Insects and Insecticides

Further supplementary written evidence submitted by Lord de Mauley, Parliamentary Under Secretary of State, Department for Environment, Food and Rural Affairs

Advice received from ACP after their 29 January meeting:

A THE BALANCE OF EVIDENCE

Ministers will recall that earlier advice from the ACP in November 2012 had concluded that there was, at that time, insufficient evidence to associate neonicotinoid insecticide usage with impacts on bees (including honey bees and other important bee species). The ACP has now discussed a number of reports of further research with invited experts on bumble bees at its January 2013 meeting. These studies included the results of the bumble bee field study conducted by FERA during summer 2012 and initial findings of a comparison of English and Welsh honey bee colony loss and pesticide usage information during the period from 2000 - 2010. As a note of caution, the results of these two studies are still provisional and the reports have not yet been peer reviewed. Interpretation of these findings was not straight forward and the need for further detailed analysis was identified in order to assist interpretation of the results.

Nevertheless members advise Ministers that the balance of the weight of evidence is changing in the light of these additional FERA studies, together with other university research findings. Whilst there is no single piece of evidence clearly identifying a significant adverse effect of neonicotinoid insecticides on bee species in the UK, the accumulation of information does not rule out the possibility that there might be effects occurring to bees in the field in the UK, and much of this new information points in the direction of potential adverse effects.

The data contributing to this shift in the balance of evidence is as follows:

1. There are possible indications within the FERA field study on bumble bees that there could be a relationship between residues of the most persistent and toxic neonicotinoids in individual colonies and the production of new queens within those colonies. This is yet to be confirmed by a re-analysis of the raw data which should also address cumulative and individual exposure of bumble bees to neonicotinoids.

2. The study examining regional honey bee colony loss data compared to pesticide use is showing initial indications that one factor which might be statistically associated with in-season losses of honey bees colonies is usage of imidacloprid. (Other neonicotinoids have not been in use long enough in the UK to run a similar comparison for them). This association is not evidence of causation, but members commented that they had considered it unlikely to see such an association between the parameters. Whilst other factors explain more of the variability in colony loss (e.g. region, probably associated with differences in climatic conditions), patterns of use of imidacloprid explained in the region of 5-10% of the variability in recorded colony loss in different regions and different years.

3. Additional information is now available on possible mechanisms associated with the potential greater sensitivity of bumble bees compared to honey bees and thus it may not be appropriate to extrapolate risk assessment conclusions from honey bees to other pollinators such as bumble bees.

4. The EFSA consideration of current products and uses identified several data gaps as well as identifying some concerns about the reliability of existing regulatory risk assessments including field studies on honey bees in light of the latest scientific developments.

There is uncertainty about the magnitude of any such effects on bee and other pollinator populations [and the associated pollination services they supply], but effects on colonies could lead to impacts on populations and population effects could be very important ecologically.

Consequently the ACP advises:

(i) that a reanalysis of the results from the FERA bumble bee field study should be completed as a matter of urgency and the report completed and submitted for peer review.

(ii) that the statistical analysis of bee health data and pesticide usage data be completed, again as a matter of urgency, in order to put the research results for neonicotinoids into a broader context. If available, additional information on the potential association of other factors with colony loss should be included in this assessment, and there should be a stringent analysis of the choice of statistical model.

B THE NEED FOR REVIEW

The ACP advised that there are therefore indications from the current balance of evidence that article 29 (1) (e) of regulation 1107/2009 may no longer be satisfied in respect of the risk to bees (and potentially other pollinators) from residues in the nectar and pollen of crops attractive to bees grown from seed treated with certain neonicotinoid insecticides. (i.e. article 4 (3)(e) it ‘shall have no unacceptable effects on the environment having particular regard to the following considerations where the scientific methods accepted by the Authority to assess such effects are available: ... (ii) its impact on non-target species, including on the on-going behaviour of those species’ may no longer be satisfied).

In accordance with article 44 of regulation 1107/2009, Ministers are therefore advised that they may wish to initiate a review of the current authorisations of products containing neonicotinoids taking into account the additional advice provided by the Committee on the regulatory options across the range of products and uses and in particular focusing on the uses identified above. This would be a precautionary decision as the evidence currently available does not indicate that such effects are occurring, but there is an indication that effects might be occurring.

C IMPORTED SEED

As the need for review has been identified for seed treatments, the ACP additionally has considered whether the test set out in Regulation 5(1) of the UK Plant Protection Products Regulations 2011 for unilateral national action to restrict or prohibit the use and/or sale of treated seeds has been met. This test requires that Ministers act if they reasonably consider that treated seeds are likely to constitute a serious risk to human health or to the environment.

The ACP advises Ministers that whilst the potential risk is associated with the planting of treated seed wherever that seed has actually been treated, until such time as the re-analysis of the FERA field study is completed it is not yet possible to confirm that there is likely to be a serious risk to bees. However the ACP advises that the concerns about potential risks to bees from residues in bee-attractive crops grown from seed treated with neonicotinoid seed treatments to date should be raised within discussions in the EU in light of any proposal by the European Commission to restrict treated seed across all Member States.

D RESTRICTIONS ON CURRENT USES WITHIN THE UK

The committee urged that the further analysis of the FERA work should be completed urgently and consideration of the need for any additional regulatory action in the UK be undertaken in March 2013 in the light of such further analysis. This further consideration will not prevent action being taken on the major use of seed treatment in oilseed rape before the main autumn sowing season should this be deemed necessary. Nevertheless, the Committee recognises that the later a decision is made the more disruptive it will be to the seed supply chain.

An alternative view was expressed by Prof Colin Brown and Prof Peter Matthiessen (both having environmental expertise) that, despite the flaws within the studies as presented to the ACP at this meeting, there were associations indicative of concern reported in both the FERA field study and the analysis of bee colony loss data and pesticide usage. On this basis a precautionary approach would be to recommend regulatory action at this time in order that changes would come into effect in time to impact crops to be drilled in Autumn 2013. They recommended a moratorium of major uses on ‘bee attractive’ crops would be appropriate whilst further data were considered to clarify the risk.

13 March 2013

Prepared 28th March 2013