Pollinators and Pesticides - Environmental Audit Committee Contents


1.  The available evidence indicates that wild insect pollinators, such as hoverflies, moths, midges, butterflies and wild bees, are experiencing serious population declines, but there is insufficient data to be precise about the extent of such declines due to inadequate monitoring. (Paragraph 13)

2.  We agree with Defra that it would be "a good idea" if pesticide manufacturers were to publish the studies underpinning applications for pesticide approvals. The agrochemical industry has produced many studies on the environmental effect of neonicotinoids and other pesticides, but the data are allegedly confidential for commercial reasons. The lack of transparency in relation to trials and studies conducted by pesticide manufacturers has resulted in inequality between the pesticide industry on one side and academics and the public on the other. (Paragraph 26)

3.  We recognise that it is impractical to conduct individual risk assessments for the thousands of species of bees, hoverflies, butterflies, carrion flies, beetles, midges, moths and other invertebrates that contribute to insect pollination, but we are not convinced that honeybees are an appropriate proxy for all such species. (Paragraph 30)

4.  For Governments, scientists and the public to have confidence in the EU-wide pesticide approvals regime, data and analysis should be rigorously scrutinised and quality checked to form a credible evidence base. The 2006 re-approval of imidacloprid for use in the EU shows two flaws in the system. First, EFSA identified the issue of soil accumulation in its peer review, but the European Commission proceeded to sign off imidacloprid as an approved active substance for use in Member States without explicitly addressing that risk. There seems little point in EFSA's assessing risk if the Commission ignores environmental threats identified in that process. Secondly, the choice of Germany as the Rapporteur Member State in the case of a substance developed and manufactured in Germany raised a potential conflict of interest. (Paragraph 39)

5.  The Henry, Whitehorn and Gill laboratory studies raised serious concerns about the potential effect of neonicotinoid insecticides on bees. While laboratory studies should as far as possible replicate field conditions, they cannot by their nature do so precisely. One of their virtues, however, is that they take place in controlled conditions. The FERA bumblebee study, which Defra commissioned to test the conclusions of the laboratory studies in the field, was, we conclude, fundamentally flawed because the bees were placed outside on different dates, some colonies had a lower starting mass than others and a different neonicotinoid from the one used in the study was present in the 'unexposed' hives. The FERA bumblebee study is not therefore a compelling basis for inaction. (Paragraph 51)

6.  Neonicotinoid pesticides are not fundamental to the general economic or agricultural viability of UK farming, although there may be specific issues in relation to oilseed rape that might require careful management if neonicotinoids were not available to growers. (Paragraph 68)

7.  Defra policy on pesticides must be evidence-based. Where the available scientific evidence is either incomplete or contradictory, Defra must apply the precautionary principle rather than maintaining the status quo while waiting for further evidence. Defra policy in relation to neonicotinoids is not currently founded on the precautionary principle as set out in the 1992 United Nations Rio Declaration and the Lisbon Treaty, in that Defra will not countenance imposing a moratorium if it would not be "proportionate". Ministers currently consider that a decision on a moratorium should be informed by potential economic impacts as well as by clearer proof about harm to bees than is currently available or is likely to be produced in the near future. We recognise the agricultural value of neonicotinoid insecticides, but economic factors should not blur environmental risk assessment and risk management, where the protection of people and the environment must be paramount. (Paragraph 69)

8.  That it was necessary to take legal advice whether the UK National Action Plan for the Sustainable Use of Pesticides complied with the minimum requirements of the EU directive suggests that the UK failed to take this opportunity to address pesticide use to benefit human health and the environment. It is difficult to see how pesticide use will change without the implementation of the objectives, timetables, measures and targets that officials dismissed as "meaningless". (Paragraph 74)

9.  In the interests of the environment, food security, minimising resistance among pests and maximising agricultural incomes, it is desirable that the minimal possible amount of chemical pesticides is used in agricultural production. This means moving away from any excessive use of chemical pesticides and utilising integrated pest management. Such an approach would prevent any ban on neonicotinoids necessarily causing the increased use of potentially more harmful substances. (Paragraph 80)

10.  There is no compelling economic or agricultural case for neonicotinoid use in private gardens and on amenities such as golf courses, which provides Defra with an opportunity to exercise its stated commitment to the precautionary principle. (Paragraph 84)

11.  While much detail remains to be negotiated in the European Commission and between Member States, the prospective CAP package for the next seven years offers opportunities for significant additional 'greening' measures, including programmes which could support greater use of 'buffer strips' and other pollinator habitats. (Paragraph 91)

12.  The conservation of pollinators is crucial to maintaining biodiversity in the UK. In addition, pollinators have a significant economic value as an ecosystem service to UK agriculture. Farmers and environmentalists therefore have a shared interest in conserving pollinators. The data on the value and health of pollinator populations is currently insufficiently precise to inform a marketised approach that could capture the benefits and costs of pesticide use. (Paragraph 95)

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Prepared 5 April 2013