Insects and Insecticides

Written evidence submitted by John Hoar

1. Summary

The UK pesticide regulatory bodies have failed to protect the honey bee and other pollinators from the hazards and risks associated with the use of neonicotinoid insecticides. Whereas in respect of neonicotinoid insecticides:

· The existing pesticide risk assessment for honey bees is inadequate;

· Neonicotinoids fail to meet the requirements of EC 1107/2009;

· There is no risk mitigation for seed treated with pesticides.

If neonicotinoids are not to be suspended under the precautionary principle, then there is an urgent need for a reporting system that mandates farmers to report the sowing of treated seed and which information is available to beekeepers to take into account in the management of their colonies.

2. Introduction

I am a beekeeper with four years’ experience and the author of two articles for the British Beekeepers Association News (BBKA News) [1] , [2]

As you are aware, about one-third of UK arable land was sown with seed treated with systemic pesticides in 2010. Neonicotinoids are the active substance most widely used in systemic insecticides for seed treatment, e.g. clothianidin, thiamethoxam and imidacloprid. They are a neurotoxin to insects, the effect of which is virtually irreversible and cumulative. Neonicotinoids are at least 5 000 times more toxic to bees than DDT and a lethal oral or contact dose for a honey bee is in the order of nanograms (billionths of a gram).

I estimate that a single seed, treated with Bayer product ‘Poncho’, for example, contains the equivalent of 100 000 lethal oral doses for a honey bee. Of course, it is not expected that bees will have direct contact with the seed but they will be exposed to pesticide residues in pollen, nectar and guttation water, as well as in soil and water. Foraging bees will also take back pesticide residues to the hive. There is considerable scientific evidence that the use of neonicotinoids are harmful to honey bees and other wildlife, see for example: Tennekes [3] and Pesticide Action Network [4] .

It is not the purpose of this submission to present scientific evidence against the use of neonicotinoids, but to ask the Environmental Audit Committee why DEFRA will not establish a reporting scheme that mandates farmers, who sow seed treated with systemic insecticides, to submit a report to a central collection point, accessible by beekeepers, so they may take this information into account in the management of their colonies. I wrote to the DEFRA Minister, Richard Benyon MP, on 13th May 2012 with this proposal, but it was refused.

3. The existing pesticide risk assessment for honey bees is inadequate.

In 2011, a Pesticide Risk Assessment for Pollinators workshop was held in the USA [5] . Two-thirds of the (48) participants were from the environmental protection agencies and agrochemical industry, including representatives from the UK Chemicals Regulation Directorate (CRD) and the Food and Environment Agency (FERA). The aim of the workshop was "to explore the state of the science on pesticide risk assessment for pollinators."

The workshop summary states:

· "no globally harmonised, tiered testing system exists for honey bees" nor a test that "addresses chronic toxicity to adult bees and larvae."

· "the methodology and testing scheme employed for foliar applications … is not adopted to assess potential hazard and risk from systemic pesticides."

The workshop summary concluded with a list of research recommendations, including:

· Compiling pesticide residue data in pollen and nectar compared with pesticide applications on seeds.

· To determine if plant guttation drops are a pesticide exposure route for bees.

· The need for a standard procedure for a chronic feeding study with adult bees.

· Further research on methods to evaluate potential pesticide effects on bee foraging behaviour.

At the Annual Open Meeting of the Advisory Committee on Pesticides (ACP) 2011, it was said that "It is therefore not expected that a standardised chronic bee toxicity guideline will be quick to develop (perhaps 5 years)." [6]

In June 2012 the European Food Safety Authority (EFSA) published a Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees. [7] Here are some of the statements from the Summary:

· "The current methods of field testing would need major improvements in order to detect for example an increase in daily mortality of foragers by 10% with high statistical power."

· "Further research is recommended on the testing of the presence and fate of residues…and on the developments of reliable exposure models."

· "The overview of the available studies on sub-lethal doses and long-term effects of pesticides on bees highlighted gaps in knowledge and research needs in the following areas: more toxicological studies to be performed in bees for a wider range of pesticides on both adults and larvae including sub-lethal endpoint, also contact and inhalation routes of exposure."

· "It is therefore concluded that the conventional regulatory tests based on acute toxicity (48 to 96 h) are likely to be unsuited to assess the risks of long-term exposures to pesticides."

· "The working group identified the need for improvement of existing laboratory, semi-field and field testing and a reas for further research."

Imidacloprid and Clothianidin were approved for use in 1993 and 2003 respectively, over 10 years ago. These statements confirm that there are major deficiencies in the existing pesticide risk assessment methodology and absence of proper research into the effects of neonicotinoids on honey bees in the field. It is clear that neonicotinoids were approved after inadequate tests designed for foliar (sprayed) products.

Thus the evidence above does not support the claim by DEFRA that "The risk assessment process, set out in European legislation, looks in detail at the risk to honey bees, considering a range of factors including methods of application and examining both lethal and sub-lethal effects." [8]

4. Neonicotinoids fail to meet the requirements of EC 1107/2009

European Regulation (EC) No. 1107/2009 lays down rules governing plant protection products and the active substances contained in these products. [9]

Persistence in the environment is an important criterion and an active substance is defined as ‘very persistent’ if the half-life in soil exceeds 180 days, yet Clothianidin has a half-life in soil of 545 days. It is surprising therefore that the UK Environment Agency does not routinely test soil and water for neonicotinoids, especially in locations where treated seed is sown in succession.

The Regulation also states that an active substance shall only be approved if it "will result in negligible exposure of honey bees, or has no unacceptable acute or chronic effects on colony survival and development, taking into account honeybee larvae and honeybee behaviour." (Annex 3, s3.8.3). As noted above, there are no internationally agreed test guidelines and the European Union risk–assessment methodology is incomplete in several respects, then it can be reasonably concluded that neonicotinoids have failed to meet this test.

5. There is no risk mitigation for seed treated with pesticides.

The EFSA states that the final decision on protection goals needs to be taken by ‘risk managers’. EFSA also says "There is a trade-off between plant protection and protecting the ecosystem services, pollination, hive products and biodiversity. From a farmer’s point of view, plant protection may be more important than hive products." In other words, there is a let-out clause in favour of economic factors.

The SETAC Workshop summary also says that if "the use of that [pesticide] product is considered efficacious and necessary [for plant protection], then the regulating authority may seek to manage the potential risk through mitigation." Risk mitigation is often in the form of label instructions.

For example, Bayer Provado© Ultimate Bug Killer (400ml aerosol spray can) contains 0.1 g Imidacloprid (0.25 g/l). The environmental protection label states "HIGH RISK TO BEES. Do not apply when blooms are open. APPLY AWAY FROM BEES." The term ‘high risk’ is worse than ‘extremely dangerous’. This product is also systemic, i.e. it is absorbed into the plant, to provide up to four weeks plant protection. This aerosol can contains enough active substance to kill two million bees, based on a lethal dose of 50ng/bee (LD50 24h). It is shocking that that the risk manager decided in favour of ornamental plant protection and then passed responsibility for the protection of bees to the general public.

Risk mitigation is also undermined when agrochemical companies promote their neonicotinoid pesticide products as being more or less "bee-friendly". Beekeepers rely on the users of insecticides to exercise caution and to liaise with local beekeepers before using pesticides that may harm bees. The term ‘bee-friendly’ serves to undermine this caution and encourage non-compliance. [10]

In respect of treated seed there is NO risk mitigation, e.g. there is no requirement for farmers to report when sowing seed. Unlike spray pesticides, which are applied at the first sign of a pest attack, i.e. reactively, pesticides applied to the seed are used constantly, whether they are needed or not, i.e. prophylacticly. There are many implications to wildlife and the environment by this approach to pest management. Yet the DEFRA publication Pesticides: Code of practice using plant protection products contains nothing precautionary about systemic products. [11]

6. Recommendations

If, as a result of this Inquiry, neonicotinoids are not going to be suspended under the precautionary principle, then there is an urgent need for a reporting system that mandates farmers to report the sowing of treated seed and which information is available to beekeepers to take into account in the management of their colonies.

Farmers derive economic benefit from the use of pesticides. The Rural Payments Agency has a Rural Land Register (RLR) which holds details of all registered land parcels in a digital format. All land must be registered on the RLR for a farmer to be eligible to receive payments from, say, the Single Payment Scheme. Each field has a unique reference number. Such a reporting scheme might be included in the current agri-environmental schemes administered by Natural England.

Farmers who sow treated seed would make an online report with relevant information to DEFRA, who could pass this information to the National Bee Unit (NBU). The NBU could then compare this information with ‘Beebase’ registered beekeepers and notify them by email accordingly. Alternatively, this information could be presented in the form of a map which beekeepers could access online. Beekeepers could then take this information into account in the management of their bee colonies. This would also allow further research into the effect of neonicotinoids on bees, by correlations between seed treated crops and colony losses nationally.

2 November 2012

[1] Hoar, J. 2012a. ‘Pesticide Risk Assessment for Pollinators Workshop: A Beekeepers view.’ BBKA New s May 2012.

[2] Hoar, J. 2012b. ‘Neonicotinoid insecticides: The case for farmers to report the sowing of treated seed.’ BBKA News October 2012.

[3] Tennekes, H. 2010. The systemic pesticides: a disaster in the making . Experimental Toxicology Services (ETS). Netherlands BV Zuphen, The Netherlands

[4] Pesticide Action Network. 2012. Pesticides and Honey Bees: Sta t e of the Science . PANNA, USA.

[5] Fischer D. & Moriarty, T. 2011. Pesticide Risk Assessment for Pollinators: Summary of a SETAC Pellston Workshop . Society of Environmental Toxicology and Chemistry (SETAC)

[6] Advisory Committee on Pesticides. 2011. Notes fr o m the 12 th Annual Open Meeting of the ACP 14 November 2011.

[7] European Food Safety Authority. 2012. ‘Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees’. EFSA Journal 2012; 10(5): 2668

[8] DEFRA. 2012. Statement on ‘Neonicotinoid insecticides and bees’. DEFRA September 2012.

[9] European Parliament . Regulation (EC) No 1107/2009 concerning the placing of plant protection products on the market. Official Journal of the European Union . 24.11.2009

[10] Houlton, S. 2012. ‘Feeding a growing world.’ Chemistry World July 2012.

[11] DEFRA. 2006. Pesticides: Code of practice using plant protection products . DEFRA.

Prepared 19th November 2012