The Canadian Food Inspection Agency's (CFIA) import risk analysis was initiated back in 2023 to determine if the importation into Canada of approximately 50,000 (24,000 to 75,000) honey bee packages from the United States (U.S.) could be allowed.
Background
The importation of all honey bees (Apis mellifera subspecies) from the U.S. into Canada has been restricted since 1987 as a result of the presence of pests and disease of concern in the U.S.. Previous import risk analyses were completed for the importation of honey bee packages from the U.S. in 2003 and 2014. Based on these analyses, the importation of individual hand-picked honey bee queens from the U.S. was permitted since 2004. However, honey bee packages still presented a higher risk than queen bees and therefore continued to be restricted from importation into Canada.
In 2022, the CFIA put out a call to the public and industry for the submission of any new, science-based information on the status of honey bee health in the U.S. and Canada. In June 2023, a new import risk analysis for honey bee packages from the U.S. was initiated to determine if the importation of approximately 50,000 (24,000 to 75,000) honey bee packages per year from the contiguous U.S. could be allowed into Canada.
The process used in this analysis is based on the approach recommended in the World Organisation for Animal Health (WOAH) Terrestrial Animal Health Code and the Handbook on Import Risk Analysis for Animals and Animal Products (World Organisation for Animal Health, 2010), which includes the steps of hazard identification, risk assessment and risk management.
The hazard identification and risk assessment documents were developed by the CFIA's animal health risk assessment experts, peer reviewed by international experts and completed in the Fall 2024. 5 hazards were identified as having a risk level above Canada's acceptable level of protection (ALOP) and therefore risk mitigation measures are required to determine whether honey bee packages can be imported from the U.S.. The final risk estimate determined that under the expected volume of importation, the probability of entry, exposure and establishment of each identified hazards on at least one recipient hive in Canada would be 100% and that the overall, national-scale impact for each of these hazards would be moderate.
As part of our consultation on risk analysis for the importation of honey bee packages from the United States to Canada, a period open to the public was held from November 7, 2024 to January 31, 2025. During that time, Canadian stakeholders, the United States Department of Agriculture – Animal and Plant Health Inspection Service (USDA – APHIS), industry and anyone with interest in the matter were invited to submit any science-based risk mitigation proposals to the CFIA. The expectations for risk mitigation measure proposals are set out within the CFIA's Risk Management Framework document, which specifies particular matters that risk mitigation proposal submissions must consider.
The CFIA encouraged all interested parties to participate in this process to ensure diverse perspectives were considered. The CFIA also met with the USDA-APHIS to discuss the process related to the risk management expectations set out in the Risk Management Framework document, and to answer any questions the USDA-APHIS had about submitting their risk mitigation proposals to the agency.
The consideration of implementation of any measures to mitigate identified risks must uphold the CFIA's mandate under the Health of Animals Act and Regulations to help protect Canadian animal health, which includes the health of the Canadian honey bee population.
Risk mitigation proposals needed to ensure that the likelihood of entry, exposure and establishment of hazards of concern on recipient hives in Canada as a result of the importation of approximately 50,000 (24,000 to 75,000) honey bee packages (over a period of one year) from the US is negligible. Risk mitigation measures must comprehensively and scientifically demonstrate how they would reduce the risk level to negligible level for each hazard prior to entry (in the country of origin) and must consider the technical, operational, and economical feasibility to effectively reduce the risks for all hazards identified to CFIA's negligeable level of risk.
Summary of risk mitigation proposal submissions from stakeholders
During the consultation period in which the CFIA invited stakeholders, the USDA-APHIS and the public to submit risk mitigation proposals, the agency received a total of 30 submissions. Of these submissions, 26 were position statements, some of which commented on the substance of the risk assessment. No risk mitigation proposals were provided in those 26 submissions. Although the hazard identification and risk assessment documents had previously been peer-reviewed by an international panel of experts, some stakeholders chose to provide subjective opinions on the substance of the risk assessment, which was outside the scope of this stage of the process, rather than providing risk management proposals. Also, many stakeholders' comments on the risk assessment appeared to have overlooked the risk assumptions section within the risk assessment for each of the identified hazards which did consider Best Management Practices (BMP) already advocated by industry and which were reflected in the likelihood scenarios to determine the risk level for each identified hazard. Nevertheless, each stakeholder comment related to the risk assessment was taken into consideration to ensure that any potentially relevant data in the matter was not overlooked. However, upon review, the CFIA determined that the comments were only subjective opinions related to the content of the risk assessment and did not provide any additional supporting scientific merit that could confer any statistical significance to alter the conclusion of the risk assessment.
Four submissions provided to the CFIA contained nominal or partial constructs of risk mitigation measures surrounding:
- a limited regional trade strategy
- evaluating the impact on interprovincial movement
- import inspections and national surveillance upon entry in Canada
- using current import conditions of queens for the importation of packages
- integrated pest management practices and best management practices and
- off-label miticide and antibiotic treatment propositions
The details regarding risk mitigation measure elements contained in the stakeholder proposals have been summarized in the Summary of risk mitigation measure proposals and includes the CFIA's assessment of each risk measure submitted.
CFIA's decision on risk management
The CFIA evaluated all risk mitigation proposals submitted by stakeholders. However, no individual mitigation measure or combination of proposals was feasible. None of the proposals were comprehensive, nor did they provide the necessary scientific documentation to demonstrate how they could reduce all risk impacts to the CFIA's negligible level for all identified hazards. Furthermore, none of the proposals addressed the risk at source (in the country of origin), and all lacked merit and failed to meet the risk management expectations outlined in the Risk Management Framework document made available to stakeholders by the CFIA. Furthermore, the USDA-APHIS's proposal did not offer any zoning proposal nor disposition to provide additional measures beyond the existing import conditions for importing honey bee queens which the Risk Assessment determined were insufficient at reducing the risk to negligible for packages.
Bee health is complex, and it is important that honey bee imports be controlled in such a way that they do not pose an unacceptable risk to the Canadian honey bee population. Due to the absence of any implementable mitigation measures, the CFIA concludes that there has been no change in the import risk status and that the risk levels of the identified hazards remain above the CFIA's acceptable level of risk for the importation of honey bee packages from the U.S. It is therefore CFIA's decision, in accordance with the agency's regulatory mandate under the Health of Animals Act and regulations to help protect all Canadian animal health, to maintain the current import status of not allowing the importation of honeybee packages from the U.S..