On Sat, Mar 23, 2013 at 3:06 AM, Ted Hancock <[log in to unmask]> wrote:

>
> "Dr. Pierre Mineau began his long and distinguished scientific career....."
>

Thanks for the post Ted.  I think it would be worthwhile to post the
address of Dr. Mineau to the committee which I have included below, since
it is very short and it directly addresses some of the things which we have
been discussing, such as longevity in the soil and movement in watercourses
as well as pollinators.
 Stan

HC 668 Insects and Insecticides

*Written evidence submitted by Dr Pierre Mineau, Emeritus senior scientist
in pesticide ecotoxology, Environment, Canada*

I am a retired (Emeritus) scientist with Environment Canada with over 30
years' experience in pesticide evaluation, risk assessment and ecological
research. For approximately half of that time, I was the lead regulatory
assessor for the risk of pesticides to wildlife in Canada.

I have a special interest in the neonicotinoids in that they were of
increasing concern to me when I retired less than one year ago. I continue
to be involved in pesticide research and assessment as a consultant and
have just finished a review of the neonicotinoids from the point of view of
their impact on birds.This particular work was commissioned by the American
Bird Conservancy.

The specific point I wish to make concerns the exchange you were having
with the representative of Bayer Crop Science during your 30 January
session. Specifically, my comment is about the UK study showing a
continuing increase in soil residues, which study Bayer dismissed as
irrelevant because it involved a field where straw was reincorporated every
year. Bayer's position was that, because straw is a valuable commodity,
that study did not follow good agricultural practice and should not be
considered.

I respectfully submit that your committee missed an opportunity to address
the fundamental insight provided by that study, whether or not the study
followed usual agricultural practice and whether the price of straw does or
does not make this scenario likely in the UK. The issue is that of systemic
pesticides more generally. In my opinion, the real question that should
have been asked is the following: What are some of the other agricultural
conditions where plant material is reincorporated into the soil after
taking up neonicotinoid insecticides? Are there other crops with
neonicotinoid uses where this happens? I believe oilseed rape might be one
of those cases. The plants are dessicated prior to harvest and broken up on
the fields when these are harvested. It may be a similar situation with
potatoes. Rotational green manuring of fields and companion planting are
other situations where it is likely that plant-bound residues will be
reincorporated in the soil horizon.

Bayer's other point was that presence per se does not necessarily denote an
impact. I agree with this point. However, it is my opinion that one of the
problems with long persistence in soil is the increased probability of
runoff. The neonicotinoids are extremely water-soluble and prone to move
from from fields to nearby waterbodies following rain events. We are seeing
this with the seed treatment products in Canada. As a group, all
neonicotinoids are extremely toxic to the aquatic larvae of several key
insect groups although they are not very toxic to some of the usual
crustacean species tested for regulatory purposes. There is also evidence
that pulses of neonicotinoids in water (most of the information here is
with imidacloprid) have an equivalent killing power to that of steady
concentrations because of peculiarities of this class of chemicals (their
irreversible receptor-based mode of action). When you put it all together,
you logically arrive at the conclusion that having the compounds persist
for as long as they do in and on the soil surface merely increases the
likelihood that they will be washed away into watercourses where they are
likely to cause serious ecological disruptions.

I do not want to underestimate the issue of potential harm to bees and
other pollinators but I believe that the focus of your enquiry should be
much broader and that this class of insecticides has much more impact on
our natural environments than merely impact on pollinators.

*31 January 2013*

©Parliamentary copyright
<http://www.nationalarchives.gov.uk/information-management/our-services/parliamentary-copyright.htm>

Prepared 12th February 2013

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