Pesticide tests fail the bees

Why have beekeepers been let down by our alleged system of pesticide-testing? Is it just sheer incompetence, or is there a growing conflict of interests? It is impossible to judge. But the question cannot be avoided: how could these notoriously weak tests, for assessing the risk which pesticides pose for bees, how could the wrong tests be used for almost twenty years, to justify licensing the latest generation of insecticides? Licensed since the early 1990s, the systemic neonicotinoids (Gaucho, Regent etc) were the focus of intense controversy before they were banned, at least partially, from the market. The latest neonicotinoid-based pesticide, ‘Cruiser’ (thiamethoxam), has recently been banned for use on oilseed rape in France; a decision challenged by Syngenta, the manufacturer. But the complete failure of the entire testing regime is far more troubling, because the risk-assessment tests were only recently revised and approved in 2010. The questions about this have not come from Greenpeace or Friends of the Earth, but from the European Food Safety Authority itself (EFSA) which has probably never endorsed such an embarrassing document. Released in late May, its 275 pages of technical text passed almost totally unnoticed by most people.

Why was such a report issued? Urged on by the European Commission, EFSA commissioned a group of fifteen scientists (some from outside the agency) to appraise the standard test-procedures, used to evaluate the risks which pesticides pose for bees.
What did the report conclude? These testing-protocols, originally designed to assess harmful effects from the spraying of insecticides, are completely useless for testing neonicotinoids; these out-of-date methodologies simply cannot be used to assess "systemic pesticides" – which are applied as seed-coatings or as soil-treatments, and permeate the entire structure of the plant during its growth.

In general, the report said: "Intermittent and prolonged exposure to systemic pesticides cannot be assessed in the laboratory"; neither can such tests assess "pesticide exposure by inhalation”; nor “bee larvae’s exposure to pesticides."
Existing calculations of the insects’ exposure to systemic-insecticides are inherently flawed: they do not take into account toxic guttation droplets exuded from plants treated with systemic insecticides, which the bees drink. Neither do they include the disastrous effects of toxic insecticide dust spread from coated seeds during the planting season

"Similarly”, the report adds, “the effects of sub-lethal doses are not fully addressed by standard tests." Such low-doses do not kill bees directly, but may affect their ability to navigate and find the way back to their hive, as recently demonstrated in a study conducted by Mickaël Henry (INRA) and published March 30th 2012 in the journal Science.

The standard field-tests are also criticized. The colonies of bees tested were too small, and bees were not exposed to the pesticide for sufficient time. Harmful effects, even when detected, were often not recognised as ‘significant’ due to the small number of bees employed.

These are not the only criticisms. Among "major weaknesses" in the testing regime, pointed out by the reporters, are the size of test-fields treated with insecticides. The study-hives were placed within a pesticide-treated test-area of just 2,500 square metres, within an untreated hectare of the crop in question (10,000 square metres). However, the report concluded that such a test-area represents only 0.01% to 0.05% of the actual area visited by a forager bee over its normal foraging range . Therefore, the bees exposure to the test-pesticide was arguably several thousand times lower than the actual exposure, especially if the colonies were located in areas of intensive crop monoculture, all using the same pesticide.

In addition the bees should have been tested to find out whether minute doses of systemic pesticides triggered diseases, which would otherwise be blamed on viruses or parasites . Recent work by Cyril Vidau (INRA) in June 2011 and published in the journal PLoS One, have revealed synergies (enhanced action) between fipronil (Regent), thiacloprid (a neo-nicotinoid) and Nosema, a common fungal disease which kills bees.

These failures of the testing regime are "an open secret", in the words of a French bee researcher, who asked to remain anonymous. Indeed, for many years, beekeeper associations and environmental groups have demanded a strengthening of these "guidelines" and test-protocols. But this has all been in vain, despite an increasing number of studies published in scientific journals since the mid-2000s, highlighting the shortcomings of standard pesticide-testing.
Why this inertia? How and by whom were these test-protocols developed, that seem blind to the truth? Janine Kievits, a Belgian beekeeper and member of the European Coordination of Beekeeping said : "In 2006, we asked ourselves: how could these pesticides, that we judge to be the main cause of the decline of bees, how were they ever approved at European level? In the appendices of the European Directive on Plant Protection, we note that the guidelines for these tests were devised by the European and Mediterranean Plant Protection Organization [EPPO]." Additional guidelines which complement those of EPPO, are issued by the Organization for Economic Cooperation and Development (OECD).

EPPO is an inter-governmental organization of fifty member states, based in Paris.
"The question of bees is a very small part of our business," said Ringolds Arnitis, its chief executive. Having no expertise in-house, the EPPO delegated - the task of framing these famous standardized tests to yet another agency - the International Commission on Plant-Bee Relationships (ICPBR), a quasi-informal body, created in 1950 and based in the University of Guelph (Canada).

"When we learned that this organization was going to convene to reform the so-called standardized tests, we decided to attend the conference as observers, says Ms. Kievits.
The ICPBR conference was held in Bucharest in October 2008."

The small delegation of just three beekeepers witnessed and recorded the proceedings.
Our first surprise, says Janine Kievits was that: "the meeting started with a speech of thanks to the generous sponsors of ICPBR, who were: BASF, Bayer CropScience, Syngenta and DuPont."

Contacted by Le Monde, the working group of ICPBR on bee protection confirms the financial support of the leading manufacturers of pesticides. But adds that the main source of income was the costs paid by those attending the conference. And that "without these external funds from industry sponsors, the costs of participation would have been higher," preventing "maximum participation of delegates from beyond industry".

The three beekeepers kept minutes of the working groups which met to update the standardized tests for assessing pesticides. "We were in a very friendly atmosphere, with very nice people, who proposed amendments that were profoundly unnacceptable”, says Ms. Kievits. “To give just one example, one of the risk-calculations presented, proposed to redefine a pesticide as 'low risk 'if less than 50% the bees died after chronic exposure to an "LD50" dose. So, the proposal was that a pesticide should be defined as 'low risk' if it only killed 49% of the bees! This was just unbelievable. We could have ‘dropped dead’ with astonishment! "

On several similar contentious issues, the beekeepers asked if they could submit comments, in the hope of changing the final recommendations of the Working Group.
"We sent our comments within fifteen days as requested, but not a single comment was accepted," said Ms. Kievits. The beekeepers also sent copies of their criticisms to the relevant agencies of all the EPPO member-states. With the exception of the Swedish Chemicals Agency (KEMI), not a single one responded. However, in a letter which Le Monde has obtained, two eco-toxicologists from the Scandinavian Chemical Products agency, wholeheartedly agreed with the damning comments of the beekeepers.

Why did the ICPBR not take note of the beekeepers comments?

"The group's final recommendations are based on a ‘consensus approach’, with agreement being reached in plenary session," said a spokesman for the ICPBR. This ‘consensual approach’ effectively places the recommendations of the organization in the hands of industry. And since participation in ICPBR is open to all, the agrochemical companies are heavily represented. In 2008, of nine members of this group ‘for the protection of the bee’, three were current employees of the pesticides industry, one was a former employee of BASF and yet another was a future employee of Dow Agro-sciences.

During the last conference of the ICPBR, held at Wageningen (Netherlands) in late 2011, seven new working-groups were formed to consider the “effects of pesticides on bees”; every one of these working-groups was dominated by researchers with a direct conflict of interest. From 50% to 75% of the experts in these working groups, are directly employed by pesticide companies, or by private laboratories under contract to those companies. The remaining minority is made up of experts from various national health agencies or, more rarely, by scientists from independent public research. Thus, the pesticide manufacturers exert a dominant influence over the design and scope of the tests, used to assess the risks, which their own pesticides pose to bees and pollinators.

In 2009, just months after the Bucharest conference, the final recommendations of the ICPBR were delivered to the EPPO. But before being adopted as official test-standards, they were subjected to review, by experts appointed from each Member State of the EPPO. Do these experts in turn, also have a conflict of interest?
Are they competent? It is impossible to discover.

"The list of these experts is not secret: it is accessible to the governments of our member states, if they so wish, but this information is not made public," said Ringolds Arnitis of EPPO. In 2010, the newly revised testing guidelines were adopted by member states of the organization and published in EPPO Bulletin.

The judgment of experts appointed by member states to EPPO raises vital questions. An expert from the Swedish Ministry of Agriculture represented his government and he approved the new testing-standards. However, two of his peers from the Swedish Agency for Chemical Products wrote in support of the critical comments of the European Coordination on Beekeeping. So the experts’ judgments seems to vary widely, depending on who employs them.

And what of France? The approval of the revised pesticide-test-standards in 2010 was supervised by an environmental toxicologist from the French Ministry of Agriculture – who also represented France on the EPPO. However, this female scientist, who particopated in the work of ICPBR, was none other than the lead-author of the very recommendations which were seeking approval. In effect, she appraised, submitted and approved her own work. A former employee of Syngenta (previously Novartis), she was later employed by various French public agencies (INRA, AFSSA, Ministry of Agriculture). She is now employed by Dow Agrosciences agrochemicals.

Source: Le Monde, 9 July 2012
http://www.lemonde.fr/planete/article/2012/07/09/abeilles-la-faillite-d…