Submission APP202077
Poncho Votivo
3rd December 2015
Apiculture Industry Technical Focus Group (AITFG)
(National Beekeepers Association (NBA) Technical Committee)
Bacillus firmus
• The application has no manufacturing information;
• On the cultivation and growing of the micro-organism.
• How is it quarantined during manufacture?
• There is a biosecurity risk to NZ bees, if other harmful micro-organisms
piggy back a ride to NZ on shipments of Poncho Votivo.
• We acknowledge the existence of this micro-organism in NZ.
• Why did Bayer not source this organism locally?
• The biggest risks to NZ bees are further importations of micro organisms
that can harm our bees.
Poncho Votivo Application
• Reference 7.2E, Page 29 Application. This statement is misleading;
“The key difference is that Poncho Votivo has B. firmus I-1582 added and a
reduced amount of clothianidin.”
True, the concentration in the drum has been reduced to 508 g/l from 600g/l
in Poncho.
There is no reduction in the amount of clothianidin used on the crop as the
seed treatment rate has been increased by 20%.
From 100 ml Poncho/80,000 maize seeds to 120 ml Poncho Votivo/80,000 maize seeds.
There is marginally more clothianidin used per 80,000 maize seeds when
using clothianidin.
Poncho Votivo 60.96 g/80,000 seeds versus Poncho 60 g/80,000 seeds.
ISO31000 Risk Management Process
Clothianidin first
registered as a seed
treatment in NZ in
June 1993.
Reference: Figure 1, ASNZSISO31000-2009
Missing in New Zealand
There is no EPA
monitoring and review
process of what is
actually happening in
NZ’s environment.
(E & R Report Sect 6.3)
“Maize flats disease”
beehive losses
• Beekeepers have been aware that their hives near maize crops die out
at the time of maize harvest and for some months afterwards
• Major maize cropping areas that this effect has been observed –
Eastern Bay of Plenty, Gisborne plains, around Te Puke and the
Waikato.
• Beekeepers call it “maize flats disease”...but it appears to not be a
disease.
• No conclusive explanation to date.
• This is the first data from an Environmental analysis conducted by
AUT and the AITFG.
The Data
Paul Badger
Bee Hive Losses - Poverty Bay
2004
Beekeeper
Site
Total Hives
Hives lost Date affected
P Badger
Ormond
30
12
Between 14/4/04 & 14/5/04
P Badger
Te Karaka
14
9
Between 18/4/04 & 3/6/04
P Burt
Tangihanga
60
55
Late April / May
B Savage
Newmans Rd ??
??
Numbers not recorded
Year Total
104
76
Hives lost Date affected
3
Between 31/3/05 & 13/4/05
2005
Beekeeper
Site
P Badger
Ormond
Total Hives
Affected
9
P Badger
Te Karaka
19
nil
Moved in 24/5/05
B Foster
J Holden
30
16
Between March & April0
Maize Crop Calendar
Oct
Maize
Crop
Nov
Planting
Treated Seed
Dec
Jan
Feb
Crop growing
Mar
Apr
May
June
Grain Harvest
Time of bee hive
losses
2015
Survey
n=4
Sampling Dates
First Survey: June 29th – Stubble and soil samples n= 4
Second Survey: September 29th & 30th – Soil samples n=45
n = number of samples tested
July
Aug
Sept
Oct
Planting
Stubble
n=
45
First survey
• ‘Jump the fence’ samples taken on 29th June
• One single stubble plant analysed and 3 soil samples.
• Chemicals detected
Sample
Analysis
Clothiandin
Stubble of maize
Hills Labs
#1444176
< 0.02 mg/kg
Soil sample 1
AUT
35 ng/g wet weight
Soil Sample 2
AUT
30 ng/g wet weight
Soil Sample 3
AUT
30 ng/g wet weight
8
Site
Site121
121
Site 111
Site 176
Site 151
9
Second survey
• September 29/30th this year soil samples were taken from 9 maize stubble
paddocks.
• Paddocks were not selected on any basis of past history. We did not survey
growers/owners first to determine the history of the seed treatments used.
• Paddocks sites have been mapped by latitude and longitude.
• 5 samples were randomly removed from each paddock. Wet areas were avoided.
Uncultivated stubble areas were preferred – but some paddocks had been
cultivated – see photos.
• Samples were removed by a trowel, depth of sample 150mm, diameter of sample
50mm. We used a normal soil fertility test selection method (Ravensdown).
• Each sample is more than 10 metres from the next one.
• Each sample is packed in a marked plastic bag, kept in a chilly bin and delivered to
the lab on 1st October.
9/11/2015
10
School of Applied Sciences
Analytical Laboratory
• Supervised by Dr Chris Pook,
Chemical Ecologist
• Neonicotinoid residues
extracted from soil and analysed
by liquid chromatography with
tandem mass spectrometry (LCMS/MS).
9/11/2015
11
Analysis of neonicotinoid residues in soil samples
5/11/2015
Results are in nanograms
of clothianidin a.i. per gram
wet weight of soil
Dr Chris Pook, AUT
clothianidin clothianidin
Mean ng/g
SD ng/g
Site
Paddock sample number
Samples
n
Matamata
101
5
17.5
12.06
Awakeri
111
5
4.7
2.74
Poroporo
121
5
11.2
4.63
TeTeko
131
5
2.8
0.55
Poroporo
151
5
2.1
2.4
Whakatane
161
5
2.5
2.4
TePuke
171
5
3.8
0.8
Te Puke
176
5
2.2
0.35
Gisborne
C1
5
26.7
46.48
Instrument Detection Limit
0.44
calculated 03-11-15
©2015
This data is Copyright of Auckland University of Technology. ©2015
Publication is not authorised without the permission of the Copyright holder.
The analysis presented in these results is being
repeated to verify the results. The chart is the
Phase 1 testing results only.
Survey Results
• No organophosphates or carbamate chemicals detected.
• All samples taken when analysed showed both clothianidin and
imidacloprid.
• We did not look for the metabolites of clothianidin.
• We did not survey growers/owners first to determine the history of the
seed treatments used.
• We did expect to find some non contaminated paddocks. This chemicals
seem to be widespread in the environment.
• Persistence of these neonicotinoids in these NZ soils is we believe
significant. 11 months after date of sowing.
• There is enough chemical in this environment to give a lethal dose to a bee,
which weighs 0.1 to 0.12 grams.
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Future Plans – continue the study.
• Complete Phase 2 – check and verify the test results achieved to date.
• Two more stages are planned;
• Stage 2 Return to these same paddocks at harvest
• Introduce hives to the area prior to harvest and monitor the harvest and period
immediately after.
• Sample and test – soils, stubble, beehive (nectar, wax and bees), for pesticides.
• Observe bee foraging behaviour in the stubble.
• Stage 3 – repeat Stage 1 testing (repeat these tests in September 2016).
• A funding requirement of $20,000 is required to complete the
project.
All donations gratefully received. See me afterwards.
9/11/2015
14
77A Control – Application Rate
• EPA has set a maximum seed treatment rate of 120ml / 80,000 maize seeds.
Okay for maize, what about grass seed and forage brassicas?
• This is the extra amount of Poncho Votivo released for a farmer sowing maize at
maximum recommended rate versus 80,000 seeds /hectare.
Seed Company
Min Seeds per
hectare
Max Seeds per
hectare
% Poncho
Votivo
Above min
EPA
80,000
None
Corson Seed
80,000
120,000
50% +
Pacific Seeds
80,000
115,000
44% +
Pioneer Seeds
88,000
110,000
27.5% +
The EPA needs to use an Environmental Exposure Limit for soils as the control
Request for the EPA
• The EPA to encourage the use of NZ environmental testing when
conducting a risk assessment.
• Apply to clothianidin an Environmental Exposure Limit (EEL) for soils.
• Review the use of neonicotinoids with respect to their use.
Is the prophylactic use of these pesticide widespread?
What needs to be done so use of these products for curative purposes?
• Have the EPA make better decisions with NZ data in their risk
assessments.
Acknowledgements
• Apiculture Industry Technical Focus Group (AITFG) (NBA Technical
Committee)
• Beekeepers; Mossops Honey, Whai Hua Bees, Barry Foster for
providing samples, history of problem and introductions.
• Farmers and Maize contractors who permitted sampling of their
paddocks.
• AUT School of Applied Science for funding the research to date.
• Dr Chris Pook and Iana Gritcan for conducting the scientific analysis.
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