Insects and Insecticides

Written evidence submitted by The Co-operative.

Executive Summary

1. The evidence base on the impacts of neonicotinoid pesticides has grown dramatically in recent years linking long-term, chronic exposure to field realistic levels of the pesticides with problems with bee fecundity, impaired ability to pollinate crops, increased susceptibility to disease and the loss of hives [1] .

2. In March 2012, the then Chief Scientific Adviser to DEFRA, Sir Bob Watson, publicly expressed his concern about the current UK position in regard to neonicotinoids and went on to state that he wanted the science reassessed "very, very carefully" [2] .

3. The use of neonicotinoid pesticides is very widespread – in 2011 in excess of 1.25 million hectares of British cropland were treated with this class of pesticide [3] . However, the chronic, long-term effects of these systematic chemicals are not adequately addressed by the current pesticide safety assessment process, a situation which should be urgently rectified.

4. In light of the European Food Safety Agency (EFSA) report and other recent research from the UK and Europe, we believe that the weight of evidence upholds our call for an independent review of the science and regulatory assessment of neonicotinoid pesticides.

The Co-operative Group

5. The Co-operative operates significant food, funeral, legal, farming and financial services businesses and has been owned and democratically controlled by its members since 1844, when it was founded on the values and principles of self-help, self-responsibility, democracy, equality and equity. With seven million members, it is one of the largest consumer co-operatives in the world.

6. The Co-operative is in the unique position of being both a food retailer and a farmer. We serve over 14 million customers a week and we farm approximately 35,000 acres in England (and 15,000 in Scotland).  It is therefore of vital importance to maintain pollinators to help food production on both the land we farm and in our supply chain.  Our successful farming business also demonstrates that prudent use of pesticides and encouragement of pollinators on the land is a viable policy.

7. We have an industry-leading policy to safely manage the use of pesticides in all own-brand fresh, chilled, frozen and canned produce sold in our food stores. The policy contains 32 banned, 90 prohibited and 328 monitored pesticides and led to our top ranking in the most recent Pesticide Action Network Supermarket Survey [4] .

8. In 2009, we launched our Plan Bee campaign in response to the worrying decline of honeybees and have since expanded our activity to include support for other at risk pollinators such as bumblebees, butterflies and hoverflies. We have trained 300 new beekeepers, distributed 1.2m packets of pollinator friendly wildflower seeds to our members and customers, and we have installed 1,200 hives on our farms. We have also conducted wildflower seed trials on our farms to determine the mix best suited to sustaining foraging bees in field margins.

9. Through the Plan Bee campaign we have taken specific action on neonicotinoid pesticides including:

· from early 2009, prohibiting the use of six neonicotinoid pesticides on our own-brand fresh and frozen produce (clothianidin, dinotefuran, imidacloprid, fipronil, nitenpyram and thiamethoxam). This requires growers to seek a derogation for use if they can demonstrate viable alternatives don’t exist;

· funding research into the impact of neonicotinoids on bees, the results of which we expect to be published before the end of the year.

· calling on the UK Government to carry out a systematic review of the impact of pesticides on our most important pollinators via a petition on our website, which 8,000 people have signed.

· a key vote at the check outs of our food stores from 5 – 19 April 2010, asking the question ‘do we need better pesticide research on bees?’, to which nearly 250,000 people (76%) voted yes.

10. For more detail of these and other Plan Bee projects, please see the Plan Bee website: www.co-operative.coop/planbee

Bees in the UK

11. Pollinators are integral to our food system – honeybees alone are responsible for pollinating around 30% of the food we eat [5] . Pollinator populations are in decline. Between 1985 and 2005, there was a 53% drop in the number of managed honeybee colonies in the UK [6] , and wild honeybees are thought to be close to extinction throughout the British Isles [7] . A number of bumblebee species are also struggling – 25 species can be found in the British Isles, but three have become extinct in the last 150 years and seven have been added to the UK Biodiversity Action Plan list [8] in a bid to safeguard their survival. There are more than 200 species of solitary bee in the UK [9] . These tend to have lower dispersal potential and more specialisation than honey and bumblebee species and as a result, are thought to be more vulnerable [10] .

12. There is a large financial cost associated with pollinator declines. It is estimated that the value of honeybee pollination of commercial crops has been estimated at between £120-200 million annually [11] . A publication from the Parliamentary Office of Science and Technology states that the total loss of pollinators could cost up to £440m a year, about 13% of UK income from farming. Insect-dependent crops can be pollinated by hand, but the cost of this would be prohibitive, estimated at around £1,500m a year [12] .

13. Pesticides, in particular neonicotinoids, have been cited as one of the major factors leading to declining pollinator populations.

14. The recent Defra report [13] appears to be a significant step forward in acknowledging the problems identified in the growing science base but stops short of taking action on testing and regulation. We look forward to Defra reporting back on the issue by the end of the year and hope that the Environmental Audit Committee will reinforce the urgency of this work.

Growing evidence base on impacts of neonicotinoids

15. The evidence base on the impacts of neonicotinoid pesticides has grown dramatically in recent years. Research from Stirling University [14] , the French National Agriculture Research Institute (INRA) [15] , Royal Holloway, University of London [16] and the opinion released by the European Food Safety Agency (EFSA) [17] on the pesticide risk assessment for honeybees all highlight that the current risk assessment fails to adequately address certain routes of exposure to neonicotinoids for pollinators and raise concerns about the use of products containing these compounds. In addition, in March 2012, the Chief Scientific Adviser to DEFRA, Sir Bob Watson, publicly expressed his concern about the current UK position in regard to neonicotinoids and went on to state that he wanted the science reassessed "very, very carefully" [18] .

16. This growing evidence base links long-term, chronic exposure to field realistic levels of the pesticides to problems with bee fecundity, an impaired ability to pollinate crops, an increased susceptibility to disease and the loss of hives.

Inadequate assessment of the sub-lethal effects of pesticides

17. The use of neonicotinoid pesticides is very widespread – in 2011 in excess of 1.25 million hectares of British cropland were treated with this class of pesticide [19] . However, the chronic, long-term effects of these systematic chemicals are not adequately addressed by the current pesticide safety assessment process, a situation which should be urgently rectified.

18. Systemic pesticides behave very differently to conventional applications. As the chemical is taken into each part of the plant including the pollen and nectar, the exposure of bees to the insecticides is prolonged, causing chronic exposure to pollinators. In the case of honey and bumblebees, this exposure continues in the hive. At present, there is no suitable standardised testing procedure for chronic toxicity of pesticides, there are no threshold values with which to identify a chemical which presents a significant risk and the wider environmental impact of their use is not considered appropriately.

19. The European assessment is also inadequate for assessing the sub-lethal effects of pesticides. Sub-lethal effects are not tested as standard – these tests only occur if the Hazard Quotient is triggered. The Hazard Quotient is the application rate of the chemical (g/ha) divided by the dose of the chemical required to kill 50% of the test population (the LD50). Only if the Hazard Quotient exceeds 50 are the higher level tests, such as those assessing the sub-lethal effects of pesticides, applied. There are no internationally agreed, standardised assessment methods for sub-lethal effects, and no validity criteria or toxic standards for them. Additionally, while honeybees undergo acute toxicity tests, the acute effects of pesticides on bumblebees and solitary bees are largely unassessed.

Recommendation

20. In light of the EFSA report and other recent research from the UK and Europe, we believe that the weight of evidence upholds our call for an independent review of the science and regulatory assessment of neonicotinoid pesticides.

31 October.2012


[1] Whitehorn P.R. et al . (2012) Neonicotinoid Pesticide Reduces Bumble Bee Colony Growth and Queen Production

[1] 336 ( 6079 ): 351 - 352. Available at: www.sciencemag.org/content/336/6079/351.abstract

[1] Henry M. et al . (2012) A common pesticide decreases foraging success and survival in honey bees . Available at: www.sciencemag.org/content/336/6079/348.abstract

[1] European Food Safety Authority (2012) Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees ( Apis mellifera , Bombus spp. and solitary bees) .

[1] (2012) EFSA Journal 10(5) 2668 .Available at: www.efsa.europa.eu/en/efsajournal/pub/2668.htm

[1] Gill R.J. et al (2012) Combined pesticide exposure severely affects individual- and colony-level traits in bees. Available at http://www.nature.com/nature/journal/vaop/ncurrent/full/nature11585.html

[2] www.independent.co.uk/environment/nature/government-to-reconsider-nerve-agent-pesticides-7604121.html

[3] The Food and Environment Research Agency. Pesticides Usage Surveys. Available online at: http://pusstats.csl.gov.uk/myindex.cfm

[3]

[4] www.pan-uk.org/supermarkets/2011-supermarket-comparison

[5] Klein A.M. et al . (2006) Importance of pollinators in changing landscapes for world crops. Proceedings of the Royal Society (2007) 274 , 303–313. Available at: www.ncbi.nlm.nih.gov/pmc/articles/ P MC1702377/pdf/rspb20063721.pdf

[6] Potts S.G. et al . (2010) Global Pollinator Declines; Trends, Impacts and Drivers; Trends in Ecology and Evolution 25, 345-353. Available at: http://www.sciencedirect.com/science/article/pii/S0169534710000364

[7] Carreck N. (2008) Are H oneybees (Apis mellifera L.) Native to the British Isles ?; Journal of Apicultural Research 47, 318-322. Available at: http://cat.inist.fr/?aModele=afficheN&cpsidt=20970698

[8] JNCC. UK BAP priority terrestrial invertebrate species. Available at: http://jncc.defra.gov.uk/page-5169

[9] Royal Entomological Society. Solitary Bees. Available at: www.royensoc.co.uk/insect_info/what/solitary_bees.htm

[10] Williams N.M. et al . (2010) Ecological and life-history traits predict bee species response to environmental disturbances; Biological Conservation 143 , 2280-2291 . Available at: www.sciencedirect.com/science/article/pii/S0006320710001138

[11] www.defra.gov.uk/food-farm/crops/bee-health/

[12] Parliamentary Office of Science and Technology (2010). Postnote 384, Insect Pollination. www.parliament.uk/documents/post/postpn348.pdf

[13] Defra, (2012) Neonicotinoid insecticides and bees, the state of the science and the regulatory response. Available at: www.defra.gov.uk/publications/files/pb13818-neonicotinoid-bees-20120918.pdf

[14] Whitehorn P.R. et al . (2012) Neonicotinoid Pesticide Reduces Bumble Bee Colony Growth and Queen Production

[14] 336 ( 6079 ): 351 - 352. Available at: www.sciencemag.org/content/336/6079/351.abstract

[15] H enry M. et al . (2012) A common pesticide decreases foraging success and survival in honey bees . Available at: www.sciencemag.org/content/336/6079/348.abstract

[16] Gill R.J. et al (2012) Combined pesticide exposure severely affects individual- and colony-level traits in bees . Available at http://www.nature.com/nature/journal/vaop/ncurrent/full/nature11585.html

[17] European Food Safety Authority (2012) Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees ( Apis mellifera ,   Bombus   spp. and solitary bees) . (2012) EFSA Journal 10(5) 2668 .Available at: www.efsa.europa.eu/en/efsajournal/pub/2668.htm

[18] www.independent.co.uk/environment/nature/government-to-reconsider-nerve-agent-pesticides-7604121.html

[19] The Food and Environment Research Agency. Pesticides Usage Surveys. Available online at: http://pusstats.csl.gov.uk/myindex.cfm

[19]

Prepared 19th November 2012