Neurotoxins seem to be on my mind a lot recently. Fortunately, the mammalian blood-brain barrier ensures that this is a figurative, not a literal concern. I refer to neonicotinoids, also known as neonics. Neonics include a class of neurotoxin pesticides in the nicotine family, the same chemical you used to see advertised in cancer sticks.
Neonicotinoids interfere with neuron pathways and bind to nicotinic receptors, which then causes paralysis and death, but they are far more toxic to insects than to humans. Recently, neonics became the focus regarding the collapse of bee colonies and other pollinators. Neonics provide a cute handle for this type of insecticide, almost like a small, programmable robotic toy you would get for your children — or perhaps your own inner child.
Neonicotinoids are the most common pesticides in use today. Most farmers do not seem to be given a choice, since neonics coat almost all corn and canola seeds planted in North America. The upside and downside seem to be that these pesticides dissolve readily in water. This means that they can be taken up through the plant’s entire vascular system to combat pests. The downside includes going down into the groundwater. Neonics have begun to show up in places where they should not.
Neonics have a short life of approximately 39 days when exposed to the sun and are not considered toxic for mammals. They are highly toxic to insects and aquatic animals such as crustaceans and fish. If neonics seep into the groundwater and are not exposed to sunlight, they can exist for up to three years. This may be sufficient time for them to reach aquifers. This can also allow them to reach wetland and impact insects, snails, scorpions and other invertebrates. With a three-year time lag, we may start to see more cumulative effects.
Other pollinators such as bees can take neonic-infused pollen and carry it back to the hive. The impact of the low-level neonics creates much debate. Some groups point to the overall increase in the number of hives in Canada as illustrating that there are no problems. Others can point to the colony collapse disorder. If neonics do not cause this directly, could they then be creating the tipping point for other problems to overwhelm the hive? Is it the grain of pollen that broke the colony’s back so to speak?
Considering the potential risks, pesticide approval falls to Health Canada under the Pest Control Products Act and its regulations with the Pest Management Regulatory Agency. The act requires reasonable certainty that the pesticide poses no safety risks, including to the environment. The PMRA can request additional data from the registrant and this allows a pesticide to be conditionally approved while additional information is obtained. I suppose “conditional” can depend upon your situation. Conditional on financing could mean a couple of weeks. Back in high school, you could borrow the car on the condition you got it back by 11 p.m. the same day. If my folks said I could have the car on condition I get it back to them in a decade, albeit with the tank full, I would think that was pretty much permanent.
The question then becomes when does conditional seem like final? Back in 2016, Ecojustice commenced an application for judicial review of the PMRA’s conditional approval of the two previously mentioned neonics. This conditional approval has continued to be rolled over for more than a decade. Accordingly, Ecojustice commenced action against two registrant companies and Health Canada as saying the decisions were outside the parameters of the legislation. The respondents attempted to dismiss the action on the basis that the 79 decisions of the PMRA on these pesticides should be time barred. They also claim that the applicants had alternative routes to deal with the PMRA decisions. The respondents brought an application to dismiss and a further appeal. Ecojustice prevailed at both levels. This has taken two years and the matter has now been set down to be heard on the merits. Although, the courts may not be the best place to go through reams of scientific data.
As the matter slowly winds through the PMRA and the courts, the concern arises whether we are better off with the neonics we know. If the application did prove successful or if the PMRA finally decided after several years that neonics were not safe, would the alternatives be worse?
Scott Pruitt, the previous head of the U.S. Environmental Protection Agency, made many impactful decisions. One was to remove the ban on chlorpyrifos, a neurotoxin that is even less selective than the neonics being discussed, notwithstanding that EPA scientists concluded the pesticide caused significant health consequences. If neonics appear to be the cute programmable robot neurotoxin toy you buy, chlorpyrifos is more like the lawn darts that you have at the cottage.
Remember DDT? It was another neurotoxin that did not have any selectivity when it came to eradicating pests. DDT opens the sodium ion channels in neurons, causing them to fire spontaneously, which leads to spasms and death. By 1945, DDT was available for public sale in the U.S. DDT’s impact became apparent with Rachel Carson’s Silent Spring in 1962 where she documented industry’s indiscriminate use of pesticides. After a public outcry and the near extinction of the bald eagle, it was finally banned in 1972.
In response to stress to pollinators, Ontario created the Pollinator Health Action Plan to safeguard against high mortality of wild and managed pollinators. Although some groups point to the fact that there are now more bee colonies than ever, the other side of this fact is that winter honeybee mortality reached 58 per cent in 2014. This is another case where you can always find a statistic to support your case.
This high mortality rate can be an extremely risky number considering that nearly $900 million in Ontario crops rely upon pollinators. Part of the action plan includes using neonics-treated seed only where there is a demonstrated need to deal with pests. This gets us back to avoiding the “indiscriminate use” of pesticides.
Europe always appears to be the trendsetter. The European Union acted upon neonics and banned them several years ago. It determined that the impact on bee populations and pollinators in general justified the ban.
The EU relies upon the precautionary principle in some areas of the law. This principle states that, in the case that there is any doubt about the safety of a chemical or action, then policy-makers should use their discretion and use precautionary measures to safeguard human health and the environment. There are many international treaties that incorporate this principle as a necessary application.
The Federal Sustainable Development Act does include the precautionary principle in that where there are threats of serious or irreversible damage, lack of full scientific certainly shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation. This principle needs to be more strongly considered for neonicotinoids.