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20 and soybean seeds. First it establishes a new class of pesti- cides Class 12 under Ontarios Pesticides Act and Ontario Regulation 6309 for corn and soybean seed when treated with imidacloprid thiamethoxam and clothianidin. Also it establishes methods for farmers to assess if pest problems require the use of neonicotinoid-treated seeds. 6309 sets out requirements for the sale and use of neonicotinoid-treated seeds and tracks the sale of neonicotinoid-treated seeds. Vendor Requirements As part of the change treated seed vendors who sell Class 12 pesticides must be licensed. The requirements vendors must meet include Obtain one license for each location. Name all treated-seed sales representatives. Submit a list of Class 12 pesticides that you intend to sell over a 12-month period starting Aug. 31. This list is to be submitted by July 31 each year starting in 2015 however changes to the list can be made after this date. Offer untreated or fungicide only corn and soybean seed for sale. Additionally when advertising treated seed for sale the vendor must make it known whether its Class 12 and whether it contains imidacloprid thiamethoxam and clothia- nidin. The vendor must also advertise that corn and soybean seeds not treated with neonicotinoids are available for sale. During the point of sale vendors of Class 12 pesticides must collect certain information which varies from 2015 to 2016 and 2017. This year vendors must collect from the farmer a seed amount declaration form or a pest assessment report showing inspection of the soil. This assessment can be completed by the farmer or any other person according to OMECC. In 2016 vendors must collect the Integrated Pest Management IPM Certification Number and have a written declaration that IPM principles have been considered as well as a pest assessment report. The assessment report can be based off a soil inspection or crop inspection. Soil inspections can be completed by the farmer or any other person if completed before Aug. 31 2016 or by an IPM certified person if com- pleted on or after Aug. 31 whereas the crop inspection must be completed by a professional pest advisor PPA only. Then in 2017 vendors are required to collect the IPM Certification Number a written declaration that IPM princi- ples have been considered and the Pest Assessment Report. This report can be from a soil inspection or crop inspection. At this point the soil inspection must be completed by an IPM certified person or PPA based on geographical region and the crop inspection must be completed by a PPA. After the point of sale starting in 2016 Class 12 pesticide vendors must submit to Ontarios Ministry of Agriculture Food and Rural Affairs copies of each pest assessment report given to them during the previous 12-month period. These are due Oct. 31 of each year. For example the 2016 submis- sion will include reports from Aug. 31 2015 to Aug. 30 2016. Additionally vendors must complete a Sales and Transfer Report form and submit that to OMECC. This too is due Oct. 31 of each year starting in 2016. This form includes aggregating results of Class 12 pesticides and non-neonico- tinoid treated corn and soybean seed sales. It also includes information from treated seed sales representatives direct- to-farm vendors and the direct purchaser. Treated seed vendors arent the only ones who have to meet these requirements. Treated seed sales representatives direct-to-farm vendors and custom seed treaters also have responsibilities under 6309 however they do not have to be licensed. New Data While government continues to push increased regulation farmers and the seed industry dont believe regulation is the best way to handle the pollinator health issue. They have introduced best management practises and put together their own blueprint for pollinator health leading up to the announcement. And according to Scott Kirby director of the Environmental Assessment Directorate of Health Canadas Pest Management Regulatory Agency the number and severity of incidents reported in association with neonicotinoid pesticide use during the 2014 seeding season was 70 per cent lower than the previous year. A full assessment of this years incidents is still underway. Incidents relating to unproductive hives and poor perform- ing queens later in the season have no clear link to neoni- cotinoid exposure Kirby explains noting that the science related to sub-lethal exposure to pesticides is not conclusive. GFOs Brock says Our organization firmly believes these regulations are not workable and we are highly concerned about how they will negatively impact the future of grain farming in this province. The amount of active ingredient introduced to the environment with seed treatments is only 10 per cent of that contributed by in-furrow treatments and its only one per cent of foliar sprays. Dave Baute