The Ontario Beekeeper's Association (OBA) received a letter from Pamela Young, Manager, Food of Plant Origin, Food Inspection Branch, Ministry of Agriculture and Food stating the position of the Ministry related to our concern of the potential repeal of the Bees' Act. We append the bulk of the letter below. According to Ms Young, the development of a new regulation for bee health under the Animal Health Act, 2009 is not a current priority for OMAF and there is no plan to move forward in the short term with any repeal of the Bees Act. She also reiterates that the Ministry has an obligation to consult on any proposed changes to the regulatory environent affecting the apiary sector.
We thank Ms Young for her swift and clear response and for her firm commitment to consult with our sector regarding any potential or future changes to the Act. We have always enjoyed a constructive partnership with OMAF, one which has strengthening the beekeeping industry and protected bee health for many years: we would hope the future would hold nothing less.
However, her reassurance is specifically 'short term', while our mandate and interests are long-term. Our position called for a suspension of the repeal of the Act as well as the removal of the header on the Act that implies repeal at a later date. Therefore, although we respect the good faith of her reply, until we are confident of the long term security of the Act, we will continue to promote and support this key legislation, so critical to our sector. Our modified public position below reflects our acceptance of Ms Young's statements, while making it clear why this Act is so important to us and why we will continue to protect it.
"With respect to your reference to the future repeal of the Bees Act, when the Animal Health Act 2009 was developed, it contained several sections that did not come into force with the rest of the legislation. One section dealt with the future repeal of the Bees Act. This section was included to allow for the possibiity that the Bees Act and its existing regulation could be consolidated and included within the Animal Health Act, 2009 as a separate regulation. The Bees Act is an older piece of legislation and it does not contain the same flexibility and scope of inspection and response powers that are included in the Animal Health Act, 2009. Quebec took a similar approach to regulating beekeepers when it repealed the Bees Act (Quebec) and developed new regulations for beekeeping and beekeeper registration under the Animal Health Protection Act (Quebec).
At some point in the future, Ontario beekeepers may wish to enter into a discussion with OMAF about how beekeeping and bee health can be most effectively regulated in the province. Consultation with Ontario beekeepers would be an essential part of the development of any new legislation. I want to assure you that the development of a new regulation for bee health under the Animal Health Act, 2009 is not a current priority for OMAF and there is no plan to move forward in the short term with any repeal of the Bees Act.
Dan, I also want to reiterate that the Ministry has an obligation to consult on any proposed change to the regulatory environment affecting the apiary sector. A further example of this duty to consult occurred when we introduced regulation 119/11, under the Food Safety and Quality Act 2001, dealing with the packaging, transportation, and labelling of honey. We worked very closely with the Ontario Beekeepers' Association throughout the regulatory development process."
The Ontario Beekeeper's Association's (OBA) mission is to work to ensure a thriving and sustainable beekeeping industry in Ontario. To this end, we advocate for beekeepers' interests, support honey bee health research and deliver practical training and information.
The Bees Act governs the apiculture sector in Ontario. It is this legislation that guides beekeepers and that gives bee inspectors the authority to inspect Ontario apiaries and enforce the regulations designed to keep Ontario's bees healthy.
The Ontario Beekeepers’ Association (OBA) strongly supports this legislation. Under this Act, the beekeeping sector gains:
Honey bees are a unique livestock and they play an integral part in our environment as the pollinator for as much as one-third of the food we eat. Their health and future is directly linked to environmental pressures that are both natural and manufactured. Bees must be managed in a distinct manner because, unlike fenced livestock, the honey bee flies freely over wide areas, coming in contact with other bees and forage beyond any practical control of the individual beekeeper. This makes the honey bee especially susceptible to disease poisoning and pest pressures that require close scrutiny and management across a very broad geography. Today's Bees Act enables such scrutiny and management. Without the Bees Act and the broad scope of authority and specialty it brings, there is much greater risk to the health and population of the Ontario honey bee.
Beekeepers help their honey bees produce food from the hive as honey and pollen, but they also affect the production of food from pollination-dependent fruit and vegetables. The Ontario beekeeping sector contributes over $200 million a year to agriculture through pollination services and hive products. The distinct guidelines and authorities delivered through the Bees Act are understood by beekeepers to be an integral part of the industry and honey bees' future.
Further, mortality levels for honey bees are high in Ontario and around the world. The natural and and man-made pressures are great, and without help a healthy future for the honey bee and other pollinators in Ontario is uncertain.
At a time when the risk to honey bees is so high, the OBA’s position is that: