The harm to bees, birds and aquatic life from neonicotinoids has still not been resolved, and despite the mounting evidence the industry maintains these agrotoxins are both innocent and effective. However, it often takes a crisis of this magnitude to highlight broken systems to politicians. It is clear that the way the pesticide market currently functions puts wildlife at risk. There are solutions to this but will the UK Government be part of the solution or part of the problem?
A new neonicotinoid – Sulfoxaflor – has given the EU its first test since the bees and neonics issue hit the press. The EU regulator, like their US counterpart, failed the test and approved a pesticide known to be a potential ‘high risk’ to bees without ascertaining if its use could be safe for bees. Member States now have to make up their own minds when pesticide companies apply to them to licence uses of sulfloxaflor.
However, last month this blew up for the US regulators when their courts overturned the approval, highlighting that the EPA had used "flawed and limited data" to justify its approval and concluding that “Given the precariousness of bee populations, leaving the EPA's registration of sulfoxaflor in place risked more potential environmental harm”.
So what needs to be done to make our approvals system safe for bees?
Currently the approvals process has thee huge failings.
1. Tests are methodology not science
The tests that candidate pesticides are subjected to are based on looking for patterns and trends, not on statistical analysis. The case of neonicotinoids has highlighted that without adequate data damaging pesticides slip through the net. The pre-application tests are obsessed with standardised methodologies and a complexity of tiered studies, but entirely neglectful of the essential role of statistics in understanding if, a) any observed effect is real, or b) any lack of observed effect can be safely considered to be an actual lack of an effect. When later serious questions are asked of an approved pesticide the lab work done as part of the approval process is of no assistance, it is simply unpublishable. Even the most thorough of pre-application studies, those higher tier studies undertaken after risks have been identified, are not statistically viable. The pesticide industry has depended on studies such as Pilling et al 2013 , however as this study itself states:-
"As these are large-scale, resource intensive trials it was not possible to include sufficient true statistical replication in the study design. The difficulty of including replication in the design of large honey bee field trials is confirmed in the EPPO guidance document for evaluating the side effect of pesticides on honey bees, which states that although replication is desirable it is not feasible because of the requirements for separation (of the treatment and control fields)."
There is not a single statistically significant result in the paper, it is quite odd that it was published at all.
Even in more normal published field studies, most of which have also been paid for by the pesticide industry, there is usually insufficient statistical power to detect an effect, as Cresswell 2011 showed "Statistical power analysis showed that published field trials that have reported no effects on honey bees from neonicotinoids were incapable of detecting these predicted sublethal effects with conventionally accepted levels of certainty".
One of the main reasons that the pesticide industry and regulators were upset with the January 2013 EFSA partial reassessment of neonicotinoid risks was that the scientists undertaking the review refused to accept the feeble, statistically irrelevant, industry studies. This is seen as a betrayal of the cosy and cheap methodologies that the companies and regulators had previously agreed were acceptable. The report led to the EU ban.
2. Pre-application tests are too narrow in scope
While it would be impossible to test every pesticide against every species, the range of species against which the pesticides are tested need to be urgently increased. In particular the process does not investigate the impacts of pesticides on beneficial wild invertebrates. Wild pollinators and predators are key to a healthy functioning agroecosystem, but the approval process ignores them. Many studies and reports over the last decade have concluded that honeybees are NOT a useful proxy of other pollinators – they are domesticated and have a highly complex and robust social community. In particular the tests should be expanded to include solitary bees, bumblebees, moths and ground beetles.
In the case of neonicotinoid seed treatments the approval process failed to adequately consider the impacts of clouds of planting dust, or of the environmental fate of the 90% of the dose that dissolves into the soil.
3. Death is not the only negative impact
The testing process has an unhealthy obsession with LD50s – the amount of chemical required to kill. While mass killing of wildlife is definitely worth avoiding, it is not the only factor. If our objective is to maintain healthy ecosystems and a flourishing planet that sustains a wide variety of life, then it is essential that other factors are also considered. The effects of pesticides on feeding, reproduction and overwintering must be incorporated into the process, unless these are understood the effect of the chemical on populations of exposed species will not be illuminated.
New EFSA Guidance on solitary and bumblebees
Produced in July 2013 updated in July 2014, but still not adopted, the EFSA bee guidance is supposed to fill some of the gaps in the approval tests highlighted by the neonic saga – dust and other bees particularly. However this minimal step in the right direction is hated by the pesticide industry that claims that it is impossible to implement and the adoption of the new guidance is being blocked, it is claimed, by the UK Government.
This creates the crazy situation where EFSA now has to approve pesticides that it suspects will be damaging to bees.
The Pesticide Dance
The obsessive focus on process, methodology and tiers may give regulators a sense that they are putting the pesticides through the paces, but in truth the pesticide industry and regulators have created a complex dance that identifies some of the greatest risks and enables them to be avoided, but is blinkered and inflexible to new threats, sometimes they seem to be just going through the motions.
The 2013 EFSA report represents the minimum needed to patch up this bit of the process around bees, it is a disgrace that chemicals like sulfoxaflor this are weaving their way through the approvals process regardless of their effect on bee populations.
Expanding the approval process to consider impacts on moths and ground beetles should also be done as a matter of urgency.
We hope that the US court decision that insecticides such as these must be shown to be bee safe before they are authorised will wake EU politicians up to what is also happening here. Reform of our pesticide approvals process is urgently needed to address the gaping holes in environmental protection that the tragedy of neonics has highlighted.
The income from neonicotinoids must now be more than $3 billion/yr and new pesticides are constantly being developed and approved. So the pesticide industry bleating about the costs of proper science is simply not credible. It must be improved.
What is the UK doing Liz Truss?
Recent revelations that UK Ministers tried to block efforts to tighten up car emissions have been highly embarrassing. So let’s hope that the Government is now alert to the risk of appearing to again be the ‘dirty man of Europe’ and is going to open the stops and ensure that we have a pesticide approvals process that will enable Liz Truss to achieve her aim for “Britain to have the best natural environment anywhere”
I have written to Liz Truss, nearly a month ago, asking:
1. It is rumoured that the UK is blocking the new bee safety measures can you confirm if this is the case, and if so, what the reasoning is?
2. What are the processes and timescales for the implementation of the 2013 EFSA bee guidance?
3. Does the UK have a position on the quality and thoroughness of the proposals?
4. When can we expect new safeguards to be in place at the EU level?
5. In the meantime will the UK be applying the EFSA guidance on every new pesticide use in the UK, or just those for which there is high risk to bees is indicated, in which case how will that be determined?
I have not had a response yet. If you think these are important questions perhaps you could email or tweet her and ask her to respond to my letter, or ask her one of the questions yourself.
Please let me know if you get a response.