Insects and Insecticides

Written evidence submitted by Friends of the Earth

Executive summary

1. Bees and other pollinating insects are essential to the economy, to the effectiveness of farming and the quality of produce and to the nation’s ecological function and cultural well-being. The Government’s recognition of the value and importance of bees in particular has yet to translate into firm action commensurate to the urgent need to ensure the survival, protection and recovery of bee and insect species.

2. The Government’s recent neonicotinoids review has not diminished concern that chemicals containing active ‘neonic’ agents are, whether individually or in combination with other crop protection applications, harming wild species and compounding the other known causes of bee and insect decline – habitat loss, general farming practice., the way built development takes place and pests and diseases in managed honey bee colonies.

3. The review announced on 13 September 2012 was less thorough than expected. Despite its limitations the review found that recent independent studies which had prompted the Government’s review do ‘provide evidence of sub-lethal effects of neonicotinoids’. But the review concluded that ‘none of the studies give unequivocal evidence that sub-lethal effects with serious implications for colonies are likely to arise from current uses of neonicotinoids.’

4. Another review finding is that the current risk assessment does not include testing for their potential effect on the majority of bee species – the honey bee (Apis mellifera) being only one of Britain’s 267 bee species. The current testing regime for chemicals and new products is uninformed by robust tests for the effect of chemicals on the majority of pollinating insects. This is a deep flaw in the testing regime and although is not especially revelatory as it was common knowledge before the review was published it is good that this is formally acknowledged in the review.

5. Notwithstanding the sizable holes in the testing regime and the Government’s ability to know the safety of products, the review stated that the Government is satisfied that the recent studies ‘do not justify changing existing regulations.’

6. Another gap in the review is its focus mainly on honey bees with only limited consideration of other bee species. Of the 15 recent published studies reappraised in the review at least 11 are studies of honey bees.

7. Further flaws in the review are that it does not comprehensively address the compound effect of exposure to chemicals on the other known causes of insect and bee decline such as habitats loss, and that it does not examine the combined effect of individual chemicals on insects.

8. The neonicotinoids review should be considered in the context of the Government’s National Pesticides Action Plan currently being drawn up as required by the European Sustainable Use Directive. The draft Action Plan submitted by the Government for public consultation does not comply with the Sustainable Use Directive. Without substantial improvement the draft Plan would be likely to continue undue threats to wildlife, water systems and public health instead of taking the required direct approach to reducing risk.

9. The issue of chemicals and insects gives the Government every opportunity to act with a sense of urgency and precaution but it is far from clear what its actions and intentions amount to. If bees and other insects are as important to farmers, food security and food prices as evidence and Government statements suggests, their welfare is a prime case for invoking the precautionary principle. Yet at every opportunity, the Government appears to express caution about the precautionary principle. The question arises; under what conditions would the Government invoke the precautionary principle?

10. Suspending use of neonicotinoids could be part of a proper testing regime as well as and a way to start helping farmers and other users to reduce their use of and dependence on chemicals.

Introduction to the submitter

Friends of the Earth has worked for over 40 years to protect our natural environment as part of shifting society and the economy to sustainable development approach

As part of The Bee Cause, our campaign to end the plight of British bees, we have commissioned the UK’s leading bee experts at the University of Reading to compile all of the latest evidence on the causes of bee decline - habitat loss, farming practice, development pressures, chemical use and pests and diseases - into a single report.

Available at the report recommends actions for the Government and others and endorses the need for a comprehensive UK Bees Action Plan to deal with all aspects of bee decline in a coordinated way.


1. Draw up a British Bee Action Plan - The drawing up of a National Bee Action Plan addressing all causes of bee decline including exposure to chemicals should be led as a matter of urgency by the Government.

2. Suspend use of neonicotinoids - The use of neonicotinoids should be suspended pending further research that they do not cause harm.

3. Revise Government statements - The Government’s own public statements about chemical and product safety should be revised to reflect the uncertainty which the Government has itself accepted about the current testing regime. Statements by Ministers and their agencies should also be revised.

4. Improve research - The remaining work due to be carried out by the Government on the remaining stages of the neonicotinoids review by the end of 2012 and spring 2013 must fully address the combined effect of chemicals on all wild bee species and other insects if it is to improve on the limited approach taken by the review up to 13 September 2012 which looked mainly at honey bees and considered neonicotinoids in isolation from other chemicals and the other main causes of bee decline. Research is also required to monitor the actual presence of neonicotinoid insecticides in nectar crop pollen, nectar, foraging bees (including bumblebees and solitary bees), stored pollen and honey.

5. Improve pesticide accreditation – accreditation should be amended to include independent, quantifiable and cross-taxa risk assessments of their impacts, including sub-lethal effects, on a range of bees and other insects in both laboratory and field conditions, including the residues within the pollen and nectar of mass flowering crops.

6. Improve product labelling - Labelling regulations for pesticides should be improved to include more specific recommendations which account for the seasonal activity patterns and nesting habits of on-farm taxa, based on up to date ecological information, and extend these standards to non-agricultural pesticides i.e. use in gardening, domestic and horticultural settings.

7. Improve the National Pesticides Action Plan - The National Pesticides Action Plan being produced by the Government by 26 November 2012 should commit to protecting nature and public health through the sustainable, phased reduction in the use of pesticides with quantitative targets for the reductions in the total application of all pesticide active ingredients; the Plan should also encourage, support and incentivise the take up of alternative methods of pest management.

Submission response

1. The use (or abuse) of evidence in this particular case, for setting policy and regulations on pesticides.

Friends of the Earth consider that the September 2012 decision of the Government to delay taking action in response to the mounting evidence of harm to bees and other pollinators from the use of neonicotinoid insecticides does not represent good use of science, sound interpretation of the precautionary principle and adequate action commensurate with public concern about the threat to British bees and other pollinating insects.

Government statements to the effect that products are safe appear premature when considerable gaps exist in its own knowledge about the safety of products containing different chemicals – including neonicotinoids - whether in commercial farming, horticulture or domestic gardening settings. For example, at a 25 January 2011 Westminster Hall debate, Lord Henley, then Defra Minister, stated, "In the UK, neo-nicotinoid insecticides are used primarily in commercial agriculture and horticulture production. Only a very small proportion is used in home garden products so the potential risk to bees, if any, from this type of product is negligible." (Hansard Citation: HC Deb, 25 January 2011, c67WH) It is hard to see how such statements can be sustained when neonicotinoids are prevalent in 20 or so chemical applications intended for use by gardeners as well as being pre-applied to most seeds and also to plant pots. All of these are available over the counter from garden centres.

The Government’s neonicotinoids review acknowledged that the recent independent studies present evidence of harm in laboratory conditions and decided that more research is needed in field conditions. The review acknowledged that there are significant gaps in the Government’s understanding of the impacts of treatments on solitary and bumble bees - the majority of bee species - and indicated the need for more research is needed.

Friends of the Earth do not dispute the value of more research especially where there are significant gaps in understanding about actual levels of exposure and about the potentially different impacts on different bee species. But conducting further research is not in itself a reason to delay action. The Government has undertaken a process of scientific evaluation and has concluded that scientific uncertainty remains. This uncertainty should support and prompt, not rule out, a precautionary approach. Gaps in the Government’s knowledge were also listed in the FERA paper for EFSA [1] which suggested that there are other routes of exposure for bees which are not currently considered such as dust during the sowing of seeds pre-coated with neonicotinoids and residues in water sources.

If harm is being done to bees then the costs of inaction are likely to be considerable, including financially. Pollination by bees has also been shown to be important to the quality of the produce that is sold to consumers. And insect pollinators are also important in wider biodiversity as they pollinate the plants that other species rely on for food and shelter. The University of Reading has calculated that it would cost UK farmers at least £1.8 billion a year to replace the services of bees and other pollinators with hand pollination. The recent review looked mainly at research into chemical effects on managed honey bees. This is in keeping with the Government’s tendency to talk mainly about honey bees and to fund research accordingly. Despite receiving far less attention Britain’s native wild bees are even more important pollinators of food crops than managed honey bees.

As the negative impact of the continued use of neonicotinoids could be irreversible, the Government should not seek to rely on the lack of full scientific certainty as a reason for delay (Article 15 of the Rio Declaration). A suspension of neonicotinoid products with most evidence of harm while further research is carried out, and regulations amended, would be entirely plausible for the Government in keeping with robust science, proportionate action and the precautionary principle.

Shortly after the publication of the Government review a further study (part funded by Defra) provided more worrying evidence of potential harm to bumblebees at realistic levels of pesticide exposure and exposed another flaw of the approvals system - that the combined effect of pesticides is not taken into account. The authors made the following points about the research:

"Currently pesticide usage is approved based on tests looking at single pesticides. However, our evidence shows the risk of exposure to multiple pesticides needs to be considered, as this can seriously affect colony success," Dr Raine.

"The novelty of this study is we show how the sublethal effects of pesticide exposure affects individual bee behaviour with serious knock-on consequences for the performance of the colony as a whole," Dr Gill.

The Government’s response to this new evidence is awaited.

1.7 A wider failure to set policy for pesticides of concern is apparent in the draft National Action Plan on pesticides – the consultation period for which closed on 22 October. The UK is due to submit a National Acton Plan to the EC by 26 November 2012 as required by the Sustainable Use Directive (SUD). The SUD requires member states to include in their NAPs targets to cover particular areas of concern which could include environmental protection, worker protection, or use in specific crops. The SUD sets out that member states should monitor use of pesticides of particular concern, especially if alternatives are available, and set reduction targets. Currently the draft UK NAP does not do this. We should be pleased to furnish the Committee with a copy of our consultation response to the Government’s draft National Pesticides Action Plan.

2. The application of real-world – ‘field’ – data. What monitoring there is of actual – rather than recommended – levels of pesticide usage, and the extent to which that influences policy on pesticides.

2.1 Research by the University of Reading [2] for Friends of the Earth highlighted the worrying increase of pesticide use on crops which rely especially on bees for their pollination:

"In general, more insecticide treatments are applied per hectare in oilseeds and fruit crops than cereals, increasing the risk of exposure to bees."

For example, FERA’s data shows that between 2005 and 2010 rates of insecticide application rates rose by 26% on oilseeds and by 295% on strawberries. Since the testing regime for chemicals excludes the effect on wild bees the effect of these considerable rises in chemical use is unknown.

2.2 Understanding of the exposure of bees and other pollinators would rise significantly if research were carried out to monitor the actual presence of neonicotinoid insecticides in nectar crop pollen, nectar, foraging bees (including bumblebees and solitary bees), stored pollen and honey.

3. Potential impacts of systemic neonicotinoid insecticides on human health.

3.1 It appears that studies into the effects of systemic neonicotinoids on human health are another area where research has been lacking. Studies include those by Barouki et al. Environmental Health 2012, 11:42 and Kimura-Kuroda J, Komuta Y, Kuroda Y, Hayashi M, Kawano H (2012) Nicotine-Like Effects of the Neonicotinoid Insecticides Acetamiprid and Imidacloprid on Cerebellar Neurons from Neonatal Rats. PLoS ONE 7(2): e32432. doi:10.1371/journal.pone.0032432

As with any chemical treatments, there is certainly a need to fully understand the level of human exposure through food residues and use of chemicals in or near to public places such as parks, open spaces, streets and drainage systems. The same concerns apply about understanding how mixtures of chemicals could affect human health and the long term impact of low level exposures.

4. What alternative pest-control measures should be used, such as natural predators and plant breeding for insect-resistance, in a bid to make UK farming more insect- and bee-friendly?

4.1 Expanding pollinator habitats and food sources such as flowering margins and hedges could also help to encourage natural predators of pests, reducing the need for insecticides. Crop rotations, especially incorporating legumes which are attractive to bees, would improve the diversity of flowering crops as well as building soil quality and reducing pest pressure.

4.2 Better monitoring of pests and more accurate forecasts of pest attack could also help to reduce the need for pesticide use. Seed treatment with neonicotinoids is now routine practice and it would be hard for farmers to purchase non treated conventional oilseed rape seed if they wanted to. Packets of seeds sold in garden centres are also pre-treated in this way.

4.3 More support for organic farming would help to reduce reliance on pesticides. But all farmers should be supported and encouraged to use Integrated Pest Management (IPM) techniques and the Government should have set out how it would do this in its National Pesticides Action Plan to assist the phased reduction in the reliance on chemical pesticides as part of reducing risks to public health, not to mention the financial cost to farmers.

4.4 The SUD requires that member states should "take all necessary measures to promote low pesticide-input pest management, giving wherever possible priority to non-chemical methods". Objectives, targets and timetables should be put in place. IPM should be at the heart of the plan. The widespread adoption of IPM techniques has the potential to achieve a real shift towards more sustainable farming practices that are insect and bee friendly and could also help farmers to reduce costs and overcome problems of pesticide resistance.

4.5 The draft UK Pesticides Action Plan is very weak in this area and it suggests that many pesticide users already follow the principles of IPM. In fact research in the UK part funded by Defra found that most British arable farmers only use a limited number of IPM techniques [3] . As effective IPM cannot be delivered by adoption of one or two techniques in isolation there is a need for a clear definition of what constitutes IPM and a commitment to supporting farmers to build on and add to the techniques they adopt.

4.6 Avoiding the use of pesticides in parks, school grounds and other public places should also be an aim of the Government in the NAP. Other cities such as Toronto and Paris have managed to go pesticide free or significantly reduce the use of pesticides. In the UK Eastbourne Borough Council [4] recently committed to reducing pesticide use in its parks and gardens. The UK Government should draw on this experience and offer leadership and guidance on this issue to all local authorities.

5 November 2012

[1] Thompson, H (2012) Interaction between pesticides and other factors in effects on bees FERA 1


[2] Breeze, T, D, et al (2012) The Decline of England’s Bees : Policy Review and Recommendations



[3] Rural Economy and Land Use Programme (RELU) 2009 “Overcoming market and technical obstacles to Alternative Pest Management in Arable Systems”



Prepared 19th November 2012