Field Tests For Pesticides:
How Robust Are They And Do They Protect Bees?
In
the UK, we are constantly told that field studies for pesticides offer the favoured
and realistic method of assessing risk of pesticides to bees.
In contrast, doubt is often cast over independent laboratory studies.
On 13 September, Defra published an analysis of the results of its review of research done earlier in the year on the effects of neonicotinoid pesticides on bees. DEFRA is the UK Department For Environment, Food And Rural Affairs.
It relies on various departments to conduct different aspects of services that inform and support DEFRA, and two of these departments include FERA (Food And Environment Research Agency) and CRD (Chemical Regulations Directorate).
What conclusions did the report reach?
The whole assertion in the face of compelling laboratory data, is that the independent lab studies are not necessarily relevant because similar effects have not been observed in the field.
Indeed, field tests are used to cast doubt on the results and legitimacy of the independent laboratory studies, whilst at the same time, the independent field studies are ignored.
As an aside, I'm sure Bayer Cropscience would agree with CRD. They also seem very keen to suggest that what is important is ‘What’s happening in the field” as demonstrated in their response to the Pettis study (below).
“I am sure there are some very interesting effects Dr Pettis has seen in the laboratory, but in reality, when you get to what’s important to everybody, which is what happens in the field, you don’t see these things happening.” – Dr Julian Little, Bayer CropScience; source: The Independent: 20/01/2011, Michael McCarthy).
Problems with the DEFRA report
- It's true that an effect seen in a laboratory will not necessarily be witnessed in the field, but this is not necessarily always the case, nor does this principle always negate lab tests.
For example:
If (even the manufacturers admit) that a poison's mode of action is to present a toxin to insects via the natural secretions of a plant, then it is perfectly appropriate within a laboratory, to investigate what happens when a non-target organism ingests those toxins.
However, there is no proper analysis or questioning of the assumption that lab tests are less valuable than field tests. - For some reason, the independent field studies were brushed over.
- The EU regulatory field tests for pesticides are in any event flawed (these are the tests used to approve the chemicals for EU-wide use).
In fact, thanks to independent lobbying from myself and others, EFSA, the
European Food Standards Authority conducted a review:
Scientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees (Apis mellifera, Bombus spp. and solitary bees).
They found
many MAJOR weaknesses with the regulatory standards for the field tests for pesticides.
(find EFSA's report here - opens new window).
These included:
- unrealistic field conditions,
- short duration of experiments,
- tiny fields (taking into account realistic foraging areas for bees),
- wishy washy flexibility regarding important elements of the tests,
- inability for the field tests to measure impacts on colony,
behavioural effects, chronic effects and so on.
It is therefore absurd to suggest that field studies using flawed methodology, can be used in any way to trash an independent, peer reviewed laboratory study.
A quote from EFSA:
EFSA:
“Field testing currently follows only one test guideline, the
EPPO 170 (4).
A precise analysis of this guideline, based on scientific knowledge, showed that it has several major weaknesses (e.g. the small size of the colonies, the very small distance between the hives and the treated field, the very low surface of the test field), leading to uncertainties concerning the real exposure of the honey bees.
Even when they are carried out in natural conditions, they may not represent the normal exposure conditions of the bee colonies.
Furthermore this guideline is better suited to the assessment of spray products than to that of SSST.
For the moment, it does not allow us to assess all the effects of pesticides on the scale of the colony, including all bee categories and relevant long-term effects.
It is therefore important and urgent to adapt guidelines to a specific mode of pesticide application and to the relevant exposure routes”
Who decides the guidelines for pesticide regulatory tests?
Astonishingly, the field
test guidelines EPPO170 are devised, it
appears, by a group of pesticide manufacturers and those related to the
industry (e.g. providing consultancy services), as well as a sprinkling of
government civil servants from the EU countries, such as Helen Thompson (one of the authors of the report described above) and Selwyn Wilkins of FERA, and Anne Alix of France.
In other words, the EU allows pesticide manufacturers a major hand in saying how their poisons should be judged suitable for regulatory approval.
It looks to me like the fox is guarding the chicken coup! They meet together at various symposiums to have a chat about the standards. For example, there was one such meeting in Bucharest in 2009:
So what were their aims?
"At the ICPBR- Bee Protection Group 10th Symposium (Bucharest, 2009-10-08/10.....the WGs (working groups) presented proposals for the revision of EPPO Standards, which were discussed in order to hear the expert comments and recommendations of all 79 participants and to reach a consensus."
So who were the 79 participants? They were mostly industry related people, again with a sprinkling of civil servants, including Helen Thompson mentioned above.
(Note: I used to have an external link to this report, but is has been removed).
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