Insects and Insecticides
Written evidence submitted by Paul Matthews
« The atmosphere was very cordial, with pleasant people proposing totally unacceptable things. To give an example, one of the risk calculations defined 'low risk' as a product which didn't expose bees to a chronic lethal dose value of 50 [which kills 50% of a population over a long period]. So the product was low risk if it only killed 49% of bees. It was simply unbelievable ». Beekeeper Janine Kievits testifying of her experience at the 10 th International Symposium of the Internation Commission for Plant-Bee Relationships - Bee Protection Group - Bucharest (Romania) in 2008.
(1) On 25 September 2012, the Environmental Audit Committee members launched what their press release calls a new inquiry into the impact of insecticides on bees and other insects. It invited organisations and members of the public to submit written evidence, setting out their views on these issues, adding that more wide ranging responses would also be welcome.
(2) The Clerks of the Environmental Audit Committee requested that I expurgate, as it were, my initial, very detailed testimony and evidence to avoid what they think might prove 'potentially libellous allegations against many people and organisations' and to restrict myself to issues covered by the inquiry's terms of reference.
(3) The Environmental Audit committee inquiry terms of reference are stated as : (a) the impact of insecticides on bees and other insects, (b) the basis on which DEFRA has decided not to take action following a review of research done earlier in the year on the effects of neonicotinoid pesticides and (c) the use (or abuse) of evidence in this particular case, for setting policy and regulations on pesticides (d) evidence of any potential impacts of systemic neonicotinoid insecticides on human health and (e) what alternative pest-control measures should be used.
(4) To examine the impact – negative, potential or otherwise – of insecticides on bees and other insects – pollinating or otherwise - and to understand the basis of action taken or not taken to limit that impact, negative, potential or otherwise, one needs to scrutinise the behaviour of human individuals and enterprises empowered by wealth made by manufacturing, approving, marketing, regulating and supposedly policing, both pesticides and themselves, able apparently to persuade UK civil servants of the need to accept what the evidence suggests is an ecocide.
(5) Neither professional beekeeper nor academic naturalist, I am a member of the public with a declared interest : the protection of fundamental human rights relevant to the sustenance and pleasure obtained from a wholesome environment. This is something which, to the best of my knowledge, is identified, determined or measured by an abundance of natural assets – called loosely biodiversity – both in towns and the countryside – and high levels of drinking water and food chain quality. The operative words here are 'identified', 'determined' and 'measured'.
(6) The public is alienated from decision-making processes by specialist knowledge often used to discredit what may be deemed lay opinion. Conversely expert opinion is de facto judged to be 'science-based'. Yet opinion-based science also exists. So while experts may be appointed or hired by government to monitor and testify to key parameters considered commensurate with human health and a wholesome environment, expertise is no guarantee against some forms of bias or conflicts of interest – declared or otherwise – prejudicial to the wider public interest,
(7) Having followed where the evidence leads and in the light of what I personally have learned about events in Europe and elsewhere since the introduction of the type of insecticides called neonicotinoids, I would like to think the Environmental Audit Committee members have a duty to consider several legal and ethical issues central to contemporary UK government practice.
(8) Corroboration of what I believe to be true can be found in a more detailed form, with references, in my proof of evidence [Not reported as evidence]. I would ask EAC inquiry members to consider the testimony presented to them fully in the light of the following phenomenon. I understand that financial and commercial pressures are seriously compromising the canons of objectivity and impartiality within which strategic committees and sub-committees of departments, non-departmental public bodies and executive agencies are expected to operate. I would ask the MPs to probe effectively the degree to which - even before the current climate of austerity kicked in - DEFRA and key statutory consultees, notably FERA, EA, CRD, Natural England, may have been 'obliged by the government to pay their way' through contractual arrangements with the private sector.
(9) In addition to the fact of a 'privatisation culture' delegating hitherto government tasks to outside organisations, budgetary constraints cause reductions in independence and loss of sovereignty, so that capacity in terms of monitoring, enforcement, research and the advisory rôles may be jeopardised by a lack of scientific rigour. So that regulation and other missions may become adjuncts of the business community's extremely focused needs. To the detriment of the wider public interest. Despite and because of the EAC inquiry's terms of reference, I suggest any such lack of scientific rigour is relevant to recommendations the MPs may choose to make.
(10) No livestock breeders of mammals or poultry are expected by DEFRA to accept as normal a loss rate among their animals regularly in excess of 30%. The use (or abuse) of neonicotinoids raises fundamental moral issues. The legal protected status of bumble bees and other invaluable invertebrates seems in doubt. Some feature as priority species in the Red Data Book system of Biodiversity Action Plans. The enforcement and prevention culture prevailing at DEFRA makes legislation unworkable and irrelevant. Eradicating irreversibly key life forms endangers entire ecosystems and is illegitimate and unethical. The question is : how can DEFRA, FERA and the CRD be allowed to continue to approve molecules whose chemical properties make them unlawful ?
(11) For example in soil under aerobic conditions, imidacloprid is persistent with half-lives of the order of 1–3 years ie significantly higher than the 120 days ceiling stipulated in REGULATION (EC) No. 1107/2009. The parent molecule produces several metabolites, two of which : the 5-hydroxy-imidacloprid and olefin imidacloprid : are toxic to bees (Cf. Araki et al. 1994). As a very water soluble systemic pesticide, imidacloprid translocates easily in the xylem of plants from the soil into the leaves, fruit, pollen, and nectar of a plant. Imidacloprid's excellent capacity for translaminar movement in plant tissues indicates that this agrochemical development - dating from 1992 – represents a paradigm shift technologically, agronomically and toxicologically. Such traits should have prevented their approval by EU regulators. Why didn't this happen ?
(12) Relative to Annex VI of the Council Directive 91/414/EEC, the Commission Guidance Document on Persistence in Soil dated 12.07.2000 (Pages 4 and 5) is categorical and limpid:
18.104.22.168 Fate and behaviour in the environment (Annex VI, part C, decision-making) : No authorization shall be granted if the active substance and, where they are of significance from the toxicological, ecotoxicological or environmental point of view, metabolites and breakdown or reaction products, after use of the plant protection product under the proposed conditions of use :
- during tests in the field, persist in soil for more than one year (i.e. DT90 > 1 year and DT50 > 3 months), or
- during laboratory tests, form non-extractable residues in amounts exceeding 70 % of the initial dose after 100 days with a mineralization rate of less than 5 % in 100 days, unless it is scientifically demonstrated that under field conditions there is no accumulation in soil at such levels that unacceptable residues in succeeding crops occur and/or that unacceptable phytotoxic effects on succeeding crops occur and/or that there is an unacceptable impact on the environment, according to the relevant requirements provided for in points 22.214.171.124, 126.96.36.199, 188.8.131.52 and 2.5.2. (Cf. http://ec.europa.eu/food/plant/protection/evaluation/guidance/wrkdoc11_en.pdf) :
(13) Clothianidin is the metabolite of thiamethoxam and has a half-life that can range from 148 days to values in excess of 1,155 days depending on soil type. It would seem that these systemic pesticide have been approved and registered in full knowledge of the fact that their persistence made them unsuitable as plant protection products. The evidence suggests their continued use and approval indicate an unscrupulous and possibly delinquent mind set, expert at subverting the risk assessment process. These substances are now massively deployed in monoculture despite :
· their obvious tendency to pollute significantly surface and groundwater ;
· their obvious tendency to impoverish soil quality - depleted of invertebrates :
· their impact on neonatal mammalian brains and other suspected adverse health effects.
(14) Further corroboration of illegality can be found in my proof of evidence (Cf. also the URL references infra). The only reasonable response to this disavowal of the wider public interest is to consider as imperative the need to apply without further delay the Precautionary Principle.
(15) Unreported by Britain's press and media, an AFP press release dated 9 November 2012 announces how, invoking their attachment to the precautionary principle, a total of five former French government ministers for the environment, hailing from France's five major political parties, have called for a revision of GMO approvals and for what amounts effectively to a call for a root and branch reform also of the European pesticide safety assessments régime.
(16) This event in France is followed by the five demands for a change at EFSA presented at Parma on 12 and 13 November 2012 by key social networks and environmental organisations, indicating the need for a radical overhaul of Europe's food and environmental safety system.
(17) A powerful statement signed by 139 French scientists, including many agricultural sector researchers and supported by others fearful of losing jobs and advised not to sign, challenges the recent virulent attacks on Gilles-Eric Séralini and his CRIIGEN team. Entitled 'Science et Conscience' and published by Le Monde on 14 November 2012, the document criticises double standards condemning a two-year scientific study on the GMHT maize NK 603 and the Roundup herbicide which reveals massive data gaps and serious shortcomings in EFSA's methodology.
(18) On 15 November 2012 an Open Letter, sent to the European Commission and signed by cross party MEPs, requires greater transparency and independence on GMOs and food safety.
(19) The CRIIGEN researchers suggest the immediate need to review market approvals for pesticide tolerant crops with the 90 day test duration extended to two years for agricultural GMOs. Crucially, they add that all pesticides be tested in their formulations (not the active principle alone) for two years, including at very low levels. They indicate that the regulatory testing process for biotech and pesticide products necessitates transparent, open-to-public scrutiny, subject to independent review and performed independently of firms manufacturing them in the future. CRIIGEN has received support from the leading scientists of 33 countries, including more than 160 letters of support from professors, doctors and researchers, while more than a hundred others have supported the CRIIGEN research study by signing an open letter.
(20) In July and September 2012, Le Monde publishes two articles concerning neonicotinoid insecticides and bees. In the first Stephane Foucart shows how, through incompetence or the accumulation of conflicts of interest, the management of Europe's key advisory group for pesticides and bee health has fallen totally under the control of the agrochemists. In the second, the same investigative journalist indicates the fact that Exeter university – named the Sunday Times' University of the Year 2012-2013 – published, on 21 September 2012, a press release, accusing a French team's research of probably being "instrumental in the French government’s recent decision to ban the use of thiamethoxam, a neonicotinoid that is the active ingredient of Cruiser OSR, a pesticide produced by the Swiss company Syngenta". It also claims, falsely, the French study is biased and ignores, declines or fails to mention the French team's solid rebuttal of criticism arising not from original research but from 'technical comments' by two Britons. These are Helen M Thompson of the Food and Environmental Research Agency (FERA) and James E Cresswell of Exeter University's Biosciences. Exeter University' press release declines or fails to
acknowledge the fact that James E Cresswell's laboratory is funded by Syngenta.
(21) Apparently part of a conspiracy of silence exercised in Britain over international concern about relations between governments, regulators and agrochemical companies - and similarly unreported by the UK mainstream media - a very important development has occurred which, if made known to and fully understood by the public would fundamentally alter the current ultra-liberal approach to the use of neonicotinoids – because of their effect on honey bees and other pollinating insects. What would also impact on the way all systemic xenobiotics are assessed in respect to human health is an admission on pages 12 of a 45 page document, published by SETAC, edited jointly by Bayer CropScience USA and the USA's Environmental Protection Agency.
«Risk assessment for systemic compounds : Many who are familiar with pesticide risk assessment recognize that the methodology and testing scheme employed for foliar application products (where exposure may be primarily through surface contact) is not adapted to assess potential hazard and risk from systemic pesticides». Summary of the SETAC Pellston Workshop on Pesticide Risk Assessment for Pollinators 15–21 January 2011 Pensacola, Florida, USA. (NB SETAC have suppressed the original URL to this document).
(22) This official acknowledgement of a serious shortfall in methodology relates to the true ENVIRONMENTAL FATE of neonicotinoids and not the one industry and government would have us believe. We have Dr Rosemary Mason, MB, ChB, FRCA (retired) to thank for this discovery. I cannot improve on the way the naturalist and writer from South Wales presents the evidence and, in the interests of brevity, quote relevant passages from her September 2011 testimony :
«So, as we suspected, the whole purpose of the SETAC meeting was to try to develop methodology and protocols for tests that are specific to systemic pesticides whilst still allowing them to remain on the market (…) The SETAC conference was heavily sponsored by the pesticides industry, so they were well represented; three from Bayer, two from Syngenta, two from BASF (one of whom had boasted on the net about BASF’s financial contribution), one from Monsanto and one from DuPont (…) The UK was represented by Mark Clook (Chemical Regulation Directorate) and Helen Thompson (Food & Environment Research Agency, FERA). Helen Thompson had worked closely with three scientists from Bayer, Syngenta and Dow on the International Commission on Plant-Bee Relationships (ICPBR) Bee Protection Group (she was the Group’s secretary). The same three had also helped with the UK Defra Research SID5A (2007-2009) Systemic Pesticide Risk Assessment, which, incidentally, only got as far as protocols for Tier 1 tests. The conclusions of the ICPBR working group in 2008 were that protocols for the second and higher tier (Tunnel Tests and Field Tests) were still to be developed. So, members of the ICPBR must have known for at least 3 years that the science underpinning protocols for risk assessment for systemic pesticides was inadequate. The ICPBR have 17 members on their three bee working groups. Six are from the pesticides industry, some of whom service two groups. This may explain why the CRD, FERA, Defra and the AFSSA (French equivalent of FERA) have repeatedly advised UK and European Ministers and informed us, the public, that there was no evidence that the neonicotinoid pesticides are harmful to honey bees». Rosemary Mason September 2011.
(23) As can be verified by scrutiny of the lists of attendees, staff members of FERA (formerly CSL) and the CRD (formerly PSD) such as Mark Brown, Mark Clook, Julie Howarth or HM Thompson are no stranger to what are regular, secretive, mostly apparently private, get-togethers uniting senior or junior government scientists, advisors from industrial academia or professional consultancies involved in the lucrative business of elaborating Draft Assessment Reports and pesticide company employees. Until 2008, what actually transpired at the triannual ICB-PR bee protection group symposia was anybody's guess. The literature says the participants have been concerned with a 'harmonization of methods for testing the toxicity of pesticides to bees' ever since the 1st symposium in Wageningen in the Netherlands in 1980.
(24) Events at annual meetings and workshops of SETAC are an enigma. Mark Clook features alongside Martin Streloke, BBA, Germany and Anne Alix, ex-Novartis France and former French government official now Dow UK, on a 2011 Steering Committee of a SETAC Environmental Monitoring Advisory Group on Pesticides (EMAG-Pest). Processing the European Probabilistic Risk Assessments for the Environmental Impacts of Plant Protection Products, (EUPRA) to harmonise Risk Assessment brought together Martin Stroleke and Mark Clook - as ambassadors of their respective governments - in a 2001 Netherlands workshop chaired by Andy Hart of the CSL in
York, alongside delegates from other EU member states, the US Environmental Protection Agency, the OECD and Syngenta representing the European Crop Protection Association.
(25) In good faith three beekeepers from Belgium and France – with professional qualifications in agronomy and/or specialist knowledge of and experience in bee husbandry - attended the 10 th International Symposium of the ICP-BR Bee Protection Group Bucharest (Romania) in 2008. They found themselves face to face with seven of the nine members of the dedicated working group - Anne Alix, Marie P Chauzat, Sophie Duchard (AFSSA), Gavin Lewis (JSC International Ltd), Mark J Miles (Dow) Christian Maus (Bayer), Ed Pilling (Syngenta), Helen M Thompson (CSL) , Klaus Wallner (Hohenheim University) - tasked with preparing the UK Defra Research SID5A (2007-2009) Systemic Pesticide Risk Assessment, which, apparently, only got as far as protocols for Tier 1 tests . This despite the fact they had been working on the problem since the 9 th Symposium of the Bee Protection Group of the International Commission for Plant-Bee Relationships) located at the CSL Sand Hutton complex, York in October 2005. As can be discerned by an examination of the transcript of the plenary discussion the three beekeeper's concerns are given short shrift.
(26) Moreover as is revealed by Stéphane Foucart's Le Monde article (q.v.) the trio of outsiders wrote to the ICB-PR sécretariat - with copies to the EPPO members state's ad hcc agencies - to express their concerns at the way the 'standardised tests' used in the preparation of the Draft Assessment Reports were divorced from the biological reality. Their letters were ignored.
(27) Worth noting are the unambiguous conclusions of a paper from a ten-strong team of Italian ecotoxicologists, whose data collected in 2008 indicates that higher number of bee loss events occurred in intensively cultivated flat areas, located in the North of Italy, mainly during or after corn sowing. They establish a spatial and temporal correlation between hive damages and corn sowing and suggest that a presence of residues of agricultural insecticides, namely imidacloprid, thiamethoxam and clothianidin, used for seed dressing, in almost half the samples confirms the relationship between spring mortality and the sowing of corn seed dressed with neonicotinoids. They go on to say that the fact that half of the analysed samples did not contain residues is not enough to exclude the responsibility of neonicotinoids in hive damages, given that many factors can influence the presence of residues and their level : the exposure path of the agrochemicals to bees can be direct due to corn sowing dust or indirect via pollen and nectar from surrounding flora ; dead bee samples could have been collected with some delay after intoxication or could have not been properly stored with a consequent degradation of the active ingredients.
(28) The EAC inquiry members will have been briefed on systemic insecticide exposure pathways via phenomena like guttation. In hot, dry conditions, pollinating insects will quench their thirst from other more classical sources of moisture. Examining the impact of neonicotinoids on water quality should therefore come within the EAC inquiry remit. In April 2012, I contacted SW Water and the Environment Agency for information on surface and ground water quality concerning residues from three water soluble neonicotinoids. The response from the utility subsidiary of the Pennon Group was almost totally void of interest. But Maggie Summerfield of the Environment Agency's Customer and Media Communications Team emailed me on 16 April 2012. Her message is reproduced in my Proof of Evidence [Not reported as evidence].The following day Environment Agency's N ational Team's Technical Adviser Rob Barron phoned to confine himself to amending this sparse information, saying that the GS/MS scan for the groundwater quality monitoring was extended to surface water – with a possible monthly frequency - and that 'procedures are under review'.
(29) The alacrity with which the authorities highlight how they control the microbial quality of drinking water, notably by the addition of chlorine - a highly reactive halogen - contrasts with the opacity governing the way the chemical hygiene of drinking water is ensured. Public unease on this topic is amplified by the prevalence of disinfection by-products (DBP), particularly the trihalomethane (THM) compounds and bromates in relation to a cocktail of xenobiotic residues.
(30) Neonicotinoids are highly miscible in water. Studies prove that they move readily from the fields of farmers fields into ditches, streams, ponds, lakes and rivers, where they poison insects, arthropods and aquatic invertebrates. Water in the USA contaminated with imidacloprid is found in pools, streams, private wells, wells on golf courses etc. Arguably as a result of lobbying, not one neonicotinoid features among the 33 compounds classed in the Water Framework Directive (WFD) as priority hazardous substances or among the eight other pollutants. Lacking data for UK water I refer to two other European regions where the results of scrutiny are rendered public. Documents from 2006-2011 show aquifers beneath an intensively cultivated alluvial plain known as Berre-l'Etang, north of Marseille, contains residues of éthidimuron, metalaxyl, oxadixyl and imidacloprid in concentrations that exceed the 0,1 μg/l WFD thresholds for drinking water quality. Two separate pieces of research in 2010 by Dutch toxicologist, Dr Henk Tennekes, and a magister student, Teresa C. van Dijk, indicate significant levels of water-borne pollution in the Netherlands. According to the former in several instances related to flower-bulb monoculture, neonicotinoid levels have been recorded in untreated water at 600 times the statutory norm. He also says the Dutch Water Board have found concentrations of imidacloprid in streams and ponds near the bulb growing areas which are 4-5,000 times above the legal limit for this molecule.
The MSc student uses, for practical purposes, the Maximaal Toelaatbaar Risiconiveau (Dutch : Maximum Admissible Risk) as a benchmark and has discovered that neonicotinoid pesticides are applied in the largest amounts where potatoes, horticultural products and chicory are grown.
(31) Teresa C. van Dijk goes on to explain that, in these areas, which are mainly found in the Dutch provinces of Zuid‐Holland, Noord‐Holland, Zeeland and Groningen, imidacloprid can be traced in surface waters in concentrations often far exceeding the MTR norm which, formerly at 13 ng/l has been raised today to 67 ng/l ; a substantial hike which, one could argue, amounts to regulatory sleight of hand, without scientific or medical justification, but introduced to mask and effectively license the currently excessive and alarming pollution rates in the Netherlands.
(32) It is well worth taking the effort to read Teresa C. van Dijk's thesis (Cf. more details in my Proof of Evidence) [Not reported as evidence]. In attempting to correlate neonicotinoid water pollution and recorded losses in insect numbesr, the MSc student herself complains of a lack of appropriate data, saying that her task is complicated by the fact many studies are funded at least in part by large chemical concerns such as Bayer, which produce the pesticides in question. She nonetheless seems to establish insect loss-neonicotinoid pollution correlations that are statistically credible for flies (Diptera), beetles (Coleoptera) aquatic crusatceans (Amphipoda) and caddisflies (Trichoptera).
(33) How does one get MPs to, as it were, 'think outside the box' ? There is clearly no made-to-measure answer. But the chapter on 'Outstanding Questions'[Not reported as evidence] may provide a means of response.
La faillite de l'évaluation des pesticides sur les abeilles LE MONDE | 09.07.2012 à 18h04 • Mis à jour le 09.07.2012 à 18h04 http://www.lemonde.fr/planete/article/2012/07/09/abeilles-la-faillite-de-l-evaluation-des-pesticides_1731092_3244.html
OGM: NKM et Chantal Jouanno se rallient à l'appel des trois anciennes ministres de l'Ecologie
Five demands for change at EFSA ; 10 years of EFSA - 10 years of blind love for industry
French scientists condemn double standards over Seralini
MEPs demand better evaluation of GMOs
Centre for Research and Independent Information on Genetic Engineering (CRIIGEN) press release
La faillite de l'évaluation des pesticides sur les abeilles LE MONDE | 09.07.2012 à 18h04 • Mis à jour le 09.07.2012 à 18h04 . http://www.lemonde.fr/planete/article/2012/07/09/abeilles-la-faillite-de-l-evaluation-des-pesticides_1731092_3244.html
Le chercheur, l'agrochimiste et les abeilles LE MONDE | 23.09.2012 à 19h15• Mis à jour le 23.09.2012 à 19h16
Pesticides not yet proven guilty of causing honeybee declines
Comment on "A Common Pesticide Decreases Foraging Success and Survival in Honey Bees"
Response to Comment on "A Common Pesticide Decreases Foraging Success and Survival in Honey Bees"
SETAC Europe 20th Annual Meeting 23-27 May 2010, Seville, Spain
SETAC Europe 21st Annual Meeting 15-19 May 2011, Milan, Italy
CATCH THE BUZZ - SETAC Summary. We have a problem. Ezezine:
SETAC Workshop on Pesticide Risk Assessment for Pollinators
http://www.setac.org/sites/default/files/executivesummarypollinators_20sep2011.pdf (link suppressed)
Pesticide Risk Assessment for Pollinators: Summary of a SETAC Pellston Workshop http://c.ymcdn.com/sites/www.setac.org/resource/
Environmental Monitoring Advisory Group on Pesticides (EMAG-Pest)
PROBABILISTIC RISK ASSESSMENT FOR PESTICIDES IN EUROPE: Implementation & Research Needs CSL UK 2001
P.A. Oomen, H.M. Thompson (Editors) Hazards of pesticides to bees 10th International Symposium of the ICP-BR Bee Protection Group Bucharest (Romania), October 8-10, 2008 http://www.jki.bund.de/fileadmin/dam_uploads/_veroeff/JKI_Archiv/JKI_Archiv_423.pdf
Spring honey bee losses in Italy : Laura Bortolotti,, Anna Gloria Sabatini,, Franco Mutinelli, Mario Astuti, Antonio Lavazza, Roberto Piro, Donato Tesoriero, Piotr Medrzycki, Fabio Sgolastra, Claudio Porrini http://pub.jki.bund.de/index.php/JKA/article/download/146/131
Henk Tennekes : The systemic pesticides : a disaster in the making http://www.disasterinthemaking.com/
Teresa C. van Dijk : Effects of neonicotinoid pesticide pollution of Dutch surface water on non‐target species abundance
23 November 2012