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Comments on the pollinator re-evaluation of imidacloprid
Submitted to the Pest Management Regulatory Agency
August 29, 2018
These are the joint comments of the David Suzuki Foundation, Équiterre, Environmental Defence, the Canadian Association of Physicians for the Environment (CAPE) and the Canadian Environmental Law Association on the pollinator re-evaluation of imidacloprid and its end use products (PRVD2018-12). Our organizations have a long history of advocacy for effective pesticide regulation to protect the environment and human health. Pollinator protection is at the nexus of these two concerns. Pollinators play a crucial role in sustaining biodiversity and natural ecosystems,as well as assuring food security. Of 124 major commodity crops directly used for human consumption, 70 per cent are dependent on pollination for enhanced production.
Content
I. The proposed phase-out of certain uses
II. The narrow scope of the assessment
III. Risks to pollinators from contamination of the broader environment
IV. Total exposure and cumulative risks
V. The value of imidacloprid
Appendix A : List of Recommendations
