Comments on the pollinator re-evaluation of imidacloprid

The document argues that the PMRA's proposed phase-out of imidacloprid is too slow and narrow in scope, failing to account for the risks to wild pollinators beyond honey bees and bumblebees. It criticizes the reliance on label statements for risk mitigation, citing inadequate enforcement capacity in Canada. The authors highlight risks from environmental contamination, such as residues in non-target wildflowers and dust from treated seeds, and argue that the economic value of neonicotinoid seed treatments is overrated. They recommend a full ban on all outdoor uses, aligned with European Union regulations, and a shift toward Integrated Pest Management (IPM).

• The authors argue that the PMRA's proposed phase-out timeline of three to five years is unjustifiably long and will prolong environmental contamination, urging Canada to match the EU timeline and end neonicotinoid use by the end of 2018.
• The risk assessment (PRVD2018-12) is criticized for being too narrow, as it primarily uses honey bee data as a surrogate and fails to adequately assess risks to other wild pollinators, such as solitary bees, flies, butterflies, and beetles.
• The document asserts that risk mitigation based on label statements is ineffective due to a lack of data on efficacy and the PMRA's inadequate inspection and enforcement capacity at the farm level across Canada.
• There is significant concern regarding environmental contamination beyond treated fields, specifically that imidacloprid residues in non-target wildflowers and dust from treated seeds pose risks that the PMRA has inappropriately dismissed.
• The authors claim the PMRA fails to evaluate the total cumulative exposure risk to pollinators from multiple applications of imidacloprid and the additive effects of using multiple different neonicotinoids concurrently.
• The document argues that the economic value of neonicotinoid seed treatments is overrated, citing evidence that they often do not increase crop yields and that cost-effective alternatives like Integrated Pest Management (IPM) and insurance models exist.

APA

Canadian Association of Physicians for the Environment (2018). Comments on the pollinator re-evaluation of imidacloprid. https://cape.ca/wp-content/uploads/2018/08/Imidacloprid-pollinator-re-evaluation-comments-FINAL.pdf

Chicago

Canadian Association of Physicians for the Environment. Comments on the pollinator re-evaluation of imidacloprid. 2018. https://cape.ca/wp-content/uploads/2018/08/Imidacloprid-pollinator-re-evaluation-comments-FINAL.pdf.

Wikipedia

{{cite press release |author=Canadian Association of Physicians for the Environment |title=Comments on the pollinator re-evaluation of imidacloprid |date=29 August 2018 |url=https://cape.ca/wp-content/uploads/2018/08/Imidacloprid-pollinator-re-evaluation-comments-FINAL.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{canadianassociationofphysiciansfortheenvironment2018comments, author = {{Canadian Association of Physicians for the Environment}}, title = {{Comments on the pollinator re-evaluation of imidacloprid}}, publisher = {Canadian Association of Physicians for the Environment}, year = {2018}, month = aug, url = {https://cape.ca/wp-content/uploads/2018/08/Imidacloprid-pollinator-re-evaluation-comments-FINAL.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }