Information on New Neonicotinoid Treated Corn and Soybean Seed Regulations in Ontario
What you need to know as a farmer…
Overview of the New Regulatory Requirements:
Regulations establish system for neonicotinoid-‐treated seeds:
- New class of pesticides under the Ontario Pesticides Act
- All pesticides once approved by PMRA are scheduled provincially under the Pesticides Act. To this point most agricultural pesticides to this point have been placed in class 3,4, etc.
- With the regulations, Grain corn and soybean seed when treated with: imidacloprid, thiamethoxam and/or clothianidin now become a “Class 12” pesticide. Class 12 defines the treated seed as a pesticide, not the treatment alone.
- Planting Class 12 Pesticides is under the regulations now deemed an extermination
- Previously pesticide treated seeds were not regulated by the province
- Regulations cover CORN AND SOYBEAN SEED ONLY
- The regulations also establish for the first time the method to assess if pest problems require use of neonicotinoid treated grain corn or soybean seeds
- The regulations also set requirements for the sale and use of neonicotinoid treated grain corn and soybean seeds in order to measure progress in reaching the government’s aspirational* target of 80% by 2017.
*Note this was an arbitrary goal developed by the government that has no basis in science.
Scope of New Regulatory Requirements:
- Requirements apply to grain corn (including silage) and soybean seed treated with the active ingredients: Imidacloprid, thiamethoxam, clothianidin.
- What is NOT COVERED by the regulations:
- Does not include popping corn, sweet corn or seed corn or seed soybeans used for the production of seed
- Does not apply to seed used under a seed production contract for the purpose of producing a soybean seed crop of certified status (as defined in the federal Seeds Regulations).
- Does not apply to research plots for corn and soybeans
- Does not apply to seed treatments for seeds of other field crops (e.g., canola, dry beans, cereals)
- Does not apply to other uses of neonicotinoid insecticides (e.g., foliar sprays)
- Does not apply to seeds treated with other substances only (e.g., fungicides, inoculants, polymers)
- Does not include corn or soybean research plots.
Regulations By Year for Growers Wanting to Purchase Neonicotinoid Treated Corn and Soybean Seed:
To August 30, 2015:
- No requirements for the grower if purchased prior to August 30th, 2015
August 31, 2015 to August 30, 2016:
Growers have three options to access neonicotinoid treated corn and soybean seed:
- For 2016 planting only, farmers can fill in a 50% self declaration form where the farmers agrees not to use on more than 50% of total area to be farmed where they intend to plant seeds of that commodity treated with a neonicotinoid seed treatment. As part of the self declaration form:
- Farmer needs to list all fields or farms impacted
- Purchases need to match documentation
- Same form can be given to multiple vendors
- To use neonicotinoid seed treatments on more than 50% of their acres, the farmer needs to do a self pest assessment using government prepared forms. Details below.
- To use neonicotinoid seed treatments on more than 50% of their acres, the farmer can wait until after the crop is emerged and have a crop damage assessment conducted which is based on a verified plant stand loss of 15% in corn and 30% in soybeans. Details shown below.
The assessment done either way is good for 12 months. Example is if a pest assessment can be done in the spring of 2016 and be used for seed purchases for that farm for the 2017 growing season.
- For any of the above options, the farmer needs to carry in tractor submitted documentation that demonstrates need for Class 12 pesticide on the field being planted.
- No action or paperwork required where planting fungicide only, untreated or seed treated with a non-‐class 12 insecticide.
- Also there is no requirement for 2016 planting to take the government mandated IPM Course. This course however is required for the 2017 season and is being offered free of charge by the government from October 2015 to August 2016.
August 31 2016 to August 30 2017:
- Growers have two options to access neonicotinoid seed treatments in corn and soybeans.
- In order to purchase any neonicotinoid treated seed the grower must first complete the mandated grower IPM Course as described below and present the course certification number to the seed vendor when buying the seed. The only exception is if you are hiring a custom planter and they plant the seed. All other documentation is required in this exemption.
- Access neonicotinoid treated seed by completing a Pest Assessment for each field:
- No self declaration option available
- Grower needs to submit self assessment by farm/field to sales representative or vendor. The pest assessment covers individual fields by municipal roll number or civic address up to 100 acres. If the field is in excess of 100 acres, the field needs to be split with multiple pest assessments done.
- Note the self assessment is good for 12 months as per the above2.
- Submit on field by field basis Crop Pest Damage Assessment form as described above.
- Grower cannot buy without submitting paperwork on field by field basis using government form. Pest Assessment good for one year.
- Fungicide only – no paperwork or restrictions
- Fungicide and alternative non-‐class 12 insecticide – no paperwork or restrictions
August 31, 2017 and After:
- The same requirements are in place as the previous year with the additional requirement for a third party assessment depending on your county and year of implementation.
- Pest Assessment by Field:
- IPM Course and Number required before can purchase unless hiring certified custom planter and they plant seed. BUT still need to supply assessments by field
- Any field where using neonic seed treatment depending on county requires:
- 3rd Party Assessment every third year with the requirement for self assessment during the intervening years.
- Submit on field by field basis Crop Pest Damage Assessment form as described above.
- Fungicide only – no paperwork
- Fungicide and alternative non-‐class 12 insecticide – no paperwork
Grower IPM Required Course for Corn and Soybean Producers
- All growers purchasing and planting Class 12 pesticides will be required to have completed training in the new IPM course in order to purchase neonicotinoid treated seed as of August 31, 2016
- Half day Integrated Pest Management course available fall 2015
- Will be available throughout the year and through a variety of locations and online.
- Will be offered free of charge if taken before September 2016.
- Certification number given once course completed.
- Certification valid for five years
- An IPM-‐trained grower can supervise up to seven people to assist with planting.
Required Pest Assessment:
- A Pest Assessment Report must be completed every year to purchase and use Class 12 pesticides with the exception of 2016 planting where a 50% declaration form can be used.
- For the Pest Assessment Reports, there are two pest assessment methods:
- Soil Pest Assessment to determine levels of grubs or wireworms present in the soil
- Crop Damage Pest Assessment to confirm damage to crops from eligible pests of corn and soybeans
- The Pest Assessment Guideline (Conducting a Pest Assessment for Use of Class 12 Pesticides) provides the details about pest assessment methodologies and pest or pest damage thresholds.
- Neonicotinoid-‐treated corn or soybean seed may be planted only in the application area identified in the pest assessment report. This is important to remember.
- Soil Pest Assessment – Scouting
- A soil pest assessment (scouting) is a method that confirms the presence of grubs or wireworms in soil at a farm property.
- A report must verify that pest thresholds have been met or exceeded (populations may be averaged over five holes):
- An average of 2 grubs per scouting location averaged over 5 scouting locations; or
- An average of 1 wireworm per scouting location averaged over 5 scouting locations
- A grower can choose when to do soil pest scouting at any point during the year.
- The Guideline contains detailed information on soil pest assessments, such as how deep and far apart holes (scouting locations) must be.
- Crop Damage Pest Assessment:
- If a grower believes they have experienced crop damage from eligible pests (grubs, wireworms, seedcorn maggot or bean leaf beetle), they can choose to have a crop damage assessment conducted.
- A certified professional pest advisor will always be required to conduct this assessment.
- Crop damage assessment is a method that confirms:
- 15 per cent stand loss in corn caused by eligible pests
- 30 per cent stand loss in soybeans caused by eligible pests.
- The Guideline contains detailed information on crop damage pest assessments, such as the eligible pests and the methods for calculating stand loss.
- Crop damage assessments may be conducted on or after March 1, 2016.
- The certified third party person completing the pest assessment report will set and describe the application area.
- An application area cannot be any larger than that listed under a single municipal assessment roll number. For example, if the intention is to use Class 12 pesticides on 250 acres, there will be a minimum of three plots identified
- Growers will be permitted to buy and use only those neonicotinoid-‐treated corn and soybean seeds that vendors have put on the “Class 12 Pesticides List”. This is actually defined as the corn hybrid or soybean variety by name that is treated with a neonicotinoid seed treatment. Each seed company or vendor needs to submit their list to the government in advance of the order timeframe. The list will be posted on a Government of Ontario website by August of each year.
- Note that farmers are required to keep copies of pest assessment reports and other records for Class 12 pesticides for at least two years.