EDM 2664 Follow Up Letter



Hence, the letter below has now been adapted:

Dear MP and Sir Robert (robert.watson@defra.gsi.gov.uk) (Find Your MP Here - opens a new window)


I am writing to urge you to ban neonicotinoids in light of the recent evidence from Stirling University and France, and in line with EDM 2664, tabled by Martin Caton MP.

I would also ask you to urgently review the regulatory system for pesticides, and would like to point out a number of misconceptions with regard to the regulatory system and the handling of this issue to date, which are as follows:

Misconception 1: “The UK has a robust system for assessing risks from pesticides”
This is frequently stated by the government, but the message will simply not ‘stick’ because it is untrue:

    1. Like other pesticide regulatory bodies across Europe, the UK system is constantly behind the innovation of the pesticides industry, and currently, it is failing to adequately assess the impact of these persistent (not easily degraded), and mobile neurotoxins.

    2. The system fails to consider cumulative effects of pesticides: build up of tiny amounts of these insecticides in soil and water over time –as stated, these chemicals persist (i.e. they are not easily degraded), and can then be taken up by plants and invertebrates. In other words, there is a risk that at some point, the residual concentrations of neonicotinoids in the environment could eventually build up beyond the original recommended application level!

    3. The system does not consider the fate of these pesticides in the environment and possible outcomes, not to mention the rights of organic farmers and gardeners, as well as protected and vulnerable environments (including water ways) that could suffer trespass from these chemicals given their mobility in soil, water and ground water.

    4. There is a lack of consideration for the impact of these pesticides when combined with other chemicals in the soil and water: such as other pesticides, fertilisers, herbicides and other possible water treatments and common contaminants.

    5. The regulatory system fails to take account of the resulting broader impact on the wider environment of killing non-target insects (fewer than 1% of insect species are “crop pests” (1)). For example, the percentage declines that might be expected on various species through the food chain (such as insect/invertebrate-eating farmland birds, already exhibiting worrying levels of decline), and the effects of toxin build up, are not considered.

    6. Scientific evidence in support of pesticides is not independently and publicly available for review prior to marketing authorisations being granted.

Misconception 2: “At present all evidence shows neonicotinoids do not pose an unacceptable risk when products are used correctly”.

    1. The regulatory system for pesticides does not adequately define the parameter of acceptable risk in terms of the broader impact on the environment – in other words, it does not define “acceptable risk” in relation to the points 2, 3, 4, and 5 noted above.

    2. Significant and compelling evidence (see below) indicates that even when applied correctly, and at the correct dose, neonicotinoid pesticides are toxic for bees. The regulatory system does not adequately monitor the impact of sub-lethal doses and chronic and sub-lethal effects (tiny amounts that impair normal function, ultimately resulting in death and demise of the insect and possibly colony - even if not immediately).

      In assessing risk in the environment, the Hazard Quotient is used to determine acute toxicity. However, this approach is completely inappropriate to assess chronic toxicity, sub-lethal effects and chronic effects. In addition, the system only considers the impact on honey bees. Where pesticides cause chronic effects, they not only affect honey bees: the impact on non-domesticated wild species could pose a very significant threat. A number of important studies have been produced highlighting chronic and sub-lethal effects of neonicotinoids not only on honey bees, but also on wild species. A study by Mommaerts et al showed that “concentrations [of neonicotinoids] that may be considered safe for bumblebees can have a negative influence on their foraging behavior. Therefore it is recommended that behavior tests should be included in risk assessment tests for highly toxic pesticides because impairment of the foraging behavior can result in a decreased pollination, lower reproduction and finally in colony mortality due to a lack of food”(2).

      Take into account that in bumblebees, few colonies are successful (studies indicate approximately 13.8% - 28% success rate for wild bumblebee colonies(3)).

    3. Unless data supplied by manufacturers is not automatically open to public scrutiny, and independently qualified prior to the granting of marketing authorisations, how can we be confident in the validity of the data used to assess the pesticides for ‘acceptable/unacceptable’ risk?

Misconception 3: Ministers will not hesitate to act however if presented with any new evidence.
The Civil Servants Code Of Practice, states: (Point 10): “You must not ignore inconvenient facts or relevant considerations when providing advice or making decisions”.

Despite the fact that significant evidence has been supplied through the years indicating the dangers of neonicointoid pesticides and deficiencies of the regulatory system, it seems the Precautionary Principle has been ignored. How many quality independent scientific papers do the government require? Meanwhile, let me remind you that even the EPA referred to some of the evidence submitted by Bayer in support of the Clothianidin registration as “supplemental”. This situation simply CANNOT continue!

    1. The paper quoted previously by Mommaerts et al of 2010 (but published online in 2009) was edited by Dr Helen Thompson of Fera! Why has no action been taken against neonicotinoids, to protect wild species such as bumblebees? Whilst we can continue to breed the domesticated honey bee, we cannot begin to breed one of every single invertebrate species these chemicals are putting at risk!

    2. A paper by Halm et al (2006)(4) states: “The procedure to assess the risk posed by systemic insecticides to honey bees follows the European Directives and depends on the determination of the Hazard Quotient (HQ), though this parameter is not adapted to these molecules”.

      It goes on to explain how the Hazard Quotient used within the regulatory system to assess toxicity to honey bees only considers spray applications of pesticide, whereas neonicotinoids may be applied to soil or seeds. They then act systemically, permeating the whole plant, and contaminate nectar and pollen. They persist in soil for years (according to Bonmatin et al, even after application has ceased), and can be taken up by successive plantings. Halm et al proposed a new system of assessing pesticides, based on the European Technical Guidance Directive (TGD) that assesses the impact of new (793/93 and 1488/94/CE legislations) and existing chemical substances (EC-67/54/8 and EEC-93/67 Directives) on ecosystems. The study also highlighted that the neonicotinoid posed a high risk for all categories of honey bees – especially hive bees. Why has Defra not taken action to strengthen the regulatory system? I would suggest to you that given the persistence in the soil, we cannot wait for European developments in order to protect our own ecosystem, and I note the very strong agrochemical lobby operates on an EU level.

    3. Here is a list of only some of the additional independent evidence (regarding the dangers of neonicotinoids to bees and inadequacies of the regulatory system), that have been produced since the initial evidence was presented in the Buglife report of 2009, and yet contrary to the notion that “Ministers will not hesitate to act however if presented with any new evidence” This evidence has been ignored thus far:

      Links between nosema, neonicotinoids and nosema in bees:

      - Cédric Alaux et al: Interactions between Nosema microspores and a neonicotinoid weaken honeybees (Apis mellifera) – Published 2009; Environmental Microbiology.

      - Cyril Vidau et al: Exposure to Sublethal Doses of Fipronil and Thiacloprid Highly Increases Mortality of Honeybees Previously Infected by Nosema ceranae - Published 2011; PLoS ONE

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

      - Judy Y. Wu et al: Honey bees (Apis mellifera) reared in brood combs containing high levels of pesticide residues exhibit increased susceptibility to Nosema (Microsporidia) infection; Published January 10 2012; Journal of Invertebrate Pathology.

      Additionally, the Bayer Premise 200SC leaflet admits that imidacloprid makes pathogenic soil fungi 10,000 times more dangerous to termites (social colony insects, like bees).

      27. The final results of a 2 year project by FERA were published (2007 - 2008), and indicate that 45% of the colonies had nosema – 8% of which had 2 strains:


      Other important research papers:

      - Henk A. Tennekes: The significance of the Druckrey–Küpfmüller equation for risk assessment—The toxicity of neonicotinoid insecticides to arthropods is reinforced by exposure time. Published 2010; Toxicology.

      - Schneider et al: RFID Tracking of Sublethal Effects of Two Neonicotinoid Insecticides on the Foraging Behavior of Apis mellifera: Published January 2012; PlosOne.

      - V. Girolami et al: Translocation of Neonicotinoid Insecticides From Coated Seeds to Seedling Guttation Drops: A Novel Way of Intoxication for Bees: Published 2009; Entomological Society of America.

      - Mommaerts et al: Risk assessment for side-effects of neonicotinoids against bumblebees with and without impairing foraging behaviour. Published 2010, Ecotoxicology.

      - Krupke et al: Multiple Routes of Pesticide Exposure for Honey Bees Living Near Agricultural Fields – (Field Study) - Published January 3, 2012; PlosOne.

      - Andrea Tapparo et al : Assessment of the Environmental Exposure of Honeybees to Particulate Matter Containing Neonicotinoid Insecticides Coming from Corn Coated Seeds – Published January 31, 2012; Environmental Science And Technology.

      - Johnson RM et al: Ecologically Appropriate Xenobiotics Induce Cytochrome P450s in Apis mellifera (Honey diet promotes better detoxification of poisons in honeybees than sugar diet – unless those poisons are imidacloprid or tau-fluvalinate) – Published February 3, 2012: PLoS ONE 7.

      - Tennekes HA, Sánchez-Bayo F: Time-Dependent Toxicity of Neonicotinoids and Other Toxicants: Implications for a New Approach to Risk Assessment. J Environment (Current toxicological risk assessment can lead to serious underestimates of actual risk of neonicotinoids); Published December 07, 2011: Environmental & Analytical Toxicology.

To state that the conclusion from the Buglife report was that it highlighted the need for more data on overwintering bees (as implied by Fera and the ACP) is very far from the truth – the report went significantly beyond that, highlighting in 2009 the need for changes to the pesticides regulatory system, and broader consideration of the impact of neonicotinoids and Fipronil on the wider invertebrate population, such as wild pollinators. (That said, when will these studies investigating risk to overwintering bees be published and available for public scrutiny?).

Civil servants have a duty to consider the strength of this independent evidence as well as its quality, and also to heed the Precautionary Principle which is enshrined in Directive 91/414 which states that “Member States shall ensure that a plant protection product is not authorized unless…..it has no unacceptable influence on the environment.” “Authorizations may be reviewed at any time if there are indications that any of the requirements….are no longer satisfied.”

I urge you to ban neonicotinoids immediately and to urgently address the inadequacies of our pesticides regulatory system.

Yours sincerely

(1)The vast majority of insect species are actually harmless or beneficial. Around a million insect species have now been discovered: http://www.environment.gov.au/biodiversity/abrs/publications/other/species-numbers/2009/03-exec-summary.html#invertebrates. Meanwhile, according to the British Natural History Museum, Globally, “Only 1000 species of insect are considered to be agricultural pests. Each year they destroy between 10 and 15 percent of the World’s agricultural produce” – and according to the UN, we waste a THIRD (33.333%) of food produced globally EVERY YEAR – mostly in the West.

(2) Mommaerts et al: Risk assessment for side-effects of neonicotinoids against bumblebees with and without impairing foraging behaviour. Published 2010, Ecotoxicology.

(3)Dave Goulson: Bumblebees Behaviour And Ecology, p 6.

(4) Halm et al “New Risk Assessment Approach for Systemic Insecticides: The Case of Honey Bees and Imidacloprid (Gaucho)” (Environ. Sci. Technol. 2006, 40, 2448-2454) published in 2006.

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