Previously, I have drawn attention to the question Are Neonicotinoids Even Legal?
A new report by EFSA casts serious doubt on the notion that they are.
“In some cases EFSA was unable to finalise the assessments due to shortcomings in the available data.”
“All of these factors mean that EFSA’s scientists were unable to finalise risk assessments for some of the uses authorised in the EU, and identified a number of data gaps that would have to be filled to allow further evaluation of the potential risks to bees from clothianidin, imidacloprid and thiamethoxam.
Finally, it is highlighted that limited information was available for pollinators other than honey bees; therefore the risk to these other pollinators should be further considered.”
Quite apart from the issue of other pollinators, let’s remind ourselves of EU law with regard to insecticides and honey bees:
EU Regulation 1107/2009 (Annex II, 3.8.3.) states:
“An active substance, safener or synergist shall be approved only if it is established following an appropriate risk assessment on the basis of Community or internationally agreed test guidelines, that the use under the proposed conditions of use of plant protection products containing this active substance, safener or synergist:
will result in a negligible exposure of honey bees, or
has no unacceptable acute or chronic effects on colony survival and development, taking into account effects on honey bee larvae and honey bee behaviour."
If EFSA were
not able to finalise risk assessments, how can neonicontinoids be legal since
it cannot be declared that they have not been sufficiently tested for ‘acceptable risk’?
The report also states that "Only uses on crops not attractive to honey bees were considered acceptable".
But:
1. Pesticide risk assessment already conducts tests on very few species, which are meant to be representative for invertebrates as a whole. As it is, assessment only requires that pesticides are tested on:
- Daphnia magna (water flea)
- Apis mellifera (honey bee)
- Earthworms
- As well as “The risk to non-target arthropods is routinely assessed under 91/414/EEC. Annex II of 91/414/EEC states that data on two sensitive standard species as well as data on two crop relevant species are required.
If effects are observed with
species relevant to the proposed use then further testing may be required.”
2.
Thus, whilst I
welcome any restrictions on neonicotinoids, I am concerned that EFSA, in their
focus on honey bees, have not taken into account that already, very few species
are assessed.
Some species such as lady birds, lacewings, moths, butterflies and a range of other species may for various reasons, visit non-flowering crops.
I am not aware of EFSA examining the data on the
other species, as they have for honey bees. Therefore, I believe it is
not simply safe to assume that restriction of application of neonicotinoids on
non-flowering crops, is sufficient.
3. The vast majority of invertebrates are beneficial or harmless. Neonics are mobile in soil and ground water, and so it is not merely a case of ‘what is applied on farm crops’ either.