HC 668 Insects and Insecticides

Written evidence submitted by Graham White, Friends of the Bees

As a beekeeper and campaigner on the issue of neonicotinoids since 2004, I would like to draw your attention to the evidence which Dr. James Cresswell gave on Weds 21st November 2012. The crucial statements are 30 minutes into the video recording. 

Dr Cresswell implied that there was virtually no data, very little evidence as to 'real' levels of contamination of nectar and pollen in the field by neonicotinoids.

The clear impression which I received from his oral evidence was that the entire issue of neonicotinoids and bee deaths was very confusing. It was all very complex; there was a huge lack of data; we don’t really know what is going on in the field; laboratory studies cannot duplicate what happens in the field.

This seems to echo the position of the Syngenta witnesses and the views of Julian Little of the Crop Protection Association. The Guardian reported that Dr. Cresswell received funding of £136,000 from Syngenta in 2011 and his public stance, in various papers, is that there is no convincing evidence that neonicotinoids are responsible for the collapse of bee colonies in the field.

Here is the Parliamentary transcript of the crucial part of Dr Cresswell’s evidence:

Q121 Mr Spencer:

" Just talk us through that dose and concentration rate. Are we

talking in the laboratory of twice as much as you would expect on a field scale or ten times or what sort of concentration are these tests being conducted on? "

Response from Dr. James Cresswell

"This goes back to this issue about publicly available data. I noticed in the Syngenta submission that they began to talk about what the range was of the concentration of residues in pollen and nectar for thiamethoxam, but the laboratory trials so far have been constrained to dredging out the one or two reported values we can get at from the scientific literature, which may or not be particularly relevant.

One of the things that struck me when I first got into this field was the complete lack of data on the residue levels. When I measured what was in the pollen and nectar of oilseed rape in the UK a couple of years ago, that doubled the publicly available data set on relevant residues. "

This ‘keynote’ theme  (the lack of data on neonicotinoid residue levels in pollen and nectar) was emphasised by Damian Carrington's in his Guardian article: Science Under Pressure as Pesticide Makers Face MPs: Wednesday 28 November 2012 , viz:

"Cresswell said the problem is far greater than [the lack of] a single study:

There is a dearth of fundamental knowledge. Strong lab knowledge can inform, but we don't even have that. There is a virtu al total lack of data on neonico tinoid residues in pollen and nectar."

I do not understand how Dr. Cresswell could make the above statement when there is a vast body of peer-reviewed evidence , on the neonicotinoid contam ination of pollen and nectar going back as far as 1998.

In Cresswell’s quoted evidence he begins by saying there is not much data on thiamethoxam , which is the most recent neonicotinoid to appear on the market; but he then conflates this comment to imply that there is a similar lack of data on pollen residues for all the neonicotonoids – including Imidacloprid and Clothianidin. On this he is completely and utterly wrong and his conflation of the two issues is unacceptable.

He is contradicted by a plethora of studies in the scientific literature , on this crucial issue . Indeed, the ‘Comite Scientifique et Technique’ , convened by the French Government in 1999 , considered more than 243 papers, many of which dealt with this exact issue. The result of their analysis was that the French banned Imidaclopr id in 1999 for use on bee related crops and later banned clothianidin and thiamethoxam for the same reasons.

Any neutral survey or of peer-reviewed papers on this topic, from 1998 to the present day, would conclude that there are in fact dozens of studies and vast amounts of data .

A 1999 study by Stor k , for example, quantified contamination of sunflowers treated with Gaucho® at 3.3 ppb in pollen and 1.9 ppb in nectar (Stork, 1999, in GVA, 2006; SCT, 2003). Other key studies on this issue were carried out by Bonmatin (1997) and by Belzunces, Tasei and many o thers (see list below). In flat contradiction to Dr Cresswell’s claims of a dearth of data, w e have more than 13 years of field and laboratory evidence documenting the contamination of pollen and nectar by neoni cotin oid pesticides .

The EFS A report ( http://www.efsa.europa.eu/en/efsajournal/doc/2668.pdf ) on which Dr. Cresswell served as an " expert-panel member " , refers to more than a dozen peer-reviewed studies on the very subject ; please see following list below .

This raises disturbing questions :

1. Since Dr. Cresswell served as an ‘expert panel member’ for the current EFSA report h ow can he not be aware of the 16 peer- revi ewed studies in that same report , covering the specific issue of contamination of nectar and pollen by neonicotinoids ?

2. Since Dr. Cresswell must, in fact , be fully conversan t with those studies , how could he possibly tell your Inquiry that there is virtually a complete data vacuum on contamination of pollen and nectar by neonicotinoids ?

Arguably the Committee should recall Dr Cresswell and ask him to clarify his evidence against the context of the large body of peer-reviewed papers, which appear to directly contradict hi m .

Please see below:

Abstract from the current EFSA report Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees ( http://www.efsa.europa.eu/en/efsajournal/doc/2668.pdf ) in which Dr. Cresswell is acknowledged as an ‘expert reviewer’. Dr. Cresswell is acknowledged  below as a member of the EFSA expert group which produc ed the attached report - and was specifically thanked by the authors fo r his expert contribution:


Scientific Opinion on the science behind the development of a risk

assessment of Plant Protection Products on bees

( Apis mellifera , Bombus spp. and solitary bees ) 1

EFSA Panel on Plant Protection Products and their Residues (PPR) 2, 3 "

" Acknowledgement: The Panel wishes to thank the members of the Working Group on Bee Risk Assessment (Robert Luttik, Gérard Arnold, Jos Boesten, James Cresswell , Andrew Hart, Jens Pistorius, Fabio Sgolastra, Noa Simon Delso, Walter Steurbaut, Helen Thompson) for the preparatory work on this scientific opinion . "

This EFSA report contains over ten pages of published data from peer-reviewed studies on the levels of contamination of p ollen and nectar with neonicoti noids. 

They are contained within tables G1 to G4 on pages 179 - 193 of the att ached EFSA report, for which Dr. Cresswell acted as an ‘expert panel member ’.  The report reference s many research papers dealing with the neonicotinoid contamination of pollen and nectar carried out since 1998 , by leading au thorities in the field. These reports include:

Quantification of Imidacloprid uptake in maize crops

Bonmatin JM, Marchand PA, Charvet R, Moineau I, Bengsch ER, Colin ME, 2005.. Journal of Agricultural and Food Chemistry, 53, 5336 "5341.

Influence of pesticide residues on honey bee (Hymenoptera: Apidae) colony health in France . Chauzat MP, Carpentier P, Martel AC, Bougeard S, Cougoule N, Porta P, Lachaize J, Madec F, Aubert M and Faucon JP, 2009. Environmental Entomology, 38, 514-523.

A survey of pesticide residues in pollen loads collected by honey bees in France . 2006. Chauzat MP, Faucon JP, Martel AC, Lachaize J, Cougoule N and Aubert M Journal of Economic Entomology, 99, 253-262.

Pesticide residues in beeswax samples collected from honey bee colonies ( Apis mellifera L.) in France, Chauzat MP and Faucon JP, 2007. Pest Management Science, 63, 1100–1106.

Influence of pesticide residues on honey bee (Hymenoptera: Apidae) colony health in France. Chauzat MP, Carpentier P, Martel AC, Bougeard S, Cougoule N, Porta P, Lachaize J, Madec F, Aubert M and Faucon JP, 2009. Environmental Entomology, 38, 514-523.

A survey of pesticide residues in pollen loads collected by honey bees in France . Chauzat MP, Faucon JP, Martel AC, Lachaize J, Cougoule N and Aubert M, 2006.

Journal of Economic Entomology, 99, 253-262.

Dynamics of pesticide residues in nectar and pollen of mustard (Brassica juncea (L.) Czern.) grown in Himachal Pradesh (India ). Choudhary A and Sharma DC, 2008. Environmental Monitoring and
Assessment, 144, 143-150.

Modes of honey bees exposure to systemic insecticides: estimated amounts of contaminated pollen and nectar consumed by different categories of bees . Rortais A, Arnold G, Halm MP and Touffet-Briens F, 2005. Apidologie, 36, 71-83.

Pesticide application in flowering rape (Brassica napus) and its effect on the residue levels in honey , nectar and pollen from the honey bee ( Apis mellifera L.). Schatz F, Wallner K, 2009. Thesis (Diploma), Universität Hohenheim, Hohenheim, Germany.

Effects of a chronic dietary exposure of the honeybee Apis mellifera (Hymenoptera: Apidae) to imidacloprid . Schmuck R, 2004. Archives of Environmental Contamination and Toxicology, 47, 471-484.

Risk posed to honeybees ( Apis mellifera L., Hymenoptera) by an imidacloprid seed dressing of sunflowers . Schmuck R, Schöning R, Stork A and Schramel O, 2001. Pest Management Science 57,225-238.

Field relevance of a synergistic effect observed in the laboratory between and EBI fungicide and a chloronicotinyl insecticide in the honeybee . Schmuck R, Stadler T and Schmidt HW, 2003. ( Apis mellifera L., Hymenoptera ). Pest Management Science, 59, 279-286.

Impact of currently used or potentially useful insecticides for canola agroecosystems on Bombus impatiens (Hymenoptera: Apidae ), Megachile rotundata (Hymentoptera: Megachilidae), and Osmia lignaria (Hymenoptera: Megachilidae). Scott-Dupree CD, Conroy L, Harris CR, 2009. Journal of Economic Entomology, 102, 177-182 .

Sprayed and seed dressed pesticides in pollen, nectar and honey of oil seed rape. Wallner K, 2009. Julius-Ku hn Archiv, 423, 152-153.

Multi-residue analysis of 80 environmental contaminants in honeys, honey bees and pollens by one extraction procedure followed by liquid and gas chromatography coupled with mass spectrometric detection . Wiest L, Buleté A, Giroud B, Fratta C, Amic S, Lambert O, Pouliquen H, Arnaudguilhem C, 2011.
Journal of Chromatography A, 1218, 5743-5756.

Method for Analysis of Imidacloprid in Soils, in Plants, and in Pollens : Analytical Chemistry. Chem. 2003, 75, 2027-2033
J. M. Bonmatin,
I. Moineau, R. Charvet, C. Fleche, M. E. Colin and E. R. Bengsch  

Further studies not referenced in the above report :
The following studies are not referenced in the current EFSA report, but they are regarded as ‘foundational’ in the study of ‘pollen and nectar contamination’ by neonicotinoids. It is impossible that Dr. Cresswell was unaware of these papers when he gave his evidence.

Report on the effects of seed treatments in sunflower Gaucho ® (imidacloprid) . Impacts on populations of bee colonies and the honey . Belzunces L, Tasei J-N. Paris: Commission d’Etude de la Toxicité des Produits Antiparasitaires à Usage Agricole et des Produits assimilés, Ministère de l’Agriculture ;1997 . 27 pp.

Effets des produits phytosanitaires sur les abeilles , Bonmatin J-M, Bengsch ER, Moineau I, Lecoublet S, Colin ME, Fleche C. Programmes 1999 et 2000. Rapport de résultats no. 3 au. Paris: Ministère de l’Agriculture et de la Pêche; 2000. 32 pp.

Quantification of imidacloprid uptake in maize crops . Bonmatin J-M, Marchand PA, Charvet R, Moineau I, Colin ME. J Agric Food Chem 2005 ;53:5336 –41.

A Method to Quantify and Analyze the Foraging Activity of Honey Bees :
Relevance to the Sublethal Effects Induced by Systemic Insecticides

Colin M, Bonmatin J, Moineau I, Gaimon C, Brun S and Vermandere J, 2004.

Environmental Contamination and Toxicology, 47, 387-395.

30 January 2013

Prepared 12th February 2013