Insects and Insecticides

Written evidence submitted by the Crop Protection Association

SUMMARY

· Plant protection products are thoroughly tested and can only be approved if there are no unacceptable effects on people or wildlife when they are used according to the conditions of approval.

· It is a legal requirement for users to follow the label which will include instructions for reducing any risks associated with the product.

· Actual pesticide use is monitored and shows that insecticide use has reduced.

· The Crop Protection Association (CPA) and other industry bodies are involved in stewardship activities to promote high standards of application and further reduce risk.

1. The Crop Protection Association

1.1 The Crop Protection Association (CPA) is a key voice of the plant science industry in the UK representing 23 member companies (see www.cropprotection.org.uk )

1.2 CPA members are involved in the development and manufacture of a wide range of plant science technologies which are of crucial importance to the cultivation and protection of food crops, protecting our gardens, woodlands, infrastructure and public places. These include the formulation and manufacture of synthetic and bio pesticides, seed and plant breeding, agricultural biotechnology and the breeding of bees.

2. Plant Protection Products testing and authorisation

2.1 Plant protection products or pesticides are developed to protect plants against specific pests. They are essential to ensure the production of healthy, safe, affordable food in sufficient quantity to feed our growing population. Insecticides are pesticides that control insect pests; herbicides control weeds and fungicides control fungal diseases. Because they contain biologically active compounds and people and non-target organisms can be exposed to them, pesticides have to be thoroughly tested and evaluated to ensure that they can be used without causing unacceptable effects.

2.2 There is detailed European legislation (Regulation 1107/2009) governing the testing, evaluation and authorisation of pesticide active substances and products. Pesticide substances have to be put through a comprehensive series of tests including acute and chronic toxicity in humans and animals, metabolism studies, residues in food, environmental and ecotoxicological studies and efficacy. The results of these tests are evaluated by the regulatory authorities in Member States. Only if the regulators are satisfied is the substance authorised for use in pesticide products which themselves must be tested and approved for specific uses. Approvals can be reviewed at any time.

2.3 Amongst other considerations, Regulation 1107/2009 requires that a plant protection product, when used according to good practice and under realistic conditions of use, must not have any unacceptable effects on the environment. This includes "impact on non-target species, including the ongoing behaviour of those species" and "impact on biodiversity and the ecosystem" (Article 4: 3(e) (ii) and (iii)).

2.4 The honey bee has been selected as a representative pollinator species in the authorisation process. The Regulation states that "An active substance, safener or synergist shall be approved only if it is established, following an appropriate risk assessment on the basis of Community or internationally agreed test guidelines, that the use under the proposed conditions of use of plant protection products containing this active substance, safener or synergist will result in negligible exposure of honeybees or has no unacceptable acute or chronic effects on colony survival and development, taking into account effects on honeybee larvae and honeybee behaviour." (Annex II: 3.8.3)

2.5 In order to ensure that this is the case, a series of tests is undertaken ranging from laboratory oral and contact toxicity tests to field trials exposing bee colonies under realistic conditions. Metabolites are also tested if they have pesticidal activity. The likelihood of negative effects is assessed and if necessary mitigation measures can be stipulated on the product label to further reduce any risks. These might include:

a. Application in the evening or early morning when honey bees are not flying

b. Reduced application rates

c. Agronomic practices such as removing flowering weeds within the crop before spraying

d. Use of seed drilling equipment which reduces the escape of seed treatment dust to the air.

2.6 Pesticide users are legally required to follow these label instructions.

2.7 Research continues after a pesticide has gained approval. Many studies have been done looking at the possible causes of bee decline some of which are referenced in submissions from Bayer CropScience and Syngenta. Those studies that have used realistic field conditions have not shown any link between poor bee health and pesticides. The general consensus is that causes of poor bee health are multifaceted and include parasites such as the Varroa mite and Nosema, viruses and diseases, a lack of genetic diversity, a lack of suitable forage and nesting habitats, and stress-induced impacts, such as the transport of managed colonies.

3. Levels of pesticide use in the UK

3.1 Pesticide use varies from year to year depending on what crops are planted and on the levels of pests, weeds and diseases. This in turn varies according to the weather conditions. Insecticide use is relatively low when compared with herbicides and fungicides.

3.2 The Pesticide Usage Survey Teams of the Food & Environment Research Agency, an executive agency of the Department for Environment, Food & Rural Affairs conduct surveys of pesticide usage. Their report for arable crops harvested in 2010 is available at the following link: http://www.fera.defra.gov.uk/scienceResearch/science/lus/documents/arable2010.pdf

3.3 Data on actual pesticide usage on various arable crops are collected and then extrapolated to give national usage estimates of the area of pesticide treatments and the amount of active substances applied.

3.4 The Pesticides Forum Report, Pesticides in the UK 2011, shows that there has been a decrease in the amount of insecticide used in winter wheat between 2004 and 2010 (see Pesticides in the UK, page 56, figure 22a).

4. Industry Stewardship

4.1 Some insecticides can kill bees if they are misapplied and not used according to the instructions. For this reason it is essential that users follow the label instructions carefully.

4.2 Instead of being applied as a spray, some insecticides can be applied to the seed so that both the seed and the emerging plant are protected from pest attack. Seed treatments are applied by specialist contractors. The European Seed Association (ESA) and seed treatment manufacturers have developed the European Seed Treatment Assurance scheme (ESTA) to set and audit standards in the seed treatment industry. The standard covers areas such as calibration of equipment and use of a HACCP (Hazard, Analysis, Critical Control Point), a form of risk assessment.

4.3 In addition to the label, all insecticides have an Environmental Information Sheet (EIS) which contains specific information on how to protect wildlife including bees when using that product. These are produced by Members of the Crop Protection Association (CPA) as part of the crop protection industry’s commitment to the Voluntary Initiative (VI) (an industry-led initiative to promote the responsible use of pesticides) and can be found on the VI website at: www.voluntaryinitiative.org.uk

4.4 The Crop Protection Association has also published advisory leaflets for farmers and growers and for gardeners.

4.5 "Bee safe, bee careful…when using insecticides" was published in 2011 and contains general stewardship advice for farmers using professional insecticide products. Nearly 180,000 copies have been distributed through the National Farmers’ Union and British Beekeepers’ Association (BBKA) to their members. It is also accessible through the CPA website: http://www.cropprotection.org.uk/media/1948/bee_safe_bee_careful.pdf

4.6 The leaflet describes general stewardship advice which should be followed when applying insecticides in flowering crops including top and soft fruit, oilseed rape, beans, cereals maize and pea crops, and where there are neighbouring flowering crops or flowering wildflowers. This includes:

• Avoid spraying when bees are actively foraging. Spray in the evening or in the early morning when fewer bees forage.

• Take care to minimise drift to nearby flowering plants or hives in and around the treated field. Check the wind speed is less than 5 mph, that nozzles are as close to the crop as possible and that appropriate nozzles are being used.

• Check with beekeepers for locations of local hives and repeat this process annually as beekeepers may change locations of hives.

• Keep local beekeepers contact details in the tractor/sprayer cab and on your mobile. Give at least 24 hours’ notice of spraying and identify the product(s) being used.

• If using with a triazole fungicide use only approved tank-mixes.

4.7 The leaflet also gives advice for the use of seed treated with insecticide. This should be planted strictly in accordance with the seed bag recommendations and in addition care should be taken to:

· Avoid leaving treated seed on the surface after planting;

· Ensure that there is no leaching of the seed treatment into puddles and watercourses as pollinators may drink these;

· Limit agitation and abrasion of seed which could lead to "dust" containing insecticide being released into the air.

4.8 Farmers are also encouraged to help bee populations by creating habitats such as tussocky grass field margins and providing nectar and pollen sources by sowing flowering plants on field headlands and managing hedgerows.

4.9 The leaflet for gardeners "Bee informed…when using insecticides in your garden" was published earlier this year and over 100,000 copies have already been distributed to consumers in conjunction with the Horticultural Trades Association. It is also available online: http://www.cropprotection.org.uk/media/31346/bee_safe_leaflet_v13_final_final_jan_12.pdf

4.10 Although the amount of insecticides used in gardens by the general public is much lower than on farms, it is still important for them to be applied according to the label instructions and following some simple rules such as: spray when bees are less active such as early morning or in the evening; do not spray directly onto open flowers; mow the lawn to remove flowers from weeds before spraying.

4.11 These leaflets, together with discussions with the British Beekeepers’ Association,  have triggered dialogue at a local level between the industry and beekeepers which is helping to develop a better understanding of the use of insecticides.

4.12 CPA encourages all pesticide users to be aware of the locations of bee hives and supports the notification of beekeepers prior to spraying insecticides.

6 November 2012

Prepared 19th November 2012