Neonicotinoids
5 April 2013
Formal Statement
Position Statement
Following the release today of the All Party Environmental Audit Committee’s report into the
effects of neonicotinoids, the Bumblebee Conservation Trust supports the call for the use of the
precautionary principle as it is defined in Article 191 of the Treaty on the Functioning of the
European Union. The Trust recognises that there are many factors which could be responsible
for the loss of insects that pollinate plants including climate change, disease, loss of habitat,
heavy metal toxins and pesticides. The Trust believes that a ban, temporary or otherwise needs
to be based on sound scientific evidence and that despite the weight of evidence now available,
believes that further testing to ascertain the effects of these chemicals in the wild is essential in
order to determine whether such chemicals should be permanently banned or their use
restricted.
In calling for the precautionary principle to be invoked, the Bumblebee Conservation Trust
continues to urge governments in the UK and those in Europe to:
1. Enhance, improve and extend the habitat on which bumblebees and other wild
pollinators depend.
2. Research and evaluate the effects neonicotinoid insecticides have on pollinators and
other biodiversity when used in the field.
3. Work with other European countries in assessing the risks associated with the use of
neonicotinoid insecticides, based on scientific evidence, not just on the honey bees but
also on other bee species.
4. Improve best practice guidance on the limited use of neonicotinoids.
5. Improve pesticide regulatory assessments to take account of sub-lethal effects.
6. Research the economic and environmental trade-offs between using neonicotinoid
insecticides, restricting or banning their use and increasing habitat available for
bumblebees.
7. Place higher priority on developing safe alternatives.
8. Improve the monitoring of bumblebees and other pollinators.
The Precautionary Principle
The Bumblebee Conservation Trust calls for use of the Precautionary Principle as defined in
Article 191 of the Treaty on the Functioning of the European Union which can be found at:
http://europa.eu/legislation_summaries/consumers/consumer_safety/l32042_en.htm).
If invoked correctly, on the basis that the three preliminary conditions (criteria) are met, this
principle may be used to stop distribution or order withdraw of neonicotinoid pesticides –
temporary or otherwise. The Bumblebee Conservation Trust supports the introduction of a
temporary moratorium on the use of these pesticides assuming the three criteria have now
been met. The Trust continues to believe that further evidence is needed in order to
understand whether these pesticides significantly harm bumblebees in the field and that this
evidence is essential in order to determine whether such chemicals should be permanently
banned or their use restricted.
The Bumblebee Conservation Trust’s position explained
Understanding the interactions between bumblebees and neonicotinoids is a complex issue,
fraught with difficulty, which is why the Bumblebee Conservation Trust has taken time to
review its current stance (agreed by the Trust’s Board on 5 December 2012) and discuss our
position with members, partners, scientists, landowners and other organisations.
The Bumblebee Conservation Trust’s position is based on its best understanding of the
information currently available. The Bumblebee Conservation Trust is not aware of evidence
which shows that neonicotinoids are the primary cause of widespread declines in bumblebee
populations but it does support the view that pesticides are one of many contributing factors to
the decline of these species. The Bumblebee Conservation Trust continues to believe that the
biggest threat to bumblebee losses is undoubtedly habitat loss and fragmentation. For this
reason, creating new bumblebee-friendly habitat, and restoring degraded habitat for the
benefit of bumblebees and other pollinators, remains our primary focus.
Neonicotinoids are a relatively new generation of systemic pesticides. Unlike their
predecessors, they are generally not sprayed onto the plant but are usually applied to the seed.
As the seed germinates and the plant grows the pesticide is translocated throughout the plant.
These insecticides are highly toxic to the target insect pests such as aphids, which suck the
plant’s sap, or others which eat the plant’s leaves (which is what these chemicals are designed
for). However, research has shown that miniscule amounts are consumed by bees as they sip
nectar from the plant or gather pollen to take back to the nest. Laboratory studies, have
indicated losses in the number of queens which a nest produces, a reduction in the number of
worker bees produced, and altered behaviour of foraging honey bees.
The difference between a chemical having no significant impact and having a damaging impact
relates to dose and exposure. It is not clear to the Bumblebee Conservation Trust how the
doses fed to bees in laboratory trials reflect doses picked up by foraging bees in the wild.
Current information does not make it clear whether there is a “safe” level of dose or exposure
for bumblebees as far as neonicotinoids are concerned.
In the UK, five neonicotinoids are authorised for use in agriculture (acetamiprid, clothianidin,
imidacloprid, thiacloprid and thiamethoxam) and have been approved for use by the Advisory
Committee on Pesticides (ACP). The UK Government licensed the use of neonicotinoids over
twenty years ago based on risk assessments provided by Bayer and Syngenta. Having licensed
the use of these chemicals, reversal of that decision has to be taken in a proportionate,
evidence-based and procedurally correct way. The Bumblebee Conservation Trust understands
that the ACP started to review its position in January 2013 and this is ongoing. The Bumblebee
Conservation Trust continues to urge that, in the absence of further research information, the
precautionary principle should be applied.
2
The Bumblebee Conservation Trust believes that understanding these issues is essential if
Governments are to change their policy on the use of neonicotinoids. The Bumblebee
Conservation Trust therefore urges better collaboration between researchers, the chemical
companies who produce these pesticides and the users of these chemicals. Unfortunately, the
Bumblebee Conservation Trust believes that the recent statement from the European
Commission contains no proposals for further research to provide evidence for the 2-year
review of the new policy.
In January 2013 the European Food Safety Authority (EFSA) published a risk assessment which
concluded that clothianidin, thiamethoxam and imidacloprid (all neonicotinoids) should not be
used on crops attractive to honey bees. Unfortunately the EFSA did not consider bumblebees,
arguing that the honey bee (Apis melifera) was a suitable model for all bees, including
bumblebees and solitary bees. This theoretical evaluation has now prompted the European
Commission to call for a two year ban on the restricted use of neonicotinoids on flowering
crops such as oilseed rape, sunflower and cotton.
Regardless of whether a two year ban takes place or not, the Bumblebee Conservation Trust
believes that it is essential that research continues to evaluate the effect of neonicotinoids in
the fields where crops are grown. It urges government to support research designed to provide
evidence as to whether or not neonicotinoids used under field conditions significantly harm
bumblebee populations. The Bumblebee Conservation Trust also calls for research to be
undertaken which addresses whether or not these chemicals make a significant difference to all
pollinator populations.
The Bumblebee Conservation Trust will continue to review its position as further research
comes to light. For the time being, on the basis of the evidence currently publically available,
the Bumblebee Conservation Trust continues to advocate the application of the precautionary
principle in the licensing and use of neonicotinoid pesticides.
Bumblebee Conservation Trust
5 April 2013
3