Extension to consultation period on strychnine denied
Despite numerous requests from various agricultural associations and individuals to extend the consultation period on federal strychnine review, there was no intent for to do so on the final day for submitting a response, Andre Gagnon, media relations officer for Health Canada said on Sept. 27, the final day of the consultation period.
Don Connick, director for District 2 of the Agricultural Producers Association of Saskatchewan (APAS), farms near Gull Lake and was disappointed to hear that the request for an extension on the consultation was not granted.
"This is very unfortunate. With harvest not done by a long shot, people are very busy. I feel there needs to be a full consultation by those who are affected the most," said Connick.
APAS is one of a group of Saskatchewan organizations that grouped together early in September to urge Health Canada to extend the consultation period because many farmers are still in the midst of harvest.
Health Canada registers pesticides after a stringent, science-bases evaluation, re-evaluates pesticides that have been on the market on a 15-year cycle to ensure the product meets current scientific standards, and promotes sustainable pest management.
Health Canada's Pest Management Regulatory Agency, which announced on June 29 the 90-day consultation period, is responsible for pesticide regulations within the Pest Control Products Act (PCPA).
The 2% liquid strychnine that is under review falls under Restricted Pesticide regulation of the PCPA.
While heavily regulated and controlled, strychnine is used by many in the agriculture community to eradicated Richardson's ground squirrels, animals that multiply quickly and can cause extensive damage to crops and pastures.
"My feeling on strychnine is that we do need it as another weapon in our arsenal. We've been very fortunate with years when we do not need it, but the last few years we have. We are now coming off two dry years and gophers have been a problem," said Connick.
"West of Gull Lake, there was a really bad infestation on some lighter land and the producer just threw his hands up. He didn't know what to do. It's amazing how many gophers there were out there. They were everywhere."
The 2% liquid strychnine has been the most effective tool for producers in combating the damaging gopher populations on their fields.
"I understand the concerns people have. Strychnine has to be used responsibly and most producers know that and there needs to be on-going education. Strychnine falls under Restricted Pesticide regulation, so people can't just go into the store and buy it," said Connick.
"It is distributed through the Rural Municipality office here in Saskatchewan (and through county offices in Alberta) and it is stored through under safe conditions. When you buy it, you have to sign for it, so there is traceability there. It is not readily available for anybody."
The most effective time for usage is early spring when the things are greening up and ground squirrels are first emerging from hibernation and prior to the arrival of young ones.
"The gophers traditionally like the early spring green-up. So, you have to get your bait out there early," he said.
"It has to be used in the spring or early summer and if there is a bad infestation, it may need to be repeated. Once you get into July though, it is almost too late. There are other products out there, but they are not nearly as effective."
Connick said he viewed the proposals, but said none were practical for a farming operation.
"I looked at some of the proposals and they just are not practical for integrated pest management," he said.
There are producers out there who do not use strychnine, but are not opposed to the use of it when it is necessary.
"There are valid reasons for its use, but there needs to be due diligence. We just don't use it here because of the livestock, we never have, and we have lots of hawks and eagles to get rid of the gophers," said Aaron Brower, who ranches in southern Alberta. "For guys who have crops though, it's a must for them. If I was cropping, I would probably use strychnine too."
Numerous agriculture organizations in Saskatchewan and Alberta have voiced their concerns to continue allowing the use of strychnine at least until an effective alternative can be found and to extend the consultation period which ended on Sept. 27.
The Saskatchewan Association of Rural Municipalities (SARM) offered its support and joined several agriculture associations in extending the consultation period.
"We understand that strychnine is the most effective way to control gopher infestations," said Roy Orb, SARM president in a press release. " We need adequate time to gather feedback from our agricultural producers because we know first-hand the significant damage gophers can have on crops and livestock without a means of effective control."
Representatives from other organizations also issued statements.
"Saskatchewan's ranchers and farmers are the only sector that would be impacted by the PMRA review," said Todd Lewis, president of the Agricultural Producers Association of Saskatchewan. "The time-period for the consultation is totally unreasonable, given that they are all completely involved in harvest and preparation for winter."
"Right now, producers have no equivalent alternative to strychnine available for controlling Richardson's ground squirrels on their crop and grasslands and they would experience major financial losses from gopher damage if they are not able to use strychnine," said Bill Huber, president of Saskatchewan Stock Growers Association. "An extension to the comment period would allow those most likely to use the gopher-control product strychnine the time to participate in the consultation."
"This is an important tool for cattle producers especially as dry conditions favour gopher proliferation. Unfortunately. a consult at this time has missed several people as they work to bring in their hay and other crops. An extension would help make sure all are aware of the opportunity to weigh in," said Rick Toney, president of Saskatchewan Cattlemen's Association.
Carol Kitchen, president and CEO of UFA (United Farmers of Alberta Co-operative Ltd.) penned a letter to federal Agriculture Minister Lawrence McAulay in support of farmers and ranchers who use strychnine.
"Our owners pride themselves on being good stewards of the land they live on with respect for natural habitants and the environment. However, ground squirrel infestation is a serious problem that has a detrimental impact to their economic livelihood. UFA acknowledges that there are alternative options to control ground squirrel infestations, but none of these alternatives are nearly as effective and only provide short-term solutions resulting in re-invasion occurring quickly. Maxim 2% Liquid Strychnine Concentrate is the only solution that provides long-term results," she wrote. "We support education and awareness on responsible application of Maxim 2% Liquid Strychnine Concentrate, but fully contest the complete banning of this product."
Likewise, the Canadian Cattlemen's Association stated that it was also asking for the registered use of the pest management control product to remain in place until there is an effective alternative in its place. And, they were asking for the development of an anticoagulant toxicant bait where a small amount would be consumed in a single feeding.
"Until such a toxicant is available, the CCA recommends the current pest control remain approved and available to bona fide farmers and ranchers and affected municipalities for the control of ground squirrels," the CCA statement read.
The timing of holding the consultation during harvest is reminiscent of last year when the consultation period for proposed federal tax changes, changes that would have a big impact on those in the agriculture business, was also held during one of the busiest times of the year for farmers, harvest.
"By doing this at such a busy time, is downright disrespectful," said Connick.
Gagnon could not reveal a ballpark figure on the number of responses received or any further information about the consultation, but did say the results would likely be released in two to three weeks.
The debate on how to best handle gophers has been debated in business and government offices the last number of months.