This letter to the editor is being written to point out some Clever (sorry for the pun) worded comments in recent articles by the Canadian Canola Council (the “CCC”) and its associates, who, to us, appear to be fighting for higher input costs for growers.
The CCC, with the Western Grain Elevator Association (the “WGEA”) & the Canola Oilseed Processors Association (the “COPA”) (collectively, the “Multinationals”) have come out against quinclorac and in particular, Clever, (a low cost solution for cleaver problems from Great Northern Growers “GNG”), which we feel are misguided, or do not convey the full story about quinclorac. For example, let’s look at the following statement:
“China has no Maximum Residue Limit (“MRLs”) for quinclorac on canola. Being one of the biggest markets for canola, China has no history of accepting imports of canola where quinclorac residues have been detected. There is also no MRL for the herbicide on canola in the CODEX Alimentarius which is an internationally recognized collection of standards considered by Chinese authorities when accepting imported products.”[i]
What this statement fails to mention, with what we feel is a cleverly worded statement, is that 23 of the 53 pesticides actives registered for canola with established MRLs in Canada could fall into a similar statement; The statement fails to mention that China has no more a documented acceptance of Codex than it does for Country of Origin, making 46 of the 53 actives for canola in Canada unsuitable for China. Yet, it seems that quinclorac is unfairly targeted. The CCC also fails to mention that Country of Origin, much the same as Codex, is also considered by Chinese authorities when accepting imported products.
The Multinationals further claim that quinclorac can be found on canola when testing samples that quinclorac was used on. Again, Clever messaging, as this statement could apply to the vast majority of the pesticides registered in Canada for use on canola when tested in the manner that quinclorac was detected in samples, and not the internationally standard manner in which China tests. Conveniently, the Multinationals do not mention that when tested, the average quinclorac residue is below .02 ppm (parts per million), falling far below the acceptable deemed safe level by Health Canada of 1.5 ppm. Further, they do not mention that quinclorac’s tested levels, when used at the rates Clever has on its label, are below 43 of the 53 pesticides registered MRLs for Canada. Accordingly, we feel that the statements are misleading. Further examples of statements that we feel are misleading can be shown when we compare quinclorac to an active such as glyphosate (with no Chinese MRL), which has an established MRL of 20 ppm – more than a 1,000 times the average MRL actually found in quinclorac sprayed seed . Further, azoxystrobin used in common pesticides like Quadris (has no Chinese MRL or Codex), has an established MRL in Canada of more than 50 times that found in samples of canola sprayed with quinclorac. No one is arguing that you may find quinclorac in seed, as it is expected to be there much like other pesticides.
Further, in these articles, members of the CCC seem to imply some form of superior morals as justification for their statements against quinclorac. One such example is seen in the commentary from BASF’s Chris Vander Kant who commented on the matter as follows: “We make a point of making sure we have the necessary MRLs for all the major export markets”.[ii] What Mr. Vander Kant fails to mention and clarify is that with only 6 actives with actual sufficient MRLs for canola in China, most of BASF’s canola products do not have registered MRLs in China as a major export market. This includes their form of quinclorac that is used on cereals at 3 times the rate with no MRLs in China or in Codex. Yet, Mr. Vander Kant goes on to say “And that’s why establishing import tolerances in necessary Canadian export markets prior to launching a new product is imperative to BASF”. ii
We believe these comments raise the following question: Is it necessary to establish an import tolerance for China, given that BASF’ does not do so and many independent experts say it is not required? Given that China only tests for MRLs they have established, and will defer to Codex and Country of Origin if requested by the importing company, is it necessary to establish an import tolerance? In making such comments, we feel that BASF also fails to mention that quinclorac has been around for over 15 years and is well known to work on canola and yet is still not added to Codex. Further, quinclorac has no schedule to be added to Codex, yet BASF’s more expensive and new products have been added to Codex.
We also take issue with the following statements which, in our opinion, are misguided:
- Cleavers rank 7th on Saskatchewan’s recent top 10 weed list.
- This statement fails to mention that this ranking is not limited to canola, where in canola, cleavers ranks 3rd, and cleavers is the fastest spreading weed, at the top of the list for recent resistance to glyphosate.
- The CCC also puts out information on how to deal with cleavers: This information uses high cost solutions like Edge, whose active has no MRL in China or Codex.
- It is also important to note the following from a recent release from the U of S Department of Soil Sciences “The correlation between increasing cleavers populations and canola acres potentially means that current canola herbicide options do not effectively control cleaver populations”. [iii]
- The CCC also fails to mention that at only 5% cleaver infestation (a minor infestation), it potentially costs growers 100’s of millions of dollars.
Gerry Ritz, former Agriculture Minister and sitting MP, recently talked about this issue with the relevant Chinese authorities when in China on a trade mission. Mr. Ritz could not be clearer that this is not an issue to the Chinese. To Mr. Ritz and us, it is clear this is a “made in Canada” problem, as quinclorac poses no more risk than many of the existing pesticides used in Canada. In our opinion, we feel that quinclorac, brought to market by a low cost input supplier like GNG, is being targeted by the Multinationals without just cause or science. It further appears that the Multinationals are waging a war against low cost alternatives and that they are looking for pesticides to go the way of seed. In our opinion, we feel that the Multinationals are waging this war so as to limit options available to growers, through the use of red herrings like MRLs, resulting in growers needing to pay upward of $50 per acre for pesticides much the way they now do for seed. To us, the saddest part of all of this, is that we feel that the Multinationals have used the CCC, an organization significantly funded by the growers’ own volunteer check off dollars, to work against the growers’ own best interests.
[ii] Western Producer pg 14, April 21, 2016
[iii] Evaluating the response of Galium species and populations to herbicides, I.G. Epp, C.J. Willenborg