Letter To MP -
Environmental Audit Committee, Insects And Insecticides
(find here -opens new window).
I am writing to you to express my support for the Buglife
position demanding 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
In supporting Buglife, 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):
- 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.
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.
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.
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).
- 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.”
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?
- 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.
- 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). They 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.
- 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.
- 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:
8): “Set out the facts and relevant issues truthfully, and correct any
errors as soon as possible”
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”.
10): “You must provide information and advice, including
advice to Ministers, on the basis of the evidence, and accurately present the
options and facts”.
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
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