Status of Policy Issue: Crop Protection Product Regulation

Policy Issue: Lambda-Cyhalothrin 

In April 2021, Canada’s Pest Management Regulatory Agency’s (PMRA’s) re-evaluation decision cancelled all feed uses for Lambda-Cyhalothrin and provided two-years (April 2023) for the decision to come into force (i.e. feed uses to be removed from the label). Food uses were maintained. As canola seed is processed for food and feed, the decision is viewed as unworkable and not practical in a bulk handling system. The anticipated implementation and compliance difficulties were expressed to PMRA by various members of the grains value chain including by provincial and national canola associations.

The lead registrant (Syngenta) applied to re-instate feed uses in September 2021 and was anticipating a decision in advance of the 2023 growing season. The Canola Council of Canada and Canadian Canola Growers Association communicated to PMRA the importance of Lambda-Cyhalothrin in December 2021, asking for an expeditious review to avoid label confusion and to prevent its loss for canola famers in 2023.

Indications from the PMRA to-date suggest a decision is unlikely to be made in time for the 2023 season. As a result, Syngenta announced Matador will not be available in Western Canada in 2023 and is working to have it available again in 2024. ADAMA has also paused their 2023 plans for Silencer and Zivata, is recalling its existing stock and has stopped taking new orders while they consult with industry. While there are alternative products on the market, questions remain about availability/supply.

Current status:

• The Pest Management Regulatory Agency’s (PMRA) re-evaluation decision regarding lambda-cyhalothrin (e.g., Matador, Silencer, LaBamba, etc.) came into force on April 29, 2023. The new and updated label for lambda-cyhalothrin indicates that crops treated with lambda-cyhalothrin cannot be used as livestock feed in Canada. This includes any harvested grain, seed screenings, meal, by-products or aftermath. As any crop entering the grain handling system is eligible for use as livestock feed, this poses a risk of becoming an off-label use. Keep it Clean provides tips to help keep your crops market-ready.

• What is the Canola Council of Canada’s advice regarding the use of lambda-cyhalothrin products for canola this growing season? Unless a grower is certain that their canola will be utilized solely for export or human consumption, they may encounter challenges remaining compliant with label directions when marketing a lambda-cyhalothrin-treated crop this growing season. The advice for growers is to seek certainty regarding the use of their harvested canola, and if they can receive assurance that it will be used solely for export or human consumption, then they will be compliant with label directions. However, in the absence of that certainty, and if there is a possibility that some of that canola or its screenings/aftermath will find its way into the domestic livestock feed market, at this time and until this issue gets addressed and resolved, we are advising growers to use alternative products that are on the market to help them address insect pest pressure they may face.

• Are there alternatives to lambda-cyhalthorin for controlling pests in canola? Yes. More information on alternative insecticide options for canola, cereals and pulses in Western Canada can be found in this collaborative publication from SaskCrops. Canola growers can also reach out to their local Canola Council of Canada agronomist or refer to the Canola Encyclopedia for complete insect management information. For further information, please refer to the Saskatchewan crop protection guide.

• Is lambda-cyhalothrin still on the market in Western Canada? Yes, lambda-cyhalothrin is on the market in 2023.

Looking forward:

Outreach to government is underway and ongoing to communicate the importance of Lambda-Cyhalothrin to the grain and livestock sectors, to support the importance of the PMRA’s review of Syngenta’s application to reinstate feed uses and to determine how compliance and enforcement will be managed. Provincial canola associations are also reaching out provincially.

Policy Issue: Pest Control Products Act

The Government of Canada is currently consulting on its approach to pesticide regulation in Canada. Changes to the pesticide regulatory system could impact farmers’ access to the latest pest control products they need to compete and thrive. It it critical that agriculture is represented and farmers’ voices are heard.

Actions taken:

• Advancing Agriculture launched a digital letter-writing campaign in response to Health Canada’s 60-day public consultation on changes to the Pest Control Products Act. Farmers can sign and submit a letter today by clicking here.

• In response, SaskCrops’ submission emphasized that Canada’s science-based, regulatory framework for pesticides is among the best in the world and already addresses several of the transformation objectives proposed by Health Canada through its operation. SaskCrops remains supportive of a fully transparent process and notes that it is important that any transformative processes do not draw scare PMRA resources away from core PMRA work making crop protection tools available to farmers. CCGA also replied with a submission, re: PMRA Notice of Intent NOI2023-01, Strengthening the regulation of pest control products in Canada.

Policy Issue: Neonicotinoids

Health Canada launched a special review of the neonicotinoids (neonics) in 2016, leading to a 2018 preliminary decision calling for a phased-in ban on outdoor use of the chemicals because of their potential negative impact on aquatic insects.

In March 2021, Canada’s Pest Management Regulatory Agency (PMRA) released its decision on clothianidin and thiamethoxam, and announced that neonics are not a threat to aquatic insects when used as a seed treatment on canola and in many other instances.

Actions taken:

• CCC, along with CCGA and SaskCanola’s policy team, advocated for PMRA to review additional data.

• SaskCanola, Sask Wheat and Sask Pulse Growers were instrumental in funding research that demonstrated very low levels of neonicotinoids in provincial water bodies. Because of these activities, PMRA’s final decision found that use of these products by canola farmers does not pose an unacceptable risk to aquatic invertebrates, and that these products can continue to be safely used as a seed treatment on canola in Canada.

Looking forward:

Working with our partners in the Canola industry, SaskCanola continues to ensure that canola growers have the tools they need to sustainably and responsibly grow their crops.