– Pesticide Free Failure

RNAO = ENVIRO ACTIVIST GROUP | Submission to the Ministry of Environment and Climate Change: EBR Registry Number 012-3733 | Registered Nurses’ Association of Ontario

Submitted by admin on Mon, 2015-05-04 16:17
Resource Type:
Submission / Letter
RNAO response to Regulatory Amendments to Ontario Regulation 63/09 under the Pesticides Act to Reduce the Use of Neonicotinoid Insecticides
The Registered Nurses’ Association of Ontario (RNAO) is the professional association representing registered nurses (RNs), nurse practitioners (NPs) and nursing students in all settings and roles across Ontario. It is the strong, credible voice leading the nursing profession to influence and promote healthy public policy. RNAO’s mandate is to speak out on nursing and health issues, and that includes environmental determinants of health. Accordingly, we are pleased to respond to the government proposals to amend the regulation of neonicotinoid (“neonics”) pesticides, as posted to the Environmental Registry under EBR Registry Number 012-3733.

Neonicotinoids. Neonics are insecticides. They work by attacking nerve receptors in insects. They are toxic to animals, but more toxic to insects than to mammals. Lethal and sub-lethal exposures are both problematic. We know that sub-lethal exposures can compromise the health of pollinators, which makes them susceptible to diseases and parasites. Neonics are water soluble, which means they can readily move into bodies of water. They are also persistent, which means they can, over time, continue to compromise animal and insect health. Biodiversity suffers not only due to the direct effects on vertebrates and invertebrates; the removal of many pollinators from the environment affects the success of plants and removes a substantial source of sustenance from creatures further up the food chain. RNAO is particularly concerned with the widespread preventive use of neonics without a requirement to investigate whether insects of concern are even present in numbers that could affect crops. Moreover, routine preventive use of pesticides preempts consideration of agricultural approaches that work with the environment rather than in conflict with it.

There is considerable evidence that neonics can harm pollinators and other invertebrates and vertebrates. The research has been summarized by the Task Force on Systemic Pesticides, which examined more than 800 peer-reviewed scientific papers on the topic over the past 20 years and published its conclusions in 2014 (see appendix). The Environmental Commissioner of Ontario has provided a brief summary of science on neonicotinoids (see appendix). Both conclude that neonics harm pollinators and that action is necessary. An April 2015 report by the European Academies Science Advisory Council concurs, with its Expert Group concluding that preventive use of neonics has “severe negative effects on non-target organisms that provide ecosystem services including pollination and natural pest control.” It cites clear evidence of sublethal effects from very low levels of neonics over time, and concludes that prophylactic use of neonics is inconsistent with the principles of integrated pest management. In the face of the evidence and the concern that use of neonics adds to the toxic load we all carry, a precautionary approach is warranted. The onus to prove safety and effectiveness ought to rest with the proponent of a given toxic. The evidence on adverse effects was sufficiently compelling that the European Commission voted to restrict the use of the three neonics listed above for two years. This happened after the European Food Safety Authority identified that neonics represented significant risks to bees.
RNAO has been advocating with other health and environment organizations for action on neonics for some time, and we welcomed the government’s proposal to protect pollinator health, as posted in January 2015. Ontario is to be congratulated for being the first jurisdiction in Canada to seek to reduce neonic use as a pollinator protection measure. Ninety seven per cent of respondents to the pollinator health posting supported restrictions on neonics. The research shows that pollinator populations are in decline and neonics contribute to the problem. We were very pleased that the government proposed strong action in its January posting, with a goal of reducing over-winter mortality of honey bees to 15 per cent by 2020 and reducing the number of acres of corn and soybean crops using seed coated with three specified neonics (imidacloprid, thiamethoxam, and clothianidin) by 2017. For us, that was a very important and laudable step forward. The 2017 acreage goal was repeated in documentation related to EBR Registry Number 012-3733, but the 2020 mortality target was not. We expect the government will keep this goal as well. The regulatory proposal was a step forward, but we continue to call for a full ban on all uses of neonics, to better protect the environment.

Neonics are an important issue for RNs, NPs and nursing students because of the extent of their usage and their potential impact. They are very widely used. For example, about 60 per cent of Ontario soybean crops use neonic-treated seed, as do 99 per cent of corn crops. These two crops account for 2.5 million and 2.4 million acres respectively of the total of 7 million acres of Ontario field crops. The two crops thus account for 70 per cent of all Ontario field crop acreage. It means that over 55 per cent of all of Ontario’s field crop acreage is planted using neonic-treated seed due to corn and soybeans alone — about 3.9 million acres (about 2.2 times the size of the Greater Toronto and Hamilton Area); that is a huge volume of land under pesticides. When we combine that with the 2014 over-winter losses of honey bee hives of 58 per cent, and the fact that honey bees alone pollinate about $897 million worth of Ontario’s crops, there is a very significant threat to our food supply. And of course that is a huge volume of pesticides to routinely use for prophylactic purposes, adding to the environmental toxic load.

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Pesticide ban hurts municipalities | Letters, May 6 – Winnipeg Free Press

On May 1, the ban on the use of cosmetic pesticides came into effect.
The Association of Manitoba Municipalities continues to voice its opposition to this unreasonable regulation not only due to its contradictory wording but also due to its impractical restrictions and skyrocketing compliance costs placed on municipalities.

The ban outlaws pesticides approved by federal government agencies, reducing the ability of municipalities to effectively manage weed-control programs and resulting in unnecessary financial constraints on municipal budgets.
Steinbach, for example, has estimated its annual cost of fighting weeds in the community will increase to more than $237,000 from approximately $15,000 — which all citizens will ultimately have to pay.

While Manitoba’s municipalities fully support initiatives to ensure public safety, the AMM urges the province to consider an exemption of urban hard-surface boulevards and highway ditches from the ban. Contrary to provincial thinking, no child plays on the side of the Trans-Canada Highway.

We hope Conservation and Water Stewardship Minister Tom Nevakshonoff will adopt a practical approach to amend the regulation on the ban of cosmetic pesticides while working with municipalities to implement practical weed-control solutions.

Doug Dobrowolski
President, Association of Manitoba Municipalities

Source: Letters, May 6 – Winnipeg Free Press

Pesticide OK for school, but not lawn? | SHERRING | Columnists | Opinion | Ottaw


There’s just something totally upside down in this town when we can’t use pesticides to kill the weeds on our lawns, but going into a school full of children and blasting cockroaches with pesticides is somehow OK.

Yes, aside from the problem of using pesticides, apparently cockroaches sometimes curl up and get cozy inside our schools.


But not to worry.

At a hastily called news conference on Wednesday by the Ottawa Public Health department, officials were quick to tell reporters the ill effects being felt by staff and students at the Adult High School and Charles H. Hulse weren’t really from the pesticide itself, but the solvents mixed with the pesticide.

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MoCo Pesticide Ban May Be Vulnerable To Court Challenge, Says Attorney General’s Office | BethesdaNow

A controversial proposal to ban the use of “non-essential” pesticides on private lawns in Montgomery County may be prevented by state law, according to the Maryland Attorney General’s Office.

Assistant Attorney General Kathryn Rowe wrote that a court could rule the part of the bill banning pesticide use for private property owners is preempted by state law already addressing pesticide use.

“While the matter is not completely clear, it is my view that the general ban on application of non-essential pesticides may well be preempted, but that other parts might not be,” Rowe wrote earlier this month in a response to an inquiry about state preemption from Montgomery Village Del. Kirill Reznik. “It is my view that a court could conclude that this provision would interfere with the purposes of these State provisions, as well as the goal of achieving uniformity.”

Rowe wrote that other parts of the bill, introduced by Council President George Leventhal to much support and opposition earlier this year, wouldn’t run into preemption issues.

Leventhal’s bill also would exempt golf courses and farms from the pesticide ban, but not county property and playing fields. Montgomery Parks, which runs the county’s nearly 300 recreational playing fields, has urged Leventhal and other Council members to exempt its fields too.
Rowe said that requirement, as well as requirements that would require signage if pesticides were being applied, shouldn’t pose any legal issues.
The private property provision has been one of the most controversial parts of the bill.

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Organic Meadow Ltd., Organic Meadow Inc. and Organic Meadow Co-Operative Inc. – Corporate Engagement Details MNP LTD

Organic Meadow Ltd., Organic Meadow Inc. and Organic Meadow Co-Operative Inc.

On April  2, 2015 Organic Meadow Ltd. (“OML”), Organic Meadow Inc. (“OMI”) and Organic Meadow Co-Operative Inc. (“OMCI”) each filed a notice of Intention to Make a Proposal (“NOI”), pursuant to Section 50.4 (1) of the Bankruptcy and Insolvency Act and MNP Ltd. was appointed as trustee (the “Trustee”) under the proposal.


Certificate of a Notice of Intention to Make a Proposal of Organic Meadow Ltd.

Certificate of a Notice of Intention to Make a Proposal of Organic Meadow Inc.

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