Insects and Insecticides
Written evidence submitted by the National Farmers Union
The NFU represents more than 55,000 farming members in England and Wales. In addition we have 40,000 countryside members with an interest in farming and the country. The NFU welcomes the opportunity to make a submission to the Environmental Audit Committee’s inquiry into Insects and Insecticides.
· The NFU aims to base its policy on sound scientific evidence and supports a risk-based approach to regulation.
· With respect to honey bee health, the NFU position follows the general consensus of the scientific community, which is that there is no single cause of honey bee colony losses, but pests and diseases, particularly the parasitic mite Varroa, are the most important factor at play.
· Farmers and growers use pesticides to control damaging pests and diseases, and thereby enable the reliable production of the safe high quality and affordable food and plants demanded by consumers.
· The decision to use a pesticide is not taken lightly - pesticides are expensive to buy and to apply and this cost has to be balanced against the cost of crop losses arising from pest or disease outbreaks.
· Wildlife Incident Investigation Scheme (WIIS) data shows that the number of pesticide incidents with bees in the UK is around its lowest since records began in 1981.
· If neonicotinoid insecticides were not available, farmers and growers would use less-effective insecticides that pose a greater risk to bees and other insects, and would compromise the production of many agricultural and horticultural crops.
· As the science moves on our understanding improves and this enables us to identify gaps in current regulatory processes and develop ways to improve them accordingly. This process is already well underway in respect of pesticides and bees.
1. The NFU has a significant interest in the impact of insecticides on bees and other pollinating insects. The issue is very important to our industry in terms of agricultural pollination and the availability of crop protection products (pesticides), both of which are important elements of sustainable food production. We also have an interest in the insect pollination of wild plants within the wider countryside, as the majority of this land falls under the management of farmers and growers.
2. The NFU also represents the interests of commercial bee farmers, and has the Bee Farmers’ Association (BFA) as a member. Through our membership of COPA-COGECA (the EU level organisation representing farmers), the NFU works closely with the BFA to represent the interests of UK beekeepers at a European level.
3. At a national level, the NFU sits on the Bee Health Advisory Forum, which among other roles acts as the project board guiding implementation of Defra’s Healthy Bees Plan.
4. Negative impacts of pesticides on non-target organisms are always an issue of concern and it is right that measures are taken to minimise and mitigate any risks. It is also important that any actual risks are looked at alongside the benefits of pesticide use. Earlier this year, the European Food Safety Authority (EFSA) published a lengthy review of the pesticide risk assessment process for bees  , which stated that ‘there is a trade-off between plant protection and the protection of bees. The effects on pollinators need to be weighed against increase in crop yields due to better protection of crops against pests.’
The use of scientific evidence
5. Concern has been raised by a number of organisations about the impact of insecticides on insects, in particular the impacts of neonicotinoid insecticides on bees and other pollinating insects. As a result there have been calls for changes to the regulatory assessments of the impacts of neonicotinoids on bees, and some organisations are calling for precautionary bans on the use of neonicotinoid insecticides until their safety is re-examined under new assessment processes.
6. There are a number of scientific studies showing that if you feed insects with neonicotinoid insecticides you see negative effects on their behaviour and life cycles. This is the evidence that sits behind calls by organisations for changes to regulatory assessments and precautionary bans, and this is the research that attracts plenty of media attention. However, there are also a number of equally valid scientific studies that have looked for these negative effects and not found them, and in particular not found them under full field conditions.
7. The NFU finds the way in which the issue is dealt with by the media particularly frustrating. Stories about pesticides and bees generally appear in response to the publication of a particular scientific study or handful of studies. The reporting does not assess how well the studies reflect the real-word field situation, or assess the relevance of the studies in the context of all the other known science in this area. As a result the science is reported, without any context of how significant the new findings are to the debate around pesticides and bees. The health of bees and other pollinating insects (including the impacts of pesticides on that health) is a science-based issue. Science works on the principle of testing and re-testing an idea to build a consensus – a weight of evidence.
8. The NFU aims to base its policy on fact and sound scientific evidence. With respect to honey bee health our position follows the general consensus of the scientific community, which is that there is no single cause of bee colony losses, but pests and diseases, particularly the parasitic mite Varroa, are the most important factor. There is no compelling weight of evidence showing conclusively that neonicotinoid insecticides are responsible for the widespread declines in bee and other pollinator populations. The NFU agrees that the impact of insecticides on bees and other pollinating insects is a factor that should be investigated. There is no room for complacency, but equally this factor needs to be kept in perspective. The NFU is concerned that a disproportionate focus on the issue of bees and pesticides actually diverts attention away from the key threats of pests and disease, to the detriment of bee health in the UK. This concern is shared by organisations representing beekeepers.
9. In the interest of taking a balanced and appropriate approach to the evidence on this issue, the NFU has welcomed the assessments of recent research in the EFSA Statement (on the findings in recent studies investigating sub-lethal effects in bees of some neonicotinoids)  and the Defra report (Neonicotinoid insecticides and bees: The state of the science and the regulatory response)  . These balanced reviews have found the recent research to be inconclusive in terms of the sub-lethal effects that are likely to arise from current uses of neonicotinoids.
10. The NFU fully supports a risk-based approach to regulation. In the absence of a weight of evidence to support restrictions on the use of neonicotinoid products, changes (bans) would be made on the basis of a precautionary hazard-based approach, which we do not support. The NFU believes that taking a hazard-based approach, when the hazard of concern is impact on non-target insects, would undermine the EU regulatory process that is anchored in a science-based approach.
11. The long running Wildlife Incident Investigation Scheme (WIIS)  provides one of the few pieces of available evidence monitoring the ‘real-world’ unwanted effects of pesticides on wildlife in the UK. WIIS data shows that the number of pesticide incidents with bees in the UK is around its lowest since records began in 1981. In the last ten years there have only been five confirmed honey bee poisoning incidents as a result of the approved use of crop protection pesticides in the UK. It is widely believed that the decline in the number of honey bee poisoning incidents in the UK has been the result of the introduction of less persistent and less toxic chemicals (such as the neonicotinoids), and improved liaison between those applying pesticides and those keeping bees. The NFU believes this evidence suggests that in the context of pesticides and honey bees, the UK agricultural landscape is around the safest it has been for more than 25 years. This view is commonly echoed back by beekeepers themselves when the NFU meets with beekeeping groups around the country.
Does the EU regulatory system governing the placing of pesticides on the market adequately assess impacts on bees and pollinators?
12. There are concerns that there are inadequacies in the way regulatory authorities assess the long-term and sub-lethal effects of systemic pesticides (such as neonicotinoids) on insects. It is very well known that the current pesticide risk assessment systems for bees were not developed to assess systemic pesticides and this is being addressed by the International Commission on Plant Bee Relationships Bee Protection Group and the European Plant Protection Organisation (EPPO). EPPO guidelines were revised accordingly in 2010, based on detailed consideration of the available scientific evidence. Even before revision, the principles underlying the changes had already being widely applied by regulators both in the UK and at the EU level for many years in assessing the risks posed by systemic pesticides, to ensure their risk assessment procedures are appropriate.
13. Further changes to the regulation governing the placing of plant protection products on the market have meant that since June 2011 pesticides have been subject to stricter requirements regarding risks to honeybees.
14. The NFU has welcomed the EFSA Scientific Opinion  published earlier this year, which identified gaps in knowledge and made recommendations to improve the current risk assessment. As the science moves on our understanding improves and this enables us to identify gaps in current regulatory processes and develop ways to improve them accordingly. It is right that this is done and that this is done at the EU level. Changes are already happening and the NFU is also looking forward to seeing the outcome of EFSA’s current work to review the current risk assessments for neonicotinoids, due to be published in December 2012.
Pesticide use and stewardship in the UK
15. All pesticides undergo rigorous assessment and there are strict regulations implemented at both an EU and UK level governing their development and use. As a result, the NFU considers that farmers and growers should be able to use all products approved through this process.
16. Farmers and growers use pesticides to control damaging pests and diseases, and thereby enable the reliable production of the safe high quality and affordable food and plants demanded by consumers. The decision to use a pesticide is not taken lightly - pesticides are expensive to buy and to apply and this cost has to be balanced against the cost of crop losses arising from pest or disease outbreaks. Having taken the decision that the risk of losses warrants the application of a pesticide, farmers and growers will use the most cost-effective product that is available to them.
17. The rate at which a pesticide can be applied is strictly controlled. All pesticides used in the UK are controlled under strict criteria as part of EU regulations 91/414 or 1107/2009. These controls set approved application rates for each product that ensure environmental protection requirements are met and that the pesticide will work effectively. These application rates include a maximum dose rate and it is a legal requirement that this must not be exceeded. This is an independently verified process and acts a regulatory control.
18. Because pesticides are expensive to buy and apply, farmers and growers will avoid higher application rates where possible to reduce costs. However they must apply products at suitable levels to achieve control, particularly as too low a dose rate would increase the risk of pests developing resistance to pesticides. Thus, actual application rates are determined by the economic need to control pests effectively and to avoid unnecessary wastage of expensive chemicals. The use of lower application rates can also be useful in enabling the option of additional subsequent applications, if these were to become necessary.
19. Application rates above recommended rates could also result in pesticide residues that exceed the permitted Maximum Residue Limits. This would result in the rejection of produce. Farmers and growers work to prevent such occurrences because the potential business impacts, such as loss of business, loss of assured status and prosecution, are huge.
20. The NFU believes that the standards of agricultural practice in the use of pesticides in the UK are among the highest in Europe, as evidenced by the high professional standards identified in the recent DEFRA Pesticide Forum report  and identified by ministerial comments concerning the achievement of the industry Voluntary Initiative since its inception in 2001 in raising pesticide stewardship standards  .
21. The basis of this achievement is the Voluntary Initiative on pesticides, which has looked to improve the standards of operators, agronomists and application equipment on an on-going voluntary basis with schemes that in all cases continue to exceed the requirements of the newly implemented EU Sustainable Use Directive. The Voluntary Initiative reports progress to Defra ministers annually. On a voluntary basis 20,359 spray operators are involved in on-going Continuing Professional Development via the National Register of Spray Operators, run by City and Guilds. Of the total sprayed area in the UK, 86.8% was sprayed using spray equipment tested annually under the National Sprayer Testing Scheme. The inclusion of these measurers in assured produce schemes, like the Red Tractor, which have very high levels of uptake by farmers and growers, have further improved standards of pesticide stewardship in the UK.
22. Growers in the fresh produce and arable sectors are supported by experts in the agronomic advice industry, many of whom have received additional training beyond expected industry standards; 847 agronomists hold the Biodiversity Environmental Training Award (BETA), designed to improve the standards of environmental stewardship and encourage best practice.
23. Following the success of the Voluntary Initiative, improved pesticide stewardship has been encouraged by a range of chemical company initiatives and also by fresh produce and arable assurance schemes. Key industry initiatives relevant to insecticide usage have focused on use of buffer zones and low drift nozzles to reduce risk of drift, while careful stewardship of all pesticide-treated seed is undertaken by the industry. This includes improving seed applications to reduce risks of pesticide dusts, and by encouraging operator care to avoid seed spills and ensure seeds are properly buried when drilled.
24. The UK 2011 pesticide survey  indicates that the total area treated with pesticides in 2011 (5,974,142 ha) is similar to the area treated in 1991 (5,990,717 ha). However, during the same period the total weight of pesticide applied has halved (falling from c. 1,023,668 kg in 1991 to 437,399 kg in 2011). This indicates that the total usage of insecticide has more than halved in the last twenty years, as a result of improvements in active ingredient effectiveness and precision application technology. These improvements are also associated with a significant decrease in the use of pesticide sprays (965,324 kg in 1991, 356,233 kg in 2011) and an increase in use of seed treatments (c. 58,344 kg in 1991, c. 81,166 kg in 2011). More targeted applications that more precisely deal with the risk (such as seed treatments) enable insecticide usage to be reduced. Foliar sprays have always been associated with higher risk to non-target insects.
The importance of neonicotinoid insecticides to UK horticulture and agriculture
25. The neonicotinoid class of chemicals includes a range of systemic insecticides, with different spectrums of activity, used in many different ways. This includes neonicotinoids considered a high risk to bees, and appropriately their use is governed by strict management practices to mitigate this risk, e.g. not applying when crops are in flower or when bees are actively foraging in the crop. But it also includes neonicotinoids that are considered such low toxicity to bees that they can be applied when crops are in flower and are vital components of Integrated Pest Management (IPM) strategies where populations of beneficial insects need to be conserved.
26. Neonicotinoids are used very widely in the UK. For example, more or less all oilseed rape would be seed treated with a neonicotinoid. There are five neonicotinoids approved for professional use in the UK; acetamiprid, clothianidin, imidacloprid, thiacloprid and thiamethoxam. Some of these are also approved for amateur use in bug killers. Clothianidin and imidacloprid are mainly used as seed treatments for crops including cereals, maize, oilseed rape, sugar beet and some horticultural crops. Thiacloprid is an IPM compatible neonicotinoid of low toxicity to bees, which is approved for use in the UK on a huge range of horticultural crops.
27. Neonicotinoids are particularly important in controlling sucking insect pests like aphids, thrips and capsids, because they are used
a. to replace less effective older chemicals, such as the organophosphate, carbamate, pyrethrum and pyrethroid insecticides, which are generally more persistent and more toxic to bees and other beneficials. E.g. thiacloprid has replaced more persistent and more ‘bee toxic’ insecticides, like the pyrethroid deltamethrin, as a treatment for raspberry beetle.
b. to control pests already resistant to the OP, carbamate, pyrethrum and pyrethroid insecticides, and as part of resistance management strategies. E.g. thiacloprid is the only effective ‘bee-friendly’ friendly’ insecticide available to control aphid pests on Brussels sprout. If thiacloprid was unavailable, growers would become dependent on just a few alternatives. This dependence would increase the risk of resistance developing to these insecticides. Moreover, these alternatives present a higher risk to bees than thiacloprid itself.
c. as effective seed treatments, negating the need for more hazardous and frequent spray applications, e.g. thiamethoxam, clothianidin and imidacloprid are the only insecticide seed treatments for oilseed rape and sugar beet. Without them the option would be more frequent sprays, using pyrethroids that are a higher risk to bees and other insects. On cereals, no neonicotinoid seed treatments would result in the need for multiple insecticide sprays against aphids.
d. as part of IPM strategies, e.g. selective neonicotinoids like thiacloprid are increasingly important on tree fruit crops such as apples. The alternative approved actives, such as cypermethrin, deltamethrin, chlorpyrifos, and bifenthrin, are more persistent and toxic to bees and other beneficial insects.
What would farmers and growers do if neonicotinoids were not available?
28. The number and range of pesticide active ingredients available to farmers and growers has already decreased significantly in recent years, following the adoption of EU Directive 91/414 in 1993 and the subsequent Directive 1107/2009, which were designed to bring an improved regulatory framework to pesticide registration. With wide ranging evaluations of toxicological effects on human health and the environment, the number of active ingredients available for use in the EU has fallen from c. 900 actives in 2001 to c. 230 actives in 2009. This has two main implications; firstly the more toxic substances are generally no longer available, and secondly the range of pesticides available to control each pest or disease has reduced significantly, such that in many cases only one or two pesticide control options may be available. This situation can be further compounded by high levels of pest resistance seen to many existing products.
29. Neonicotinoid insecticides are relatively new products compared with the alternative insecticides available and offer an alternative mode of action. Farmers and growers use these pesticides because they are the most effective products available. As indicated in point 27 above, neonicotinoids are used to replace less effective older chemicals, which would often have to be used in higher volumes and are generally more persistent and more toxic to bees and other invertebrates. Having no neonicotinoids would leave farmers and growers no option but to use insecticides that actually pose far greater risk to bees and other insects. Assuming of course that alternative pesticides are available at all. The use of these less effective pesticides would also seriously compromise production of many crops.
30. A recent survey by Bayer of oilseed rape farmers in the UK on the consequences of losing neonicotinoid seed treatments suggested that 90% of them would need to apply more insecticide sprays, 79% of them felt their yields would decrease, and 72% of them felt that there could be adverse environmental consequences.
31. Approximately 92% of sugar beet seed sown by UK growers was treated with neonicotinoid insecticides in 2012. The neonicotinoids are used to control aphid pests and in particular the virus diseases spread by these aphid pests. Research has shown that in the absence of adequate crop protection, 8 of the last 12 years would have resulted in virus epidemics that would have proved devastating to the industry. The loss of neonicotinoids would result in significant yield reductions that would render the sugar-beet industry uneconomic in the UK. Growers have no real control alternatives to neonicotinoids as the main aphid pest concerned has developed resistance to the single alternative insecticide spray currently approved for use.
Reducing pesticide use and alternative pest-control measures
32. The NFU believes that farmers and growers support the opportunities for including integrated pest management (IPM) strategies in their production systems. Many farmers already undertake integrated management strategies  when these strategies can reliably reduce the need for expensive pesticide applications. A well-rounded IPM strategy will encourage the use of seed technologies through variety selection and seed treatments. Improving application technology to reduce the overall quantities of pesticide applied, and the use of cultural control techniques such as crop rotation and changing cropping cycles, are all measurers undertaken commonly in field crop production today.
33. The NFU and other industry groups are actively involved in promoting the uptake of IPM strategies. For example, we are supporters of the Defra and industry co-funded SCEPTRE project  that aims to deliver applied research to help secure approvals for new and safer pesticides and biopesticides, and develop sustainable IPM programmes for use on edible crops. These IPM programmes would be compliant with the new EU Sustainable Use Directive.
2 November 2012
 EFSA Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees (Apis mellifera [honey bees], Bombus spp. [bumble bees] and solitary bees), http://www.efsa.europa.eu/en/efsajournal/pub/2668.htm .