Bees And Neonicotinoids - Please Write to EU Commissioner Borg

On the 29th April 2013, EU member states will vote once more on whether to restrict use of just 3 of the neonicotinoids.  It is a small but important step.  Some countries voted against the restrictions last time, and it is expected that some will do so again. Here is a letter to encourage EU Commissioner Borg to act to uphold EU Law, and to continue to apply pressure on EU member states.


Please send this letter to Commissioner Borg

tonio.borg@ec.europa.eu



Dear Commissioner Borg


Firstly I would like to thank you for your efforts to date with regard to the securing of restrictions to the use of 3 neonicotinoids, to help protect bees and other pollinators.

As the next vote is shortly upon us (on 29th April) I write to impress upon you the following:

1. It is the responsibility of the Commission to ensure member states uphold EU law. EU Regulation 1107/2009 (Annex II, 3.8.3.) states (1): 

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.”

It is clear from EFSA investigations that at least 3 neonicotinoids (imidacloprid, clothianidin and thiamethoxam) should not have been authorised and are currently on the market illegally.  EU states must surely withdraw them from sale pending submission of a full and complete assessment dossier.  It should be noted that honey bees are one of a myriad species, selected to represent not only pollinators but also non-target invertebrates, regardless of whether or not they visit flowering crops.

2. The UK government has advocated the need to wait for its own field studies, and this data has now been entered onto the UK DEFRA website (Thompson et al (2)).  This flawed study provides no justification whatsoever to delay a ban.  The study had no control, statistical information were omitted from public scrutiny, it has not been peer reviewed and has been heavily criticized by independent scientists(3).  Furthermore, it is inconsistent with findings of the UK Environmental Audit Committee inquiry, published earlier this year(4).

3. Given the initial interrogation of the Risk Assessment standards by EFSA in May 2012 (5), it is clear that regulatory tests were inadequate for assessing systemic insecticides.  In light of this, I ask that (in addition to the impending EFSA assessment of Fipronil), the remaining neonicotinoids be assessed with urgency and to at least the same standard and independence, and that neonicotinoids and systemic insecticides with authorisations impending, be immediately delayed until EFSA can be certain that they meet completely the requirements of the law.

4. Millions of EU citizens have repeatedly expressed their support for a ban on neonicotinoids.  No government or corporation should be above the law, nor the rights and wishes of the citizens, including those enshrined in the Aarhus Convention, which: links environmental rights and human rights. It acknowledges that we owe an obligation to future generations. It establishes that sustainable development can be achieved only through the involvement of all stakeholders. It links government accountability and environmental protection” (6).

Again, I wish to emphasize that I fully support your actions to protect pollinators, and to encourage you to exert full pressure on Member States to uphold the law.  The restrictions proposed thus far, are more than a generous compromise that favours corporation far more than pollinators, the environment and citizens, for allowing some continued use of a poison that has no legal right to be on the market, and for which no evidence-based justification can be found.

 

Yours sincerely

 

 

(1)  http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:309:0001:0050:EN:PDF

(2)  https://www.gov.uk/government/publications/an-assessment-of-key-evidence-about-neonicotinoids-and-bees

(3)  One example:  http://www.the-scientist.com/?articles.view/articleNo/35058/title/A-Political-Battle-Over-Pesticides/

(4)  http://www.publications.parliament.uk/pa/cm201213/cmselect/cmenvaud/668/66802.htm

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

(6) Aarhus Convention: http://www.unece.org/fileadmin/DAM/env/pp/acig.pdf



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