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From:
Juanse Barros <[log in to unmask]>
Reply To:
Informed Discussion of Beekeeping Issues and Bee Biology <[log in to unmask]>
Date:
Sat, 15 Jan 2011 15:30:47 -0300
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http://www.buglife.org.uk/Resources/Buglife/revised%20neonics%20report.pdf

<http://www.buglife.org.uk/Resources/Buglife/revised%20neonics%20report.pdf>
The impact of neonicotinoid insecticides on bumblebees, Honey
bees and other non-target invertebrates

1.0 Executive summary
The current declines being witnessed in both wild bees and Honey bees have
been
attributed to a number of possible factors, including: varroa mite
infections, habitat loss,
mobile phone masts and pesticides.  Central to the global debate are
neonicotinoid
pesticides, banned to different degrees in a number of European countries,
these
pesticides have been regularly linked to bee declines.
This report covers neonicotinoid pesticides and fipronil, a chemically
distinct pesticide
that is grouped with neonicotinoids because it is also a systemic
insecticide that acts on
the nervous system of insects.  The report reviews existing approvals
research and
independent research on the effects of these chemicals on Honey bees,
bumblebees
and other non-target invertebrates, and investigates the current approvals
mechanism
and its standards.
Findings reveal a disparity between independent research and the research
that was
undertaken by Bayer, the producer of the neonicotinoid pesticide
imidacloprid, for the
imidacloprid ‘Draft Assessment Report’ (DAR), the 2005 report that was the
foundation
of the EU regulatory approvals process for this pesticide.  Independent
research found
significant negative impacts on bees that were not included in the DAR
because the
research was invalidated by the DAR.  The basis for this invalidation is
questionable, but
it resulted in key evidence not being considered as part of the approvals
process.
Additional research post-dating the DAR has provided more evidence that
neonicotinoids may damage populations of bees and other non-target
organisms.
These peer reviewed independent research papers show significant negative
impacts of
imidacloprid on bees and other non-target invertebrate occur at levels
predicted to be
present in the UK countryside.  These predicted levels are based on
imidacloprid
application rates approved for use in the UK.  Similar levels have been
found present in
hives of other countries when EU approved imidacloprid products were used
for example
Gregorc & Bozic 2004 found five samples of bees out of 12 hives tested in
Slovenia
were found to contain imidacloprid above 5 µg/kg
42
 and Chauzat et al. 2006 found levels
of 5.7 µg/kg in pollen from French hives
55
 .
Papers on impacts at predicted environmental concentrations include:-
• Yang et al. 2008 - foraging Honey bees reduced their visits to a syrup
feeder
when it was contaminated with 3 µg/kg of imidacloprid
48
 .
• Alexander, Heard & Culp 2008 - mayflies of the genera Baetis and Epeorus
showed a reduction in reproductive success when exposed to concentrations
of
imidacloprid as low as 0.1 µg/l and in addition there were reductions in
head
length in Baetis and thorax length in Epeorus
22
 .
• Alexander et al. 2007 - found that imidacloprid levels reduced survival,
feeding
and egestion in the mayfly Epeorus longimanus and aquatic worm Lumbriculus
variegatus at concentrations between 0.5 and 10 µg/l
23
 .
• Rose, Dively, & Pettis 2007 - an imidacloprid level of 10 µg/kg within
pollen cakes
in Honey bee colonies caused a 20% reduction in the number of brood cells
54
 .6
• Colin et al. 2004 - sub-lethal doses altered the behaviour of foraging
Honey bees
and 6 µg/kg of imidacloprid reduced the proportion of active bees
51
  .
• Suchail, Guez & Belzunces 2001 – this study tested chronic toxicity on
Honey
bees using a 0.1 µg/l solution given every day for eight days.  The LD50
was
reached at a mean rate of 12 µl/d per bee; after 8 days this was 0.01 ng/bee
(0.1
µg/kg), showing chronic toxicity to cause bee deaths at much lower
concentrations of imidacloprid than acute toxicity
35
 .
Test methods utilised for the approval process of imidacloprid were found to
be
insufficient for assessing sub-lethal effects and chronic exposure risks to
Honey bees
from imidacloprid.  We found that overall the existing approval mechanisms
for crop
protection products controlled by Plant Protection Products Directive 91/414
are
generally inadequate for assessing the impacts on non-target invertebrates,
with no
standards for sub-lethal effects and inappropriate assessment methods for
systemic
pesticides; this means that the product approval decisions which are made in
the UK by
the UK’s Chemicals Regulation Directorate are reliant on inadequate
research.  There
were also a number of exposure routes that had not been properly
investigated, such as
exposure from dust formed during the sowing of dressed seeds
11,12
   .
There is a lack of independent research into the potential impacts on
non-target
organisms from other neonicotinoid pesticides and therefore the respective
DAR
research cannot be as thoroughly reappraised as has been possible for
imidacloprid.  It
is highly likely that risks posed by imidacloprid will also be posed by
related pesticides
that are used in comparable circumstances.
The precautionary principle states that if there are reasonable scientific
grounds for
believing that a new product may not be safe, it should not be used until
there is
convincing evidence that the risks are small and outweighed by the benefits.
 This is
enshrined in Directive 91/414 which states that “Member States shall ensure
that a plant
protection product is not authorized unless…..it has no unacceptable
influence on the
environment.”  “Authorizations may be reviewed at any time if there are
indications that
any of the requirements….are no longer satisfied.”
Given the essential nature of pollination services provided by the Honey bee
and wild
bee populations and the current precarious state of these animals any
additional risk to
their populations from pesticide use constitutes an unacceptable influence
on the
environment.  In addition we have identified generic key weaknesses in the
European
approval process in relation to imidacloprid making the approval research
not
comprehensive enough in regard to risks to bees.  Buglife and the
organisations that
have signed onto this report call for the following action to be taken:
• A review of the inclusion of imidacloprid, other neonicotinoids and
fipronil on the
positive list of authorised substances in Annex I of Directive 91/414.
• A review of existing neonicotinoid and fipronil products authorised for
outdoor
use in the UK.
• Until the reviews are completed a precautionary suspension of all
existing
approvals for products containing neonicotinoids and fipronil where these
products have been authorised for outdoor use in the UK.
• The development of international methodologies for assessing the effects
of
systemic pesticides and sub-lethal impacts on invertebrates.

-- 
Juanse Barros J.
APIZUR S.A.
Carrera 695
Gorbea - CHILE
+56-45-271693
08-3613310
http://apiaraucania.blogspot.com/
[log in to unmask]

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