On May 23rd the European Food Safety Agency (EFSA) published its scientific opinion on how pesticide-risk for bees should be assessed. This thorough scientific analysis finally confirms what many have claimed for years: that systemic pesticides, blamed for killing bees and wildlife on a vast scale have never been properly evaluated before their introduction into the market.
After a series of published analyses, letter exchanges and public criticisms from beekeepers, as well organisations working on governmental transparency, the Commission gave the EFSA the job of reviewing the risk assessment of these pesticides for bees, before these products are released onto the market.
For many years, the pesticide manufacturers themselves have defined the testing methodologies; they managed to insert their own people into the expert-groups, which actually define the testing-methods. In effect, the pesticide industry was running the entire show: defining its own rules for authorisation and licensing of its own products in the market. EFSA has now reviewed these industry-defined methodologies and found many gaps and deficiencies. Indeed, EFSA has taken a bold and brave stance by publishing this scientific opinion.
For the last thirty years, tests for the authorisation of a pesticide only considered acute toxicity: whether bees were killed within hours of a pesticide being applied. Pesticides were sprayed onto a field of crops and the impact on bee colonies would be studied and assessed. However, the introduction of systemic pesticides in the early 1990s posed a new and revolutionary threat to bees (which the existing tests could simply not assess adequately). Systemic pesticides are applied both in spray or as seed-dressings or soil treatments; the insecticide is absorbed into the plant and rapidly perfuses the entire structure of the plant: roots, stem, sap, leaves, flowers, pollen and nectar. The new systemics were also hyper-toxic by comparison to the older insecticides (lethal or damaging to bees at just a few parts per billion; Imidacloprid for example is more than 7,000 times more lethal to bees than was DDT). The older pesticides were applied to the leaves of the crop externally (and might remain active for only a few days) before rain and sun rendered them harmless. However, systemic pesticides remain toxic within the plant structure for the entire growing season (weeks or even months). As a result, bees feeding on the nectar and pollen of such treated crops are exposed to minute doses of hyper-toxic insecticides over very long periods of time.
Therefore the existing tests, which had only considered the acute toxicity of a pesticide in order to assess its potential impact on bees, could not evaluate or measure the effect of systemic pesticides, which act over very long periods and at sub-lethal doses. Unfortunately, the incorrect application of these short-term tests allowed the neurotoxic systemic pesticides onto the market: these include the neonicotinoids and the phenyl-pyrazoles, such as fipronil. These are now used on vast areas of crops (more than 240 million acres of crops in America are treated with neonicotinoids).
EFSA’s report clearly shows that the theoretical legal procedure (under Regulation (EC) 1107/2009) which supposedly allows Member States to withdraw a pesticide if it is seen to be causing problems, or if new scientific evidence suggests it should be withdrawn; -this procedure is in fact useless. It would never enable Member States to protect human health or wildlife from damage.
Sadly the EFSA report fails to address the crucial question: since it has been admitted that the older methods of risk-assessment were wrongly used to assess the toxicity of the systemic pesticides, will the use of these products now be suspended until they are completely re-evaluated and re-assessed? If this question is not answered. Then arguably EFSA’s report may be condemned as a smokescreen; a palliative concession which appears to address beekeepers concerns, but which in fact allows the use of these wrongly-tested pesticides to continue as normal; in short, business as usual.
EFSA’s scientific opinion will form the basis for a Guidance Document to help define new and more appropriate tests, which pesticide companies must carry out to prove that their products do not harm bees. It will also serve as a manual for the evaluation of dossiers by public authorities. Regulation (EC) 1107/2009 envisages a complete risk assessment of pesticides before they are released onto the market; this includes an environmental risk assessment of their impact on bees.
If governments at EU and national level do not bite the bullet, and address this crucial failure on their part, they will only confirm what many beekeepers have suspected all along, namely, that the pesticide manufacturers are in the driving seat. This is completely unacceptable in a democratic society where agricultural policy is meant to be based on the neutral, science-based risk assessment of pesticides, rather than on the narrow economic self-interest of a small group of corporations.
Let us hope that the positive steps, which EFSA has already taken in recommending better and more stringent methods of evaluating pesticide risks, will not be watered down or kicked into the long grass by selfish commercial interests.