Sandra Finley

May 172018

From: Gord.Johns   (my MP)
Sent: May 16, 2018
Subject: RE: Canada should ban bee-killing neonics in 2018!

Dear Sandra,

Thank you for taking the time to write to us about the decision made by the Pest Management Regulatory Agency (PMRA) regarding the use of the neonicotinoid pesticide imidacloprid.

Like you, the NDP wants decisions to be science-based and we want to ensure that our environment and human health are not being compromised.


In November 2016, the Pest Management Regulatory Agency (PMRA) published the results of its risk assessment of imidacloprid. Following that assessment, the PMRA proposed that most agricultural uses of imidacloprid be phased out over a three to five year period, depending on the availability of adequate alternatives.  Here are comments made by the PMRA’s Executive Director before the Standing Committee on Agriculture and Agri-Food regarding the Agency’s decision to withdraw the pesticide imidacloprid:

«As part of our broader, cyclical re-evaluation of the three major neonics, we are conducting an examination of all the available science—this is both published and proprietary information—regarding risks to the aquatic environment. These risks are evaluated in the context of how neonics are used in Canada and all the available information. This includes actual levels found in water by federal and provincial governments and academic sources in Canada. We have completed our review of the risks to the aquatic environment of the neonic imidacloprid, one of the three neonics, and the reviews of two other neonics are in progress. One of the key outcomes of PMRA’s re-evaluation of the neonic imidacloprid was the conclusion that the use of imidacloprid in Canada is causing harm to aquatic environments. » Mr. Richard Aucoin (Executive Director, Pest Management Regulatory Agency, Health Canada), March 7, 2017


The NDP believes that the Agency’s decision regarding imidacloprid is based on science and aims to protect our environment. We hope that in this case, science and environmental protection will continue to take precedence over the economic interests of major corporations that design pesticides. The Agency must continue to make science-based decisions and pursue its regular re-evaluation of pesticides that may be harmful to humans or the environment.


We thank you again for contacting us.


Yours sincerely,


Gord Johns, MP Courtenay-Alberni

May 172018

By Robin Booker

A study into the presence of neonicotinoids in Canadian waterways suggests a ban or restriction of neonicotinoid seed treatments is not necessary.

The Environmental Monitoring Working Group (EMWG) was set up to monitor the presence of imidacloprid, clothianidin and thiamethoxam in waterways after Health Canada’s Pest Management Regulatory Agency (PMRA) 2016 decision to phase out imidacloprid in three to five years.

The PMRA cited acute and chronic risks to aquatic invertebrates as reasons for the ban, and its final decision on whether to ban imidacloprid is expected in December.

The PMRA is also reviewing and may ban two other neonicotinoids, thiamethoxam and clothianidin, because of their effects on aquatic insects. The final decisions on these neonicotinoids are expected to be made in 2020.

Environment Canada doesn’t routinely test ponds, wetlands and creeks across the Prairies for pesticides and little data is available on the levels of neonicotinoids in prairie water, or if the neonicotinoids affect invertebrates in the region.

In the absence of such data, the EMWG established protocols for sampling, storage, handling and shipping, sample preparation, analytical methods for the tests, as well as detection limits for the three neonicotinoids.

The EMWG co-ordinated with provincial and federal water monitoring agencies, and flowing water from all major watersheds in Canada were tested. Ducks Unlimited Canada (DUC) helped conduct wetland monitoring.

In the prairie provinces, 620 samples at 168 sites were collected in 2017 from flowing water systems including streams, rivers and irrigation canals. A further 60 wetland sites were monitored by DUC.

The samples were taken throughout the growing season.

“Detection frequency and concentration of imidacloprid, clothianidin and thiamethoxam were low, with majority being below the limits of detection. When detected, the insecticides were typically well below the chronic or acute endpoints established by PMRA for imidacloprid. By the middle or end of July, the insecticides were no longer detectable, said Warren Ward of the Canola Council of Canada during the University of Saskatchewan’s Soils and Crops event in Saskatoon.

He said in instances when neonicotinoid insecticides were found to be above acute or chronic levels, greenhouse or urban applications could be to blame not field crop use, but further investigation is needed.

“The data does not support any kind of restriction or ban on neonicotinoid seed treatment use, especially for field crops such as canola, pulses, cereals,” Ward said.

Soon after the PMRA 2016 decision to ban imidacloprid, farmers and industry stakeholders said restricted use of the neonicotinoid would cost the industry hundreds of millions of dollars.

In response to the PMRA decision, Agriculture Canada established a multi-stakeholder forum on neonicotinoids, which lead to the development to the EMWG.

Until last fall, the PMRA accepted submissions of new information that could influence its final decision on whether it will ban the use of imidacloprid.

Water testing results from the EMWG’s work last summer have been submitted to the PMRA for consideration.

“In January 2017, the PMRA provided the EMWG with parameters that needed to be addressed in order to generate scientifically robust environment water monitoring data. The generation of this data was quickly identified as the main focus area of the EMWG,” Ward said.

Provincial and Canadian grower associations provided most of the funding for the EMWG.

May 172018

Note:  During the public consultation for imidacloprid, approximately 46,000 comments were received.

Update on the Neonicotinoid Pesticides

19 December 2017
PDF Version – 125 K


This document provides a progress report on Health Canada’s Pest Management Regulatory Agency’s (PMRA) ongoing assessments of the neonicotinoid insecticides (last update on the Neonicotinoid Pesticides, 2017). The assessment of this group of insecticides is extremely complex and multi-faceted; a status update for each aspect of the assessments follows.


Declines in honeybee and other pollinator populations have generated considerable scientific and public interest both in Canada and internationally. A number of factors are seen as potential contributors to these declines and no single factor has been identified as the cause. The available science suggests that multiple factors acting in combination may be at play, including loss of habitat and food sources, diseases, viruses and pests, and pesticide exposure.

One group of pesticides, the neonicotinoids, is often linked to potential effects on pollinators. Neonicotinoids are a group of pesticides that are widely used in agriculture to protect crops from various insects. They are also used for other purposes, including killing insects in homes, controlling fleas on pets, and protecting trees from invasive insects such as the Emerald Ash borer. There are three important neonicotinoids currently approved for agricultural use in Canada, imidacloprid, clothianidin, and thiamethoxam.

Beginning in 2012 the PMRA began receiving large numbers of bee incident reports. The subsequent investigation and analysis of pesticide residues suggested that exposure to neonicotinoids in dust generated during the planting of treated corn or soybean seed with vacuum planters contributed to the mortalities observed. Before the 2014 planting season began, the PMRA, in collaboration with many stakeholders, worked to help ensure risk mitigation measures were communicated to growers across Canada and that a dust-reducing lubricant was readily available. The numbers of incidents reported between 2014 and 2017 during the planting period were between 70 and 92% lower, compared to 2013.

The PMRA continues to track and investigate bee mortality incidents with the support of the appropriate provincial ministry and plans to complete in 2018 a comprehensive analysis of the incidents that occurred between 2012 and 2016. Further information on the reported incidents between 2012 and 2016 can be found in the Health Canada document entitled Update on Bee Incident Reports 2012-2016.

Pollinator Assessments

The assessments of clothianidin, imidacloprid and thiamethoxam were announced in 2012 (Re-evaluation Note REV2012-02, Re-evaluation of Neonicotinoid Insecticides). These assessments were initiated to assess the potential risk to pollinators in light of international updates to the pollinator risk assessment framework, including information requirements. A Re-evaluation Note (REV2017-03, Re-evaluation of Neonicotinoid Insecticides: Update on Pollinator Risk Assessments) was published in January 2017 which provided an update on these assessments. The PMRA’s pollinator risk assessments have largely been conducted in collaboration with the United States Environmental Protection Agency and California Department of Pesticide Regulation and are nearing completion.

Current status of pollinator assessments

The PMRA has recently published proposed re-evaluation decisions for clothianidin and thiamethoxam and two proposed registration decisions. The validity period of these two pesticides was extended to allow time to complete the necessary public consultations. As a result of comprehensive scientific assessments of the effects of clothianidin and thiamethoxam on bees and other pollinators, we are proposing to phase out some uses of these pesticides. We are also proposing to further restrict other uses in cases where the acceptable risk to bees and other pollinators could not be demonstrated. The PMRA is currently consulting Canadians on these proposed regulatory decisions for 90 days.

The PMRA is updating the pollinator risk assessment for imidacloprid based on additional data from the registrant, additional literature that has recently been published, and the comments that were received during the public consultation period for the preliminary assessment (REV2016-05, Re-evaluation of Imidacloprid – Preliminary Pollinator Assessment). The PMRA expects to publish a proposed decision regarding imidacloprid pollinator safety in March 2018.

The PMRA will consider the information submitted during the consultation periods for these proposed decisions prior to making final decisions, which are expected to be published in late 2018.

Imidacloprid – Health and Environment Assessments

A human health risk assessment for imidacloprid was included in PRVD2016-20, Imidacloprid, published 23 November 2016. The health assessment did not identify human health concerns from any exposure route when used according to current label standards. An extensive body of information was considered for any potential toxicity and exposure, including sensitive populations such as children. To date, our assessments of the available data and published literature do not point to unacceptable risks to human health. The PMRA is also looking at the potential for neonicotinoids to affect other parts of the environment including aquatic life such as fish, insects, and other organisms. An environmental risk assessment for imidacloprid was included in PRVD2016-20. This assessment showed that, in aquatic environments in Canada, imidacloprid is being measured at levels that are harmful to aquatic insects. These insects are an important part of the ecosystem, including as a food source for fish, birds and other animals. For the protection of the environment, PMRA proposed to phase-out all the agricultural and a majority of other outdoor uses of imidacloprid over three to five years.

The assessment and proposed risk management was open to public consultation for 120 days, which was completed in March 2017. During the public consultation for imidacloprid, approximately 46,000 comments were received. These comments are currently being reviewed by PMRA. In addition, a Multi-Stakeholder Forum was facilitated by Agriculture and Agri-Food Canada to examine the use of neonicotinoids in agriculture. Federal and provincial government agencies, grower groups, independent researchers, non-government organizations (NGOs) and manufacturers have undertaken several initiatives including; examination of alternative risk management strategies, the generation of supplemental water monitoring data, and identification of potential alternative pest control products to replace imidacloprid. This information was formally submitted to the PMRA on 31 October 2017 and will be considered along with the information submitted during the consultation period before making a final decision on the acceptability of the continued use of imidacloprid in Canada in late 2018.

Clothianidin and Thiamethoxam – Assessment of Aquatic Risks

During the re-evaluation of imidacloprid, it was identified that clothianidin and thiamethoxam also occurred frequently and at comparable levels to imidacloprid in certain Canadian waterbodies in areas of intensive agriculture. Given the similarities in toxicity to imidacloprid, the PMRA prioritized the review of the potential risks to aquatic invertebrates (such as insects) for clothianidin and thiamethoxam in November of 2016 (REV2016-17, Initiation of Special Reviews: Potential Environmental Risk to Aquatic Invertebrates Related to the Use of Clothianidin and Thiamethoxam). Since then, environmental data relevant to the review of the neonicotinoids have been submitted by the registrants and some provincial government agencies. The PMRA received a large amount of additional neonicotinoid water monitoring data from agricultural use areas across Canada in October 2017. Discussion papers on possible ways to mitigate neonicotinoid exposure in the environment developed by a multi-stakeholder working group were also provided to the PMRA at that time. These data, along with available information from the open scientific literature will be considered prior to publishing proposed decisions for thiamethoxam and clothianidin in mid-2018. These documents will be open for public consultation.

Publication Schedule for the Neonicotinoid Assessments
Imidacloprid Clothianidin Thiamethoxam
Consultation on outcome of science reviews and proposed measures to protect pollinators March 2018 December 2017 December 2017
Final science reviews and decision on measures to protect pollinators December 2018 December 2018 December 2018
Consultation on outcome of science reviews and proposed measures to protect aquatic life July 2018 July 2018
Final Decision on measures to protect aquatic life December 2018 January 2020 January 2020
Date modified:
May 172018

By Robert Arnason

Scientists have conducted dozens of studies on neonicotinoid seed treatments and the potential impact on bee health.

Now, researchers at the University of Saskatchewan have found that canola seed coated with imidacloprid, a type of neonicotinoid, can be toxic to songbirds.

“Imidacloprid dosed birds exhibited significant declines in fat stores and body mass and failed to orient correctly,” the scientists wrote in a study published Nov. 9 in the journal Scientific Reports.

“These results suggest that wild songbirds consuming the equivalent of just four imidacloprid-treated canola seeds… per day over three days could suffer impaired condition, migration delays and improper migratory direction, which could lead to increased risk of mortality or lost breeding opportunity.”

Neonicotinoids, also known as neonics, are applied as a seed treatment to almost all of the canola and corn grown in North America and a portion of the soybean crop. The insecticides have been controversial, for years, because research suggests a link between neonics and bee colony losses.

Christy Morrissey, a U of Sask environmental toxicologist, wanted to know if neonics had an impact on songbirds.

Morrissey and her team fed imidacloprid-treated seed to white-crowned sparrows, a type of songbird, and compared the sparrows to a control group.

They also fed the sparrows granules of chlorpyrifos, an organophosate insecticide sold as Lorsban.

In a statement the scientists said the doses were realistic exposure for songbirds, which stop and feed on farmland during spring migration.

“What surprised us was how sensitive and rapid the effects were, particularly to imidacloprid,” Morrissey said in a statement. “The birds showed a significant loss of body mass and signs of acute poisoning (lethargy and loss of appetite). The migration trials also showed that birds completely failed to orient or changed their northward orientation.”

The chlorpyrifos insecticide didn’t reduce the sparrow’s body mass but it did impair sense of direction.

“These chemicals are having a strong impact on songbirds,” said Margaret Eng, a post-doctoral researcher in Morrissey’s lab. “We are seeing significant weight loss and the birds’ migratory orientation being significantly altered.”

A spokesperson for Bayer, which manufactures imidacloprid, said the study is misleading because it doesn’t represent real world conditions for white-crowned sparrows in Western Canada.

“The repellent properties of the seed treatment would normally deter birds from ingesting whole canola seeds treated with imidacloprid … previous studies of caged birds indicated a lack of interest in imidacloprid treated seed if other food sources were available,” said Paul Thiel, vice-president of product development and regulatory science for the crop science division of Bayer in Canada.

“Scientific evidence clearly shows that imidacloprid has minimal environmental impact when used according to the label, including ingestion by seed-eating songbirds.”

Thiel added that imidacloprid is rarely used as a seed treatment for canola, which severely reduces potential exposure.

Regardless, the U of Saskatchewan findings could affect the future of imidacloprid.

In November 2016 Health Canada proposed to ban imidacloprid because the insecticide was accumulating in water near agricultural land.

That was reportedly putting aquatic insects at risk and threatening animals that rely on those insects for food.

The proposal was controversial in Canada’s agriculture sector. The Bayer product was once the most popular insecticide in the world. It is used as a seed treatment on field crops, but is very important to fruit, vegetables and potato producers in Canada.

On the Prairies, it’s used on wheat crops to control wireworm.

The public and ag industry reps submitted comments on Health Canada’s proposed ban. Over the last year, government scientists have been reviewing the comments and gathering more data on imidacloprid and its impact on aquatic insects.

Health Canada may announce its plans for imidacloprid in December, but the department hasn’t committed to a timeline for a final decision.

May 172018

by Robert Arnason

Health Canada proposed last November to ban imidacloprid, an insecticide applied to fruit, vegetables, potatoes and many other crops across the country.

Twelve months have passed since the announcement, but Canadian farmers who use the insecticide will have to wait another year to know if it’s banned or not.

“Health Canada is reviewing an extensive amount of data and information, including recently submitted water monitoring data,” a Health Canada spokesperson said.

“Once this information is reviewed, the proposed decisions will be subject to a public consultation period and final decisions are anticipated by December 2018.”

Health Canada’s Pest Management Regulatory Agency has proposed phasing out agricultural and outdoor uses of imidacloprid over three to five years. The PMRA said the phase-out is necessary because the insecticide was accumulating in water near agricultural land.

The concentrations in water were reportedly putting aquatic insects at risk and threatening animals that rely on those insects for food.

The mode of action of imidacloprid is similar to two other neonicotindoids: clothianidin and thiamethoxam. Those products are used as a seed treatment on nearly every canola and corn crop grown in North America and a portion of the soy crop.

PMRA scientists are also reviewing those insecticides to determine if they threaten aquatic life.

A number of agricultural groups have said banning imidacloprid is an extreme response because other policies could limit the use of the insecticide and reduce the threat to aquatic insects.

Many growers depend on the Bayer product for insect control. Fruit, vegetable and potato producers are the main users of imidacloprid, but prairie growers use it on wheat crops to control wireworm.

The PMRA is going slow with its decision on imidacloprid, which gives scientists time to publish new research on the insecticide.

In November, toxicologists at the University of Saskatchewan released a paper on imidacloprid and songbirds in Scientific Reports.

The scientists fed canola seed coated with imidacloprid to white-crowned sparrows. They observed detrimental effects in birds that consumed only four canola seeds.

“These chemicals are having a strong impact on songbirds,” said Margaret Eng, a post-doctoral researcher who led the U of S study.

“We are seeing significant weight loss and the birds’ migratory orientation being significantly altered.”

The toxicologists said exposure to imidacloprid could compromise the health of songbirds and their ability to reproduce.

A spokesperson for Bayer said the study is misleading because it doesn’t represent real world conditions for white-crowned sparrows.

“The repellent properties of the (insecticide) seed treatment would normally deter birds from ingesting whole canola seeds treated with imidacloprid,” said Paul Thiel, vice-president of product development and regulatory science for the crop science division of Bayer in Canada.

“Previous studies of caged birds indicated a lack of interest in imidacloprid treated seed if other food sources were available.”

Thiel said imidacloprid is rarely used as a seed treatment for canola, reducing the chance of birds eating such seeds.

A Health Canada spokesperson said PMRA scientists are considering the U of S study.

“It is too early to tell what impact it may have on the final decision.”

May 172018

This information is available and known.  Wikipedia has a write-up, with sources foot-noted.


From Wikipedia.   Imidacloprid. 

The last item is:

Neonicotinoids banned by the European Union

In February 2018, the European Food Safety Authority published a new report indicating that neonicotinoids pose a serious danger to both honey bees and wild bees.[51] In April 2018, the member states of the European Union decided to ban the three main neonicotinoids (clothianidin, imidacloprid and thiamethoxam) for all outdoor uses.[52]


SELECTED OTHER HEADINGS (go to the URL for more):

Bees and other insects

To members of the species Apis mellifera, the western honey bee, imidacloprid is one of the most toxic chemicals ever created as an insecticide. The acute oral LD50 of imidacloprid ranges from 5 to 70 nanograms per bee.[24] Honeybee colonies vary in their ability to metabolize toxins, which explains this wide range. Imidacloprid is more toxic to bees than the organophosphate dimethoate (oral LD50 152 ng/bee) or the pyrethroid cypermethrin (oral LD50 160 ng/bee).[24] The toxicity of imidacloprid to bees differs from most insecticides in that it is more toxic orally than by contact. The contact acute LD50 is 0.024 µg active ingredient per bee.[25]

Imidacloprid was first widely used in the United States in 1996 as it replaced three broad classes of insecticides. In 2006, U.S. commercial migratory beekeepers reported sharp declines in their honey bee colonies. Such declines had happened in the past; however unlike as was the case in previous losses, adult bees were abandoning their hives. Scientists named this phenomenon colony collapse disorder (CCD). Reports show that beekeepers in most states have been affected by CCD.[26] Although no single factor has been identified as causing CCD, the United States Department of Agriculture (USDA) in their progress report on CCD stated that CCD may be “a syndrome caused by many different factors, working in combination or synergistically.”[27] Several studies have found that sub-lethal levels of imidacloprid increase honey bee susceptibility to the pathogen Nosema.[28][29][30]

Dave Goulson (2012) of the University of Stirling showed that trivial effects of imidacloprid in lab and greenhouse experiments can translate into large effects in the field. The research found that bees consuming the pesticide suffered an 85% loss in the number of queens their hives produced, and a doubling of the number of bees who failed to return from food foraging trips.[31][32]

Lu et al. (2012) reported they were able to replicate CCD with sub-lethal doses of imidacloprid. The imidacloprid-treated hives were nearly empty, consistent with CCD, and the authors exclude Varroa or Nosema as contributing causes.[33]

In May 2012, researchers at the University of San Diego released a study showing that honey bees treated with a small dose of imidacloprid, comparable to what they would receive in nectar and formerly considered a safe amount, became “picky eaters,” refusing nectars of lower sweetness and preferring to feed only on sweeter nectar. It was also found that bees exposed to imidacloprid performed the “waggle dance,” the movements that bees use to inform hive mates of the location of foraging plants, at a lower rate.[34]

Researchers from the Canadian Forest Service showed that imidacloprid used on trees at realistic field concentrations decreases leaf litter breakdown owing to adverse sublethal effects on non-target terrestrial invertebrates. The study did not find significant indication that the invertebrates, which normally decompose leaf litter, preferred uncontaminated leaves, and concluded that the invertebrates could not detect the imidacloprid.[35]

A 2012 in situ study provided strong evidence that exposure to sublethal levels of imidacloprid in high fructose corn syrup (HFCS) used to feed honey bees when forage is not available causes bees to exhibit symptoms consistent to CCD 23 weeks post imidacloprid dosing. The researchers suggested that “the observed delayed mortality in honey bees caused by imidacloprid in HFCS is a novel and plausible mechanism for CCD, and should be validated in future studies”.[36][37]

Sublethal doses (<10 ppb) to aphids have been found to lead to altered behavior, such as wandering and eventual starvation. Very low concentrations also reduced nymph viability.[38] In bumblebees exposure to 10 ppb imidacloprid reduces natural foraging behaviour, increases worker mortality and leads to reduced brood development.[39] A 2013 study showed that bumblebee colonies exposed to 10 ppb of imidacloprid started failing after three weeks when the death rate increased and the birth rate decreased. The researchers attributed this to exposed colonies performing essential tasks, such as foraging, thermoregulation and brood care, less well than unexposed colonies.[40] This suggests that sublethal imidacloprid causes colony failure through reduced colony function.

In January 2013, the European Food Safety Authority stated that neonicotinoids pose an unacceptably high risk to bees, and that the industry-sponsored science upon which regulatory agencies’ claims of safety have relied might be flawed, concluding that, “A high acute risk to honey bees was identified from exposure via dust drift for the seed treatment uses in maize, oilseed rape and cereals. A high acute risk was also identified from exposure via residues in nectar and/or pollen.”[41] An author of a Science study prompting the EFSA review suggested that industry science pertaining to neonicotinoids may have been deliberately deceptive, and the UK Parliament has asked the manufacturer Bayer Crop Science to explain discrepancies in evidence they have submitted to an investigation.[42]


In bobwhite quail (Colinus virginianus), imidacloprid was determined to be moderately toxic with an acute oral LD50 of 152 mg a.i./kg. It was slightly toxic in a 5-day dietary study with an acute oral LC50 of 1,420 mg a.i./kg diet, a NOAEC of < 69 mg a.i./kg diet, and a LOAEC = 69 mg a.i./kg diet. Exposed birds exhibited ataxia, wing drop, opisthotonos, immobility, hyperactivity, fluid-filled crops and intestines, and discolored livers. In a reproductive toxicity study with bobwhite quail, the NOAEC = 120 mg a.i./kg diet and the LOAEC = 240 mg a.i./kg diet. Eggshell thinning and decreased adult weight were observed at 240 mg a.i./kg diet.[11][13]

Imidacloprid is highly toxic to four bird species: Japanese quail, house sparrow, canary, and pigeon. The acute oral LD50 for Japanese quail (Coturnix coturnix) is 31 mg a.i./kg bw with a NOAEL = 3.1 mg a.i./kg. The acute oral LD50 for house sparrow (Passer domesticus) is 41 mg a.i./kg bw with a NOAEL = 3 mg a.i./kg and a NOAEL = 6 mg a.i./kg. The LD50s for pigeon (Columba livia) and canary (Serinus canaria) are 25–50 mg a.i./kg. Mallard ducks are more resistant to the effects of imidacloprid with a 5-day dietary LC50 of > 4,797 ppm. The NOAEC for body weight and feed consumption is 69 mg a.i./kg diet. Reproductive studies with mallard ducks showed eggshell thinning at 240 mg a.i./kg diet.[11][13] According to the European Food Safety Authority, imidacloprid poses a potential high acute risk for herbivorous and insectivorous birds and granivorous mammals. Chronic risk has not been well established.[13][16] The hypothesis that imidacloprid has a negative impact on insectivorous bird populations is supported by a study of bird population trends in the Netherlands, where correlation has been identified between surface-water concentrations of imidacloprid and population decline. At imidacloprid concentrations of more than 20 nanograms per litre, bird populations tended to decline by 3.5 per cent on average annually.[43] Additional analyses in this study revealed that spatial pattern of bird population decline appeared only after the introduction of imidacloprid to the Netherlands, in the mid-1990s, and that this correlation is not linked to any other land usage factor.

Aquatic life

Imidacloprid is highly toxic on an acute basis to aquatic invertebrates, with EC50 values = 0.037 – 0.115 ppm. It is also highly toxic to aquatic invertebrates on a chronic basis (effects on growth and movement): NOAEC/LOAEC = 1.8/3.6 ppm in daphnids; NOAEC = 0.001 in Chironomus midge, and NOAEC/LOAEC = 0.00006/0.0013 ppm in mysid shrimp. Its toxicity to fish is relatively low; however, the EPA has requested review of secondary effects on fish with food chains that include sensitive aquatic invertebrates.[8]

May 172018

By Robert Arnason

Health Canada won’t issue a final decision on whether it will ban imidacloprid for at least six months, says a horticultural industry representative.

Last November, the Pest Management Regulatory Agency proposed to ban the use of imidacloprid, a neonicotinoid insecticide, because it was accumulating in water near agricultural land. That was reportedly putting aquatic insects at risk and threatening animals that rely on those insects for food.

Craig Hunter, who works in research and crop protection with the Ontario Fruit and Vegetable Growers Association, said the PMRA is considering more information before it makes a decision.

“Their plan is to make their final determination by December…. and probably be published by the spring of (2018).”

A Health Canada spokesperson didn’t provide a date for the final decision. The public and agriculture industry representatives submitted comments about the PMRA proposal from late November until the last week of March. Health Canada experts continue to review that information.

“We’ve received a significant number of comments (during) the consultation period,” the spokesperson said. “We’re still going through them, so we can’t give on timeline on when to expect a final decision.”

The Bayer product was once the most popular insecticide in the world. It is used as a seed treatment on field crops, but is very important to fruit, vegetables and potato producers in Canada.

On the Prairies it’s used on wheat crops to control wireworm.

Environment Canada data, from 2012-14, showed that imidacloprid concentrations were highest in creeks and streams in southern Ontario, particularly in areas with intensive vegetable, fruit and grape production.

Health Canada also used computer modelling to estimate imidacloprid levels in water bodies in other parts of Canada.

Many grower associations told the PMRA, an agency operating under Health Canada, that nationwide phase-out of imidacloprid, over five years, was too severe and there wasn’t sufficient evidence to justify such a ban.

With the comment period over, Health Canada continues to gather more data on imidacloprid levels in ponds and wetlands.

“There’s been a huge increase in the effort for monitoring (water bodies) this year, in various parts of the country,” Hunter said.

“They will wait for the data from that. Hopefully that will all get in by October.”

At this stage, it’s hard to know what Health Canada will do, but Hunter is feeling somewhat optimistic that the PMRA will revise its initial decision.

They might ban the use of imidacloprid in certain geographies, where there is a greater risk of it accumulating in water.

“Other areas where they’re not finding anything of concern, OK, those uses can continue,” Hunter said. “So it (might) be by area and not necessarily by crop…. That would be my guess.”

The PMRA decision on imidacloprid is significant because the agency is also evaluating two other neonicotinoids and their impact on aquatic insects.

Those neonics, clothianidin and thiamethoxam, are applied as a seed treatment to almost all of the corn and canola acres in Canada, and a portion of the soybean crop.

Hunter said the decision on imidacloprid could be a “bellwether” for the other neonics.



May 172018


Boston, MA – The likely culprit in sharp worldwide declines in honeybee colonies since 2006 is imidacloprid, one of the most widely used pesticides, according to a new study from Harvard School of Public Health (HSPH).

The authors, led by Chensheng (Alex) Lu, associate professor of environmental exposure biology in the Department of Environmental Health, write that the new research provides “convincing evidence” of the link between imidacloprid and the phenomenon known as Colony Collapse Disorder (CCD), in which adult bees abandon their hives.

The study will appear in the June issue of the Bulletin of Insectology.

“The significance of bees to agriculture cannot be underestimated,” says Lu. “And it apparently doesn’t take much of the pesticide to affect the bees. Our experiment included pesticide amounts below what is normally present in the environment.”

Pinpointing the cause of the problem is crucial because bees—beyond producing honey—are prime pollinators of roughly one-third of the crop species in the U.S., including fruits, vegetables, nuts, and livestock feed such as alfalfa and clover. Massive loss of honeybees could result in billions of dollars in agricultural losses, experts estimate.

Lu and his co-authors hypothesized that the uptick in CCD resulted from the presence of imidacloprid, a neonicotinoid introduced in the early 1990s. Bees can be exposed in two ways: through nectar from plants or through high-fructose corn syrup beekeepers use to feed their bees. (Since most U.S.-grown corn has been treated with imidacloprid since 2005, it’s also found in corn syrup.)

In the summer of 2010, the researchers conducted an in situ study in Worcester County, Mass. aimed at replicating how imidacloprid may have caused the CCD outbreak. Over a 23-week period, they monitored bees in four different bee yards; each yard had four hives treated with different levels of imidacloprid and one control hive. After 12 weeks of imidacloprid dosing, all the bees were alive. But after 23 weeks, 15 out of 16 of the imidacloprid-treated hives—94%—had died. Those exposed to the highest levels of the pesticide died first.

The characteristics of the dead hives were consistent with CCD, said Lu; the hives were empty except for food stores, some pollen, and young bees, with few dead bees nearby. When other conditions cause hive collapse—such as disease or pests—many dead bees are typically found inside and outside the affected hives.

Strikingly, said Lu, it took only low levels of imidacloprid to cause hive collapse—less than what is typically used in crops or in areas where bees forage.

Scientists, policymakers, farmers, and beekeepers, alarmed at the sudden losses of between 30% and 90% of honeybee colonies since 2006, have posed numerous theories as to the cause of the collapse, such as pests, disease, pesticides, migratory beekeeping, or some combination of these factors.

This study was supported by a grant funded by Harvard University Center for the Environment.

In Situ Replication of Honey Bee Colony Collapse Disorder,” Chensheng Lu, Kenneth M. Warchol, Richard A. Callahan, Bulletin of Insectology, June 2012

For more information:

Todd Datz

May 162018

In follow-up to  (2018-01-15)   Input to Govt: How can the Criminal Justice system be changed to better suit Canadians?,

the Government Report “What we heard . . . ”  is at

I have so far only skimmed “The Conclusions“.

I want to know what is envisioned by:

collaborative approaches that partner with social systems, the private sector, and others in the criminal justice system . . .  

I read “the private sector” as “the corporate sector”.   Corporate values are fine in the Commercial sphere of a society – – it’s where they belong.  They are NOT okay in the sphere of Governance.  Business values are DIFFERENT from, and do not serve the public interest.

We are deliberately setting up conflicts-of-interest

against which Laws have been written,

SPECIFICALLY because of the CORRUPTION of Governance that always results.  

See  Thinkers of the Day on the Unholy Alliances between Government (public institutions) and Industry

Somewhere on this blog I have posted the experience in the U.S. with the intrusion of the “private sector” into the justice system.

I need to make time to read and digest this Report on the Public Consultations.   And the Government’s “next steps”.

Also need to look for the reactions of other citizens to the Report.    Please use the Comments below to share your thoughts.   Thanks!   /Sandra

May 112018 

Suncor Energy files application for 160,000-bpd Lewis oilsands project


Geoffrey Morgan


CALGARY – Canada’s largest integrated energy company has filed an application for a massive new oilsands project defying expectations of slowing growth in the oilsands.


The Alberta Energy Regulator issued a notice Tuesday that Suncor Energy Inc. is seeking regulatory approval to build a 160,000-barrels-per-day steam-based oilsands project north of Fort McMurray called Lewis. The project would not require federal approval from the National Energy Board, which Ottawa is currently reorganizing.


Regulatory filings from Calgary-based Suncor show the project – which would be built in four identical 40,000-bpd phases – would cost $6.2 billion in total and the company hopes to begin construction in 2024, with oil production starting 2027.


“This is a growth project,” Suncor spokesperson Erin Rees said in an email, adding that the company has not officially sanctioned the project.

In its application, Suncor said the project would contribute almost $3.4 billion to Alberta’s GDP and employ an average of 580 construction workers per year and 1,000 construction workers at its peak it 2027 and 2028.


The permit will help Suncor plan its next projects to replace the production that will end in the 2030s, according to one analyst.


“The life of mine plans show production ending. It’s so far away that nobody really thinks about it, but it’s probably a decade of planning,” GMP FirstEnergy analyst Michael Dunn said of the mine retirement.


He said Suncor is looking at ways to boost production so that its oilsands upgrading facilities — vital for the company to get a higher price for its bitumen — will continue to be fully utilized.


“All these things go into the decision-making,” Dunn said, adding that Suncor will need to look at replacing its production from its base mine potentially through lease swaps with Syncrude or through new projects.


The Lewis project’s timeframe aligns with Suncor’s efforts to boost production ahead of the anticipated closure of the company’s main mining operation north of Fort McMurray in the early 2030s. Suncor’s detailed mine plans, and the AER’s tailings plans, show the company’s primary mining operations will wrap up in 2033.

“With Suncor’s Oil Sands Base Plant approaching end of mine life (2033), the AER is concerned with the length of time remaining to resolve Suncor’s site-specific issues,” an AER report from Oct. 2017 states. The AER approved Suncor’s plan to address those issues the regulator had identified.


Suncor produced 296,700 bpd from mining operations in the fourth quarter of 2017, which accounts for roughly 55 per cent of the company’s operated oilsands production with the balance coming from steam-based projects.


Suncor has also recently boosted its stake in the Syncrude oilsands mining venture to 58 per cent and is also ramping up production at its recently completed $17-billion Fort Hills project – neither of those projects will expire in the 2030s.


During an earnings call this month, Suncor president and CEO Steve Williams described the Lewis project – and the company’s Meadow Creek East and Meadow Creek West projects – as the next wave of growth for Suncor, beginning at the end of 2022. “You will start to see one of those come on every 12 to 24 months,” Williams said.


At the time he said those “replication” projects would drive growth for Suncor rather than investment in major new projects and blasted Canada’s current regulatory and tax framework as being too burdensome for major projects like its recently completed $17 billion Fort Hills mine.


Financial Post