PMRA Call for Comments on bees and neonicotinoids, this is from the current newsletter from the Ontario beekeepers, (OBA)

http://www.ontariobee.com/

PMRA has recently released a consultation document putting forward a plan to protect bees from exposure to neonicotinoid pesticides. The report says, in part:

“PMRA has determined that current agricultural practices related to the use of neonicotinoid treated corn and soybean seed are affecting the environment due to their impacts on bees and other pollinators….

In the spring and summer of 2012, we received a significant number of pollinator mortality reports mainly from corn growing regions of Ontario and Quebec. Areas of high corn production correlated well with the locations of bee mortalities. Approximately 70% of the affected dead bee samples tested positive for residues of neonicotinoid insecticides used to treat corn seeds while neonicotinoids were only detected in unaffected bees in one sample at very low levels. We concluded that the majority of pollinator mortalities were a result of exposure to neonicotinoid insecticides, likely through exposure to contaminated dust generated during the planting of treated corn seed. The unusually warm and dry weather conditions were thought to be a contributing factor…

However, in spring 2013 with more typical weather patterns, we continued to receive a significant number of pollinator mortality reports from both corn and soybean growing regions of Ontario and Quebec, as well as Manitoba. Consequently, we have concluded that current agricultural practices related to the use of neonicotinoid treated corn and soybean seed are not sustainable.”

 
The report goes on to provide their intention to implement additional measures, including labelling with enhanced warnings, safer lubricants and planting practices as well as more analysis.

While we greatly appreciate PMRA’s analysis of the issue and commitment to consultation and action, we are disappointed that removing these pesticides from use is not one of the options presented.

We intend to respond and to point out that continued use of neonicotinoid pesticides poses an unacceptable likelihood of serious, imminent harm to honey bees and native pollinators, that it could have a negative impact on agriculture by limited pollination services and that it reduces pollination of wild plants in a way that may alter ecosystems.

As well, that simply reducing the spread of dust from neonicotinoid-coated seeds during planting (which research shows amounts to less than 2% of the pesticide load), will not prevent toxic build up in the soil. Nor will it prevent the spread of these water-soluble chemicals to ponds or other sources of water that bees and other insects access during spring and summer. We will be asking that these toxic chemicals be removed from use.

We encourage you to add your voice to this discussion by responding to their report through this email address. You will need to provide your name, phone number and email address along with your comments. The deadline is December 12th. We’ll share our full submission with you when it’s ready.

Petition!

More than 45,000 people have signed the petition so far!
OBA’s petition to ban neonicotinoid pesticides has now passed 41,000 signatures on-line and more than 4,000 in hard copy thanks to the efforts of many of you who signed it or brought it to events or farm markets. This will significantly strengthen our case with the Government of Ontario. We are currently reviewing our options for delivery when we pass 50,000 and will let you know how we plan to provide the signatures to the Premier. (It’s not too late to sign or circulate to friends (www.change.org/SaveOntariosBees) if you haven’t already!)

But this level of public support is gratifying for another reason. As we make progress on our efforts to take these pesticides off the market, we get more pressure from those with neonicotinoid interests who, as part of their strategy, encourage individuals – even other beekeepers – to contradict or criticize us. Differences of opinion are one thing (of course we don’t expect everyone to agree with us) but those who want to ‘stir the pot’ by circulating inaccurate or incomplete information or questioning the integrity of the OBA, its individual board members or its partners, will not distract us from the information-based, collaborative, respectful approach we have chosen to take. As we tell our children, doing the right thing isn’t always easy.

On the other hand, the encouragement and support we get from our members, farmers and some farm groups, the general public and others far outweighs the criticism. Usually even those who may not agree will ask questions and listen to our point of view. We are often invited to present to groups who are open to information. That’s all we can ask. So if you get questions, or wish to have more information to discuss this important topic, you can go to http://www.ontariobee.com/neonics for our position, the science and other resources. Let us know if you need any more background materials and please share with us what your experience has been regardless of your point of view