Letter to the Editor – Response to WP Articles

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.

[i] http://www.canolacouncil.org/news/canola-council-advises-against-using-quinclorac-in-2016/

[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

Producer Competitiveness Threatened by Unfounded Advisory

Chicken Little is alive and well in the farm community. Threats that the ‘sky is falling’ and that Canadian canola will be barred from China because of MRLs (maximum residue levels) of quinclorac have no basis in fact.  We believe that this is causing unfounded worries among producers, reducing competition in crop protection supplies, and undermining producers’ ability to access low-cost, effective control of rapidly spreading cleavers.

“Here are some basic facts,” says Ash Skinner, CEO of Great Northern Growers which distributes quinclorac in a generic product called Clever. “First, China has never rejected Canadian canola because of quinclorac. In fact, quinclorac is made in China and Chinese producers are the world’s largest users of the product. Second, China has threatened to reject Canadian canola due to dockage.  Cleavers are difficult to clean out and are becoming more prevalent, making them even more relevant of an issue for Prairie canola farmers.”

The Canola Council of Canada (the “CCC”) is advising canola producers to forego quinclorac – a low cost product that is also available to producers in other canola-growing regions of the world – because of the MRL threat. However, says Skinner, this argument is ‘hollow’ as China has no policy on MRLs for quinclorac.  “This is an issue that is being advanced domestically, not from a foreign buyer,” Skinner added.

Among those questioning the assertion that the Chinese market is being threatened is former Agriculture Minister Gerry Ritz who has asked: “where’s the science?”

Even the CCC’s own website is fuzzy and speculative on the issue, stating “quinclorac on canola MAY result in residues that are unacceptable to China” (emphasis added) and “canola processors and exporters are CONCERNED that a canola shipment will be rejected.”[i]

“This is woulda, coulda, shoulda,” adds Skinner, “It isn’t will, does or shall.”

We believe that the CCC, in attributing concerns to the Canadian ‘value chain’, is the one making this an issue, as there is no basis to suggest that it is the Chinese importers.  The CCC then goes on to recommend that farmers fight cleavers in one of two ways: by incurring significant cost through expansion of herbicide use with multiple products or to take a multi-year approach through their crop rotation even though a low-cost generic product that can do the job immediately is available. [ii]

Further, Skinner notes, farmers in other canola-growing countries have access to low cost generics giving them a profound competitive advantage over Canadian farmers who are being warned off low-cost alternatives.

“It appears to us that the industry wants pesticides to go the way of seed.  Rather than allowing low cost alternatives it is looking to advance red herrings such as MRLs to allow them to pick and choose what pesticides farmers can use.  The foreseeable result is growers paying $50 plus per acre for needed pesticides,” he concluded.

[i] http://www.canolacouncil.org/media/574504/quinclorac_qa_11-01-2016.pdf.pdf

[ii] http://www.canolacouncil.org/crop-production/keep-it-clean/cleavers/


Quinclorac in the News

The following three articles were featured in the April 21st, 2016 edition of the Western Producer.

As with previous communications from the Canola Council and their corporate members, these articles are full of misinformation and half-truths.

As we see it the key take away points from these articles are as follows:

  1. China has not and does not have any issue with Canadian MRLs
  2. China, as a major export market for Canadian crops, is not concerned with Quinclorac.
  3. The Canola Council and their partners continue to fail to provide any sound, scientific reason for treating Quinclorac differently than other herbicides currently used on canola.

Read the following articles and ask yourself if the quinclorac MRL issue is real or simply a red herring created by the Canola Council and it’s corporate members.

Quinclorac controversy heats up

Ritz questions advice to avoid quinclorac

MRL for quinclorac on canola in the works


Watch for our response to these articles in our Letter to the Editor.