AND EDM 1267

This is a letter from 2011 in response to arguments used against banning neonicotinoids and a EDM 1267.

EDM 1267 was a motion tabled to the UK parliament by Martin Caton MP, as follows:


"That this House is gravely concerned by the contents of a recently leaked memo from the the US Environment Protection Agency whose scientists warn that bees and other non-target invertebrates are at risk from a new neonicotinoid pesticide and that tests in the US approval process are insufficient to detect the environmental damage caused; acknowledges that these findings reflect the conclusions of a 2009 `Buglife' report that identified similar inadequacies in the European approval regime with regard to neonicotinoids; notes reports that bee populations have soared in four European countries that have banned these chemicals; and therefore calls on the Government to act urgently to suspend all existing approvals for products containing neonicotinoids and fipronil pending more exhaustive tests and the development of international methodologies for properly assessing the long-term effects of systemic pesticides on invertebrate populations."

Various politicians argued against the EDM.  Here is a rebuttal of the arguments generally put forward against the EDM.

The item remains a useful reference in 2015, although the issue has moved on at the time of writing.

See below for further information.

Dear MP


The EDM acknowledges the report by Buglife (2009) (1) which concludes that our regulatory system is inadequate for the assessment of this group of pesticides.

Indeed, there is significant and serious doubt that these pesticides are safe, yet I am aware of a number of erroneous arguments opposing this motion:

1. The Buglife report, 2009 has been examined by the Advisory Committee on Pesticides/DEFRA . Given the evidence, there is no need to change the system that regulates pesticides.

a. The Advisory Committee on Pesticides have examined the Buglife report (2).

This document appears to completely ignore very relevant (and difficult/impossible to refute) data contained within the Buglife report.

It actually fails to address the key points made and instead, focuses on scenarios primarily concerned with ‘mistakes’ made during application, or what they consider to be “unlikely” scenarios (without justifying how they came to these conclusions).

Additionally, they have not justified why or how they can consider the regulatory system to be acceptable, when it fails to require sensitive and specific data that:

    - Considers cumulative effects: build up of tiny amounts of these insecticides in soil and water over time – note these chemicals persist (i.e. they are not easily degraded), and can then be taken up by plants and invertebrates

    - Considers the fate of these pesticides in the environment and possible outcomes: these chemicals are mobile in soil and water

    - Considers 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

    - Considers the resulting broader impact on the wider environment of killing target and non-target insects: such as the percentage declines that might be expected on various species through the food chain, and resulting consequences, and as a result of toxin build up.

b. A response to the report by Defra (3) is exceedingly weak. There are too many weaknesses to mention here, however, a very key and serious deficiency in Defra’s response is that they have failed to justify why they have not applied the ‘Precautionary Principle’ in accordance with EU Directive 91/414(4).
Defra state that these chemicals do not pose ‘unacceptable risk’. However, Defra do not define how they measure this risk specifically, such as, with regard to water and soil; for example:

    - the PRECISE measures (exact concentration specifications) that are used for the assessment of ‘acceptable risk’ for water and soil contamination,
    - the PRECISE measures that consider the impact of combinations of chemicals and pesticides in the environment.
    - how this risk is continually and systematically monitored, and by what standards and guidelines.

Yet at minimum, this is what the tax payer should expect from an organisation such as Defra. If Defra deny that they have failed to heed the ‘Precautionary Principle’, then let them immediately provide details of how ‘unacceptable’ and ‘acceptable risk’ are quantified, how these measures were determined, who was involved in defining them, and details of how it is monitored.

Should Defra propose that measuring and monitoring risk is NOT their responsibility to execute, then on whom have they offloaded this responsibility, how are Defra controlling it, against which guidelines and measurements, and who is ultimately paying for this service?

As stated, it would be too time consuming to outline every inadequacy in Defra’s response to the Buglife report. Many of these are technical points (for further information, please contact Buglife directly).

2. There is no evidence that a ban on these chemicals has resulted in soaring bee, and other pollinator and insect populations elsewhere.

a. Evidence of this is not actually required. It is not the responsibility of society to provide anecdotal evidence of any kind at all. It is the responsibility of the company to prove their products are safe prior to marketing authorisation being granted, and there is significant doubt that they are – and that they ever were.

b. These chemicals persist in soil. Research conducted in the field by J Bonmatin et al (5) for the French Ministries of Agriculture showed that even when usage of a neonicotinoid had ceased, 2 years later (the duration of the experiment) the chemical was taken up from the residues in the soil, and became available to bees in the flowers, at toxic levels.

c. This is an exceedingly complex situation, because the use of these pesticides does and is occurring in tandem with habitat destruction. The suspension of harmful pesticides, must be accompanied by adequate habitat for species to thrive.

d. Despite various EU initiatives, there are no well-established, EU-wide, uniform, systems for measuring impact on wild and domestic species, although in the case of honey bees, it was beekeepers who drew attention to bee deaths on a major scale, following the introduction of a neonicotinoid, Imidacloprid, in France in 1995(5).e. In actual fact, no country has imposed a complete ban on all neonicotinoid pesticides, and where some neonicotinoids have been restricted, others have merely taken their place.

3. There is insufficient field-based data to justify a suspension of neonicotinoids.

a. This argument is ironic given that insufficient data was required for the authorisation of these chemicals in the first instance – see point 1a and 1b above.

b. Further, Bayer’s own studies have been found deficient, not only by the EPA(6), but also by other (independent) scientists. For example, the Bonmatin et al study (4) was an important field study. It makes reference to research by Bayer Cropscience scientists (Placke & Weber 1993), which indicated there were no traces of imidacloprid in sunflowers that were raised from Gaucho® (Imidacloprid) dressed seeds. However, Bonmatin et al make the point that the methods used by Bayer only allowed quantification from 20-50 microgramms per kilogram, whilst neglecting to measure levels lower than this, but that have been found to be toxic to bees.

c. There is significant independent published, peer reviewed, laboratory evidence, as well as analytical evidence, to raise doubt about the safety of these chemicals to bees (Tennekes 2010 (7), Girolami et al 2009 (8), Suchail et al (9) to name ONLY a few). These strongly highlight dangers and toxicity for bees. To deny their relevance would be akin to the pharmaceutical industry giving medicines to humans in laboratories, witnessing their deaths, but then continuing to give the same medicines to humans, on the basis that the deaths had not occured in those humans whilst they were at home going about their daily lives, and therefore, cannot be proven to be unsafe. This is nonsense.

Finally, in view of the above points, Defra’s handling of this situation is poor, and additionally I note a report in the Yorkshire Post with regard to the leaked clothianidin EPA document (10):

    “A Defra spokesman said: "We already know that there are risks if a product isn't used correctly – and we're glad that this memo reinforces that view.
    We have a robust system for assessing risks from pesticides in the UK that is based on evidence - and current evidence shows that there is not an unacceptable risk to bee health from these products."”

This statement is misleading, and deflective. Defra know full well that the EPA document (5) refers to inadequate data from Bayer, calling it “supplemental” . With regard to evidence supplied by Bayer, the document states:

    “However, after another review of this field study in light of additional information, deficiencies were identified that render the study supplemental. It does not satisfy the guideline 850.3040, and another field study is needed to evaluate the effects of clothianidin on bees through contaminated pollen and nectar. Exposure through contaminated pollen and nectar and potential toxic effects therefore remain an uncertainty for pollinators.”

I provide you with this information in support of the EDM, “to suspend all existing approvals for products containing neonicotinoids and fipronil pending more exhaustive tests and the development of international methodologies for properly assessing the long-term effects of systemic pesticides on invertebrate populations.”

(1) 2009, V. Kindemba; Buglife: “The Impact of Neonicotinoid Pesticides on bumblebees, honeybees and other non-target invertebrates”;
(4) The precautionary principle states that if there are reasonable scientific grounds for believing that a new product may not be safe, it should not be used until there is convincing evidence that the risks are small and outweighed by the benefits. This is enshrined in Directive 91/414 which states that “Member States shall ensure that a plant protection product is not authorized unless… 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.”
(5) 2005: J.M.Bonmatin et al: “Behaviour of Imidacloprid in Fields. Toxicity for Honey Bees”. (Carried out for the French Ministries of Agriculture and Environment).
(6) Leaked EPA doc:
(7) 2010: 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. Toxicology
(8) 2009: V. Girolami et al; “Translocation of Neonicotinoid Insecticides From Coated Seeds to Seedling Guttation Drops: A Novel Way of Intoxication for Bees”. (Published: Entomological Society of America).
(9) 2001 SUCHAIL S., GUEZ D., BELZUNCES L. P., “Discrepancy between acute and chronic toxicity induced by imidacloprid and its metabolites in Apis mellifera.- Environmental Toxicology and Chemistry, 20 (11): 2482-2486.