CAAR is one of several industry groups forming a unified coalition to respond to the PMRA’s proposed decisions on Clothianidin and Thiamethoxam that were announced August 15.

Together, this group has formed a series of common messaging that CAAR is encouraging its retail members to utilize in their own responses in addition to CAAR’s official response. Comments can be submitted to PMRA’s Publication Section. The comment period on this proposed decision is open until November 13, 2018. If you have questions or would like to discuss this issue further, please contact Mitch Rezansoff at This email address is being protected from spambots. You need JavaScript enabled to view it. or 204-989-9303.

Common Messaging: Clothianidin and Thiamethoxam August 15 Proposed Decisions

Human health and the environment are priorities.

• Growers ensure approved crop protection products are used in ways that are safe for human health and the environment.
• When changes to approved uses are being considered, the human health and environmental impacts of alternatives need to be part of that analysis.

PMRA’s work is critical to trade and growers’ competitiveness.

• Canada has set a goal of hitting $75 billion worth of agricultural exports by 2025.
• PMRA is the only agency in Canada with the specialized expertise to help support and defend Canada’s interests with our trading partners. The PMRA needs the mandate to do this.

These proposed decisions add to the evidence that the process is flawed and urgently needs fixing.

• Public consultations on the proposed risk assessment need to be decoupled from the proposed risk mitigation measures.
• In the August 15 decisions, PMRA itself questions the quality and statistical significance of the data it used in its risk assessment – had stakeholders been consulted, we could have helped refine the evaluation to inform decisions on appropriate uses.

The proposed decisions on neonics contain no plausible evidence of benefits for either human health or the environment and risk making growers less competitive.

• We need a re-evaluation policy environment that is predictable - proposed decisions like these send unfounded shocks into the market place and negative signals to investors.
• The Canadian and United States markets are highly integrated, similar pest control products should be available in each country allowing Canadian growers to remain competitive.

Maintaining public trust is essential.

• Given the current process does not allow stakeholders to comment on the draft risk assessment first, major differences are expected between proposed decisions and final decisions which creates unfounded perceptions of "big agriculture influence."
• Changes result from the science that wasn’t considered in the draft risk assessment until after the proposed decision was published.

Solutions have been identified and can be made under PMRA’s existing authorities.

• Discussion prior to starting the evaluations could identify risk of concern and allow stakeholders the time needed to address these and to generate data, if required.
• If additional risks are identified once the evaluation has begun, there should also be an opportunity for dialogue to address these.
• Right now, the proposed decisions are often based on incomplete risk assessments.

PMRA’S backlog can be addressed.

• Actively collaborating with international partners (i.e., U.S. EPA) to the share workload.
• Exploring the use of emerging scientific analysis tools (e.g., Risk21 approach).
• Commissioning a third-party review of the current post-market review processes to identify further opportunities for streamlining.