(Notes from a presentation to SEEOG, by Dr. Keith Tyrell, Director of Pesticide Action Network UK – May 2013)

There will always be questions in science. Policy makers cannot wait until there is 100% certainty, because there will never be 100% certainty. The case of DDT showed that policy had to move in the absence of scientific certainty, indeed it had to move ahead ofscientific consensus. Which is why we have the Precautionary Principle PP. And it is why the PP is enshrined in European Law – in the Lisbon Treaty no less.

So let’s remind ourselves what the PP is – I should say here that the PP has numerous definitions and interpretations, but I think it boils down to three basic elements:-

  1. Scientific uncertainty should not automatically preclude regulation of activities that pose a potential risk of significant harm
  2. Regulatory controls should incorporate a margin of safety; activities should be limited below the level at which no adverse effect has been observed or predicted
  3. Activities that present an uncertain potential for significant harm should be prohibited unless the proponent of the activity shows that it presents no appreciable risk of harm.

Stewart (2002)

The precautionary principle should be more than adequate to prevent another silent spring, but unfortunately, again and again we see the principle which is aimed at protecting the common good trumped by vested interests. Environmental policy is NOT based on the PP.

And I’m now going to give you a clear example where our regulators are failing in their duty and are ignoring the precautionary principle

Pesticides and Pollinators

Bees and pollinators have been in decline around the globe for the past 20 years. In some places these declines have become catastrophic. Some countries are seeing losses of between a fifth and a third each year. This decline has coincided with the widespread adoption of a new class of insecticide: neonicotinoids.

Attention has focussed on honeybees because there is more data about their declines. They have an economic value – they produce honey – and are therefore monitored. But we believe that the declines of other pollinators like butterflies, moths and solitary bees are at least as great.

This is a big deal

Pollination is estimated to be worth €153 Billion

Out of some 100 crop species which provide 90% of food worldwide, 71 of these are bee-pollinated.

At the moment we are trying to feed ever more people with less and less land. Pressures are mounting urbanisation, biofuels, manufacturing, climate change – all of these are reducing the amount of land available. The last thing we need is to lose our pollinators

There could be lots of causes for the declines: varroa mite, husbandry, habitat loss but little doubt that Pesticides are part of the equation.

There are five neonics licensed for use in UK – Imidacloprid, clothianidin, acetamiprid, thiacloprid, thiamethoxam.

Neonicotinoids are neurotoxins that act on invertibrates’ information processing.

They are systemic pesticides in that they are used as seed dressings and soil treatments that are then taken up into the very structure of the plants and kill insects that try to feed on them.

Highly bee toxic – imidacloprid is 7,000 times more toxic to bees than DDT and just as persistent.

Imidacloprid is the world’s best selling pesticide netting Bayer over $860 million a year.

Worldwide, neonics account for nearly a quarter of all insecticide sales worth around Euros 1.5 billion in 2009

These are widely used

Every time a bee collects pollen from a plant treated with imidacloprid gets a little zap of the insecticide and these doses are cumulative and irreversible.

And then it takes the contaminated pollen back to the hive

Even if it doesn’t kill the bee, it disrupts its ability to forage, communicate and navigate – bees that have been affected behave strangely – can’t waggledance – and neglect their eggs and larvae

As the sunflowers opened in France in 1994 france’s honeybee population suddenly collapsed – 1994 was the first year imidacloprid was used in France; Germany experienced something similar in 1998.

In both of these cases the cause was thought to be the release of huge amounts of imidacloprid laden dust during sowing rather than through the systemic nature of the pesticide.

As a result both of these countries have severely restricted neonics; Italy and Slovenia have also acted.

The case of Italy is particularly interesting in that they recognised that there was scientific uncertainty and therefore put in place a new monitoring system designed specifically to see if the ban had any impact on bee colonies – and lo and behold it found that bee colonies recovered.

But the EU and UK are way behind. The UK govt. refuses to acknowledge there is a problem and this meant that we had to rely on the EU to act.

EFSA and Commission Response

As long ago as last year, the European Food Safety Authority admitted that there were some major flaws in the way that neonics were assessed, and earlier this year they issued a truly damning report – really unusual.

What is the problem

Basically, the risk assessment process for evaluating pesticides cannot cope with systemic insecticides.

The tests and protocols that pesticide manufacturers must follow were designed for older pesticides which were:

  • applied via spraying
  • Degraded rapidly
  • Exposure route is acute contact
  • LD50, NOEL, (Tier 1) just 48-96 hours
  • If no clear conclusions = Tier 2 (semi field, but no standard protocols)
  • Only honey bees
  • Only worker bees – short-lived (what about, queens, larvae, nurse bees, those that overwinter and feed on pollen reserves, etc.)

Systemic insecticides on the other hand have the following characteristics:

  • Translocation to all parts of the plant
  • Oral exposure via nectar, guttation drops
  • High persistence in soil and water
  • Toxic and much lower doses
  • Sub-lethal and chronic effects
  • Cocktail effect – commonly fungicides such as propiconazole increase the toxicity of some neonics by 1000-fold
  • Impacts on viruses and fungal infections (eg nosema – 3 studies showed they were more susceptible)

The European Commission responded to this report by proposing partical restrictions on 3 neonics – imidacloprid, thiomethoxam, clothianidin. It at first blocked proposals by abstaining, but when the balance switched, it actively opposed the move by voting against the ban.

Why?

Defra’s response was astonishing in its complacency, and shows clearly that the precautionary principle plays little or no part in UK pesticides policy.

Defra published its own paper which while effectively admitting there were gaps in the assessment process for neonics and other systemic pesticides, but said it would not do anything.

It has stuck to this in spite of mounting evidence and public outrcry.

questions whether the doses that bees are exposed to in the new studies are “realistic” – it does not even recognise that a margin of error might be desirable [refer to point  2 of PP above]

Says there is no measurable impact from “current uses” of neonics – There is no recognition that usage patterns are not static. In the past, defra has argued that other countries such as France and Italy experienced problems because of their cropping systems – ie lots of maize and sunflower – and neither of these are major crops in the UK, so there’s no need to do anything.

But cropping systems do not stay the same – over the past couple of years we have seen a massive increase in Oil Seed Rape. OSR currently accounts for around 60% of neonic use in UK, it is virtually impossible to buy OSR seed that is not treated with neonics. Bees love OSR, they will avoid other wild flowering plants and head straight for OSR, as the acreage grows, the exposure of bees and pollinators to neonics will only increase.

Concerns about impacts on the profitability of farming

Most ridiculous and depressing though was defra’s final response – Now let’s remind ourselves that bees are declining, there is no argument about that. The dispute is over what is causing those declines.

I am going to quote this

“none of the studies gives unequivocal evidence that sublethal effects with serious implications are likely to arise.” [refer to point 3 of PP above]. It is not up to us to prove there is no impact, it is up to the people who sell the pesticides to prove that their products are safe.

So why does the UK refuse to act, even when other countries have acted – One explanation is that there is just a lack of political will.

Industry lobbying – attempts to sow disinformation (shift attention away from neonics); threatening letters sent to EFSA, cosy relationship between regulators (and farming industry) and industry – FERA;

The other reason is that the public have not placed pressure on government, so politicians have little incentive to act.

In France there were mass demonstrations by farmers and beekeepers before the government acted; in Italy beekeepers went on hunger strike.

We just don’t do that sort of thing in the UK. We trust our regulators to do their job and to protect our environment. At the moment, they are not doing so. But I think things will change. Pressure is mounting: March of the beekeeper, Avaaz and 38 degrees, 80,000 emails to Paterson – cyber attack or concerned citizens expressing their democratic rights.

So what does the case of bees and neonics tell us – things have not changed much since RC’s time. Industry continues to throw huge amounts of money to protect its products, and deploys all sorts of tactics to foster uncertainty.

Meanwhile, our regulators are paralysed, and in spite of the fact that the PP exists and is enshrined in law, seem incapable of action.

Government only acts when there is a public outcry

Further information:
Pesticide Action Network UK