I made a presentation to the Pesticide Advisory Committee of Prince Edward
Island regarding the use of imidacloprid on potato fields here and it
gathered a lot of media coverage.  It was the first story on our local news
on TV, and both radio stations mentioned it throughout the day in their
newscasts.  I had produced a graph which showed use and accumulation on PEI
and held it up under my head throughout the whole news interview after my
presentation, but it was NOT shown on TV because the lawyers at CBC (our
national public television station) head office did not stand up to the
lawyers from the Bayer company.  Our newspaper has said that it will publish
the graph.  I will ask Allen if he might put it on his wonderful
imidacloprid website.

I had already been in touch with the PMRA (the pesticide registration agency
in Canada) but I guess that after the news coverage that the story got here
when reporters contacted them they said that they have requested Bayer to
produce all the results of the French testing and the results of the
Cynthia Scott-Dupree study without delay and they will review the use of
this insecticide on potatoes (they are already considering its use on canola).

The following is the text of my presentation.  It is long, but perhaps in
view of the fact that this subject has received considerable attention on
this list and the fact that this product is now one of the most-used
insecticides in the world the moderators might allow it to be posted.

Submission to the Pesticide Advisory Committee
>From Stan Sandler,  beekeeper
Date:  March 27, 2001

Concerning:  Use of Imidacloprid  (Admire) on PEI

Imidacloprid was first given a temporary registration for use on potatoes in
1995 and its use in PEI has increased dramatically since then until today it
is the probably the main insecticide used on potatoes.

Recently, partly as a result of beekeeper experience in France in
particular, and Europe generally,  and partly because of new techniques to
measure residues and  detect effects, and partly due to questions about the
quality of the research proving imidacloprid safe, concerns have been
surfacing about the danger to the environment and to both natural and
managed pollinators from this insecticide.   Since December of 1998 there
was a moratorium put on the use of imidacloprid in three provinces of
France, and four teams of independent government scientists were asked to
study the toxicity of imidacloprid to honeybees and its ability to manifest
itself in succeeding crop years.   That study cost many millions of Francs
and is about the only good independent research that is available on the
subject.  I strongly urge this committee to contact the "Commission des
Toxiques" in France and get copies of the findings of these studies and get
them translated so our Minister of Agriculture can use that information.
References to their findings, and to the original papers  are included in
the "Composite Document of Present Position Relating to Gaucho / Sunflower
and Bees", by three national beekeeper organizations in France.
Imidacloprid is marketed by the Bayer company as "Gaucho" in France, for
sunflowers, as Admire 240 F here on PEI for potatoes.   This paper which was
presented to the French Minister of Agriculture is included in this
submission as Appendix 1.  After that document was presented  the Bayer
company  brought forward some additional  data, and the three beekeeper
organizations responded.  That response is included as Appendix 2.   It is
very informative, but unfortuneately I do not have it translated yet.   Some
of this committee's members may be bilingual.    The moratorium on
imidacloprid use on sunflowers has now been extended to the whole country.
The Advice to the Minister of Agriculture by the Commission des Toxiques is
included as Appendix 3.  I would draw this committee's attention to the fact
that all the teams of independent French scientists found that imidacloprid
was toxic to honeybees in extremely tiny concentrations, down to single
digit parts per billion (ppb).  In fact the data from the manufacturer has
been revised downward in just over two years so that they no longer claim
that the NOEC (no observed effects concentration) is 5000 ppb, which is what
they claimed at the time this insecticide was registered in Canada for
potatoes, but now say it is 4 ppb.  (data presented to the Commission des
Toxiques on 16/12/1998) or 20 ppb (recent paper by Bayer researchers
Schmuck, et.al, included as Appendix 4).

In this area  (the Atlantic Provinces) there has been little study of
imidacloprid.   To be exact there has been one study by Environment  Canada
and Agriculture Canada  to determine the potential for water-borne transport
from treated fields.  This study was called "Field and Test Plot Studies of
Disperal of Imidacloprid (Admire) in NB and PEI (1995)".  It is included in
this submission as Appendix 5..

I would draw the committee's attention to this quote from page 7 of that study:

"Imidacloprid is persistent in soil (DT50 = 2 years) with a high potential
for carryover and buildup of chemical residues  (Mulye 1996a,   Mulye
1996b)".  note: DT50 is decay time for 50% of material.

Couple that with the report's conclusion that imidacloprid shows significant
translocation to other locations by water during the growing season when
applied foliarly, and after the growing season when applied in furrow, and
you have the reasons why this insecticide is so dangerous to bees.  Bees do
not visit potato flowers for either nectar or pollen.  But imidacloprid is
washing into the ditches and being expressed in the nectar and pollen of the
goldenrod and clover there.  It is also carrying over and being expressed in
the crops and weeds in the years following potatoes.  That is quite well
known by the company.  If you look at the label you will see that they do
not recommend treatments of the same field in successive years for just that
reason.  How much is being carried over?  We have no idea, because noone has
done any testing.   But if you look at the data from the French teams quoted
in Appendix 1 you will see that when they looked in France they found
concentrations significant to bees in succeeding crop years.  And consider
this fact:  Admire can be put on potatoes, in furrow application, at 1.3
l/ha.  But it can also be applied at a low dose of 0.85 l/ha.  Now if you
put it on at 1.3 l/ha and it has a half life of one year, then the next year
the soil concentration is going to be up to 0.65 l/ha which is 75% as much
as the low dose application.  If the low dose application is sufficient to
render the potato plants toxic to insects don't you think that 75% of the
low dose might certainly be sufficient to render the clover and other plants
growing the following year toxic to bees?

Now I would like you to refer to data from the French team studying the
persistence of imidacloprid  (the Bonmatin team) which I have included as
Appendix 6.   There were 68 soil samples, only ten of which were from the
year of treatment, the others were from one or two years previous.  In 91%
of the samples imadcloprid was detectable and it reached levels between 1
and 10 ppb. in almost half the samples.   That study also showed that not
only was imidacloprid present in the soil, but it was absorbed into the
maize, sunflower, wheat and rape crops growing in those later years.  And if
you look at the graph on the last page of that appendix you will see that
not only was imidacloprid present in those crops, but it got concentrated in
them by the increased metabolic activity at the time of flowering and showed
a increase of near five times in the flower head.   But in PEI the situation
is potentially far worse!

On sunflowers imidacloprid is used as a seed dressing and the loading to the
soil is at a rate of 52 grams of active ingredient per hectare.  (0.7 mg
active ingredient per seed and 75,000 seeds per hectare)   This is Bayer's
data from the Schmuck paper.  The maximum in furrow application rate of
Admire on potatoes is over 350 grams of active ingredient  per hectare or
SEVEN TIMES THAT AMOUNT!  (1.3 litres per hectare with active ingredient 240
g/l)    The French scientists found imidacloprid residues in crops growing
in successive years, so I think that we can assume that there is a high
likelihood that we will find even higher rates here, given that the
application rate is seven times  higher, potato soils have even longer half
life values, and our winters are colder with more snow cover (which also
extends the half life).   Moreover, if you look at the toxicity to bee data
from the abstract of the Bonmatin report (Appendix 7) you will see that they
conclude that vital functions of bees are affected by sub-lethal doses of
imidacloprid in the range from 1 to 20 ppb.  The graph (also in that
appendix) comparing feedings on comtaminated and uncomtaminated syrup shows
clear response at 3 ppb.  Other data which you can find in Appendix 2 shows
toxicity of the olefin metabolite of imidacloprid to honeybees at only 0.75 ppb!

Now, some of you may be thinking:  well in the most common PEI rotation, it
is usually grain that follows potatoes and  the clover in hay doesn't
usually flower until the third year.  But remember, that clover is usually
underseeded with the grain in the second year.  It sprouts and grows and
absorbs toxic imidacloprid that is still in the ground in the second year.
Usually it won't flower until the third year, but it was certainly capable
of taking up toxins in year two.  Moreover, occasionally clover will flower
in the seeding year, if the grain is harvested early enough, or if there is
a blowdown in the field, or a miss in the grain drill.

I recently asked a friend who grows a lot of potatoes what he used for
colorado beetle control before admire.  He said "Furadan, thiodan, velmar,
sevin, ripcord...  We used them all.  This stuff does a real good job of
killing beetles".  I can sympathize with my friend.  Who would want to go
back to using those organophosphates that are more toxic to people and have
to be sprayed repetitively?  And they are all highly toxic to bees as well.
But for the bees they have one huge advantage:  They get sprayed on
potatoes, which bees do not visit, and then they quickly break down.
Unless there is significant drift onto adjacent  hay and pasture bees are
unaffected.  The spraying is usually done before goldenrod in the ditches
flowers.  By contrast, imidacloprid is a ticking time bomb.   Those other
insecticides also are very apparent to the beekeeper when hives are affected
by drift.  The forager bees often die on or in front of the hive entrance
and it is apparent what has happened.  Imidacloprid is more insidious.  At
low concentrations it does not necessarily kill the foragers.  But it
disorients them and alters their behaviour.  Many lose their way and don't
return or return but cannot dance or otherwise function as foragers.  The
young bees and brood starve.

PEI beekeepers lost 20% of our hives  last year IN THE SUMMER.  That is a
remarkably high number.  Usually we make increase during the summer;  have
losses in the winter.    The winter yards I have checked so far show 35%
mortality, and enough severely weakened hives that I believe final winter
mortality will probably be 50%.  The snow was not the killer.   I know that
in my hives it was the poor condition in which they entered the winter that
was the killer  ( poor stores and  insufficient bees to take down feed and
form a large enough winter cluster).  And I am pointing the finger at
imidacloprid as the cause of their poor condition.

If  honeybee colonies are being killed by this insecticide I think that is
highly likely that bumblebees and solitary bees which forage on the same
plants are also being killed.   Honeybees and wild pollinators  pollinate
most of the fruit  and many of the vegetables on this island:  blueberries,
apples,  raspberries, strawberries,  pumpkins, cucumbers, tomatoes,  peas
and so on.    Neither your committee, Agriculture Canada, Environment
Canada, the PMRA, or the provincial department of Agriculture has done any
testing as to how much imidacloprid is present in the environment and being
expressed in the wild and managed flowers that these pollinators visit.  But
the beekeepers of PEI have been doing a form of testing.  We had about 2000
beehives on this island last year monitoring the environment  in  many
locations.  I myself had 50 apiaries all over Kings and Eastern Queens
Counties.  That works out to be about 100 million bees on PEI  out there
testing the quality of nectar and pollen.    About half of those beehives
are now dead.  We cannot prove that imidacloprid is what has been killing
our hives and causing our bees to do so poorly,  but we can say that it
certainly seems to us to be the culprit, and our experience with it is very
similar to the losses and symptoms it caused in France.   It is not up to
beekeepers to prove that imidacloprid killed our hives.  We can't do it.
The bees that died or got lost did not come back to the hives.  The hives
died from lack of foragers and starvation.  But this committee advises the
minister of agriculture who has duty to the people of this provinces and to
other agricultural sectors, like the bee and blueberry sectors,  not to
allow the use of a chemical which has not been proven to be harmless to us.
There is not a single INDEPENDENT study that will show that this chemical
either goes away or stops killing.   The Bayer company has two studies that
it will hold up as exploring the toxicity of imidacloprid and bees, but
remember,  other bee researchers in France and in Canada have questioned the
findings of those studies.  The company paid big bucks for those studies.
The company made half a billion Eurodollars last years selling imidacloprid.

 The minister is well aware of the importance and the shortage of
pollinators on PEI, because he has been petitioned by the Blueberry
Association to open the border to the movement of hives from Nova Scotia as
a consequence of the shortage here.  Letting hives in will not be a solution
if those hives also get sick and die or do poorly as a result of the use of
this insecticide.   The blueberry industry has a list of growers requesting
beehives that totals about 3,400 beehives.  I doubt if there are more than
1000 beehives left on PEI this spring.  And the beekeepers are hardly
ordering any packages of bees for replacements.   Do you blame us for not
wanting to invest in bees if they are going to get poisoned?

I ask this committee to recommend to the Minister that there be a moratorium
put on the use of imidacloprid on PEI for year 2001 while the Department of
Agriculture samples crops growing in soils that were treated in year 2000
and determines the levels that are present in those crops and weeds, and the
levels that are present in nectar and pollen and honey.   We are very
fortunate to have the technology right on this island.  The Atlantic
Veterinary College has the equipment to detect imidacloprid at 0.4  parts
per billion which is finer detection that the Bayer company usually uses.
Even if we spread no new imidacloprid this year we will have 6.700 kg of
active ingredient going into the environment as an accumulated load from
previous years.  We have no idea how this is affecting the insect fauna of
this island, because noone except beekeepers monitors "non target species"
closely.   Insects are not just pests.  They pollinate many of our foods,
break down material in the soil, and are food for many other animals.
Imidacloprid is also highly toxic to earthworms.

I am putting a good deal of material in front of this committee for
examination and suggesting that this committee could obtain even more
original documents and papers from France for the minister.  But there is
one graph that I have made that I would like to draw your attention to.
It is so dramatic that I would like to see it on TV, in our newspapers and
discussed on the radio and in the legislature.    The facts and the
calculations  that I have used to create the graph are simple and do not
require testing to validate.   It is included in this submission as Appendix
8, "Imidacloprid Use and Accumulation on PEI"..

Let us look first at the data used to create the graph:

IMIDACLOPRID USE AND ACCUMULATION ON PEI (KILGRAMS OF ACTIVE INGREDIENT)

YEAR     1996    1997    1998     1999      2000      2001

amount    504    522     1324     5930     10,000+
used in year

We have good exact data for four years on the amount of imidacloprid  used
in this province.  We do not have the figures yet for 2000, but I am fairly
confident that for 2000 we will see imidacloprid has moved into Group B
(sales of active ingredient between 10,000 and 50,000 kg).   Confirmation of
that should be available very soon.  I phoned two agrichemical dealers in
PEI and one looked up the sales figures and told me that sales of
imidacloprid had quadrupled in 2000 from the 1999 level, and the other said
that although their increase was not so dramatic, sales had probably more
than doubled.

Then I figured the cumulative amount going in to the environment at the
start of the next season:

YEAR         1996  1997  1998  1999  2000    2001

cumulative     0   252   388   856   3,393   6,696
amount in
PEI envir. at
start of the year

I arrived at those figures by using the half life value of one year for
imidacloprid and applying that value to the amount of imidacloprid in the
environment at the start of the previous season.  For a discussion of the
half life of imidacloprid please see page 4 of Appendix 9, a document on
imidacloprid by the National Pesticide Telecommunication Network.  The US
Environmental Protection Agency considers the half life of imidacloprid to
be one year.  Our  Pest Management Regulatory Agency in Canada put out a
document on August 15, 1997 on Admire called Regulatory Note R97-01 which I
have included as Appendix 10.  In that document it states on page 2 that
terrestrial field dissipation studies indicate that the half life of
imidacloprid in Canada in soil planted with potatoes ranged from 266 to 457
days, so the one year half life figure I have used should not be controversial.

So, to visualize what the graph is showing, you take the use of admire in
one year  (the blue bar) and add it to the accumulated load from the year
before (the brown bar).  Then you divide the sum by half since half of that
degrades during the year.  The result is the accumulated load for the next
year (the brown bar).  From this anyone can clearly see that using such a
persistent toxin is madness.  Even if the people of this province see this
graph and raise their voices to demand that its use be stopped, and the
Minister hears them and acts quickly, we will still be loading the
environment with over 6,700 kg of active material this year and over 3,350
kg. the next.    Our pollinators and other beneficial insects will continue
to die.   And if we don't stop now the brown bar keeps getting closer to the
blue bar and the situation keeps getting far, far worse.  We will have more
toxins expressing themselves in the environment this year just from
accumulated load than from all the material we spread in 1999.      That is
several tons of  material that ALL researchers, even the Bayer company ones,
have shown to be toxic to essential pollinating insects in  unbelievably
tiny amounts; amounts far smaller than what was previously thought and
presented by the company when the material was registered.   And that
material will be active in plants growing in fields that are no longer in
potatoes, killing insects it was never intended for.

There are a few factors that I have not included in the graph.  They are
minor, but I should deal with them now,   because potato growers have
invested a lot of money in specialized equipment to make in furrow
applications of Admire, it works well on potato beetles, and they are not
going to be pleased if it is deregistered and will be looking for flaws in a
graph that is so simple that almost everyone can understand why we can't
keep spreading this.

First, some growers will say that they do not use the high in furrow
application rate of Admire.  This is really of little consequence.  At the
low rate they are still spreading four times the rate that is applied to
sunflowers with demonstrated residual effects to bees in successive crop
years.  The graph does not even look at rate.  It is simply concerned with
the amount of the toxin that is in the environment.

Some imidacloprid does leave the environment in the potatoes that are
harvested.   Let us say that 50,000 kg of potatoes are taken from a hectare
of treated field.  If those potatoes all had the maximum rate of
imidacloprid residue that is allowed in Canada  (Appendix 11) on potatoes,
300 parts per billion, that would still only remove 15 grams of active
material from a field dose that ranged between 200 grams and 350 grams.  And
it is most likely, and I know all potato farmers will agree, that the
residue in potatoes is far less than the allowable limit, and so much less
than this is leaving in that manner.  The other parts of the potato plant
return to the soil.

Some toxin does leave in water.  The study by Gary Julien on Environment
Canada (Appendix 5) looked at this.  And soon, we should have results on
testing of water wells on the island that might give us some data.  But when
I asked Gary Julien, who I actually hoped might be able to be here,  whether
he thought that the removal by water would be significant to the graph, he
did not.  Apparently much of the dispersal that they found and documented in
their study was not in the form of dissolved imidacloprid, but more in the
form of sediments that were removed from the fields by water (erosion
basicly) and by windblown particles of soil.  That does not really remove
imidacloprid from the PEI environment, it merely spreads it around and it
should still be included in the graph.  For the bees the ditches are one of
the most dangerous places to have the material  because that is where many
of the weeds like goldenrod that the bees work hard are found.

I might mention, that Gary Julien told me that the work they are doing now
shows that imidacloprid has effects on fish at much lower levels than its
lethal dose.  It acts as an endocrine disruptor, or hormone mimic, and leads
to genetic damage. He said that this was totally unknown and unstudied at
the time that this product was registered.

The beekeepers on this island would like to see the use of this product
suspended until it can be proved safe to our bees and other essential
pollinating insects.   We can't afford to do the testing necessary.  The
Atlantic Vet College has the equipment necessary, and it is very precise,
and can do the tests for about $160 a sample.  But they need a mimimun
number of samples which is large for each matrix that they test (nectar,
honey, pollen, flowers).   If the potato growers want to use this product in
the future, and if the company wants to sell it,  they should have to prove
it is safe.  And if that requires expensive testing, then the sale of it
should be subject to a tax to fund that testing.   But if the Minister has
the good sense to halt the sale of this, then I suppose that it would be up
to the company to fund the testing to show it is harmless and try and get it
reintroduced.  On this same subject, the use of imidacloprid,  I believe
that Walter Bradley when he was Minister of Agriculture responded to a
question by Pat Mella concerning its safety by saying that the Province of
PEI did have the power to regulate the sale of materials it deemed
potentially hazardous.  I think that if this committee looks carefully at
the material I have presented it will have to recommend to the Minister that
imidacloprid is potentially hazardous to bees and other pollinators at least.