Western Growers submitted the following comments in response to a Notice of Intent issued by Health Canada regarding a proposed action to protect bees from exposure to neonicotinoid pesticides:
While bee health is one of the most critical issues affecting production agriculture, we are submitting comments to express our concern over any premature decision by regulators that may limit the use of neonicotinoids without first exhausting all science based analysis on the multitude of influences causing this crisis. Any preliminary action would not only result in increased production costs for farmers, but severely inhibit the production of a wide range of crops, including fresh vegetables, fruits, and tree nuts. The agricultural community is dutiful in the management of pesticide tools used to protect crop production.
As stated in your Notice of Intent NO12013-01, bee health is a complex and critical issue and may involve a number of factors, including parasites, disease, and climate. Therefore, we caution any rush to reach a decision that would preclude the necessary research and incorporation of all the available data necessary to reach a scientific based decision. We encourage regulators to preserve access to these critical materials by working to mitigate any impacts through stewardship and labeling as opposed to suspending or canceling registrations.
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