This was part of a letter writing campaign I instigated from 2009 onwards.
This particular letter is from 2012.
It remains on this website for reference and information purposes.
I am writing to you to express my support for an immediate ban on neonicotinoids in line with the Precautionary Principle, and to further request a complete overhaul of the regulatory system for pesticides.
Specifically, I request that you, as my MP, forward my
letter to Lord de Mauley, Parliamentary Under-Secretary of State for Resource Management, and Mr Owen Paterson, Secretary of State for Environment, Food and Rural
I wish to make the following points to yourself, Lord de Mauley and to Mr Paterson – (please note that the points below, though referring to DEFRA, very often apply precisely to the work of its departments, namely FERA and CRD):
1. Patents for pesticides are very revealing in indicating the types of species potentially at risk from harm. For example, patents for products containing neonicotinoids indicating that they ‘combat Lepidoptera’ are referring to moths and butterflies. In the UK, it seems reasonable to presume that over 2,000 beneficial and harmless species of butterfly and moth are at risk, for the sake of very few crop pests. The regulatory system does not require manufacturers to test on harmless butterflies and moths. Actually, the system requires tests on only 7 invertebrate species: honey bees, earth worms, waterfleas, and 4 others.
I note Butterfly Conservation report significant declines in butterflies, (including farmland butterflies). Would Lord de Mauley and Mr Paterson agree that it is right to do more to preserve the sight of butterflies and moths, not merely for the preservation of biodiversity in its own right, but also for our children? Even if they are not the only factor in butterfly declines, it would take a huge leap of faith for me to believe that these pesticides are only going to kill 'pest' species of Lepidoptera, but conveniently remain non-toxic for our harmless species. What do you, Lord de Mauley, and Mr Paterson think? Of course, whilst this example concerns Lepidoptera, there are numerous other species mentioned on patents (including Vespa spp – wasps, from which bees are believed to descend), and I invite Lord de Mauley and Mr Paterson to investigate this themselves. I think when international patents suggest efficacy against a class of insects or species within it, this should be taken into account in risk assessment for non-target species, especially given the application of pesticides across vast areas of agricultural and horticultural land, golf courses, gardens and potentially council owned land.
prior to independent examination of the regulatory standards for pesticide
tests on honey bees by EFSA(1), it is apparent that the standards are
disturbingly inadequate, having very serious flaws. These standards – such as EPPO 170, are
available for public viewing.
3. DEFRA’s response to quality independent studies (given point 2 above), is hypocritical. They will apparently accept flawed guidelines and studies from pesticide manufacturers for the registration of poisons, yet demand ‘unequivocal evidence’ to dislodge them. It is not the responsibility of the tax payer or anyone else to fund anecdotal proof that these chemicals are harmful to wildlife – it is the responsibility of industry to prove the products do not pose ‘unacceptable risk’ to the environment, and as such, our regulators are required to ensure this is the case.
4. That said, at least 30 independent studies since the publication of the 2009 Buglife report, indicate harmful effects of neonicotinoids on bees. How much evidence would DEFRA accept as ‘unequivocal’? I think it is highly doubtful that DEFRA have ‘unequivocal evidence’ that neonicotinoids do not pose unacceptable risk to bees, but if they have it, let them make it available immediately for public scrutiny. At most they have thus far stated the studies supporting registrations "conform to regulatory guidelines" – hardly reassuring given their inadequacy.
5. DEFRA frequently question whether independent science emulates ‘realistic field conditions’. This query is highly surprising – and again, hypocritical, given that they know regulatory tests for pesticides provide unrealistic levels of exposure to bees(1).
6. 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.”
7. The tests are designed such that they are not only generally inadequate, and are ill-adapted to test systemic pesticides such as neonicotinoids, they are not able to take into account effects on honey bee larvae and behaviour as required by law. Thus if testing is inadequate, then ‘acceptable risk’ cannot have been established. In this case, how can neonicotinoids be legal? Again, is it the job of DEFRA through its departments to ensure pesticides are adequately tested, or not?
8. When manufacturers make claims in their marketing literature for the efficacy of their products in killing other social colony insects (such as termites(2)), and draw attention to the differing modes of action, colony and behaviour effects, duration of toxicity, and mobility of their neonicotinoids, it is not only shameful of our regulators to ignore this and not measure for similar modes of action on our beneficial species, I would put it to Mr Paterson and Lord de Mauley that it is against the Code Of Conduct for Civil Servants, which I will expand upon below, and may provide cause, with other evidence, for Formal Complaint against DEFRA and its departments.
9. FERA, in their advice to DEFRA, have misled the public
and ministers with regard to independent science. Just one example of this can
be found in the misleading treatment of the Girolami guttation study, in
contrast with a seriously flawed Swiss government study(3).
FERA state the Girolami study "should be treated with caution as the data were generated by feeding collected droplets directly to bees and in many cases sucrose was added to ensure the honeybees consumed the dose.”
In actual fact, Girolami added 15% honey only to some of the samples, and other bees were fed plain guttation drops.
The addition of honey or not made no difference to the toxic effects.
With regard to the feeding of bees, regulatory tests for oral toxicity use a very similar method for measuring acute oral toxicity in the laboratory (confirmed in EPPO 170 for Oral Toxicity tests). The test pesticides are mixed with a sucrose solution, which is fed directly to bees via single use feeders.
Indeed, Helen Thompson of FERA used this method when she conducted the oral toxicity tests on behalf of Bayer CropScience to support the registration for imidacloprid. The Swiss study, used to cast doubt on the importance of guttation, involved a tiny 2ha field surrounded by wild flowers and apple blossom, and only 36% of which was sown with the test neonicotinoid. This represents completely unrealistic field conditions, but FERA's report offers no criticism of the flawed study design, despite the significance. Regardless of any further work FERA may or may not have subsequently executed on 'guttation', the fact remains that they misled the public in their 2010 report. This is not acceptable from our civil servants.
11. The Precautionary Principle states that if there are reasonable scientific grounds for believing that a 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 says 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 suggest to Lord de Mauley and Mr Paterson and yourself that grounds for immediate application of the Precautionary Principle have long been surpassed.
12. I would draw Lord de Mauley and Mr Paterson's attention to the Civil Servants code, and ask them to ensure DEFRA and its departments henceforth comply with it in their advice to government and the public:
(Point 8): “Set out the facts and relevant issues truthfully, and correct any errors as soon as possible”
(Point 9): “You must not: deceive or knowingly mislead Ministers, Parliament or others; or be influenced by improper pressures from others or the prospect of personal gain”.
(Point 10): “You must provide information and advice, including advice to Ministers, on the basis of the evidence, and accurately present the options and facts”.
(Point 11): “You must not ignore inconvenient facts or relevant considerations when providing advice or making decisions”.
Given the above points coupled with the persistent and mobile characteristics of these products, it is not acceptable to delay application of the Precautionary Principle even a moment longer. Requests for further information and studies given the weight of quality independent data appear tantamount to tactical time wasting.
I look forward to your response,
(2) Bayer literature: The Secret Life Of Termites, and information leaflet for 'Premise 200SC' (containing neonicotinoid).
(3) "A review of guttation and implications for pesticide exposure in non-target invertebrates and honeybees" 2010, http://randd.defra.gov.uk/Document.aspx?Document=PS2361_9170_FRP.pdf See also: https://www.buzzaboutbees.net/field-tests-for-pesticides.html