Key issue: Crop protection
Section Chair: Charles Stevens
The OFVGA recognizes changing public attitudes towards the use of crop protection and supports the safe and responsible use of these products.
OFVGA works closely with organizations such as Farm & Food Care who advocate this same responsible approach.
Members of OFVGA's crop protection section committee deal with a variety of issues affecting crop protection, including registrations and availability of products, relations with the federal Pest Management Regulatory Agency, identifying research needs, grower education and certification and ensuring a science-based approach to crop protection regulation.
Crop protection issues the OFVGA is currently involved with:
New pests that threaten fruit and vegetable crops are constantly emerging. Some of the latest are:
Spotted Wing Drosophila (SWD) is an invasive vinegar or small fruit fly from Asia that was first identified in California in 2008 and has spread rapidly through North America’s fruit-producing regions. Most small fruit flies lay their eggs in damaged or decaying fruit but SWD attacks healthy, immature fruit that is just beginning to ripen. This means that eggs or larvae can be found in affected fruit at harvest, such as tender fruit and berry crops, as well as some grape varieties. There are many wild hosts as well, like dogwood, yew and honeysuckle, making SWD a landscape-level pest.
The populations grow with the season, so late-harvest crops like fall raspberries, blueberries, blackberries and day-neutral strawberries can be at a higher risk. The Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA) began surveying for SWD presence in Ontario in 2011.
Brown Marmorated Stink Bug comes from Asia and is already causing damage in the United States, including Pennsylvania, Virginia, New Jersey etc. It has many different hosts, including field and horticulture crops. Through monitoring in Ontario, it has been found in Hamilton, London, Niagara-On-The-Lake, Essex and Newboro near Kingston as mainly homeowner finds. BMSB likes to overwinter in houses in adult stage. OMAFRA is watching it closely and a monitoring project is underway.
For more information on emerging pests: http://www.omafra.gov.on.ca/english/crops/insects/insects.html
Grower Requested Own Use (GROU) program
GROU (Grower Requested Own Use) is a federal government program that allows growers to import the US version of Canadian-registered crop protection products for their own use should they be available in the US at a lower price than in Canada.
The Pest Management Regulatory Agency (PMRA) evaluates all nominated products to determine their eligibility for the program. The GROU Nomination Committee selects high priority products and requests that PMRA make them available for import.
Once a product has been approved for import, growers must submit an application for a GROU Import Certificate along with the container label and proof of participation in an acceptable container disposal program to the PMRA prior to being able to bring it into Canada. GROU products can only be purchased and imported by growers for their own use on their land and for one growing season only.
For more information, including a list of products approved under the program: http://www.hc-sc.gc.ca/cps-spc/pest/agri-commerce/import/_grou-piapda/index-eng.php
Several years ago, the Regulatory Co-operation Council (RCC) launched a process to harmonize regulatory processes for crop protection products between Canada and the United States is ongoing. This would give growers on both sides of the border equal access to products.
The OFVGA and the Canadian Horticultural Council adopted the following definition for a North American label that they feel is reflective of the intent of the RCC process: A common Canada-United States label on all new actives thereby giving growers of Canada and the USA equal access to all new registrations at the same time on the same crops with the same restrictions with the same MRLs and with Canada-United States access.
In 2014, the Canadian Pesticide Advisory Committee has been working on developing action plans for implementation of regulatory harmonization between Canada and the United States. Fourteen topics are being addressed and a sub-committee worked on proposals for each topic with respect to implementation.
The Ontario government has launched consultations with respect to upcoming legislation to restrict the use of neonicotinoid by farmers starting in 2016.
OFVGA is responding through Farm & Food Care and Farm Action Now.
Click here for the OFVGA submission to the Environmental Bill of Rights regarding pollinator health and neonicotinoid pesticides.
More information about the consultations is available here: http://www.omafra.gov.on.ca/english/pollinator/meeting-reg.htm
Canadian bee health fact sheet: http://www.farmfoodcare.org/images/pdfs/BeeHealthfactsheet.pdf
The re-evaluation of crop protection products the Pest Management Regulatory Agency (PMRA) is ongoing. The CHC Crop Protection Committee works to submit responses to each product re-evaluation with respect to the importance of the product in question to the industry and how the product is applied in edible horticulture.
The OFVGA’s response has been focused on toxicological perspectives with regards to worker exposure platforms and has been meeting with PMRA on this issue as it relates to re-evaluation of crop protection products.
Crop protection report to the 2014 OFVGA annual general meeting
This is now my 6th year dealing with the vast issues in horticultural crop protection. How time flies when you’re having fun, but many of our issues remain the same. The more regulated crop protection materials are, the greater the need for action on the part of the growers. This report will address the major issues in horticultural crop protection such as: harmonization of labels; re-evaluation of horticultural crop protection materials, invasive species, the GROU program and Neonicatinoid pesticides and bees.
The Regulatory Corporation Council addresses the harmonization of crop protection materials between the United States and Canada. It became clear that the main goal is to increase trade between the two countries and the efforts are focused on MRLs. Through joint submissions, the use of label expansions and fully aligned labels, harmonized MRL will happen. Agreements between PMRA and EPA are continuing to happen. Because the agreements between these two bodies are ongoing, joint review projects are increasing thereby reducing the cost of crop protection material in both countries. This is good for government, registering companies and the growers. As in any industry, the growers and representing organizations; in the name of fair trade, will encourage and help this process but we need fully harmonized labels in order to give our growers a level playing field. To this effect, both the OFVGA and CHC boards have put into policy the grower definition of crop protection harmonization. To define: Harmonization refers to “a common Canada-United States label on all new actives thereby giving growers of Canada and the USA equal access to all new registrations at the same time on the same crops with the same restrictions with the same MRLs and with Canada-United States access”. This essentially will give the growers of Ontario and Canada a level playing field for one of its major technologies used in growing crops. A meeting is currently being arranged to begin the lobbying with the Federal Health Ministry’s Director of Strategic Policy. To this PMRA has asked for our input on major obstacles to harmonization. Occupational health is of major concern. If we can harmonize MRLs we can harmonize our labels. Harmonization would solve a lot of major issues involving crop protection in Canada. Before I leave this section, I wish to thank PMRA and PMC for their positive relationship working together with EPA an IR4 in the United States.
The re-evaluation of crop protection materials has a major impact on our farms through either loss of that material or a change in labels so that the materials are no longer effective. With the re-evaluation prepared by PMRA, CPAC is the committee that then complies, writes and presents comments on behalf of the commodities of concern. Provincial government, registrants and provincial commodity organizations also provide detailed comments and input. A lack of grower input from some commodity groups for potential lost products is of concern, as the grower is the one with the most to lose. Only the grower has a clear picture of use patterns in their commodities, and this information can make the difference between the loss of the use of a crop protection material to a commodity or not. We often criticize PMRA for its decision, but if we do not present facts on how a product is used, and are important to us, we can only blame ourselves for the loss.
The recent evaluation of Mancozeb has taken place, hopefully with positive results. Many of the issues can be averted with minor changes to labels instead of losing a needed crop protection material completely. Joint reviews with the United States will increase down the road, and the PMRA is going to update us on proposed product re-evaluation in the future to give us more time for our input. A common goal is to have more dialogue between the growers, registrants and PMRA before a re-evaluation is complete to make the outcome more accurate and the process less costly. There is no word on the outcome of the Linuron and Sevin re-evaluation, and the next major re-evaluation on Captan should be released this year. I would like to emphasize the importance of the Staff of our grower organizations in making reports to prove value and use patterns on re-evaluation, but they can’t achieve this without grower input.
As you know a large amount of the crop protection portfolio is national in nature. Craig Hunter and I sit on the CPAC of CHC. Our committee has identified four key areas that require priority. These issues include the re-evaluation of pesticides, invasive species, harmonization under RCC, including MRLs and the GROU program. We are also addressing specific crop protection issues on an as needed basis. A recent addition to the CHC staff as research and policy representative, Andre Bourbonniere, will be a much needed asset to the CPAC agenda and we look forward to working with him.
If harmonization of crop protection labels between Canada and the United States does not happen, the Grower Requested Own Use (GROU) program will become increasingly important. Craig Hunter compiled information on price differentials in crop protection materials between the United States and Ontario, based on a Ridgetown Campus survey, with results indicating an estimated $22 million additional cost to Ontario growers over those in the United States. Currently the GROU program is going through its last stage of becoming regulated with hopes of attaining status this year. If this happens it will give the program more power to do its job of creating a more level playing field for Ontario growers. Remember, this program only works on chemistries off data protection so United States and Canada’s label harmonization is a far better way to address the imbalance of prices. A reciprocal agreement between Ontario and New York is underway to recognize pesticide licenses on both sides of the border in order to make the GROU program more accessible to Ontario growers on restricted products.
Both Neonicatinoid pesticides and bees are needed for growing most horticultural crops. There is a correlation between seeds treated with Neonicatinoid pesticides and air seeders releasing the pesticide into the air and causing bee mortality. To this, PMRA has issued a science-based notice of intent to mitigate the problem. PMRA and EPA are conducting a joint re-evaluation of all Neonicatinoid pesticide uses, plus PMRA is proposing to implement label improvement similar to those of the US EPA. Active grower lobbying is needed to preserve this group of pesticides. This issue has hit the media and fuelled a full-blown attack on the new groups of insecticides by the Sierra Club and other well-funded activist organizations without just cause. The debate is now political. CHC has been asked to assist in the debate and will assist Crop Life and PMRA in a science based campaign. I am very pleased with the professional approach taken by PMRA and Crop Life. This is a serious situation, as it could develop into a total attack on crop protection technologies.
Another serious situation of concern is over two new invasive species, the Spotted Wing Drosophila fruit fly (SWD) and the Brown Marmorated Stink Bug (BMS). Both species are currently being monitored in Ontario. The SWD has been found in all parts of Ontario, and the BMS is in more locations than last year , for example: Hamilton, London, Niagara-on-the-Lake, Essex and Newboro near Kingston. These have been mainly as homeowner finds. The pre-harvest intervals on crop protection materials controlling SWD are problematic because of the short harvest time for small fruit. We are addressing this issue to try to get the PHI times reduced. We still have time but there is no magic bullet for the BMS yet. There is a continued dialogue between the PMC invasive species coordinating group, growers, and research representatives across Canada. Continued monitoring and registration of new crop protection products will continue until the issue is addressed.
On October 23, 2013 the OFVGA had its annual crop protection section meeting to address commodity issues. Most major horticultural commodities were represented and Jim Chaput gave a comprehensive update of minor use. One person missing was the late Wayne Roberts. His vast knowledge and energetic personality was sorely missed. A void will be left for some time. This meeting allowed Craig Hunter and I to get current information on issues evolving from specific commodities:
Some issues discussed beyond disease and insects are:
PHIs & REIs
Minor use registration and meeting
Rotation for resistance control
Again, everyone is welcome, and the meeting is held the same time every year. This National Minor Use Priority meeting is held in March in Gatineau, Quebec each year. A large change to this year’s meeting is replacing the Bio pesticide day and replacing it with the prioritizing of one new Bio pesticide action per section, e.g. entomology, weeds and pathology. Craig Hunter and Jim Chaput are two key individuals that do an excellent job of representing your industry at these meetings. A large grower contingency would also help. Only twelve actual growers attended the last meeting. I am including Jim’s report on minor use for 2013 plus, our annual meeting for those of you that would like more detail.
In closing I would like to thank OFVGA, OMAFRA, CHC, PMRA, PMC and the Ontario Provincial Commodity Board for their continued positive relationships and hard work on this ever changing and complicated portfolio of crop protection.
Respectfully submitted by
Crop Protection Chair