Are Neonicotinoids Even Legal?
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Considering the serious deficiencies of regulatory guidelines for testing pesticides on honey bees, the public have every right to challenge whether or not neonicotinoids are legally registered for use. If manufacturers' evidence is based on those flawed guidelines and does not robustly prove 'no unacceptable risk' in accordance with the law, then they may have been brought onto the market illegally.


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Dear MP (find here -opens new window).

I am writing to ask you to forward my concerns about the legality (or possible illegality) of neonicotinoid pesticides, to Lord de Mauley, Parliamentary Under-Secretary of State for Resource Management, and Owen Paterson, Secretary of State for Environment, Food and Rural Affairs.

1. EU Regulation 1107/2009 (Annex II, 3.8.3.) states: “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.”

As you are aware, EFSA found many weaknesses in the standards for testing of pesticides on honey bees for the purpose of Risk Assessment(1). These weaknesses included: unsuitability for testing systemic pesticides such as neonicotinoids, inadequacy for testing behavioural, chronic and sub-lethal effects, potential colony effects not adequately measured, testing on honey bee larvae inadequate (among many other serious flaws).

Thus, when DEFRA stated that data submitted by the manufacturers to support pesticide registrations, complied with EU/international test guidelines for pesticides, this did not mean it was enough to ensure the pesticides are legal since those guidelines were inadequate!

If even one element from EU Regulation 1107/2009 (Annex II, 3.8.3.) is not robustly addressed within the data, then surely their use should not be permitted, since they have not been properly assessed for ‘acceptable risk’.

2. A further report by EFSA of 16th January has now confirmed that indeed, there are shortcomings with data supporting registrations for neonicotinoids:

"EFSA identifies risks to bees from neonicotinoids"(7) and the report states:

  • "In some cases EFSA was unable to finalise the assessments due to shortcomings in the available data."
  • "All of these factors mean that EFSA’s scientists were unable to finalise risk assessments for some of the uses authorised in the EU, and identified a number of data gaps that would have to be filled to allow further evaluation of the potential risks to bees from clothianidin, imidacloprid and thiamethoxam. Finally, it is highlighted that limited information was available for pollinators other than honey bees; therefore the risk to these other pollinators should be further considered."
  • “Only uses on crops not attractive to honey bees were considered acceptable”:

I am specifically concerned that even restricting neonicotinoid use to non-flowering crops, would not provide sufficient protection for other non-target species that may visit them, such as butterflies and beetles.

Pesticide risk assessment already conducts tests on very few species, which are meant to be representative for invertebrates as a whole.  As it is, assessment only requires that pesticides are tested on:

-          Daphnia magna (water flea)

-          Apis mellifera (honey bee)

-          Earthworms

-          As well as 4 further species (according to the Chemicals Regulation Directorate “DATA REQUIREMENTS HANDBOOK”- Version 2.2, June 2012)

Thus, perhaps EFSA have failed to take into account that testing on honey bees may be assumed to safeguard butterflies (which do not only visit flowering crops), hoverflies, lady birds, lacewings and a range of other species whether or not they forage on flowering crops – indeed, various species may inhabit areas around foliage crops, for example.  I am not aware of EFSA examining the data on the other species, as they have for honey bees.  Therefore, I am concerned that it is not safe to simply assume that restriction of application of neonicotinoids to non-flowering crops, would be sufficient to protect other non-target invertebrates.


In addition to which, if is not possible to complete risk assessment for any chemical, for the whole range of species in all areas, how can it be legal?

3. If they are illegal, I think our regulatory departments need to be put under serious scrutiny for not ensuring the UK complies with regulations, and that bees and the environment are protected – and especially considering that there are senior FERA staff who are part of the EPPO ICPBR panel which has played a major role in formulating the deficient guidelines for testing pesticides on honeybees(2).

4. I note that DEFRA claim that manufacturers are now required to submit data on over-wintering bees. In 2003, Helen Thompson, a FERA scientist, published a paper: Thompson, H.M (2003) Behavioural effects of pesticides in bees – their potential for use In risk assessment Ecotoxicology 12 317-330 in which she stated: “longer term consequences of sublethal changes in colonies e.g. over-wintering survival, should also be assessed”.

(This issue (overwintering bees) was also noted in response to the Buglife report of 2009). Despite this being raised in 2003, I am not aware of any study undertaken by FERA in this area. Whilst data may have been more recently demanded from manufacturers, if the tests are based on the exceedingly flawed methodology advocated in the aforementioned guidelines, then we may seriously doubt the robustness of the data produced. In addition to which, the regulatory standards for tests ignore synergistic relationships between pesticides and diseases, even though this issue is clearly recognised by manufacturers (e.g. Bayer CropScience claim their neonicotinoid imidacloprid in Premise 200 SC, makes pathogenic fungi 10,000 times more dangerous to termites, which are social colony insects like honey and bumblebees(3)). Even if disease were to be noted by our regulators, I am concerned they would not identify any link between the pathogen and the insecticide, especially given findings by Pettis et al regarding subsequent undetectability of neonicotinoid pesticides: The finding that individual bees with undetectable levels of the target pesticide, after being reared in a sub-lethal pesticide environment within the colony, had higher Nosema is significant”(4).

5. I note the most recent EU report  "Existing Scientific Evidence of the Effects of Neonicotinoid Pesticides on Bees" also concludes that neonicotinoids should be banned in line with the Precautionary Principle(5).

6. I would also like to take the opportunity to remind Mr Paterson and Lord de Mauley that neonicotinoids are more toxic for bees than DTT, with imidacloprid at 7279 times more toxic for bees, and the UK’s most widely used neonicotinoid (clothianidin) being 6750 more toxic for bees than DDT(6).

I hope Mr Paterson and Lord de Mauley will agree with me that whilst environmental monitoring is wise, it is not the tax payer’s job to compensate for lax regulatory standards, by providing anecdotal evidence of any kind regarding the impacts of chemicals on the environment and the species it supports (despite the plethora of independent science highlighting the risks of neonicotinoids to non-target species). If neonicotinoids do not fulfil requirements of EU law, and are therefore illegal, they must be banned, not later, or ‘pending more evidence’ but immediately.

Thank you for your assistance,

Yours sincerely


REFS:

(1) http://www.efsa.europa.eu/en/efsajournal/pub/2668.htm

(2) The ICPBR ‘Bee Protection Group’ (which “provides the technical input for both EPPO Standards” see - http://www.eppo.int/PPPRODUCTS/honeybees/honeybees.htm)

(3) “Imidacloprid makes fungi 10,000 times more dangerous to termites. Nature assists imidacloprid in giving unsurpassed control. This control is called Premise 200SC plus Nature." http://www.elitepest.com.sg/brochure/Premise_200SC.pdf

(4) Jeffery S. Pettis et al: Pesticide exposure in honey bees results in increased levels of the gut pathogen Nosema – Published 2011; Naturwissenschaften

(5) "Existing Scientific Evidence of the Effects of Neonicotinoid Pesticides on Bees" http://www.europarl.europa.eu/committees/en/studiesdownload.html?languageDocument=EN&file=79433

(6) van Dijk 2010 Effects of neonicotinoid pesticide pollution of Dutch surface water on nontarget species abundance (Citing Bonmatin, published 2009) http://www.moraybeedinosaurs.co.uk/neonicotinoid/Effects1.pdf

(7) "EFSA identifies risks to bees from neonicotinoids" http://www.efsa.europa.eu/en/press/news/130116.htm?utm_source=homepage&utm_medium=infocus&utm_campaign=beehealth




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