Ontario Bee Association lobbies for far greater limits on pesticide seed treatments based on flawed environment ministry data

Bee photo

Less than half of Ontario corn seed was neonic-treated in 2017; however, 78% of planted acreage was neonic treated.

What, that can’t be right, you say.

Oh yes it is according to data released recently by the Ministry of Environment and Climate Change (MOECC), and there are more surprises in a recent ministry report on neonic corn and soybean seed sales/usage.

A comparison between 2016 and 2017 numbers in the ministry data shows some other strange findings. The MOECC data show the seeding rate per acre for corn increased 23% in 2017 versus 2016. Total Ontario corn acreage in 2017 is calculated at 3.3 million acres using the ministry numbers – almost 40% higher than reported by Statistics Canada.  Usage of Poncho (chlothianidin) for corn jumped 107% in 2017 versus 2016, say MOECC numbers, even though seed industry contacts tell me they know of no such shift.

The MOEC data are equally weird for soybeans.

The ministry numbers and a related report can be found here and here.

Well so what, you ask?  Obviously just another screwed-up government report which will likely be corrected in the course of time.

The problem is that the Ontario Bee Association (OBA) has used the information to lobby for some rather draconian changes.

It has proposed even more stringent rules for neonic seed treatment for corn and soybeans, an upper limit of 20% of seed for any farm regardless of soil assay results for wireworm and white grub presence. They want the restriction expanded to include winter wheat and sweet corn. They imply that “Schedule 12” type restrictions might be extended to other insecticides like Lumivia and to fungicides.

OBA blames Certified Crop Advisors (CCAs) for the continued substantial usage of neonic seed treatment in 2017 – even though treatment needs for 2017 could be determined entirely using field assays done by farmers.  (The requirement for CCAs-only begins with the 2018 crop.)

The OBA focus on crop pesticides as a priority concern seems very much at odds with what Ontario beekeepers themselves report as their problems. For example, an OMAFRA survey report (it can be found here) on causes of 2016-17 overwinter losses shows that beekeepers consider starvation,  poor queens, ineffective varroa control, and weak colonies were the priorities, along with “other” and “don’t know.”  National reports from the Canadian Association of Professional Apiarists in 2016 and 2017 (link here) do not identify pesticides as a major cause of deaths in any province – indeed, do not even mention neonicotinoids as a cause. The Pest Management Regulatory Agency reports complaints from beekeepers about pesticide-induced losses have dropped 80-90% since 2014.

I don’t blame OBA for the flawed data from MEOCC but it’s disappointing to see their continued vendetta against crop pesticides and their recent pitch to government which is weak, poorly researched, and ignores critical new information from both OMAFRA and Ontario researchers.

I recommend that those involved in grain growing and the farm service industry in Ontario not ignore this request from the Ontario Bee Association. A similar pitch made by OBA to the Ontario Premier just before the 2014 election led to the highly complex procedures which we now follow for neonic seed treatment.

The OBA letter to ministers can be found here.

My letter to minsters in response, which contains much more detail relative to comments made above, follows:


April, 2018

To: Minister Jeff Leal, Ontario Minister of Agriculture, Food and Rural Affairs, Minister Chris Ballard, Ontario Minister of Environment and Climate Change, and Ontario Premier Kathleen Wynne

Re: Request from Ontario Bee Association for further restrictions on pesticide usage for food crop protection.

Dear Ministers Leal and Ballard and Premier Wynne:

The March 7 request from the Ontario Bee Association (OBA) for major additional restrictions on pesticide usage for food crop protection in Ontario is based on some seriously inaccurate statistics, flawed interpretations and a lack of reference to critical new information from the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA), Health Canada, and the University of Guelph. Details are provided below.

The OBA request is based in part on data published by the Ministry of Environment and Climate Change (MOECC) apparently demonstrating only a 22% and 27% reduction in the respective Ontario corn and soybean acreage planted with neonicotinoid-treated seed between 2014 and 2017 (https://www.ontario.ca/page/neonicotinoid-regulations-seed-vendors#section-5) . The source of those data is here, https://www.ontario.ca/data/corn-and-soybean-neonicotinoid-treated-seed-data. (OBA modifies the analysis to calculate only a 16% reduction for soybeans in 2017, but that’s of peripheral significance to the discussion below.)

Unfortunately, an analysis of those statistics shows they cannot possibly be correct.

Consider the following table in which I have reproduced the MOECC data, adding some calculations based on the MOECC statistics.

Corn Soybeans
Growing season 2016 2017 2016 2017
Acreage with imidicloprid-treated seed 52,413 48,861 264,841 478,632
Acreage with chlothianidin-treated seed 713,614 1,475,230 NA NA
Acreage with thiamethoxam-treated seed 870,337 111,866 1,106,636 862,476
Tonnes of neonicotinoid-treated seed 15,650 19,296 42,306 42,243
Tonnes of untreated seed 5,061 19,705 35,926 78,158
Total neonicotinoid-seed-treated acres (MOECC data) 1,636,384 1,635,957 1,371,477 1,341,108
Kg seed/acre – neonicotinoid-treated seed, based on MOECC data (% of 2016) 9.6 11.8


30.8 31.5


Total untreated acres (assuming same seeding rate per acre as with treated seed) 529,185 1,670,633 1,164,649 2,481,318
Total Ontario acreage, MOECC data*

(% of 2016)

2,165,569 3,306,590*


2,536,125 3,822,426


Total Ontario acreage, OMAFRA data

(% of 2016)

2,265,000 2,420,000


2,710,000 3,075,000


MOECC/OMAFRA 96% 137%* 94% 124%
*Note that the calculated acreage planted with both treated and non-treated corn seed in 2017, based on MOECC data, would be 23% higher than shown in the table (i.e., to a total of 4,064,350 acres) if the seeding rate per acre was the same in 2017 as in 2016. This, in turn, would increase the MOECC/OMAFRA Ontario corn acreage ratio to 168%.


There are a number of serious anomalies to note:

  • The total number of corn and soybean acreages estimated by MOECC increased dramatically from 2016 to 2017 compared to OMAFRA data showing much smaller changes. OMAFRA data are at: http://www.omafra.gov.on.ca/english/stats/crops/estimate_new.htm .
  • MOECC data indicate that 23% more treated corn seed (19,296 versus 15,650 tonnes) was used to plant virtually the same acreage in 2017 as in 2016. This is not credible. This distortion means that the error in the MOECC-data-based estimate of total corn acreage in 2017 is actually about 68% compared to OMAFRA statistics (see note to table). That’s a huge discrepancy.
  • The MOECC data show huge changes in the relative amount of seed and acreage treated with the different neonicotinoid chemicals between 2016 to 2017 – for example, an increase of 761,616 (+107%) in corn acres treated with chlothianidin from 2016 to 2017 and a reduction of 758,471 (-87%) in acres treated with thiamethoxam. Large swings are also shown for soybeans. However, my personal check with seed companies which sell an estimated 90% or more of the corn and soybean seed in Ontario revealed no comparable changes in the reported relative use of the respective products in 2017. (A notable exception is the largest seed corn seed supplier in Ontario which abandoned almost all usage of neonicotinoid seed treatments in 2017, using another, newer insecticide, safer to pollinators, as a replacement).

In brief, the data provided by MOECC cannot be correct, and any conclusions based thereon – at least until the ministry corrects the errors – are equally erroneous. I am tempted to point out the dramatic increase in the planting of seed not treated with neonicotinoids in 2017 versus 2016 in the MOECC data, but must assume that these statistics are also highly unreliable.

The Ontario Bee Association blames Certified Crop Advisors (CCAs) for a claimed substantial usage of neonicotinoid-treated corn and soybean seed in 2017 – perhaps because of non-familiarity with the details of Ontario Regulation 139/15 to the Ontario Pesticides Act (June 2015). The regulation states that purchases of neonicotinoid-treated corn and soybean seed (i.e., Schedule 12 pesticides) for 2017 could be based entirely on farmer assays for the presence of wireworms and white grubs in farm field soils. The regulatory requirement for the use of CCAs did not start until seed purchases for the 2018 crop season, now just beginning (and even then for only a few counties/regions).

The OBA also claims that provincial average crop yields increased (corn) or did not change much (soybeans) from 2014 through 2016 and 2017, thus apparently demonstrating that insecticide seed treatment is not important to yield. OBA needs to recognize the dominant effect of other factors such as seasonal differences in weather and genetic improvement on crop yields.

The OBA letter claims without evidence that the number of claims of loss reported to PMRA-Health Canada is down since 2014 (actually down 80-90%, https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/decisions-updates/reevaluation-note/2017/evaluation-neonicotinoid-insecticides-update-pollinator-risk-assessments-rev2017-03.html) because bee keepers have no incentive to report losses. The much more logical explanation is that claims are down because the there are fewer incidents to report, possibly because of changes in seed treatment procedures mandated by PMRA before the 2015 crop season. Happily, percent over-winter losses have declined substantially in Ontario (average of 28%, 2015-2017) since the very high percentage (58%) in 2014, even as the number of honey bee colonies remains well above that of a few years ago.

I am especially disappointed in the OBA request that Province’s very restrictive policy on seed treatment with neonicotinoids be extended to winter wheat, even though wheat produces no pollen or nectar to attract foraging bees – and also to include other insecticides being introduced despite their low toxicity to honey bees. They even suggest inclusion of fungicides perhaps based on very minimal evidence from laboratory work (notoriously unreliable for predicting effects on bee colonies in the real world; see more on this at https://link.springer.com/article/10.1007/s10646-012-0863-x ). One gets the impression that OBA is most interested in restrictions on agricultural pesticide usage as a goal in itself – though apparently (hopefully) not for pesticides needed to address in-hive pests that harm bees, e.g. varroa treatments.

Also, a note about the assumption in some public statements that only 20% of Ontario corn and soybean acreage needs insecticide seed treatment for control of insects like wireworm, white grubs and seed maggot: My understanding is that this comes from an educated guess which an OMAFRA specialist provided at an OMAFRA-chaired working group meeting. There is no reference to any such goal in Ontario Regulation 139/15 to the Ontario Pesticides Act. OBA is incorrect in stating in its March 7 letter than this a stated aspirational target in “passed legislation.”A far more accurate assessment of need will be available from the extensive assays mandated under Ontario Regulation 139/15, especially when this process is managed by CCAs, beginning in the 2017/2018 reporting year (2018 growing season). Presumably the Ontario goal is to use neonicotinoid-treated seed on those corn and soybean acres which require treatment as identified by the Integrated Pest Management processes described in the Regulation. That need may well prove to be significantly higher than 20%.

Each year the Canadian Association of Professional Apiculturists (CAPA) (mainly government and academic bee specialists across Canada) does a survey of over-winter honey bee colony losses across provinces and reports both the loss statistics and results of a survey of beekeeper impressions on the reasons for losses. Neither the 2017 nor 2016 reports list pesticides as a principal cause of colony deaths in Ontario. Indeed, the word ‘neonicotinoid’ does not even appear in either report. The 2017 report is here: http://www.capabees.com/shared/2016/07/2017-CAPA-Statement-on-Colony-Losses-r.pdf .

This finding matches the survey information provided by the OMAFRA report on over-winter bee losses, http://www.omafra.gov.on.ca/english/food/inspection/bees/2017winterloss.htm . A table from that report is shown below. Pesticides, at least other than those used directly on bees (see “ineffective varroa control”), are not listed as a major factor.

Ontario Apiarist bee losses

In 2017, a major report from the University of Guelph, commissioned and funded by OMAFRA, was released showing that while pesticides do affect bee health, bee pests such as varroa mites, and inadequate bee management are dominant causes of over-winter bee mortality in the province. The full 238-page report is here: https://rainelab.files.wordpress.com/2015/12/status-and-trends-of-pollinator-health-in-ontario-march-8-2017-tagged.pdf. A shorter summary is provided here: https://tdaynard.com/2017/04/17/comments-on-status-and-trends-of-pollinator-health-in-ontario-a-review-by-pindar-et-al-march-2017-university-of-guelph/.

Also in 2017, a team at the University of Guelph, including internationally recognized pesticide toxicologist Keith Solomon, completed a mega-review of world literature on the effects of neonicotinoid seed treatments on honey bee colony health. Their conclusion is summarized succinctly in the news release title, “Correctly used neonics do not adversely affect honeybee colonies,” https://news.uoguelph.ca/2017/11/correctly-used-neonics-do-not-adversely-affect-honeybee-colonies-new-research-finds/ .

The Pest Management Regulatory Agency of Canada released statements of intended regulatory changes for chlothianidin and thiamethoxam in December 2017 and an equivalent statement is expected, imminently, for imidicloprid, https://www.canada.ca/en/health-canada/services/consumer-product-safety/reports-publications/pesticides-pest-management/fact-sheets-other-resources/update-neonicotinoid-pesticides.html. PMRA proposed no changes in usage of seed treatments for chlothianidin and thiamethoxam other than a labelling change for cereal-crops and forage-legume seed.

In an earlier report, PMRA estimated the economic benefit to Canadian corn and soybean farmers to be in excess of $100 million annually, https://www.canada.ca/en/health-canada/services/consumer-product-safety/pesticides-pest-management/public/consultations/re-evaluation-note/2016/value-assessment-corn-soybean-seed-treatment-use-clothianidin-imidacloprid-thiamethoxam/document.html .

The preceding comments pertain mainly to effects of neonicotinoids on honey bees. Little is known about the vitality of wild bee colonies in Canada/Ontario or the effects of various pesticides. (See 2017 University of Guelph reports cited above.) There is growing evidence that honey bees may be one of the largest threats to wild bee well-being – both through the competition provided for wildflower nectar and pollen – and for the role of honey bees in spreading bee diseases to wild species. A major overview can be found here: http://www.xerces.org/wp-content/uploads/2016/09/Xerces_policy_statement_HB_Final.pdf .

In closing, I commend the Ministries of Agriculture, Food and Rural Affairs and Environment and Climate Change for their continuing work on pollinator health and encourage them both to focus on threats that both individual beekeepers in Ontario and good science judge to be most important ones. Conversely, please be cautious in being swept up by the quite contrary, anti-pesticide agenda promoted by the Ontario Bee Association. Finally, I encourage MOECC to re-examine the base data used to provide annual reports on Schedule 12 pesticide usage (neonicotinoid-treated corn and soybean seed). The most recent report provides a data summary which contains so many discrepancies as to be largely meaningless.


Terry Daynard

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