The lambda issue is likely to make liars out of a bunch of normally honest farmers.
When a rule changes, you may not like it, but if there’s a logical reason for the rule change most people are likely to abide. On the registration change for the insecticide lambda-cyhalothrin, there’s an amazing lack of logic.
Lambda products such as Matador and Silencer are relatively inexpensive and effective ways to control flea beetles and grasshoppers. With grasshoppers causing serious problems in many areas, producers are tempted to use lambda even though this is likely breaking the rules.
The PMRA (Pest Management Regulatory Agency) in its re-evaluation of lambda approved it for food use, but not feed use. For feed barley fed domestically, grain screenings fed to livestock and even canola meal, lambda use is now prohibited. Even if you’re growing wheat and only two percent of it will be dockage that goes to livestock feed, you’re not supposed to use lambda.
Some producers haven’t even heard about the registration change. They have a lambda product left over from previous years and they’ll turn to it if grasshoppers need to be controlled.
Other producers will be aware of the change, but they’ll also recognize how the ruling is ripe with ambiguity. Lambda products have not all been pulled from the marketplace with the onus being put on producers to check with their grain buyers before applying the product.
Grain from crops on which lambda may have been applied can still be imported from other countries and fed to livestock in Canada. A lot of American corn is shipped north to Alberta’s feedlot alley.
Corn imports won’t be restricted, won’t be tested for lambda and won’t require any declaration that lambda was not used. In some years, this is millions of tonnes.
Conversely, Canadian producers delivering grain to buyers will need to sign declarations that they only used registered products. Since lambda is still registered on food crops, this is now a murky area. Some buyers may specifically prohibit lambda in their declarations. Some may not.
Applied early in the growing season for the control of grasshoppers, it’s quite possible that lambda residues could be less than detection levels in the harvested grain. The closer an application is to harvest, the greater the likelihood of detectable residues. Will anyone even be testing?
What about grain carried over from 2022 or even earlier? Will a producer even remember whether that grain came from a field where lambda was applied? No restrictions existed back then, but admitting to lambda now could make that grain difficult or even impossible to market through regular channels.
Amazingly, on harvested grain that is shipped in its entirety to another country, no restriction applies. This would be the case for feed barley shipped to export and some red lentils that are shipped field dressed, in other words shipped without cleaning.
No other country is restricting lambda, so if the screenings don’t stay here to be fed to livestock, there isn’t a problem.
The PMRA has created an illogical, unworkable regulation and has been unmoved by a concerted lobbying effort based on common sense.
On grain delivery declarations where lambda is specifically prohibited, there will be a strong temptation to be less than truthful. Of course, provincial agriculture departments, farm organizations and farm journalists shouldn’t and won’t be advising producers to sign false declarations, but considering all the facts, it’s hard to condemn anyone who decides to be a lambda liar.