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.
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.
- National Agriculture Leaders’ Debate With the federal election just over a month away, do you know where party candidates stand on the big issues facing agriculture today? Watch the National Agriculture Leaders’ Debate, hosted by the CFA on Sept. 24th a...
- Reminder: Updated E2 Regulations Now in Force CAAR is reminding retailers that the Environmental Emergency Regulations, 2019 have come into effect as of Saturday, August 24, 2019. Please continue reading for important information. If you haven’t yet had the o...
- CAAR's Industry Committee Participation As a CAAR member, you help support your association’s advocacy activities. In turn, when important industry issues and initiatives are brought forward, your association can help represent your interests by ensuring y...
- MEMBER ALERT: Environmental Emergency Regulation Updates in Effect August 24 The finalized Environmental Emergency Regulations, 2019 have been published in the Canada Gazette Part II and will come into force on August 24, 2019. Fertilizer Canada has released a technical bulletin to provide gu...
- CAAR Members Invited to Comment on Draft MRL Policy CAAR members are encouraged to submit comments to the Canada Grains Council on the Market Acceptance of Pesticide Use Policy. The Canada Grains Councils is consulting stakeholders until August 31, 2019 on a new frame...