Protecting Bees Through Science-Based Regulation: CRE Comments to Health Canada

December 11, 2013

The Center for Regulatory Effectiveness’s comments to Health Canada on their Notice of Intent, Consultation on Action to Protect Bees from Exposure to Neonicotinoid Pesticides is attached here. CRE’s comments explain that the real process of science requires ongoing community analysis and feedback; thus we will be ventilating key bee health issues discussed in the comments of leading stakeholders on the Review of Bee Health Decline.

Below is an excerpt from the introduction of CRE’s comments:

Dear Dr. Aucoin:

Writing recently in the London Free Press, a former Associate Dean for Research & Innovation of Ontario Agricultural College provided the public with two data points about bee health that define the range of potential consequences stemming from PMRA’s pending decision on neonicotinoids:

  1. In Ontario, “bee colony numbers are increasing, climbing almost 50% in Ontario since neonic seed treatments were introduced in 2004.”
  2. “In France, the number of bee colonies dropped by 25% after a neonic ban was imposed in 1999.”[1]

Effectively protecting pollinators will require that PMRA abandon any predetermined conclusions about the causes of bee health in favor of an open and thorough review of the scientific record.

[1] Terry Daynard, “Proposed insecticide ban buzzes industry,” London Free Press, Friday, November 22, 2013, available at

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