Insects and Insecticides

Written evidence submitted by Sussex Beekeepers Association

Areas of concern over the rapidly expanding use of Neonicotinoids for systemic crop protection.

There is a substantial risk of conflicts of interest arising in that DEFRA as it is solely

responsible for :-

Farming economics

National food security

Protection of the natural environment

Pesticide regulation and approval

Environmental safety of pesticides

Health and maintenance of Honey bees as pollinators

The only test applied to arrive at a balanced policy is the Balance of Economic Advantage test which is heavily weighted towards the first two items as these are measurable in monetary terms.

The Chemical Regulation Directorate CRD together with the Advisory Committee on Pesticides ACP advises DEFRA on the effects of pesticides but carries out no research on an independent basis on the effects of these, relying instead on the crop protection industry to both fund, frame and execute such research as is done.

As Neonicotinoids are highly water soluble and have a relatively long residual half life, more than 1.5 years in the field of use, there is a strong risk that in crops like maize used for silage which is often planted for two or three successive years without a treatment break that soil residual levels are higher than expected as not only are stalk and root residues containing these substances left in situ but manure and slurry effluents containing them when fed to cattle is spread back onto the land as part of the crop cycle. Grazing pastures are also used to spread potentially contaminated manure and slurry and effluents enabling the unmonitored risk of uptake by non target bee forage plants such as clovers. It appears that such risks have not been considered or assessed by CRD, nor by ACP

There is no system for regularly testing for residues either in soils or in groundwater and standing water, the later being important water sources for honeybees. There is evidence that neonicotinoid levels may often be very high in standing water.

There is a strong risk of re-uptake of these substances by plants in field margins which are not targets of use. No samples/ censuses are taken either of residues or invertebrate populations in field margins and adjacent land to assess collateral damage.

There is strong evidence that when used as a systemic insecticide in maize the substances are present in sap exuded as guttation which is attractive to honeybees and is also present in the pollen of both maize and oil seed rape both of which are collected, frequently in large quantities, by bees and processed into food for their larvae.

There is strong evidence that significant concentrations of neonicotinoids can exist in dust in arable areas which can adhere to bees and other invertebrates.

There is published evidence that sub lethal doses of these very powerful neurotoxins can affect the behaviour of insects, including honeybees. These sub lethal dosage effects have not been assessed, measured or monitored either by the producers of neonictinoids or independently by CRD /ACP who have stated that the risks are acceptable.

These substances are freely available for use by the general public. 36 products are currently licensed for domestic use. The only safeguard against misuse is a label, danger/harmful to bees. This is sufficient to be considered an adequate risk control by CRD/ACP. There is no requirement for point of sale advice to be given to purchasers nor are retailers required to have any training to explain the risks involved. This endangers bees and other non target insects in gardens, a very important source of honeybee forage.

There appears to be a strong correlation between the use or increased use of these substances and recently (5-6 years) observed changes to honeybee behaviour which cannot realistically be attributed to the advent of the varroa mite in UK honeybees (1992-1997)

These include:-

Fatally late swarming activity which is normally over by end June, and has been occurring as late as October and not weather related.

Significantly large numbers of virgin queen not returning to colony after mating flights, suggesting failed navigational abilities.

Failure of mated queen to continue to lay fertilized eggs once laying has been established.

High proportions of queens produce only unfertilized (male) eggs leading to collapse of colony (not colony collapse disorder as seen in US) suggesting either that neural control of spermetheca mechanism has failed ( this allows the queen to deposit a sperm fertilising an egg which will become a female, worker or queen) or that the queen is unable to sense the dimension of the cell to be laid in. Worker cells are narrower than drone(male) cells which is sensed by the queen in deciding whether to fertilise that particular egg). This again suggests a neural breakdown

Abnormal supersedure (replacement by the colony) of normally laying young queens suggesting that the young queen is producing insufficient 9 ODA (queen pheromone’ controlled by the endocrine/ neural system)

Anecdotal evidence is provided of these occurrences by comparing four apiaries each with similar colony numbers, two near extensive rape fields (East Sussex), one adjacent to maize silage crops West Kent and one more than two miles from any rape or maize crops ( East Sussex).

In the first, second and third these events are common affecting 30%+ of colonies each year and becoming increasingly common over the last 3-4 years. In the fourth they are very uncommon despite the bees being more stressed because of the more exposed location.

Whether or not these observations are as a result of the use of neonicotinoids, the important effects should be researched as a matter of urgency. At the very least this would eliminate the increasingly widely used neonicotinoids from suspicion. If neonicotinoids are indeed implicated in these now frequently reported events the future of honeybees in the UK is in extreme peril

31 October 2012

Prepared 19th November 2012