Insects and Insecticides

Written evidence submitted by Syngenta

1. Introduction

1.1. Syngenta welcomes the opportunity to respond to the Environmental Audit Committee’s inquiry into ‘Insects and Insecticides’.

1.2. Our recently published booklet ‘Straight Answers on the disappearance of honey bees in Europe’ will be of value to committee members.

1.3. Syngenta is an integrated global agribusiness selling agricultural inputs – seeds and chemicals – to farm businesses of all scales (including smallholders) around the world. We are the global number one in the agricultural chemicals market and third in the seeds market.

1.4. In the UK, we are unique amongst our agribusiness peer group in that we have a major research and development centre; manufacturing and production facilities for chemical production and conventional seed breeding; and a major commercial sales operation here. We discover, develop, and manufacture world leading agricultural technologies in the UK.

1.5. In doing so, we employ over 2000 people and spend in excess of $250 million on research at our Jealott’s Hill research site, the largest commercial agricultural research site in Europe. We also partner with hundreds of public and academic institutions in the UK in the development phases of our products. And our trained and expert agronomists engage with farming businesses of every size from single farmer operations to the largest agricultural producers in the country.

1.6. We understand farming, how our products benefit the agricultural sector, and the ways in which they interact with and help protect the environment. We are committed to delivering technologies which will enable the sustainable intensification of agriculture.

2. Position statement

2.1. Syngenta believes that insecticides, in particular neonicotinoid based seed treatments, are an essential contributor to sustainable intensive agriculture and do not damage the health of bee populations. They significantly reduce the load on the environment when compared to many other pesticides because of their extremely low dose; long lasting protection against pests that destroy crops; and when used in via seed treatment application result in fewer sprays over the course of the growing season.

2.2. Our own active ingredient, Thiamethoxam (TMX), is used as a seed treatment and its safety is reinforced by years of extensive monitoring in the field and based on millions of hectares of treated seed use without a single substantiated report of hive destruction.

2.3. Although several Member State Governments, reputable universities, and experts across Europe share the view that these innovative pesticides are safe, there are a small number of vocal individuals and groups who continue to suggest the opposite by focusing only on the intrinsic hazard of these products. In recent years these groups have leveraged media reporting of individual alarmist studies despite the fact that they are typically based on unrealistic dose rates and/or the forced exposure of bees to the insecticides in question.

2.4. It’s clear that we need healthy and thriving bee populations. The sustainability of agriculture and – indirectly our business – depends on this. But we also need safe, modern, and innovative pesticides like TMX if we are to produce the food we need. Rather than looking at the theoretical hazard we need to look at how bees and pesticides co-exist together in a sustainable agriculture system.

2.5. Syngenta is fully committed to this objective. We continue to deepen our understanding through research and by putting in place schemes such as Operation Pollinator. Today, 2,500 hectares of pollinator strips have been sown as part of this project providing essential habitat and nutrition for bees alongside field crops which are treated with pesticides. They have helped to produce a dramatic recovery in bee populations reversing the decline of some bumblebee species close to extinction.

2.6. Given our determination to approach farming in a holistic way, we would like to assure the Committee that we are open to work with any stakeholder who shares our goal of sustaining a thriving bee population in a sustainable agriculture system where the safest and most innovative pesticides are used.

3. Scope of our response

3.1. This written submission focuses primarily on providing information regarding Syngenta’s neonicotinoid active ingredient Thiamethoxam (TMX), which is used both for seed treatment application and as a foliar spray in numerous products used on flowering and non-flowering crops. Our response primarily references TMX’s use in Oil Seed Rape (OSR). Syngenta’s branded TMX product in OSR is Cruiser OSR.

3.2. By focusing on this compound and its associated products, we look to address the committee’s wider announcement on 25th September, 2012 that the inquiry is, ‘a new inquiry into the impact of insecticides on bees and other insects.’

3.3. It should be noted that our response is limited in regard to the Committee’s central focus and remit for its inquiry – Defra’s analysis and use of a review of recent studies looking at neonicotinoid pesticides and bees - as announced on the Guardian newspaper website on 21st September, 2012.

3.4. However, we do take this opportunity to applaud Defra’s commitment to a science based approach on the issue of bee decline and on issues relating to agricultural technology more widely. We believe ministers and officials at the department have acted properly and have ensured in recent times that an emotive and complex issue has not been politicised. To date, we believe that policy decisions in the UK on this issue have been based on rigorous scientific assessment and evidence.

3.5. In calling upon FERA, CRD and ACP to independently and expertly assess recent studies relating to neonicotinoids and bees we believe that Defra has acted impartially and appropriately. We note that the government’s subsequent analysis and use of the assessment of these studies is in line with other major European governments including those of Netherlands and Germany.

3.6. We point out that the decision of the French government to withdraw the registration of Cruiser OSR based on the Henry et al study was counter to the assessment and position of their own advisory agency – ANSES – which supported continued registration [1] .

4. Multi-variable factors in bee decline - points of reference

4.1. The issue of bee decline is complex. Accordingly, we feel it is essential that political stakeholders are well informed before looking for and deciding on an appropriate course of action or recommendations.

4.2. Based on Syngenta’s own detailed and expert technical assessment of the issue we believe that a number of variables are potential causal factors. Insecticides, and particularly seed treatments, when used appropriately and in accordance with label and product guidance are not responsible for colony collapse or large scale bee mortality.

4.3. Accordingly, we stand by the integrity of our insecticide seed treatments and foliar applied products and believe that they play a significant role in protecting yield and quality and by doing so also play a role in environmental protection, particularly in terms of land sparing.

4.4. There is now significant independent research that suggests that bees are impacted by a range of factors. In addition, there is also specific research showing neonicotinoids are not the key variable in bee decline.

4.5. We direct the committee to review the following research papers, which look in detail at the range of likely variables involved in this issue [2] .

§ Data s howing no effect of field releva nt doses of neonic otinoid s to bees or papers that state neonic otinoid s are unlikely to be responsible for decline in bee health

Schneider et al, 2012 (return to hive imidacloprid + Clothianadin) ; Cresswell 2011 (metanalysis of imidacloprid field trials) ;  Cresswell et al, 2012 (neonics in bee food);  Blacquiere et al, 2012 (Neonic bee review); Imdorf et al,  2006 (overwintering losses in Switzerland); Oliver, 2012 (bee keeper view of neonics).  

§ Va rroa or Varroa + disease/virus are the likely main reason for bee decline

Dainan et al, 2012;  Martin et.al, 2012;  Guzman-Nova, et al, 2010;  Szabo et al 2012 (bumble bees);  Charriere & Neumann, 2010;  Nazzi et al, 2012;  Genersch, 2010;  Rosenkranz et al, 2010.

§ Complicated and multi-variable nature for bee decline

van Enngelsdorp et al, 2012;  Neumann & Carreck, 2010;

5. Thiamethoxam (TMX) – assessment of lab based research and field data publication

5.1. Like all insecticides TMX is intrinsically toxic to insects. In the case of honey bees, the LD 50 for TMX is 5 ng/bee.

5.2. However, the committee should note that risk is a factor of both toxicity and exposure - and the exposure of bees even within a field of TMX seed treated Cruiser OSR is correspondingly low due to the low application rate and the period of time from drilling the seed to flowering.

5.3. All insecticide applications, including systemic seed treatments such as Cruiser OSR, see a degradation of their activity and hence their effect in the field ensuring that plants have greatest protection at the early and emergent phases. In a crop such as OSR the systemic active ingredient will be at trace levels at the point of flowering, significantly reducing risks to insects such as foraging bees.

5.4. All the independent research studies to date that we are aware of relating to Cruiser OSR have attempted to "simulate" this real world scenario in the laboratory; this is fraught with difficulty and typically doses used by researchers have over- estimated the amounts of chemical that bees are exposed to in the field. For example, in the case of the recent Henry et al study at INRA we estimate the concentration tested in the study was at levels up to 30x those seen in OSR nectar in the field.

5.5. As the committee will be aware, there are also high quality in-field monitoring schemes (Wildlife Incident Investigation Scheme) run by the Chemicals Regulation Directorate (CRD), Natural England and the National Bee Unit, which have detected no incidents with bees related to the use of thiamethoxam.

The Wildlife Incident Investigation Scheme (WIIS)

https://secure.fera.defra.gov.uk/beebase/index.cfm?sectionid=33

5.6. In regard to Syngenta’s own field data (i.e. data taken from the real environment), we have recently submitted a manuscript for publication in peer reviewed open literature, which summarises our comprehensive field study programme which has investigated the potential long-term effect of exposure of honeybee colonies to nectar and pollen from TMX seed treated flowering OSR and maize. This covers four years consecutive exposure, including the sensitive over-wintering phase, where TMX is applied at the maximum label rate.

5.7. These in field studies have shown no effects (lethal or sub-lethal) on bee mortality. Factors assessed include foraging behaviour, colony strength and weight, brood development and overwintering success.

5.8. In addition, Syngenta is currently drafting a second paper summarising our pollen and nectar residue data from our regulatory field trials conducted with TMX as a seed treatment.

4.9 This paper reports that TMX residues in pollen and nectar collected from bees foraging on treated oil seed rape, are typically very low (ie <1 – 3.5 µg/kg in pollen and <0.5 – 2.5 in nectar) with residues in hive pollen and nectar being even lower (typically at or below 1 µg/kg).  Residues of the primary metabolite were always lower than parent TMX in both pollen and nectar.

This paper not only confirms low residues of TMX and its primary metabolite in pol len and nectar from TMX seed treated OSR and maize in the field, but will also fill a current data gap in the public literature. This paper will be submitted for publication shortly, and it is hoped that both papers will be published by end of this year/early next year.

6. Use and utility – benefits of Cruiser OSR to UK farmers

6.1. Syngenta estimates that the UK planting of OSR in the UK in the 2012 season was approximately 700,000 hectares. Of this planting, Cruiser OSR was planted on approximately 400,000 hectares - ~57% of the UK market.

6.2. OSR has become a very important crop to UK arable growers, driven in part by the increase in commodity prices in recent years. Previously grown as a break crop to help control pests and diseases in cereals, it now provides a similar gross output to wheat.

6.3. Often grown in tight rotations with wheat, OSR suffers from a significant number of pests and diseases. Two key autumn pests are aphids especially the Peach-potato aphid and flea beetles. Both pests invade newly emerging seedlings. Both feed on the young plants, flea beetles potentially causing significant plant loses if infestations are high. The Peach-potato aphid is responsible for the spread of Turnip Yellows Virus (TuYV), which in severe cases has been shown to cause up to 26% yield loss in UK conditions.

6.4. Control of both of these pests in the autumn is critical to establishing the yield potential of the crop for the following spring. Currently, because of insecticide resistance, there are no effective alternatives to the neonicotinoid seed treatments for control of Peach-potato aphid. There are foliar sprays that are effective against flea beetles but the timing of use of these products is very important and autumn conditions can make the optimum spray timing very challenging. Furthermore the use of pyrethroids in the autumn against flea beetles has the potential to make resistance problems with Peach-potato aphid worse.

6.5. The effect of seed applied insecticides lasts between 6-10 weeks after sowing. Trials have shown yield increases of up to 0.66T/Ha for hybrids (approx. 60% of the area sown), a value-add of £231/Ha (@ £350/T).

6.6. Without the existing seed treatment technology based on the neonicotinoids , more foliar insecticide sprays would be used in the autumn to control flea beetles and new products would have to be approved to provide adequate control of Peach-potato aphid. In marginal areas OSR may be taken out of the rotation leading to tighter cereal rotations which could lead to greater problems with weed management in cereal crops which already face significant issues with Black grass control.

6.7. Cruiser OSR is only sold to seed processors in the UK who apply the treatment through machinery designed and manufactured for the purpose by trained and qualified operators - stewardship of the product in the UK, which is an important component of safety, has been assessed as excellent.

6.8. Seed processors are required to submit representative samples of treated seed for chemical and dust loading analysis to ensure accurate application and all applicators have been independently audited to ensure they are able to apply the treatments correctly.

7. Current regulatory requirements relating to bee health for registration

7.1. We believe that it is important for the committee to note the current regulatory requirements for registering a crop protection product in the EU, specifically with regard to assessing the potential impact on bees.

7.2. Before a pesticide can be used in the UK, it has to be registered under the EU Plant Protection Product Directive 1107/2009 and under this Directive the following first tier honey bee safety toxicity data are required from Registrants:-

· laboratory acute toxicity (both oral and contact) of pesticides to adult honeybees

· chronic toxicity to adult honeybees

· chronic toxicity to larval bees/bee brood

7.3. These studies reflect the intrinsic hazard of a pesticide under worst case laboratory conditions and must be conducted according to published international Guidelines (eg OECD/EPPO) and also meet Good Laboratory Practise requirements.

7.4. Data from the above laboratory studies are assessed by UK CRD, under Directive 1107/2009’s Honeybee Risk Assessment Framework, and if EC agreed safety thresholds are not met, either labelled restrictions in use are applied (eg "Harmful / Dangerous / Extremely Dangerous to bees: Do not apply to crops in flower or to those in which bees are actively foraging. Do not apply when flowering weeds are present"); or further honeybee safety testing is required in order to demonstrate safety to honeybees under semi-field/field conditions.

7.5. Such field studies are a better reflection of the actual risk to honeybees under in-use conditions and are targeted to support specific crop/application type scenarios eg foliar applications to OSR.

7.6. The European Food Safety Agency (EFSA) is currently reviewing the EC Guidelines for bee pesticide testing and risk assessment, and a finalised Guideline is expected in early 2013.

8. Human health and neonicotinoids

8.1. TMX is of low acute toxicity and is non genotoxic.  TMX has been extensively evaluated in a whole range of toxicity studies up to lifetime bioassays and is not carcinogenic and is not a developmental or reproductive toxicant.

8.2. It causes no significant neurotoxicity and is not developmentally neurotoxic.

9. Henry et al and our commitment to new research

9.1. As we have detailed Syngenta has a comprehensive honeybee safety data package for its TMX containing products, including laboratory/semi-field studies and multiple field studies covering various different crop application type uses worldwide.

9.2. We also assess all new environmental research and data relating to all neonicotinoid products (TMX and competitor compounds) and respond accordingly.

9.3. A recently published paper in Science (Henry et al 2012) reported foraging disruption for bees from an experiment simulating exposure to residues in pollen and nectar (at unrealistically high concentrations – 30x above those found in OSR nectar) from TMX seed treated OSR.

9.4. In light of this study, Syngenta is in the process of developing and conducting an in-use field study exposing honeybees to TMX seed treated OSR, and using the same Radio-Frequency Identification Tags (RFiD) technology as Henry et al, which will investigate any potential foraging effects on honeybees under more realistic in-use field conditions.

9.5. Results from this study should be available after next year’s bee season - 2013.

9.6. Syngenta has also recently funded an 18 month Post-Doctoral Research Project at Exeter University to investigate an epidemiological study on European Honeybee health using the established "Hill’s Criteria" [3] .

9.7. This study will investigate the following factors:- neonicotinoids; other insecticides; degraded honeybee forage; varroasis; bee viruses; Nosema; honeybee economical factors; and honeybee husbandry practices. This study will be completed in April 2014. The study author is open to interpret and publish the results of this work without permission or approval from Syngenta.

10. Operation Pollinator

10.1. Forage and habitat for bees are critical to their success. As part of our own commitment to sustainable farming we are supporting the rollout of pollen and nectar rich field margin strips across 10,000 hectares in key European countries through our Operation Pollinator project – www.operationpollinator.com

10.2. To date over 1000 hectares have been planted and established in the UK – with data showing significant increases in pollinator numbers and indications of yield increase in flowering crops grown adjacent and alongside these strips.

10.3. In May 2011, as part of Operation Pollinator , a further project was undertaken in the UK to look at ways of increasing OSR yield and improving oil quality using native and managed pollinators from the landscape as an ecosystem service to enhance the OSR potential.

10.4. A team of six ind ependent entomologists le d by the Centre of Ecology and Hydrology (CEH) carr ied out field observations in twenty four flowering commercial crops of winter OSR across the South Central Region of the UK.

10.5. This action was carr ied out to establish which pollinators were active in the flowering crop, the level of flower visitation taking place , and pollen transfer active between the stigma and the stamens when pollinators were present on the flower.

10.6. The farmers growing these crops had established them in the previous autumn in 2010 , unaware of the project s conception or their future involvement and had all applied Cruiser OSR seed treatments to their OSR seed , drilled the crop , applied full autumn crop protection programmes and subsequently applied a spring crop protection programme as recommended by their farm agronomist which included a foliar applied insecticide in all cases to control a significant attack on the crop at green bud growth stage of Pollen Beetle that season.

10.7. The results concluded from these observations, at peak flowering time within the OSR crop, that visitation to the OS R f lowers took place by some 36 diff erent species of bee pollinator, including the Honey Bee ( Apis mellifera ) most abundant vis i tors, 9 Bumblebee Species ( Bombus spp .) and 26 Solitary and Mining bee species ( Andrena, Megachile and Osmia spp )

10.8. Indications also suggest that stronger fly ing species such as honey bees and b umblebees moved from surrounding hives & nest sites to the cro p and back whilst foraging for p oll en and n ectar bu t the less powerful fliers the s olitary and mining bee species actually lived within the crop itself , often setting up nest sites within the "crop tramlines" where bare ground for their burrows could be established.

10.9. The project continues to investigate the potential of using both managed (honey bees ) and native bee species ( b umblebee and solitaries) within the intensively farmed crop to increase yield and oil quality as a sustainable ecos y s tem service.

11. Syngenta Bioline

11.1. The committee’s inquiry remit makes reference to integrated pest management (IPM). Syngenta supports the principle of IPM as a component of sustainable agriculture and we work to support these approaches where applicable to context.

11.2. As part of that approach, Syngenta Bioline produces high quality products containing natural beneficial insects and mites for use in Integrated Crop Management programmes to control pests. The principal crops where these products are covered salad vegetables, soft fruit , and ornamentals.

11.3. Syngenta Bioline is an integrated component of Syngenta’s wider business and our crop teams work with customers to look at ways in which beneficial insects can be used to deliver effective outcomes in terms of pest management.

11.4. Although we are ambitious for the continued growth and development of our Bioline business we also believe (based on technical assessment and data) that there are considerable limitations and inherent risks to large scale - in-field - substitution of insecticide chemicals by targeted biological pest management processes.

11.5. However, we remain committed to delivering sustainable farming systems with a range of proven inputs (including IPM practices and beneficial insects), relevant to context, and balanced to ensure optimal environmental and economic output for farm businesses in the UK and around the world.

8 November 2012

ENDNOTES


[1] http://ww w.anses.fr/Documents/DPR2012sa0092.pdf - ANSES concluded - ‘ In the current state of knowledge, the results presented in the article by Henry et al. 2012 are not considered to challenge the conclusions of risk assessments conducted as part of the application for authorization to market the product CRUISER OSR and done according to current regulatory criteria, but the study shows that the methodologies implemented in this framework have limitations in terms of sensitivity. The bee toxicity information considered for the approval of thiamethoxam under Regulation (EC) No 1107/2009 and listed on page 8 of this Opinion are not modified by the results of this study. ’

[2] Reference points - titles, authors and journals.

[2]

[2] Data showing no effect of field relevent doses of neonics to bees or papers that state neonics are unlikely to be responsible for decline in bee health

[2]

[2] C. Schneider, J. Tautz, B. Grunewald and S. Fuchs , (2012).  

[2] RFID Tracking of Sublethal Effects of Two Neonicotinoid Insecticides on the Foraging Behavior of Apis mellifera:

[2] PLoS One, Vol 7, Issue 1.

[2]

[2] J. Cresswell,  (2011).

[2] A meta-analysis of experiments testing the effects of a neonicotinoid insecticide (imidacloprid) on honey bees:

[2] Ecotoxicology Vol 20: pp149–157

[2]

[2] J. Cresswell, N. Desneux and D. van Engelsdorp (2012).

[2] Dietary traces of neonicotinoid pesticides as a cause of population declines in honey bees: an evaluation by Hill’s epidemiological criteria

[2] Pest Management Science Vol 68, Issue 6, pages 819–827.

[2]

[2] T. Blacquiere, G. Smagghe, A.Cornelis, M. van Gestel, and V. Mommaerts , (2012).

[2] Neonicotinoids in bees : a review on concentrations, side-effects and risk assessment.

[2] Ecotoxicology Vol 21, pp 973-992.

[2]

[2] A. Imdorf, J. Charriere and P. Gallmann (2006).

[2] Mögliche Ursachen für die Völkerverluste der letzten Jahre

[2] Schweizerische Bienen-Zeitung 8/2006

[2]

[2] R. Oliver (2012). 

[2] Neonicotinoids: Trying To Make Sense of the Science:

[2] American Bee Journal, August, 2012 .  

[2] http://scientificbeekeeping.com/neonicotinoids-trying-to-make-sense-of-the-science/

[2]

[2] Varroa or Varroa + disease/virus’s are the likely main reason for bee decline

[2]

[2] B. Dainat, J. Evans, Y. Chen, L. Gauthier and P. Neumann (2012).

[2] Predictive Markers of Honey Bee Colony Collapse.

[2] PLoS One, Vol 7, Issue 2

[2]

[2] S. Martin, A. Highfield, L. Brettell, E. Villalobos, G. Budge, M. Powell, S. Nikaido and D. Schroeder (2012).  

[2] Global Honey Bee Viral Landscape Altered by a Parasitic Mite.

[2] Science 336 , 1304.

[2]

[2] E. Guzm´an-Novoa, L. Eccles, Y. Calvete, J. Mcgowan, P. Kelly, A. Correa-Ben´itez (2010).

[2] Varroa destructor is the main culprit for the death and reduced populations of overwintered honey bee ( Apis mellifera ) colonies in Ontario, Canada.

[2] Apidologie, Available online at: www.apidologie.org . INRA/DIB-AGIB/EDP Sciences, 2010  

[2]

[2] N. Szabo, S. Colla, D. Wagner, L. Gall and J. Kerr (2012). 

[2] Do pathogen spillover, pesticide use, or habitat loss explain recent North American bumblebee declines?

[2] Conservation Letters 00 (2012) 1–8 Copyright and Photocopying: c 2012 Wiley Periodicals, Inc.

[2]

[2] J. Charrière and P. Neumann (2010).

[2] Surveys to estimate winter losses in Switzerland.

[2] Journal of Apicultural Research 49(1): 132-133.  

[2]

[2] F. Nazzi, S. Brown, D. Annoscia, F. Del Piccolo, G. Di Prisco, P. Varricchio, G. Vedova, F. Cattonaro, E. Caprio and F. Pennacchio (2012).

[2] Synergistic Parasite-Pathogen Interactions Mediated by Host Immunity Can Drive the Collapse of Honeybee Colonies.

[2] PLoS One, Vol 8, Issue 6.  

[2]

[2] E. Genersch (2010).

[2] Honey bee pathology: current threats to honey bees and beekeeping.

[2] Appl Microbiol Biotechnol Vol 87: pp87–97  

[2]

[2] P. Rosenkranz, P. Aumeier and B. Ziegelmann (2010).

[2] Biology and control of Varroa destructor.

[2] Journal of Invertebrate Pathology Vol 103, pp96–119

[2]

[2] Complicated and multi-factorial nature for bee decline

[2]

[2] D. van Engelsdorp, D. Tarpy, E. Lengerich and J. Pettis (2012).

[2] Idiopathic brood disease syndrome and queen events as precursors of colony mortality in migratory beekeeping operations in the eastern United States.

[2] Preventative Veterinary Medicine . http://dx.doi.org/10.1016/j.prevetmed.2012.08.004

[2]

[2] P. Neumann and N. Carreck, (2010).

[2] Honey bee colony losses

[2] Journal of Apicultural Research Vol 49(1): pp1-6)

[2]

[3] Hill A, The environment and disease: association or causation? Proc R, SocMed 58 :295–300 (1965).

[3]

Prepared 19th November 2012