1. Canadian Seed Trade Association
Seed Treatment and Environment Committee
December 6, 2016
Chicago, Illinois
Dave Carey
Director, Government Affairs and Policy
Growing for the World/ Une Croissance Axée sur le Monde

2. Overview About CSTA Ontario Regulations Quebec Regulations
Federal Reviews:
Neonics
Fungicides
Growing for the World/ Une Croissance Axée sur le Monde

3. About CSTA Formed in 1923 132 seed company members
16 member Board of Directors
50 crop kinds
All aspects of seed
All company sizes
All 3 production systems
One member one vote
Member companies engaged in all aspects of seed and seed technology in or on the seed
Research, plant breeding, trait development
Production
Processing
Marketing
Trade
Organic to biotech products Family owned to multi-national
Many Shared ASTA Members
Growing for the World/ Une Croissance Axée sur le Monde

4. CSTA Mandate Vision: Growing for the World
Mission: To Foster Seed Innovation and Trade
Strategic Goals:
Open Trade
Increased Investment in Innovation
Industry Wide Voice
Efficient Regulatory System
Stakeholder and Public Perception of Innovation and Agriculture
Growing for the World/ Une Croissance Axée sur le Monde

5. Ontario Regulations Based on 2014 election promise – Liberal Majority
Desire to be first to regulate in N. America
Europe as example
Regs impact corn and soybeans only – Neonics Only
Regs result of ‘Perfect Storm’ of Bee loses in 2012:
Very warm, dry and early spring - bees foraging early
Adoption of air planters
So I’ll start with a bit of a How Did we Get Here?

6. Ontario Regulations (2)
Ideology over science
Intense public pressure from activist NGO groups
Extensive, one sided media coverage
Driven by the MOECC rather than OMAFRA
Objectives-Aspirational Goals:
80% reduction in acres of neonic treated corn and soybeans by 2017
15% honeybee overwinter loss by 2020
Set a precedent

7. Class 12 Regulatory Requirements
Pesticides are approved by PMRA federally and scheduled provincially
In Ontario Neonic treated corn and soybean seed is classified as a Class 12 under the Pesticides Act
Treated seed is classified as the pesticide
Applies to imidacloprid, thiamethoxam and clothianidin
Planting Class 12 is considered an extermination

8. Scope of Ontario Regulations
Corn:
Corn refers to grain or silage corn
Does not include popping corn, sweet corn or corn used for seed production
Soybeans:
Does not apply to seed for certified seed production
Does not apply to research plots

9. Regulated Parties Vendor:
Sells, offers to sell or transfer corn and soybean seed treated a neonic.
Require 5 year license
Vendors Include:
Seed companies treating with a neonic via own plant or through 3rd party processor
Retailer purchasing seed, treating seed using their own third party treater and reselling treated seed to a farmer
Retail purchasing and reselling treated seed that does not have a treater
Vendors Do Not Include:
Direct-to-farm (qualifying seed dealers)
Sales reps including retail dealers
Custom Seed treaters
Vendors are the primary target of the regulations.
I intentionally made this slide word heavy as this deck can be distributed

10. Vendor Obligations
Treated Seed Vendor License cost $300 – valid 5 years and must follow all regulatory requirements
Provide list of all Class 12 pesticides available for sale by July 31st annually
Corn hybrids and soybean varieties
Disclose in all product advertising whether seed being sold are Class 12 pesticides and which active they contain and
Including that non-Class 12, fungicide only or bare seed are available
Again this is just corn and soybean seed.
Also includes record of sale requirements

11. Vendor Obligations (2)
Obtain required grower documentation before sale
Retain grower required documentation for 4 years
Report the summarized sales of Class 12 pesticides and non neonic treated corn and soybeans seed to MOECC by October 31st annually
Forward completed pest assessment reports to OMAFRA by October 31st annually
Ensure Sales Reps have received training and have proper identification

12. Grower Obligations Up to August 31, 2016:
50/50 self declaration – 50% of acres can be planted with Class 12
Self Pest Assessment or Damage Assessment by Field:
Self assessment valid for 12 months
Assessment done spring 2016 = 2017 planting
Fungicide only = no paperwork
Fungicide + non-neonic insecticide = no paperwork or restrictions
Vendor and Sales Rep must track non neonic sales
Retain grower required documentation for 4 years
Report the summarized sales of Class 12 pesticides and non neonic treated corn and soybeans seed to MOECC by October 31st annually
Forward completed pest assessment reports to OMAFRA by October 31st annually
Again corn and soybean only and Ontario only

13. Grower Obligations (2) August 31, 2016 – August 2017:
IPM Certificate Number
IPM Declaration Form
Pest Assessment or Damage Assessment by Field:
No 50/50 self declaration
Do not need IPM number if using custom planter but pest assessment still required
Self assessment good for 12 month – Spring for Planting 2017
Fungicide only = no paperwork
Fungicide + non-neonic insecticide = no paperwork or restrictions

14. Grower Obligations (3) August 31, 2017 and beyond 
Same as previous slide except:
By county 3rd Part Professional Pest Advisor Assessment
Required every 3 years
Self assessment or 3rd party assessment every year
Fungicide only = no paperwork
Fungicide + non-neonic insecticide = no paperwork or restrictions
Retain grower required documentation for 4 years
Report the summarized sales of Class 12 pesticides and non neonic treated corn and soybeans seed to MOECC by October 31st annually
Forward completed pest assessment reports to OMAFRA by October 31st annually

15. Professional Pest Advisor – Implementation by County
Here is a convoluted map of southern Ontario that shows the phase in of 3rd Party Assessments by County: Purple being 2017, Green 2018 and Orange 2019
I could go on forever about the issues with these regulations, from the Grower Required IPM Courses, confusion about when a sales does and does not occur, record keeping, the Pest Assessments themselves, that CCA’s that work with seed companies aren’t eligible as 3rd party etc etc etc
Instead I will briefly touch on industry impact and reaction 15 15

16. Industry Impact
Great deal of confusion, anger and frustration. Significant education still required
Paperwork and record keeping is very onerous, some smaller companies struggling to manage the HR requirements
Regulations are very hard to interpret and therefore comply with
GFO sued the Ontario Government but lost at the Superior Court level

17. CSTA Action Participated in many government WGs and Meetings
Participated in consultations-drafted submissions
Engaged members to participate and reach out to local policy makers
Testified at Senate Committee x 2
Implemented BMPs for planting treated seed
Adopted use of Fluency Agent – members distributed
Creation of AAFC Bee Health Roundtable
CSGA-CSTA Guide to Treated Seed Stewardship: Best Practises for the Safe Handling, Storage, Transportation, Use, and Disposal of Treated Seed

18. Quebec
Government has had an aspirational goal of reducing pesticide use as a goal for several years
Water and soil of greater concern than pollinators
There has been work done to create a database of ‘high-risk pesticides’. CLC members have been active on this file
December 12th there is a stakeholder meeting in Quebec City where we expect a regulatory announcement to be made

19. Quebec (2) Increased monitoring of water ways for pesticide residues
Increased monitoring of residues on fruits and vegetables (and this by source; ie, domestic or imported fruits and vegetables)
Additional funds for ag extension services by the province
Studying options to track pesticide sales in QC, particularly neonics
Increased support for organic production
Requiring prescription from a certified agronomist for the use of plant protection products
Bit of a crystal ball here from my friends at CLC but based on the AG report we may see.
I can report back through ASTA and Jane about what happens next week.

20. Federal Reviews
PMRA Timelines of cyclical re-evaluations of Neonic Underway:
Imidacloprid cyclical re-evaluation
Human health and environmental assessment (excluding pollinators)
Expected proposed decision (for consultation): Nov-Dec 2016*
Expected final decision: December 2017
Clothianidin and Thiamethoxam cyclical re-evaluation
Initiated: November 2016
Expected proposed decision: December 2018*
Pest Management Regulatory Agency (PMRA) of Health Canada
For Imidacloprid as many are aware there is now a proposed decision which I will touch on shortly
*Astrix there as things have changed…

21. PMRA Timeline for Pollinator Re-Evaluations
Imidacloprid pollinator re-evaluation
Re-evaluation of Imidacloprid- Preliminary Pollinator Assessment (REV )
Published for consultation January 2016
Expected Proposed decision (for consultation): December 2017
Clothianidin and Thiamethoxam pollinator re-evaluations
Preliminary Pollinator Assessments: TBD
The Cyclical Re-evaluations were underway, bee related incidents prompted an additional review focusing on pollinators

22. Imidacloprid Preliminary Pollinator Assessment
Foliar Applications – risk dependent on application timing
During bloom application – expected to pose risk
risk minimized by current labels that restrict during bloom application
Post-bloom application – not expected to pose risk
Pre-bloom application - may pose risk
minimal information to date
current labels restrict pre-bloom applications for many bee attractive crops
Soil Applications – minimal risk; potential risk under some conditions
May vary with soil type and application timing relative to bloom
Minimal risk for most soil applications (e.g., melon, pumpkin, blueberry)
Potential risk for some crops under certain conditions (e.g., strawberry, tomato)
Seed Treatments – risk dependent on exposure route
Exposure route: Pollen and nectar through systemic transport throughout plant
Negligible risk to bees was indicated
Exposure route: Dust generated during planting of treated seed
Potential for risk from planting of corn and soybean treated seed
Risk reduction measures put in place in 2014.
Very favourbale
This slide is very dense but the key take away seed wise is that seed treatments posed a negligible risk to bees

23. Proposed Decision to Phase out Imidacloprid
Nov. 23rd PMRA host impromptu stakeholder call to announce they are proposing to phase out the use of imidacloprid over 3 years
This launched a 90 day public consultation on their proposed decision document
“The environmental assessment of imidacloprid identified risks to aquatic insects, such as midges and mayflies, which are an important food sources for fish, birds and other animals. In some aquatic environments in Canada, imidacloprid is being measured at levels that are harmful to certain insect populations” - PMRA
To quote PMRA directly…………..”……………….”

24. Proposed Decision to Phase out Imidacloprid
The proposed decision on imidacloprid has triggered special reviews of clothianidin and thiamethoxam as well*
CSTA has already raised concerns with the Minister of Agriculture and Agri-Food
In response AAFC will be hosting a multi-stakeholder forum to discuss the potential impacts:
Full day in Ottawa December 21
The full PMRA release is available here: sc.gc.ca/cps-spc/pest/part/consultations/_prvd /prvd eng.php
*We aren’t sure how accelerated these reviews will be but*
CSTA has already raised concerns with the Minister of Agriculture and Agri-Food. We happened to already have a breakfast meeting scheduled with him, and his department and Hill staff
In response AAFC will be hosting a multi-stakeholder forum to discuss the potential impacts. We had an initial call last week where concerns were raise with PMRAs modelling and a lack of data from some provinces.
There will be a full day meeting in Ottawa on December 21st where PMRA will participate as an observer. Stewardship activities are expected to be discusses – ways to mitigate risks identified by PMRA
I have one more slide on another topic but I believe there is someone here from Bayer that is going to speak to the technical science side.

25. Update on Thiram and Captan Re-evaluations
Proposed re-evaluation decisions for a number of fungicides were published for public consultation earlier in 2016
Thiram: February 2016; consultation ended May 2016
Captan: March 2016; consultation ended July 2016
Final decisions are expected in 2018 (as per published 5 year re-evaluation and special review workplan REV )
Thiram: June 2018
Captan: March 2018
Published documentation will include:
Final registration decision
Summary of the comments and proposals received
PMRA's response to these comments and/or proposals
Just briefly, essentially earlier this year PMRA came out with a proposed decision to cancel or limit the registrations of several fungicides. CSTA worked with ASTA and shared members to address the concerns raised by PMRA, in particular Thiram and Captan

26. Questions?
Any questions?