Safety of the crop, the animal and the consumer are big reasons for using registered products for their approved uses only. “By definition, non-approved translates to not examined, not tested, of unknown strength, unknown toxicity, unknown withdrawal times with no measure of acceptable and safe maximum residue levels,” explains Curt Hagele, registrar and secretary treasurer of the Saskatchewan Veterinary Medical Association.
“In Canada, any drug or chemical destined for use in food producing animals for pest control must have been tested for efficacy, toxicity to the animal, stability, shelf life and residue depletion from tissue if the drug or chemical is absorbed into the animal’s tissues. Once a drug or chemical is found to be effective and safe to administer to an animal, withdrawal times must be established, and minimum residue levels for the product in meat or milk from treated animals are established. These levels can then be monitored by the Canadian Food Inspection Agency’s inspectors during processing or slaughter,” Hagele says.
“Our registration systems give us the ability to assure meat and milk is free of harmful substances and unsafe levels of chemical residues,” Hagele says.
Another benefit to producers using “approved” drugs or chemicals is manufacturer’s accountability. “Any problem linked directly to the proper and correct use of an approved product sold by a Canadian company would mean that company would have to stand behind the product and deal with a problem,” he adds. At the same time, if you’re using a non-approved product, or an approved product for a non-approved use, you hold all the responsibility for what may occur to the plant or animal.
Granted, a non-approved product isn’t necessarily unsafe for either the crop or the consumer. But in the world of food and trade, regulatory hurdles are what matter most. Take the case of Bayer CropScience’s Stratego 250 EC last year. The fungicide was first registered for use on wheat, oats and barley in Canada, but was launched before the U.S. had passed its approval for the product on oats and barley. This created a possible trade risk because the U.S. did not have a maximum residue level (MRL) for Stratego on barley and oats. If the U.S. does not have an MRL set for a chemical, the limit is zero. Without the harmonized label, any oats or barley shipped into the U.S. could have been rejected if traces of the fungicide were found. Once alerted to the problem, Bayer CropScience worked with PMRA to have oats and barley removed from Stratego’s label until such a time that the U.S. set an MRL. (For more on MRLs, see the following article.)
“It was never a question of safety,” explains Paul Thiel, vice-president of industry relations for Bayer CropScience. “There was concern that this would become a trade irritant between grain companies and millers in the U.S. and we wanted to do our part to avoid that happening.” Stratego was finally approved in the U.S. for barley and oats and so the 2 crops were put back on the Stratego label in Canada. Thiel credits PMRA for moving so quickly to first withdraw and then reinstate the approval.
Genetically modified (GM) crops also face tough scrutiny when it comes to international trade. Real threats of trade upheaval prompted the Canola Council of Canada to launch its Canola Export Ready program in the spring of 2006. The aim is to end the use of non-approved products and varieties. JoAnne Buth is the Canola Council’s vice-president of production. She explains that tightening regulations from importing countries and the de-registration of certain GM events prompted the council to be proactive.
“Pesticide residues are a sensitive issue for Japan, whereas variety and GM traits are the sensitive issue for gaining access to the European Union or maintaining our access to certain countries, such as China,” Buth says. A GM “event”, she explains, is a genetic transformation that occurs as a result of biotechnology. For example, the Roundup Ready trait involves one event, and the Liberty Link trait is a result of 5 events. For canola, all of the events involve herbicide tolerance, but they don’t have to in other crops. What has happened, Buth explains, is that the approval and registration of certain GM events have expired or will expire soon. These events are found in older varieties that could still be hanging around in farmers’ bins. Should a variety containing these old events be found in a shipment to a country that has never approved the event or has de-registered it, the shipment may be refused and the integrity of the Canadian quality assurance system could be jeopardized.
“Unfortunately, in the world of regulatory approval if it’s not approved, there’s zero tolerance,” Buth says. “And we can detect minute amounts of either pesticides or genetic events.” There are of course some simple ways of avoiding these problems — don’t grow de-registered varieties, clean out your bins, and don’t use lindane or malathion on canola. (See the sidebar “Don’t grow these varieties” on page 46 for a complete list of de-registered varieties.)
“Farmers growing these de-registered varieties or using lindane or malathion run the risk of having their shipments turned away at the elevator. It hasn’t happened yet, but as these regulations tighten and as we work harder to gain access to new markets, the responsibility will move down the supply chain,” Buth says.
Peter MacLeod, executive director of CropLife Canada, can’t stress enough how important it is for farmers to know where their crops will ultimately end up and the specific regulatory requirements for those markets. “We have such an integrated food chain, so using a non-approved variety or product, or using a registered product improperly, can have a huge impact on the entire industry,” MacLeod says. “And as Bayer learned with Stratego, it’s not just about Canada’s regulations and product approvals. Some pesticide products are registered for use in Canada but aren’t allowed in other markets. “It used to be that if you could buy, you could apply, but that’s changed,” MacLeod says. “Farmers need to keep in touch with what they should and shouldn’t use on their farm.” CG
Don’t grow these varieties According to the Canola Council of Canada’s Canola Export Ready program, the following varieties, or seed saved from the following varieties, should not be grown:
* HySyn 101 Roundup Ready
* 295BX, Cartier BX, Zodiac BX, Renegade BX (the bromoxynil-resistant varieties)
* Exceed, 2631 LL, Swallow, SW Legion LL, SW Flare LL, LBD 2393 LL
* 3850, 2153, 3640
* 3880, 2163, 2273
* Innovator, Independence, HCN 14, Phoenix
Do not use seed treatments containing lindane insecticide and do not use malathion insecticide. Any bins that have contained seed treated with either of these chemicals should be thoroughly cleaned or not used for canola storage. All bins used to store canola should be free of treated seed and any animal protein.
For more information on why these varieties and pesticides have been de-registered or are not acceptable, call 1-866-834-4378 or visit www.canolacouncil.org/export_ready.html.
MRLs for Canada and the U.S. CropLife Canada has an MRL database on its web site to help farmers find limits for both Canada and the U.S. Go to www.croplife.ca and click on “Resource Centre” to find the MRL database.