With the ‘bee crisis’ fading and European farmers fearing an insect invasion, EU’s neonicotinoid ban fiasco stumbles into the New Year

The future of a controversial agricultural pesticide remains very much in limbo, the victim of both scientific uncertainty and political malfeasance. I am talking about neonicotinoids, a family of insecticides first deployed in the 1990s as an agricultural insecticide applied mostly as a seed coating and thought to be both more effective and less toxic to beneficial insects, including bees. Yet because of fears based on controversial and less-than-convincing laboratory studies that neonics, as they are called, might harm honeybees or wild bees, the European Union issued a moratorium in 2014 on their use. Since then, farmers in England have turned to other pesticides, which has turned out to be problematic ecologically for bees.

Toxic alternatives to neonics

One possible alternative to neonicotinoids is the organophosphate category of insecticides, including chlorpyrifos. These insecticides are far more toxic to humans than neonicotinoids according to the Environmental Protection Agency. The EPA writes that while thirty-six such pesticides are presently registered for use in the US, “All can potentially cause acute and subacute toxicity.” The other major alternative adopted by desperate farmers, and blessed by anti-neonic activists are pyrethroid pesticides, which are derived from two species of asters and currently permitted in organic agriculture. Pyrethroid insecticides are supposedly low in toxicity to mammals and birds, but as the Washington Post has reported, it turns out they are highly toxic to most insects, including beneficial insects like honeybees; in fact they are considered far more harmful to bees than any neonic. An oft quoted study published in 2015 in Chemosphere found that sublethal doses of pyrethroids reduced the movement and social interaction of honey bees. What a mess, for both science and farmers. The current crisis was set in motion by the passage of the Bee Guidance Document, or BGD for short, which created the regulatory framework used to make its assessments of bee health and set a decision matrix to regulate pesticides, paving way for last April’s continental-wide ban recommendation by the European Food Safety Authority. Considering the ongoing crisis, it’s not surprising that once again, the European Commission tried and failed to get its member states to officially adopt the BGD. The vote was supposed to have happened at the European Commission’s Standing Committee on Plants, Animals, Food and Feed, which met in December. Activists such as BeeLife, the French National Beekeepers Union and Pesticide Action Network had been geared up for months pushing for its adoption. SumofUs delivered a petition with 130,000 signatures to “push European governments to protect bees from killer pesticides.” Nevertheless, the Committee meetings came and went without a vote. The activists were outraged, as one might imagine. As had happened at similar recent failures to ratify the BGD, they accused the members of “cynically kowtowing to the wishes of agro-industry” and “putting profit before protection of bees.” Those are familiar talking points when they don’t get their way. Nevertheless, it’s fair to ask, what’s going on? The member states were practically falling over each other in their eagerness to vote for the neonics ban last April; so eager in fact that they banned neonicotinoids on everything, even crops such as sugar beets that don’t flower, don’t attract bees and can’t possibly pose a threat to bee health. No matter, no one wanted to be outdone in their commitment to saving and protecting vital pollinators. When it comes to voting on the regulatory guidance on which that ban was based, however, the member states suddenly have become shy. It’s been five years now since the BGD was written and it still exists in a kind of legal limbo. Do the members harbor secret doubts about the integrity and workability of the BGD or about the economic and ecological consequences of officially adopting it as regulatory law?

BGD’s troubled history

If so, they’re right to be concerned. Voting the BGD into law means that it would automatically become the standard by which all pesticides are reviewed. The law of unintended consequences would suddenly kick into place as the result could be economically problematic to agriculture in Europe, multiplying many-fold the billions of losses already experienced due to the neonics ban. The BGD has been an evolving problem for years. As I and others have previously reported, the BGD was first hijacked by anti-pesticide activists in 2011, creating guidelines that are so onerous and in some cases literally impossible to meet that they would force almost any pesticide tested under its regime to fail. Science writer Matt Ridley has called it a “bizarrely one-sided piece of politicised science.”

Three examples:

The BGD requirements are statistically impossible to meetThe BGD requires studies to demonstrate that a pesticide causes no more than 7 percent mortality in honeybee colonies. Bee colonies naturally fluctuate as much as 15 to 21 percent, due to rain, temperature, varroa mites and other diseases. It is statistically impossible to demonstrate no more than a 7 percent effect when the normal variation is some 2 to 3 times as large.

The BGD creates a Catch 22 for researchers that automatically invalidates realistic studies. For field studies to be accepted, they must demonstrate that at least 90 percent of the honey bees in a colony have been exposed to the pesticide being tested. This, however, makes it impossible to conduct a realistic field study. In real life, there is practically no pesticide residue left in the nectar and pollen by the time the crops are flowering and bees are foraging on them (typically 1.5 parts per billion—or 6% of the residue level that the US EPA has identified as observably harmful to honeybee colonies). Bees generally forage on a variety of plants as well, including wild plants in the surrounding landscape, so the small residue levels will be even further diluted. Finally, bee colonies have natural self-detoxification capabilities that further reduces the pesticide exposure for the average bee within the hive. Meeting the required 90 percent exposure rate can only be accomplished by artificially and massively overdosing the bees, defeating the whole purpose to conducting a realistic field experiment.

The BGD spatial requirements of field studies create practical impossibilities. It’s been calculated that to comply with all the BGD’s field separation distance and replication requirements would demand an area of some 173 square miles, approximately four times the size of the city of Paris— something that is probably not possible in the crowded European landscape.

Genetic Literacy Project, 9 January 2019 ; https://geneticliteracyproject.org