Pesticides risk assessment process
Controls on pesticides work at a number of levels, initially by identifying and managing risk. Under European pesticides legislation, pesticide active substances are evaluated at Community level. If an active substance meets EU safety requirements the products containing that active substance can then be authorised at Member State level, taking into account that country’s individual agronomic, climatic and dietary requirements.
In the UK, pesticides can only be sold or used after they have been approved. As part of this approval process, the Chemicals Regulation Directorate (CRD) of the Health and Safety Executive (the Government body responsible for regulating pesticides) carries out checks to ensure the risks that can arise from the use of these products are not unacceptable. This will include an assessment of the toxicity of each product and the ways in which spray operators, the public or environment (in particular honey bees) may be exposed to it either directly or indirectly (eg consuming treated produce). CRD routinely restrict the way products can be used (e.g. specifying dose rates, timing and place of application) to ensure protection of human health and the environment. A key part of the authorisation process of pesticides is an assessment of risks to wildlife, including foraging bees and bee hives.
Uses of neonicotinoid insecticides
Some of these pesticides are approved for use as seed treatments, some as foliar applications and some for both. In terms of area treated almost 90% of the use is as seed treatments although foliar use is increasing and includes use on crops such as oilseed rape.
These pesticides prevent damage to important crops such as cereals, oilseed rape, brassicas and sugar beet from pests such as aphids. When the aphid feeds on the crop it can introduce viruses which cause disease such as barley dwarf yellow virus (affecting cereals) and beet yellow virus (affecting sugar beet). They can have serious effects on crop yields and quality. The seed treatments are important as they provide an alternative mode of action to organophosphate and pyrethroid insecticide sprays and play a key role helping to prevent the build up of resistance in the pests concerned.
Resistance to the main alternatives to neonicotinoids (pyrethroids and organophosphates) has emerged to a significant degree in pollen beetle (which is a widespread pest of oilseed rape) in France, Poland and Germany. Although resistance in the UK is limited to relatively small pockets of Eastern England, use of foliar neonicotinoids is the recommended agronomic strategy for containing resistant communities.
Action in other Member States
Four EU Member States have placed restrictions on the use of neonicotinoid insecticides. However, there were very specific circumstances in Germany involving neonicotinoid seed treatments that led to incidents of significant losses of bees in 2008. These factors included the application of high doses and the use of insufficient sticker to hold the pesticide onto the seed and the timing of sowing of treated seed (at the same time as neighbouring crops were flowering and on which bees were actively foraging). Initially the German authorities withdrew approval for eight products used on maize and oilseed rape, but since then they have re-instated the use of four products containing imidacloprid (one of this group of pesticides) for use on oilseed rape. Later in the year, Italy and Slovenia took action on similar products. The Slovenian action followed incidents similar to those in Germany, but the Italian action is based on the German experience, and is a precautionary measure while it develops a monitoring system similar to the UK Government’s Wildlife Incident Investigation Scheme (WIIS). France has had restrictions on use of certain neonicotinoid pesticides since the 1990’s, but does authorise their use on a number of arable crops, fruits and vegetables.
Bee health
In recent years, Britain’s honey bee colonies have suffered significant losses, due to a combination of factors including poor spring/summer weather, the Varroa mite, and other husbandry issues. The Food and Environment Research Agency’s (Fera) National Bee Unit (NBU) has been investigating the causes of cases of these losses. Analysis of the results of this research shows that the most important risk factor in the mortality or weakening of colonies is Deformed Wing Virus, a virus transmitted by the parasitic Varroa mite, clearly indicating failed or unsuccessful treatments of mite infestations. This highlights the importance of improving standards of husbandry and is in agreement with results from earlier studies investigating abnormal colony losses in 2007. A final report with the results from these investigations has been published on the NBU’s BeeBase website (www.nationalbeeunit.com).
A scientific report submitted in December 2009 to the European Food Safety Authority, entitled Bee Mortality and Bee Surveillance in Europe, showed that in recent years colony losses in England and Wales were generally less than those in a number of other European countries. Contact the Food and Environment Research Agency for more detailed information (http://www.fera.defra.gov.uk/plants/beeHealth/).
Research
As part of its pesticides research programme the Government is funding a number of projects in support of the development of the pesticides risk assessment process. Some of these specifically relate to the potential impact of pesticides on honeybees, both from wide scale professional use and home-garden use of insecticides. To this end, the Insect Pollinators Initiative (IPI) was announced on 21 April 2009 and up to £10 million of funding is being made available to research teams across the UK under the Living With Environmental Change (LWEC) partnership. The IPI is a joint initiative between the Biotechnology and Biological Sciences Research Council (BBSRC), Defra, the Natural Environment Research Council (NERC), the Scottish Executive and the Wellcome Trust. Defra is contributing £2.5 million over 5 years to the Initiative. Research funded by the Initiative will provide a much needed evidence base for policy makers, farmers, growers and producers to develop new policies, strategies, tools, techniques and methods that will reverse the worrying decline of pollinating insects. Details of the nine projects that will be funded under the Initiative were announced on 22 June 2010. These have been published on the BBSRC’s website (http://www.bbsrc.ac.uk/).
2009 Buglife report
Buglife’s 2009 report was reviewed by CRD for any new scientific information which might be of relevance for the pesticides risk assessment process, and CRD’s assessment was considered by the independent Advisory Committee on Pesticides (ACP). (See linked documents under Related Documents below). The ACP concluded that the Buglife report highlighted a need in the risk assessment process for data on the impacts of neonicotinoid pesticides on overwintering of bees. This is an area where regulatory science has developed recently, and the need for such data has already been recognised in the latest draft risk assessment adopted by the European and Mediterranean Plant Protection Organisation (EPPO). Inclusion of this requirement in the EU regulatory process means that it will apply to all substances when harmonised data requirements are brought into force. Government is also aware that some pesticide approval holders are already carrying out work to develop data on overwintering effects of neonicotinoid insecticides on bees, but that those data have not raised any particular cause for concern. On the basis of current evidence, we do not consider there is a justification for requiring such data in advance of the timetable for the EU regulatory process.
CRD will continue to be involved with the development of bee risk assessment methodology, particularly through the revision by the EPPO. CRD would, of course, act on any substantive evidence should incidents occur in the UK and will continue to keep abreast of research and developments in other EU Member States and elsewhere to see if they are relevant to the UK.
US EPA memo on clothianidin
The US Environmental Protection Agency has issued a statement about the memo on clothianidin raised in connection with this issue. This can be found on the EPA website at http://www.epa.gov/pesticides/about/intheworks/honeybee.htm. The memo essentially concludes that this type of insecticide could pose a risk to bees if used incorrectly, and raises no new issues. The Government is fully aware of all the points covered in the memo and they have been fully addressed in the European regulatory regime.
February 2011
Related Documents
ACP Paper 6 (341/2010) on Buglife Report
Update to CRD Assessment
ACP Paper 6 (341/2010) - Appendix 1
ACP Paper 6 (341/2010) - Appendix 2
ACP Paper 6 (341/2010) - Appendix 3
ACP Paper 6 (341/2010) - Appendix 4
ACP Paper 6 (341/2010) - Appendix 5
ACP Paper 6 (341/2010) - Appendix 6
ACP Paper 6 (341/2010) - Appendix 7
ACP Paper 6 (341/2010) - Appendix 8
ACP Paper 6 (341/2010) - Appendix 9
ACP Letter re Buglife Report
