The past year has been another very active time in crop protection to say the least. While a staff transition occurred at Ontario Fruit & Vegetable Growers’ Association (OFVGA), the ongoing re-evaluation program at the Pest Management Regulatory Agency (PMRA) was by far the major area of focus.

Crop Protection Advisor

This was a transition year for the Crop Protection Advisor role at OFVGA as Craig Hunter, a long-serving member of the OFVGA staff, retired at the end of June. Throughout his career spanning more than 40 years in crop protection, Craig left a huge impact on horticulture – perhaps none bigger than helping to establish and continuing to facilitate the Canadian Minor Use Program, resulting in numerous new registrations for growers.

Upon Craig’s retirement, the OFVGA hired Chris Duyvelshoff as Crop Protection Advisor who started on September 4, 2018. Chris joined OFVGA following an early career in tree fruit extension and crop protection sales. It is certain there will be no shortage of work for the role in 2019!

OFVGA Crop Protection Committee

There were four meetings of the OFVGA Crop Protection Committee in 2018 which was higher than average due to several ongoing issues. Re-evaluation of mancozeb has been the primary item for discussion along with the neonicotinoids. The OFVGA would like to thank all of the participating members for their valuable contributions to this section over the past year.

Re-Evaluation Program

The re-evaluation program at PMRA continues to be the number one issue in crop protection across the country. Last year’s report expressed concerns around several proposed re-evaluations including the Group M fungicides. We have now mostly learned their fate, with all uses of ferbam, ziram, thiram (with some seed treatment exceptions), and metiram (except potatoes) being phased out over the next two to three years. Final decisions were also issued for captan and chlorothalonil, which included very restrictive limitations on the number of applications in certain crops and much longer re-entry intervals. This is making the current re-evaluation of mancozeb even more critical. Resistance management is in serious jeopardy without access to some of these Group M materials.

Mancozeb

The OFVGA and the Canadian Horticultural Council (CHC) successfully lobbied to have the PMRA retract its original final decision on mancozeb as published this past June 2018. The publication of this final decision was in violation of the Pest Control Products Act as a complete summary of the risk-reduction measures (including cancellation of uses) was not published in the original proposed decision consultation document from July 2013. Subsequently, the PMRA reissued a new proposed decision on mancozeb in October, which much to the objection of industry, indicated that all uses were to be phased out with the exception of greenhouse tobacco transplants. 

Since this time, the OFVGA and CHC have been working with the Mancozeb Task Force (representing registrants) to support its continued registration. The OFVGA recently submitted comments presenting significant concerns with the risk assessment conducted in PMRA’s proposed decision. There is plenty of supporting evidence that this assessment has been grossly overestimated. We remain optimistic. At the same time, the OFVGA has been working with various industry stakeholders to gather information on the critical needs of mancozeb by crop to help support a new label submission to PMRA by registrants. This work is expected to continue early in 2019. 

In December 2018, a letter was circulated among the OFVGA Crop Protection Committee to encourage growers to write to the federal Minister of Health and Minister of Agriculture on mancozeb and the challenges with the re-evaluation program. Thank you to the many growers who sent personal comments on the impact of mancozeb to their farm operation. It is hoped this will bring this matter to Ottawa’s attention.

Neonicotinoids

Final decisions are also expected in 2019 for three key neonicotinoid insecticides including clothianidin, imidacloprid, and thiamethoxam. Imidacloprid was the first of these active ingredients to undergo re-evaluation with a proposed decision from November 2016 to phase out all agricultural uses. This was followed by proposed special-review decisions in August 2018 to phase out both clothianidin and thiamethoxam. Initially in response to the imidacloprid proposal, AAFC established the Multi-Stakeholder Forum on Neonicotinoids which had several objectives including to gather further environmental monitoring data, examine potential alternatives, and explore risk mitigation strategies. This has been a productive forum, in particular with respect to water quality monitoring, where a substantial new body of data has been obtained over the past two years. 

The OFVGA made submissions to support the continued registration of these active ingredients for key horticulture uses. It should be carefully considered in the final decisions by PMRA that these products have replaced many older chemistries with higher relative toxicity, and have often reduced total required insecticide applications. The loss of the neonicotinoids would be a step backwards in pesticide risk reduction practices for many crops. We should know the final outcome of these reviews later in 2019.

PMRA Program Review & Stakeholder Engagement Unit

The current re-evaluation program at PMRA is not sustainable – as stated by the PMRA officials themselves. The Pest Control Products Actrequires that the PMRA perform re-evaluation of each registered crop protection material every 15 years to determine if uses are acceptable for current standards. Due to a number of new active ingredients registered in the 2000s, the program of scheduled re-evaluations is going to increase substantially over the next few years. There are 25 active ingredients currently scheduled for re-evaluation commencing in 2019, 34 in 2020, and 50 in 2021. Re-evaluation workloads are already exceeding available resources at PMRA and the future demand is unsustainable. The program simply cannot continue in its current form – even beyond the very significant concerns from industry. 

To that end, the PMRA is initiating a review of the re-evaluation program that will seek to enhance stakeholder engagement, improve efficiency, and increase collaboration with international regulators on re-evaluation work. This past fall, the PMRA organized sessions with stakeholders across Canada to seek input on current challenges and successes of the existing program. Several OFVGA members participated in a productive discussion with PMRA staff in Guelph on December 3. Re-evaluation processes were highlighted from other countries, including the U.S., Australia, and Europe. These will be examined by PMRA to determine potential alternative models. One of the key areas for review by PMRA is going to be around what triggers a re-evaluation. Rather than on a 15-year arbitrary timeline (unsustainable), are there specific science-based criteria that can be used to determine if and when an active ingredient needs to be reviewed? The PMRA will present its findings and options for changes to the re-evaluation process to stakeholders in late winter or spring of 2019. Further recommendations will be made in consultation with stakeholder feedback. The inclusion of a benefit analysis is a key recommendation from industry, as discussed further below.

A valuable addition to PMRA this year has been the establishment of the Agricultural Stakeholder Engagement Unit (ASEU) led by Terri Stewart. The ASEU was established by the PMRA in July 2018 specifically to enhance communication with minor use stakeholders. Its focus has been on regulatory issues and re-evaluations that pertain to minor use crops in Canada, which comprise a large segment of horticulture. Terri and her group have been extremely valuable to date on facilitating improved communications with PMRA, providing feedback on active re-evaluations, and suggesting the best ways to direct our efforts within the agency. The OFVGA once again commends the PMRA for creating this unit and believes that increased communication and engagement with grower stakeholders are a positive development for both the PMRA and the horticulture industry.

The year ahead

It is expected that 2019 will be another very demanding year in crop protection with several key areas of focus for the OFVGA. 

The review of the PMRA re-evaluation program will be the primary initiative for 2019. As mentioned above, inclusion of a benefit analysis in the re-evaluation program has been discussed numerous times by industry. Under the United States Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Environmental Protection Agency (EPA) must consider the benefits of use in making its regulatory decisions. When evaluating acceptable risk for product registration or re-evaluation, there must be consideration of “economic, social, and environmental costs and benefits of the use of any pesticide.”

In Canada, to date, we do not have consideration for the benefits side of the equation weighing in our re-evaluation decisions on crop protection products. Protecting human health and the environment is indeed of critical importance. However, we should make regulatory decisions with a holistic view of crop protection – including an understanding of the benefits of use – to make the best possible decisions for Canadians. This is particularly important in light of the fact that registrations of new active ingredients have been declining. There were 18 registered in 2015-16, 10 in 2016-2017, and only seven in 2017-2018. We cannot continue to lose access to products if new ones are not coming along to replace them.

In order to accomplish this goal of improving the re-evaluation program, we will require additional efforts in Ottawa.With a federal election scheduled for October 21, as well as an anticipated statutory review of the Pest Control Products Act in 2020 – it is an opportune time to make some positive impacts moving forward. Please stay tuned, as the OFVGA will need input and support from all to help create the change that is needed!

Another key objective in the near future will be the development of a centralized method of collecting current use information for all crop protection products. This is one of the main challenges faced by PMRA currently. Without updated use information, PMRA must assume the worst-case scenario – maximum number of applications X maximum label rate. This is not accurate in many instances. Instead, if current use information is available, then PMRA risk assessments can be made with what growers are actually using. Several digital systems now exist for collecting this type of information (e.g. Croptracker, Spray Hub, Ginseng Manager, etc.) that can potentially be utilized to generate updated use pattern information quickly. This only requires aggregate, non-personal data and does not need to identify a farm or specific locations. Having an industry summary of this information would be a huge advantage for growers, as an updated use pattern can make an active ingredient much more likely to successfully pass re-evaluation. Further discussions on data collection efforts will continue in 2019.

As regulatory pressure continues to increase on crop protection tools, growers must take every precaution to adhere to product labels. For example, one proposal to help mitigate risks to post-application workers includes the use of protective gloves when performing hand labour tasks. The PMRA must be confident that growers will ensure that workers use gloves when required for these tasks in order to implement this strategy. This may be the only potential option for maintaining certain product uses in the future. Governments and public must be able to trust the industry in order to help retain product access.

Finally, the OFVGA wishes to thank the CHC, in particular Caleigh Irwin and Jason Smith, who continue to provide valuable contributions to support crop protection efforts on the national level!