the recent government release, “EU Food Safety Authority announcement that
neonicotinoid pesticides should not be used on crops attractive to honey
bees”(1) , I thought I would consider more carefully the notion that “Only uses on crops not attractive to
honey bees were considered acceptable” - this following the recent EFSA report outlining unacceptable risk of neonicotinoids to bees.
I am specifically concerned that even restricting neonicotinoid use to non-flowering crops, would not provide sufficient protection for other non-target species that may visit them, such as butterflies and beetles:
1. Pesticide risk assessment already conducts tests on very few species as a representative sample of invertebrates. As it is, assessment only requires that pesticides are tested on:
- Daphnia magna (water flea)
- Apis mellifera (honey bee)
- As well as 4 further species (according to the Chemicals Regulation Directorate “DATA REQUIREMENTS HANDBOOK”- Version 2.2, June 2012)
2. Thus, perhaps EFSA have failed to take into account that testing on honey bees may be assumed to safeguard butterflies (which do not only visit flowering crops), hoverflies, lady birds, lacewings and a range of other species whether or not they forage on flowering crops – indeed, various species may inhabit areas around foliage crops, for example. I am not aware of EFSA examining the data on the other species, as they have for honey bees.
Therefore, I am concerned that it is not safe to simply assume that restriction of application of neonicotinoids to non-flowering crops, would be sufficient to protect other non-target invertebrates. In addition to which, the EFSA report stated “In some cases EFSA was unable to finalise the assessments due to shortcomings in the available data”. If is not possible to complete risk assessment for any chemical, for the whole range of species and in all areas, are they legal?
3. Note, the vast majority of invertebrates
are beneficial or harmless, and given the uses of neonicotinoids, it is not
merely a case of ‘what is applied on farm crops’ either. They can be used on golf courses, in gardens, lawns and potentially on council land. In some countries, they are even used on trees. They are mobile in soil and water, meaning they have the potential to trespass into areas not intended for pesticide, including on land and in aquatic systems. They also persist in soil. Research has shown that even after usage has ceased, they have been taken by plants and presented through flowers and nectar at levels toxic to bees (Bonmatin et al).
support the protection of bees, but we also need to consider the other ‘unsung
heroes’ of our eco-system – and I would remain in support of the Buglife
position requesting a complete ban on neonicotinoids. You can help by sending this letter to your governement representative here.
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