Letter to Commissioner Borg highlights some contradictions remaining in the new Guidance document on risk assessment of pesticides on bees.

Wednesday 14 August 2013

SANCO risk assessment pesticides Guidance document bees

Friends of the Earth Europe, the European Professional Beekeepers Association, Pesticide Action Network Europe and the European Beekeeping Coordination, sent a letter to commissioner for Health and Consumer Policy, concerning the specific protection goals in the risk assessment of pesticides on bees, in particular the EFSA Guidance Document on risk assessment of plant protection products on bees.

This guidance document, published in July 2013, furnish pesticides manufacturers and risk assessors with the methodologies of tests and risk assessment to be followed in order to have a pesticide active substance or product placed on the market.

These associations welcome the new guidance document, but also highlight some incoherence still remaining in the document. The main contradictions in the new Guidance Document are summarized below.

- According to the guidance document, a 7% reduction in the size of the colony after exposure to a pesticide would be acceptable. However, would any farmer accept that a cow loses 7% of its body weight after being exposed to a chemical? Not one percentage of reduction of the size of the colony should thus be allowed.

- Moreover, the 7% reduction thresholds proposed by EFSA concern a single pesticide whereas bees are confronted in the reality to many chemicals, simultaneously or consecutively. Security factors should thus be applied due to the possible multiple exposures.

- The guidance says that in extreme cases (e.g. hedge of fields treated), 90% of the colonies will be exposed to a level considered safe (no harmful effect), so that 10% will be exposed to a higher level, possibly damaging to the colonies. In view of the inestimable value of honeybees, not one single bee should be exposed to pesticides in regulatory zone. In the frame of current agricultural practices, reaching a percentile of 100% is difficult and therefore setting the limit at 97.5% would be acceptable.

- The Guidance should include the impact on honey production as an indicator of toxicity; honey production is a proof of the health of a colony.

- The guidance should include homing flight test as a mandatory test. This is a key test to assess sublethal toxicity to bees, and protocols exist to carry out this test in a simple way.

From a more general perspective, the letter concludes by welcoming the efforts devoted by the EFSA in order to achieve a bee panel that does not present conflict of interest, but ask for more bee experts to be part of the panel.