In the UK, we are constantly told that field studies for pesticides offer the favoured and realistic method of assessing risk of pesticides to bees. In contrast, doubt is often cast over independent laboratory studies.
On 13 September, Defra published an analysis of the results of its review of research done earlier in the year on the effects of neonicotinoid pesticides on bees. DEFRA is the UK Department For Environment, Food And Rural Affairs. It relies on various departments to conduct different aspects of services that inform and support DEFRA, and two of these departments include FERA (Food And Environment Research Agency) and CRD (Chemical Regulations Directorate).
I read the report, and it was clear there was a regular theme running through the comments that CRD made with regard to the independent scientific studies, some of which were laboratory studies. I have included them on the right.
Can you spot the recurring theme?
Well, it seems at least Bayer Cropscience would agree with CRD. They also seem very keen to suggest that what is important is ‘What’s happening in the field” as demonstrated in their response to the Pettis study (below).
So one wonders:
"just how good are regulatory field tests for pesticides, and do they protect our bees?"
Aside from the fact that some of the studies featured right, were at least partial field studies anyway, nowhere that I am aware of, do FERA/CRD/DEFRA justify:
…Afterall, their report also states:
Well, EFSA, the
European Food Standards Authority, despite various controverial influences from industry, conducted a review: 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), and they have found
many MAJOR weaknesses with the regulatory standards for the field tests for pesticides.
But this did not surprise me, having read the guidelines myself. The field test guidelines EPPO170 are devised, it appears, by a group of pesticide manufacturers and those related to the industry (e.g. providing consultancy services), as well as a sprinkling of government civil servants, such as Helen Thompson and Selwyn Wilkins of FERA.(see work of the EPPO - opens new window).
Note the quote:
"At the ICPBR- Bee Protection Group 10th Symposium (Bucharest, 2009-10-08/10.....the WGs (working groups) presented proposals for the revision of EPPO Standards, which were discussed in order to hear the expert comments and recommendations of all 79 participants and to reach a consensus."
(see pages 158 -159 - opens new window).
So who were the 79 participants? They were mostly industry related people.....
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“Due to the artificiality of the test design and dosing regime, there are uncertainties regarding the risk in a more realistic field exposure situation”.
“The key question for this study is how far it illuminates the likely real situation at field level - are the exposure and the resulting effects seen under normal conditions?”
“The following points require consideration in trying to interpret this study: whether factors such as exposure are in line with field situations”.
“The key issue is how this relates to potential exposure under field conditions – i.e. will bees be exposed to this level of pesticide under field conditions?”
“There is no information regarding the relevance of the concentrations given to the bees – i.e. were the levels appropriate and/or realistic?”
"It is unclear as to the relevance of the concentrations tested and hence whether the results can be extrapolated to the field situation”.
“the issue of detoxification and the relevance of diet should be considered under realistic field conditions.”
“the next logical step would be to employ this methodology at the field scale to see if the effects observed in this study were replicated under field conditions”.
“As regards the effects seen, it is important to note that they need to be related to what is likely to be encountered either in the hive (i.e. were the rates used realistic in terms of exposure to tau-fluvalinate) or in the field (i.e. were the rates used realistic in terms of what a worker honey bee is likely to encounter in the field.)”