Can Canadian Producers Remain Competitive in Our Pest Management Regulatory Environment? (Summer 2017 PCN) JUL 7 2017 | Pulse Crop News
Ron Pidskalny, M.Sc., P.Ag., Strategic Vision Consulting Ltd.
Canadian growers may find it challenging to remain globally competitive due to an accelerating reduction in access to pest management tools. Two ongoing issues have reduced the competitiveness of Canadian farmers for decades:
• The continuing loss of or lack of access to pest management products due to regulatory issues; and
• Regulatory impediments to the registration of new crop protection products.
A third issue, the loss of pest management tools due to pest resistance issues is an on-farm management issue; however, the Canadian regulatory environment has exacerbated the extent and seriousness of specific pest problems.
Two recent examples of regulatory issues that have had a direct effect on the pulse industry are:
• The termination of streptomycin use in dry beans; and
• The proposed phase-out of all agricultural uses of the neonicotinoid insecticide, imidacloprid, over a three to five year period.
Termination of streptomycin use on dry beans
Pulse Canada has worked with Health Canada since 2004 to allow for the importation of dry bean seed treated with streptomycin into Canada from the United States (U.S.). Health Canada’s most recent letter of approval expired December 31, 2016. Pulse Canada requested continued support for the importation of streptomycin-treated dry bean seed beyond the deadline; however an extension was not granted. Shortly thereafter, an article appearing in the Manitoba Producer noted that, “Health Canada’s PMRA has not banned the import of streptomycin treated bean seeds … growers may import and use streptomycin-treated bean seeds for their 2017 crop.” Health Canada’s apparent lack of clarity on this issue left those in the Canadian
dry bean industry in a state of confusion regarding the status of streptomycin use on dry bean.
In 2017, Canadian dry bean importers purchased untreated dry bean seed from U.S. exporters. To do otherwise would have meant taking the risk of having streptomycin-treated bean seed
held at the border by the Canadian Border Services Agency.
Proposed termination of imidacloprid use
In its proposal to phase out all agricultural uses of imidacloprid, the Pest Management Regulatory Agency (PMRA) takes a different position than that of the U.S. The U.S. Environmental
Protection Agency (EPA) concluded in its own assessment of imidacloprid that it was “… in general agreement with recent findings published by Canada’s Pest Management Regulatory Agency …” yet the EPA made no proposal to phase out the use of imidacloprid in the U.S.
The loss of imidacloprid seed treatments for the control of insect pests in pulse crops may have a considerable impact on the competitiveness of Canadian pulse producers. Not only may U.S.-based pulse producers continue to access imidacloprid in an open and competitive insecticide market, a phase-out of its use in Canada would leave one company with a virtual monopoly in pulse insecticide seed treatments. The extent to which seed treatment prices could rise in Canada relative to other pulse exporting nations, and to what extent Canadian pulse production margins decline relative to those of U.S.-based growers has yet to be determined.
The continuing loss of pest management products due to regulatory issues
The pulse industry has lost three insecticidal active ingredients included in a range of products:
• Sevin® XLR Plus (carbaryl) for use on bean, chickpea, lentil and pea;
• Lorsban® 4E (chlorpyrifos) for use on bean, chickpea and pea; and
• Agrox® B-2, Agrox® CD and Agrox® DCT (all diazinon) for use on bean, pea and soybean.
The transition from older, potentially more toxic or environmentally less friendly active ingredients, to newer and more benign products is expected. Unfortunately, newer insecticide technologies, such as the neonicotinoids, which were expected to be available to replace older active ingredients, are now proposed for phaseout.
What is more important to note is that older technologies tend to be off-patent and consequently, less expensive – as opposed to newer technologies that are increasingly costly to develop
and tend to be ever more pricey in the retail market. In addition, new modes-of-action (MOA) tend to replace existing MOA and the toolbox becomes less diverse as fewer active ingredients replace those that have been phased out.
Regulatory impediments to the registration of new crop protection products
Canadian regulatory impediments continue to restrict the number of active ingredients and commercial products available to producers. Consider an example for dry bean insecticides. Canadian dry bean growers have access to five active ingredients with four unique MOA or groups. U.S.-based producers, on the other hand, have access to 20 different active ingredients
in eight groups. Dry bean is not the only crop with fewer pesticide options relative to what is available in competing jurisdictions. This same situation may be documented in a number of crops for a range of pest management products.
Management of pest resistance
To avoid selecting for pest resistance, growers need to diversify the MOA used to manage each pest. However, rotating MOA can be a challenge when active ingredients are restricted to certain crops or when producers do not have access to the same pest management products in all regions. Effective rotation management strategies depend on the availability of products from completely different groups. Clearly, U.S.-based producers have an advantage over their Canadian counterparts in managing insect resistance with twice as many MOA groups available for dry bean production. While the loss of pest management tools due to pest resistance issues is an on-farm management issue, the Canadian regulatory environment exacerbates the extent and seriousness of specific pest problems due to lack of availability of the full range of tools offered to growers in competing jurisdictions.
Increases in farm productivity fuel growth in agricultural production and exports – but growers need to realize gains in agricultural productivity to drive the continuing expansion of the Canadian agricultural economy. Most would agree that the supply of high quality farmland is not increasing, advances in agricultural technology are slowing and agricultural productivity gains may not continue forever. Access to a wide range of competitively priced inputs such as seed, fertilizer, pest management tools and machinery help Canadian producers maintain a competitive position in the global agricultural economy. The continuing termination and phase out of efficacious and cost-effective pest management tools and impediments to the registration of new crop protection technologies is counterproductive. It increases the complexity of farm management and may ultimately compromise the economic success of Canadian farm operations.