Insects and Insecticides

Written evidence submitted by Amanda Williams

General Inadequacies Of Regulatory Risk Assessement For Bees And Industry Influence versus lack of public consultation

1. The Civil Servants Code Of Practice, states that Civil Servants must:

(Point 8): "Set out the facts and relevant issues truthfully, and correct any errors as soon as possible"

(Point 9): "You must not: deceive or knowingly mislead Ministers, Parliament or others; or be influenced by improper pressures from others or the prospect of personal gain".

(Point 10): "You must provide information and advice, including advice to Ministers, on the basis of the evidence, and accurately present the options and facts".

(Point 11): "You must not ignore inconvenient facts or relevant considerations when providing advice or making decisions".

The EAC is requested to consider whether the Civil Servants’ Code has in any way, been breached.

2. EU Regulation 1107/2009 (Annex II, 3.8.3.) "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 a negligible exposure of honey bees, or has no unacceptable acute or chronic effects on colony survival and development, taking into account effects on honey bee larvae and honey bee behaviour."

EFSA find many weaknesses in the standards of testing for Risk Assessment http://www.efsa.europa.eu/en/efsajournal/pub/2668.htm . It actually appears the requirements of EU law have not been met, and that serious faults with, for example, field study design have been identified. Members of FERA have been involved in developing regulatory test guidelines (EPPO 170), and it is surprising that these weaknesses have not been addressed by our civil servants.

3. Regardless of any regulatory guidelines is it not the duty of DEFRA to ensure standards ARE robust, and to reject any chemical not adequately tested, because not to do so, would break EU law?

4. DEFRA have repeatedly stated: "The UK has a robust system for assessing risks from pesticides and all the evidence shows neonicotinoids do not pose an unacceptable risk when products are used correctly. We will not hesitate to act if presented with any new evidence". The EFSA report referred to above, was published in May 2012 – yet no action has been taken.

5. DEFRA state: "The regulatory field studies fully comply with current guidance……hives exposed to treated crops did not show any gross effects on a wide range of important endpoints when compared to control hives exposed to untreated crops."

6. A comment from the EFSA report indicating that field tests by manufacturers provide unrealistically LOW levels of exposure to pesticides: "Hence, the bees could be exposed to an unrealistically low total quantity of toxic substance, if residues are expected to be available in a large area at a similar time, e.g. in the case of SSST. This quantity will be much lower than that to which bees are exposed in real conditions, when the surface of all the treated fields in their foraging area will be significant (hundreds of hectares or more), and where the interval between the flowering periods for the different fields in the same area, can lead to exposure lasting for several weeks to more than a month".

7. In their Sept 18 report, despite deficient regulatory standards for field studies, CRD frequently raised queries over the application of these studies to ‘realistic field conditions’ in response to independent papers (even when studies have been at least partially field based). This formed part of CRD’s view of papers by: Henry et al; Whitehorn; Pettis et al; Vidau et al; Wu et al; Mommaerts V et al; Schneider et al and Teeters et al.

8. It appears that DEFRA have never justified how or why field tests are scientifically more acceptable and robust than laboratory assessments, in response to any of the independent studies they have criticised, nor have they published guidelines as to what they would accept for those particular study areas not covered by regulatory tests, but covered by independent scientists.

Agrochemical Industry Involvement In Setting Regulatory Standards

9. The agrochemical industry has been exceedingly influential in setting the terms of pesticide research for regulatory submissions via the EPPO and industry sub-group "The Bee Protection Group". http://www.eppo.int/PPPRODUCTS/honeybees/honeybees.htm

10. Despite presence of FERA Civil Servants within these groups, they have failed to ensure tests were adequate for assessing risks to bees and non-target invertebrates.

11. At the ICPBR- Bee Protection Group 10th Symposium (Bucharest, 2009-10-08/10 - Proceedings published in the Julius-Kühn-Archiv 423, 2009 ) the WGs presented "proposals for the revision of EPPO Standards" and attendees were primarily from industry (or related background), although some UK and other civil servants were present: http://www.jki.bund.de/fileadmin/dam_uploads/_veroeff/JKI_Archiv/JKI_Archiv_423.pdf Two beekeepers raised concerns with the standards (these same concerns were also raised by EFSA).


12. In 2003, Helen Thompson, a scientist from FERA, published a paper: (2003)

Behavioural effects of pesticides in bees – their potential for use In risk assessment Ecotoxicology 12 317-330. The paper notes "Further work is required to allow risk assessment to include significant behavioural effects and their longer term consequences on colony survival and development" and: "The OECD and EPPO guidelines require all abnormal behavioural effects to be reported but give no guidance on the types of effects to be recorded" (despite this, guidelines for regulatory submissions remained inadequate).

13. In spite of the above paper from Thompson discussing behavioural effects in 2003, in 2007, she produced a paper in co-operation with Bayer CropScience’s Christian Maus: "Perspective: The relevance of sublethal effects in honey bee testing for pesticide risk assessment"; publ: Pest Management Science (sublethal effects include behavioural effects). It states: "The authors conclude that sublethal studies may be helpful as an optional test to address particular, compound-specific concerns, as a lower-tier alternative to semi-field or field testing, if the effects are shown to be ecologically relevant. However, available higher-tier data (semi-field, field tests) should make any additional sublethal testing unnecessary, and higher-tier data should always override data of lower-tier trials on sublethal effects".

Lack of Balance: Industry vs Public Consultation

14. According to the FERA website, part of FERA’s remit is: "Research and assurance:
Fera provides its public and private sector stakeholders with robust scientific evidence and thorough analysis to support them in both the strategic and day-to-day decisions they face"

15. Despite the level of activity with industry, DEFRA/FERA/CRD do not appear to proactively consult truly independent organisations and scientists that receive no funding directly or indirectly by industry. The public are also not consulted – despite use of neonicotinoids on 1,278,811 ha of crops in 2011, http://pusstats.csl.gov.uk/myindex.cfm. and many public petitions requesting a ban on neonicotinoids.

16. The EAC are asked to consider whether Article 6 (2) CONVENTION ON ACCESS TO INFORMATION, PUBLIC PARTICIPATION IN DECISION-MAKING AND ACCESS TO JUSTICE IN ENVIRONMENTAL MATTERS applies, and if so, whether DEFRA and its bodies must do more (and have done enough) to involve and consult the public PRIOR to registering chemicals that will be used on large surface areas of the UK. It should also be noted that there have been many public petitions requesting a ban on neonicotinoids.

17. The UK tax payer may prefer funds and advisory positions to be allocated to independents scientists and institutions not those with connections to industry.

Efficacy Claims In Insecticides Product Patents: Implications For Non-Target Insects

EAC are asked to consider whether the use of insecticides and potential effects on other species, generally out of balance with the reality of threat from ‘crop pests’.

1. Patents are on public view via: www.google.com/patents for insecticides. It is interesting to note the claims of efficacy against various insect orders, and provide crucial insight as to their potential for effects on a wide range of invertebrates. In other words, insecticides may claim within patents to be effective against species within an Order of insects, but for the sake of targeting a small number of ‘pest species’ within that insect order, it may be reasonable to assume many beneficial species may be harmed.

2. For example, a patent for an insecticide containing neonicotinoid imidacloprid, can be viewed and downloaded here: http://www.google.co.uk/patents/US5994331?dq=5994331&hl=en&sa=X&ei=sliNUMbCE6qs0QXN5YBI&ved=0CC8Q6AEwAA It is active against species of ‘lepidoptera’ (for the purpose of killing ‘pest moths and butterflies’). According to the Royal Entomological Society, Britain has 2,500 lepidoptera species, and few ‘pest’ Lepidoptera (butterflies and moths). Indeed, it appears FERA mention only 10 lepidoptera ‘pest’ species specific to agriculture and approximately 4 specific to trees. It seems reasonable to suppose that many beneficial species of Lepidoptera could be at risk, for the sake of targeting a small number of ‘target’ species. It is interesting to note that statistics suggest specific agriculture related butterflies are declining on farmland in the UK, and have been doing so since 2003 - source Butterfly Conservation report: page 3: http://www.butterfly-conservation.org/uploads/State%20of%20the%20UK%27s%20Butterflies%202011%281%29.pdf Vespa spp (wasps) also is listed. Bees are hymenoptera, believed to be descended from wasps. Given regulatory system flaws and significant independent study outlining effects of neonicotinoids on bees it seems unreasonable to ask the intelligent public to convince ourselves these insecticides present ‘no unacceptable risk to bees’.

3. It should be noted that in regulatory testing, only a tiny number of invertebrate species must be tested as a representative sample: honey bees, waterfleas, earth worms, and 2 further species. http://www.pesticides.gov.uk/Resources/CRD/Migrated-Resources/Documents/D/DRH_v2_2_Complete.pdf

4. There is no requirement by law that this author is aware of, which compels manufacturers to list all the beneficial insects potentially harmed.

Chronic And Behavioural Effects Of Insecticides

5. The EFSA report May 2012, outlined weaknesses in standards for testing pesticides, and these weaknesses included failure to test for chronic, behavioural, colony, larval, effects, among many others. http://www.efsa.europa.eu/en/efsajournal/pub/2668.htm

6. Behavioural, sublethal and chronic effects of insecticides are recognised by pesticide manufacturers as providing efficient means of killing insects. There are multiple means of exposure and the spreading of a toxin through a colony on insects – again, this is acknowledged within industry.

7. A significant example of this is described in detail within an information leaflet for Bayer’s neonicotinoid Imidacloprid Termite killer: Premise 200sc, and in the Bayer brochure "The Secret Life Of Termites". Though not present in the UK, Termites are social colony insects (interdependent) with a queen, like bumblebees and honeybees, but their colonies can be significantly greater – according to The Secret Life Of Termites" they can reach from 250,000 to 3 million individuals.

8. Bayer CropScience Product Claim Premise 200SC (imidacloprid) leaflet:

"Unlike other termiticides, termites cannot detect the treated zone, so they enter it and are immediately affected. Termite stop feeding, grooming and becomes disoriented."

"Imidacloprid binds to the nicotinergic acetylcholine receptors at the nervous systems which leads to paralysis and eventual death".

"Low doses of Premise 200SC such as the edge of the Treated Zone, disorientate the termites and cause them to cease their natural grooming behaviour. Grooming is important for termites to protect them against pathogenic soil fungi. When termites stop grooming, the naturally occurring fungi in the soil attack and kill the termites. Premise 200 SC makes fungi 10,000 times more dangerous to termites. Nature assists Premise in giving unsurpassed control. This control is Premise 200SC plus Nature."

9. From Bayer CropScience Brochure "The Secret Life Of Termites":

"When one termite meets another, it uses its mouthparts to clean and tidy it. This behavior, which scientists refer to as ‘grooming’, opens up an opportunity for more effective control

of termites, as it allows an active substance to be passed from one insect to the next. This mode of transmission helps imidacloprid reach the furthest corners of the complex system of tunnels inside a termite nest, so that it has the potential to affect the entire population very quickly,"

10. Independent evidence testing on bees have found similar effects as those seen in termites, e.g. M.E. Colin et al 2004: They tested both Imidacloprid and Fipronil, and found ability of honey bees to forage was severely impaired. V. Girolami et al 2009: Fed guttation drops collected from a canola treated field and noted effects were agitation, arching of the abdomen, regurgitation, uncoordinated movement, wing paralysis, and death.

11. Grooming and social grooming in honey bees has been detailed in a number of research studies, (forexample: Moore et al 1995; Winston and Punnett, 1982; Frumhoff and Baker, 1988; Kolmes, 1989; van der Blom, 1993).

12. Importance of grooming has also been highlighted as a defence against Varroa mite in both Apis cerana (Peng et al., 1987) and Apis mellifera (Ruttner and Haenel, 1992) and this phenomenon can even be observed on computer screen at : http://www.brnda.com/Beefightingvaroa/tabid/66/language/en-US/Default.aspx ). Varroa mite has been increasing in the UK: Page 9 http://www.juliegirling.com/images/stories/Bee_Conference/Thompson_MEPs_presentation_30032011.pdf

13. On April 2011, David Hanson MP tabled a parliamentary question asking the Secretary of State for Environment, Food and Rural Affairs, if she would commission a comparative study of the effects of neonicotinoid pesticides on the grooming behaviour of (a) termites and (b) bees (50755). In his reply, Jim Paice said "Effects of insecticides on grooming behaviour are not currently a standard data requirement in the regulatory process, and have not been identified as a requirement in the revised regime to be introduced shortly by Council Regulation 1107/2009".

14. Bayer CropScience publicly admit not to have tested for effects on grooming in bees: "Government asked to investigate new pesticide link to bee decline" - The Independent; 30th March 2011: "Dr Julian Little, Bayer's UK spokesman, said: "We do a lot of tests of the effects of insecticides on bees, and impairment of grooming has never shown up." Specific tests to see whether or not bees' grooming ability was impaired by neonicotinoids had not been carried out, he added". http://www.independent.co.uk/environment/nature/government-asked-to-investigate-new-pesticide-link-to-bee-decline-2256737.html

 

15. Bayer CropScience Product Claim Premise 200SC (imidacloprid) leaflet:

"Termite colonies work as interdependent units – they all rely on each other for survival. Premise 200 SC interferes with this instinctive social behaviour, contributing to the termites’ demise."

From Bayer CropScience Brochure "The Secret Life Of Termites":

"Genetic analysis from the house studies has now proven this. Feeding on the wooden structure was stopped in days, termites disappeared within a week or two from soil monitors immediately outside the structure, and after three months all termite colonies attacking these structures were eliminated. After two years of monitoring since treatment, not one of these colonies has recovered."

16. Whilst manufacturers acknowledge the importance of colony effects, EFSA have stated that guidelines are inadequate in this area. The field tests being only of 28 days required duration, and the semi-field tests of only 7 days, have no requirement for, nor realistic method of observing multiple distribution routes through the colony.

Do Neonicotinoids Increase Vulnerability of Non-Target Insects To Fungi?

17. A number of studies have highlighted relationships between neonicotinoid pesticides and mortality in bees due to pathogenic fungi nosema by: Cédric Alaux et al, Cyril Vidau et al; Jeffery S. Pettis et al: Pesticide; and Judy Y. Wu et al.

18. The relationship between neonicotinoids and disruption to grooming in insects, and also vulnerability to fungi, has been noted in studies: Galvanho et al, 2012: Imidacloprid Inhibits Behavioral Defences of the Leaf-Cutting Ant Acromyrmex subterraneus subterraneus (Hymenoptera:Formicidae) (Ants are in the same insect order as bees – i.e. Hymenoptera); Santos et al 2006: Selection of entomopathogenic fungi for use in combination with sub-lethal doses of imidacloprid: perspectives for the control of the leaf-cutting ant Atta sexdens rubropilosa Forel (Hymenoptera: Formicidae); Albrecht M. Koppenhöfer et al in 2000, Synergism of imidacloprid and entomopathogenic nematodes against white grubs: the mechanism.

19. EFSA Panel on Plant Protection Products - EFSA Journal 2012; 10(5):2668 comment: "Indeed, it has been shown that low levels of some pesticides may have synergic actions with diseases such as Nosema. Finding diseases in test colonies, which were healthy before the experiment, and not finding such diseases in control colonies, can imply a synergic effect of pesticides and diseases".

20. The final results of the 2 year project in England and Wales, were published, and indicate that 45% of the colonies had nosema – 8% of which had 2 strains: https://secure.fera.defra.gov.uk/beebase/downloadNews.cfm?id=60

Link Between Neonicotinoids And Varroa Mite?

 

21. Some research suggest a link between neonicotinoids and increased abundance of certain mites belonging, like Varroa mite, to the arachnid taxon ‘Acari’ (i.e. mites and ticks), for example: Chun-Xiang Zeng and Jin-Jun Wang 2008: Influence of exposure to imidacloprid on survivorship, reproduction and vitellin content of the carmine spider mite, Tetranychus cinnabarinus: http://www.insectscience.org/10.20/i1536-2442-10-20.pdf; Adrianna Szczepaniec et al 2011: Neonicotinoid Insecticide Imidacloprid Causes Outbreaks of Spider Mites on Elm Trees in Urban Landscapes http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0020018; Tessa Van Dyk’s earlier study: Effects of neonicotinoid pesticide pollution of Dutch surface water on non‐target species abundance 2010:
http://www.boerenlandvogels.nl/sites/default/files/FinalThesis_VanDijk.pdf Do neonicotinoids) favour/assist VARROA MITES?

 

Persistent, Cumulative And Mobile Properties And Chronic Effects Of Insecticides

Cumulative and chronic effects are not adequately assessed, and when insecticides are persistent and mobile in soil – such as neonicotinoids, they have the potential to accumulate. Neonicotinoids may also to trespass into areas not intended for treatment.

22. And: From Bayer CropScience Brochure "The Secret Life Of Termites":

"After two years of monitoring since treatment, not one of these colonies has recovered."

23. Bonmatin et al have confirmed persistence in soil, and that after 2 years (duration of the experiment), imidacloprid could be taken up from the soil and presented to bees through pollen and nectar, at toxic levels, even after usage ceased.

24. EFSA: P 42: http://www.efsa.europa.eu/en/efsajournal/pub/2668.htm "biological persistence nevertheless presents a potential risk to bees that should be assessed. However, the conventional regulatory tests are likely to be unsuited to assess the risks of long-term exposures because they are based on short-term measurements (48 to 96 h), and may fail to detect the true potential for long-term effects".

25. Bayer CropScience Product Claim Premise 200SC (imidacloprid) leaflet:

"Any termiticide is less effective if there are gaps in the treated area. Lateral Soil Movement (LSM), however, helps Premise 200C achieve a more complete treated zone. LSM refers to movement in all directions in the soil. Because of its moderate water solubility, imidacloprid moves with the wetting front of the soil. Then as the soil dries, it binds with the soil particles, ensuring a continuous treated zone."

26. If chemicals have the potential to trespass beyond the treated zone (which results in superfluous application of pesticide in areas not intended for treatment), what benefit can wildflower ‘pollinator’ strips planted along the sides of agricultural fields really serve?

27. The EAC are asked to consider whether the general public and bodies shall be entitled to suitable compensation for trespass of pesticides, and who should pay the compensation? The EAC are asked to investigate whether this feature has been properly explained to end users on product application instructions.

28. Tennekes The significance of the Druckrey–Küpfmüller equation for risk assessment-The toxicity of neonicotinoid insecticides to arthropods is reinforced by exposure time. Publ: Toxicology 2010 illustrates the risk of repeated exposure to neonicotinoid (imidacloprid and thiacloprid) doses at very low levels. Thus chemicals that persist in soil offer repeated exposure risk.

29. Toxic Soup Effects EFSA from page 102 onwards: http://www.efsa.europa.eu/en/efsajournal/doc/2668.pdf

A Misleading And Unbalanced View Of Independent Evidence

30. FERA present and have presented, an unbalanced summary of independent Scientific data – especially with regard to neonicotinoid impacts on bees, which are then released into the public domain, and may have serious implications for decision making and the environment. An example of this is the Girolami study: Translocation of Neonicotinoid Insecticides From Coated Seeds to Seedling Guttation Drops: A Novel Way of Intoxication for Bees. Journal of Economic Entomology 2009, 102 (5), 1808-1815) summarised by FERA here: http://randd.defra.gov.uk/Document.aspx?Document=PS2361_9170_FRP.pdf

31. Directly within the Executive summary, the document states: "Only one study (Girolami et al 2009) has shown a significant effect in honeybees but this should be treated with caution as the data were generated by feeding collected droplets directly to bees and in many cases sucrose was added to ensure the honeybees consumed the dose."

This is a misleading and unbalanced statement. Even if the above statement were true, then it should be noted that for regulatory assessment measuring acute oral toxicity in the laboratory, the tested pesticides are mixed with a sucrose solution. In addition, in regulatory tests, small quantities of test solution are mixed with sucrose and fed to bees via single use feeders. FERA know this they conducted the oral toxicity tests on behalf of Bayer CropScience to support the DAR for imidacloprid. In these test, they fed bees the test solution mixed with sucrose. The bees in the Girolami study are fed the guttation fluid using a capillary glass tube. FERA fed the test+sucrose solution directly to the bees also, "the dose being measured into a small, pre-weighed, glass feeder with the cage using a variable Gilson pipette". How is the methodology used by FERA anymore robust/better/fair than that used by Giorlami? In actual fact, Girolami added 15% honey only to some of the samples, and other bees were fed plain guttation drops. The addition of honey or not made no difference to the toxic effects - this significant point is not mentioned above.

The Full Summary Of The Girolami Study By FERA:

32. "Girolami et al (2009) undertook laboratory studies with honeybees in which they fed guttation fluid from treated maize to honeybees in the laboratory. The maize seeds were treated with imidacloprid (0.5mg Gaucho 350/seed), clothianidin (1.25 mg Poncho/seed), thiamethoxam (1mg Cruiser FS/seed) or fipronil (1mg Regent FS/seed) and grown in open field conditions. Guttation droplets were collected at 0800-0900 each morning for the first 3 weeks after emergence (when guttation reduced). In the field 1-3 mls of fluid could be collected from 100 plants (in the laboratory 30-150μl /plant/ day was collected) and each sample was split into two, one for chemical residue analysis and the other for bioassay. The bioassay was conducted with honeybees deprived of food and water for 2 hours before dosing and individuals dosed with guttation fluid only or guttation fluid with 15% honey. 20 minutes after fluid consumption fresh honey was provided. The time to first toxic symptoms was recorded. Field collected guttation fluid resulted in wing block within 2-9 minutes after consumption of fluid collected from plants grown from clothianidin, thiamethoxam or imidacloprid treated seed but not from control plants or plants grown from fipronil treated seed. There was a significant delay in the consumption of guttation fluid alone and only addition of honey resulted in consumption within 5 minutes of the dose being offered. The residues in the guttation fluid from plants grown from treated seed were 47± 9.96 mg imidacloprid/ L; 23.3 ± 4.2 mg clothianidin/ L and 11.9 ± 3.32 mg thiamethoxam/ L.; no fipronil was detected. Although the authors relied on sublethal effects for their bioassay the published LD50 data are 0.0037 μg imidacloprid/bee, 0.004 μg clothianidin /bee, 0.005μg thiamethoxam /bee. Based on intake of 20μl per bee these are equivalent to test solution concentrations of 0.185 mg imidacloprid/L, 0.084 mg clothianidin/L and 0.25 mg thiamethoxam/L.. Therefore the levels in guttation fluid were 254 times the LD50 for imidacloprid, 280 times the LD50 for clothianidin and 48 times the LD50 for thiamethoxam".

33. For clarity, quotes are lifted from the passage above, with comment below:

FERA: "honeybees deprived of food and water for 2 hours before dosing"

- This is exactly the same procedure for regulatory tests. Note in regulatory tests, they are dosed for a max 4-6 hours. Note that in regulatory studies, "a dose of 10 or 20µl of test solution per bee" is offered, and bees that do not drink are still included within the results. There is an assumption that "bees share the test solution between themselves and so receive similar doses". Yet some bees may not feed at all, hence affecting the results! In the Girolami study, a drinking event is defined by the consumption of 5µl solution, and bees that do not drink are discarded from the analysis. If an oral toxicity study is to measure just that, shouldn’t the question be "If X number of bees consume solution Y, how many will die?"? If bees do not drink the solution, is it right for them to be included in the analysis of oral toxicity. If tests for repellency are required, surely they should be carried out separately?

34. FERA: "20 minutes after fluid consumption fresh honey was provided".

Again, in regulatory assessments, sucrose is offered following the experiment period (max 4-6 hours).

35. FERA: "In the field 1-3 mls of fluid could be collected from 100 plants"

The study actually states: "Collection in the field was carried out from 8:00 to 9:00 a.m. from all plants within a row, until a volume of 5ml was available. In the laboratory, because guttation occurs throughout the days and night, it was possible to collect them three times a day, yielding a volume of≈ 1-2 ml/d". And: "whereas in the field a single collection in the morning easily allowed to gather 1-3ml from 100 plants."

36. FERA: "The bioassay was conducted with honeybees deprived of food and water for 2 hours before dosing and individuals dosed with guttation fluid only or guttation fluid with 15% honey. 20 minutes after fluid consumption fresh honey was provided. The time to first toxic symptoms was recorded. Field collected guttation fluid resulted in wing block within 2-9 minutes after consumption of fluid collected from plants grown from clothianidin, thiamethoxam or imidacloprid treated seed but not from control plants or plants grown from fipronil treated seed. There was a significant delay in the consumption of guttation fluid alone and only addition of honey resulted in consumption within 5 minutes of the dose being offered".

To be clear, there were several types of toxicity test conducted by Girolami. The guttation from field crops had NO honey added – and it resulted in wing block within 2 – 9 minutes. Honey was added to guttation drops from laboratory pot grown plants. For this sample, he ensured some of the pot grown guttation samples had honey added, and some did not. This can be clearly seen in Fig 4. Regardless, Girolami found that the addition of honey or not made no difference to the intoxication symptoms. The above description by FERA almost sounds as though the honey was significant to the results in the experiment. The reason for the addition of honey, however, was to speed up the experiment.

37. FERA: "The residues in the guttation fluid from plants grown from treated seed were 47± 9.96 mg imidacloprid/ L; 23.3 ± 4.2 mg clothianidin/ L and 11.9 ± 3.32 mg thiamethoxam/ L.; no fipronil was detected. Although the authors relied on sublethal effects for their bioassay the published LD50 data are 0.0037 μg imidacloprid/bee, 0.004 μg clothianidin /bee, 0.005μg thiamethoxam /bee. Based on intake of 20μl per bee these are equivalent to test solution concentrations of 0.185 mg imidacloprid/L, 0.084 mg clothianidin/L and 0.25 mg thiamethoxam/L.. Therefore the levels in guttation fluid were 254 times the LD50 for imidacloprid, 280 times the LD50 for clothianidin and 48 times the LD50 for thiamethoxam".

Guttation drops were collected directly from corn that was planted using the manufacturers insecticide treated seeds. When this guttation fluid was fed to bees, sub-lethal effects were exhibited and ultimately death.

38. FERA’s treatment of the Girolami study is in contrast to their treatment of a Swiss study, using methodology which is flawed, but nevertheless, it appears to comply with the EPPO regulatory standards for field tests. The flaws of the Swiss study, are not pointed out to the reader of the report. This is the full summary from document:

FERA: "The Swiss Federal Government for Agriculture commissioned a study in 2009 (www.blw.admin.ch/themen/00011/00077/00590/index.html?lang=fr) to assess the risks to honeybee colonies during sowing of maize seed treated with Poncho (25g ai/ 50,000 seeds, i.e. 0.5 mg ai/seed) through drift of dust and guttation. No effects were observed due to dust drift. Guttation fluid collected from maize after emergence (7-10 days after sowing) was reported to contain 25-37 mg clothianidin/L reducing to around 0.1 mg/L by 40 days after sowing (as above the LD50 for clothianidin is around 0.084 mg/L) (Figure 3). No clothianidin residues were detected in the honeybees or in honey sampled from the colonies and no increased mortality was identified at honeybee colonies placed at the edges of the treated fields and the colonies developed normally".

39. The link to study is to a French version, not an English version. It would have been useful if FERA had provided the English translation. The study was called: "Presence of Clothianidin in Hives (Monitoring)", and the objective of this study was "Quantitatively and qualitatively establish the presence of neonicotinoids (clothianidin)" The study investigated clothianidin residues in guttation, pollen, honey and dead bees.There were 2 elements of this test:

Test 1

A 2 ha field was used. Foraging bees will fly several kilometres – even at only 2.5 km, this corresponds to a theoretical foraging area of 19.6 km2, i.e., about 2000 hectares (EFSA). Only 36% of this tiny field was sown with clothianidin, the pesticide that was the subject of the study! 74% of the field had no clothianidin at all. The rest of the field was sown with: Gaucho - imidacloprid , Cruiser – thiamethoxam, Mesorol which is not a systemic neoniocotinoid. It is a bird repellent and molluscicide and a non-systemic carbamate pesticide. The study does not refer to these other pesticides later – so we don’t know anything further about residues of other neonicotinoids. Colonies of bees with 20,000 bees each were installed by the side of the clothianidin treated field. 6 colonies of bees were used – 3 on each side – in reality, these colonies must have been close together – a regulatory field trial fault also identified by EFSA. Six days before planting, the hives were installed. The fields were close to wildflowers and trees, and dandelions. 4 colonies from the sample of 6 (2 from each side) were used for monitoring of dead bees collected in traps at the hive. Pollen and honey samples were collected from the remaining 2 hives and analysed for residues of clothianidin. In the case of the honey, the samples were taken 3-5 weeks before and after planting the corn. Trial began 17 April – seeds sown April 23rd. The trial lasted just 50 days from April 23rd (where April 23rd = 0). Guttation fluid was collected from the corn in this field early in the morning. Indeed from the results, it appears that no guttation was collected until day 15 of the study FOLLOWING the sowing of the seeds on 23rd April. However, the study confirms that guttation is collected only on 14 times.

Test 2

The second field test was only 200m to 300m from the first field test. The field was surrounded by wildflowers, dandelions, clover. The bee colonies were "placed on either side of the cornfield in a meadow". The size of this field was a mere 1 ha. Again, residues were measured, with predicable results.

40. Results: Not surprisingly, the authors find no significant mortality of bees. They do not detect residues of clothianidin in pollen and honey, with the exception of one sample of pollen. The authors state the contamination of this sample is likely to be caused by increased exposure to clothianidin of the dandelions close by, due to frequent use of the field for trials. Thus an admission by the authors that the bees are more likely to have foraged on dandelions than the corn. A 2 ha field sown with a few rows of corn over just 36% of the surface area appears very unrealistic. The authors do find very significant levels of clothianidin in guttation samples: with levels of 27 to 37,000 (thirty seven thousand) microlitres per litre. The authors (concede that this is high, but since they haven’t found any clothianidin residues in dead bees, honey or pollen during the time period the corn was guttating, the authors conclude this must mean the guttation doesn’t pose a threat, but they advise that if water is of limited availability to the bees, then beekeepers should engage in good beekeeping practice, by supplying water in the beehive.

41. FERA go on to summarise a further study by Shawki et al (2006). This study does not add any weight at all to the notion that guttation from crops treated with systemic insecticides, is not harmful to bees. Nor does it support in any way, the findings of the Swiss study above. The fact that the crops were treated with a non-systemic insecticide seems highly relevant. This is not explained by FERA, nor is it properly explained why guttation results would be so different from those in the other studies. As such, FERA are omitting important information that will potentially mislead the reader of this report.

42. FERA refer to the Swiss study again, to cast doubt on other evidence suggesting that guttation could be highly toxic for bees: "The only oral toxicity data available for non-target arthropods readily available are those for the honeybee……However, as studies in Switzerland showed no significant mortality in bee colonies located at the edge of treated maize fields the significance of guttation fluid as a source of water for bees is unclear".

WIIS And Monitoring Of Diseases Associated With Colony Collapse In Honey Bees

43. The scheme for reporting poisoning of honey bees by pesticides (WIIS - Wildlife Incident Investigation Scheme) to the National Bee Unit (NBU), is inadequate in the UK, and does not provide a true picture A report by Dr Bernie Doeser draws out inadequacies with the scheme: http://www.buzzaboutbees.net/support-files/wiis.pdf

44. Yet IMPORTANTLY, data provided by the WIIS is used in setting regulatory analysis measures to assess risks of pesticides to bees. The EFSA report: http://www.efsa.europa.eu/en/efsajournal/doc/2668.pdf

45. It should be noted that WIIS can only gather acute poisoning data where direct poisoning is concerned, and cannot give the whole picture with regard to practical effects of pesticides in the field through chronic exposure.

46. Meanwhile, there is no on-going recording by the NBU to monitor prevalence of nosema, despite presence of nosema in CCD cases, and data linking nosema with neonicotinoids. A project involving 4600 colonies in England and Wales found nosema in 44% of cases.

9 November 2012

Prepared 19th November 2012