Ontario due to all causes
  • Reduction in bee mortality from pesticide exposure
  • Reduced exposure (to neonticotinoids) by bees
  • Take stresses away from bees
  • (Reduce) Negative effects of neonicotinoids on non-targets
Based on Science
  • Recommendations are based on science
  • Science-based objective research on all aspects of the issue
  • Continuous innovation to find more solutions
  • Arriving at a voluntary approach to the solutions versus heavy-handed regulated and mandated solutions
  • Ability to build on this process to mitigate against similar situations in the future
Cooperation and Relationships
  • Allowing growers to manage pests but also protects bees
  • Improved communication between beekeepers and grain farmers
  • Positive relationships and good dialogue between sector players i.e. growers and beekeepers
  • Leverage relationships that are built through this process for overall bee health
  • Ability to build on this process to mitigate against similar situations in the future
  • Improved collaboration to continue to tackle complex issues
  • An action plan that is practical, implementable, measurable and shows balance and understanding that will be an improvement for all parties
Miscellaneous
  • A healthy environment for all pollinators
  • Avoidance of the introduction of measures that have a greater environmental footprint
  • Consistent message on this issue from the agricultural sector
  • Inspectors can focus their time on other non-pesticide calls
  • Improved process for licensing new products
  • Increased Ontario Ministry of Agriculture and Food transfer of technical knowledge to the industry
  • Grain farmers still have access to technology

D. Options Implementation Status

Options for Action Status
A - Update Best Management Practices (BMPs)

Completed

  • The revised BMPs have been extensively promoted at grower meetings and are available on line.

Underway

  • The revised BMPs have been extensively promoted by the Ministry at grower meetings, through hand outs and publications and are available on line. They have been distributed by the Grain Farmers of Ontario to over 30,000 corn and soybean producers and agri-business representative. All major seed companies are distributing best management practices information through their seed dealers. The agricultural input industry (e.g., CropLife, Bayer CropScience, Syngenta) has also been promoting BMPs in the agricultural press, at grower meetings and directly to growers and agri-businesses.
  • Growing Forward 2 (GF2) funding support is available for grain growers to implement best management practices to protect pollinators. Scouting services to identify risk levels of soil borne insects are eligible under GF2 Capacity Building. These services will complement other initiatives to increase growers' adoption of integrated pest management practices. GF2 will also support the modification of planters to decrease the risk of contaminated dust moving off the field.
  • The Ministry is evaluating other options to encourage beekeepers and grain growers to adopt BMPs.
B - Invest in Integrated Pest Management (IPM) Research

Underway

  • Ministry funding is being directed to support the development of an IPM guide for the identification and management of soil borne insects.
  • Ministry staff are collaborating with University of Guelph researchers to access industry funding to support research to evaluate soil borne pest populations across multiple sites in the province.
  • This project will assist in understanding the implications and risk factors associated with using treated as opposed to untreated seed in various locations across Ontario.
  • Updates of key findings will be made available on the Ministry website.
C - Promote Availability of Non-Insecticide Treated Seed

Completed

  • The Ministry collaborated with the Grain Farmers of Ontario (GFO) and the Canadian Seed Trade Association in the promotion of non-insecticide treated seed for spring (2014) planting, with increased varieties now available for the 2014 growing season.
D - Encourage Development of New Seed Treatments

Underway

  • New Directions Bee Health Program funding is enabling the evaluation of new polymers and their interaction with the new Fluency Agent and with planter modifications.
  • A summary of this research will be made available upon the completion of the project.
  • The Ministry will incorporate any new seed treatments into the Field Crop Protection Guide which is updated every second year with a supplement released in the intervening year. The Guide is publicly available on the Ministry website.
E - Centralize and Communicate Bee Location Data

Underway

  • Through Ministry funding and with collaboration between Grain Farmers of Ontario and the Ontario Beekeepers' Association an app is in development to improve the ability of grain growers and beekeepers to connect with each other. The app will be piloted in the 2014 season and plans are to have the app fully functional by 2015.
F - Develop Strategy for Pollinator-Friendly Habitats

Underway

  • The ministry is in the process of removing five weeds from the Weeds Control Act which will enhance the habitat for bees around corn and soybean fields.
  • 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 an Ontario Pollinator Health Strategy which will include pollinator friendly habitats.
G - Investigate Modifications for Air Planters

Underway

  • Ministry staff are working closely with industry partners to increase growers' ability to access air planter deflector kits prior to Spring (2014) planting.
  • A guidance document to assist growers to make modifications to their planters has been developed and widely circulated across Ontario by OMAF, agri-business, the Ontario Soil and Crop Improvement Association and the farm press.
  • Producers who need to modify planters may apply to GF2 for funding support.
H - Promote ISO Standard for Air Planters

Underway

  • The Association of Equipment Manufacturers is leading the development of the standard.
  • The ISO standard is expected to be in place by 2015 for application by manufacturers in 2016
I - Stakeholders Promote New Fluency Powder

Underway

  • The PMRA has made the new fluency agent mandatory for all seed lubrication for the spring of 2014.
J - Update the Ontario Pesticide Safety Course

Underway

  • The Ontario Pesticide Safety Course has been updated with new information related to protecting pollinators.
  • Over 5,300 growers have been trained for this growing season on the updated information.
  • Over the five year certification cycle, more than 22,000 growers are expected to receive training on the revised material.
K - Encourage Crop Rotation

Complete

  • This is a standard cropping systems recommendation that is widely implemented across Ontario.
L - Require Grower Consultation Prior to Purchasing Neonicotinoid Treated Seeds

Underway

  • Extensive effort, both by OMAF and by the agricultural input industry (e.g., seed and pesticide) has been made to have certified crop advisors, agricultural input industry representatives and growers aware of the recommended BMPs.
  • The Ministry funded Soil Borne Insect Guide, which will contain descriptions of insects, thresholds and scouting suggestions, will enable certified crop advisors and the agricultural input industry to be able to provide their growers with information to assist in decisions about the need for seed treatment.
M - Consider a Temporary Ban of Neonicotinoids

Underway

  • The Ministry will host a forum with other jurisdictions including France, Italy, England and Australia to better understand how and why decisions were made regarding restricting or not restricting neonicotinoid seed treatments and what their experience has been.
  • The Pest Management Regulatory Agency is expediting the re-evaluation of all uses of neonicotinoid insecticides and is implementing measures under its jurisdiction to protect pollinators until the review is complete.

 


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Creation Date: 19 March 2014
Last Reviewed: 30 April 2014