Wild bees are vulnerable, the acceptable loss of them because of pesticides should be 0%!

The European Food Safety Authority (EFSA), EU Member States and the European Commission are discussing how much it is acceptable to harm wild bees and pollinators with pesticides.

The European Commission has asked the EFSA in May 2019 to revise the "Guidance on the risk assessment of plant protection products on bees (Apis mellifera, Bombus spp. and solitary bees)", what was published in 2013.

As part of this revision, EU agriculture ministers defined the Specific Protection Goal (SPG) at 10% for honey bees (the maximum threshold of acceptable loss on colony strength for honey bees due to pesticides is 10% (in June 2021)). With this decision, EU Member States have already favoured farmers ahead of beekeepers and nature.

The revision is still in progress and after defining the SPG for honey bees now the parties are focusing on the definition of SPGs for bumble bees and solitary bees. To support this process EFSA published a technical analysis at the end January 2022 - "Analysis of the evidence to support the definition of Specific Protection Goals (SPGs) for bumble bees and solitary bees" [1].

By receiving this technical analysis from EFSA, the EU Commission started a discussion with Member States to agree on harmonised (means that member states needs to agree on a common number) SPGs for bumble bees and solitary bees. In a short form it means that now these institutions are discussing the acceptable loss (%) of these animals due to pesticides.

BeeLife European Beekeeping Coordination is concerned about this technical study published by EFSA, which is used as a basis in the decision of Member States on SPGS.

The document is raising several questions and dangerously forecasting that EU Agri ministers will accept as a norm a 10% loss of wild bees in favour of a pesticide (the same as they did for honey bees).

Find below some of BeeLife's main concerns towards the technical analysis

• The EFSA analysis states that there is a lack of available knowledge and research on the topic, what is resulting in big data gaps.

When there is not enough information the precautionary principle should be followed, saying that the level of protection of bumble bees needs to be maximum (0% loss) until data allows to define specific thresholds.

• The key question used by EFSA as a basis of this analysis, and to establish the bumble bee SPG is "Can colonies grow strong enough to provide pollination services and produce queens to be able to establish new colonies the following season?"

Regulation (EC) No 1107/2009 concerning the placing of plant protection products on the market [2] states that a new pesticide introduced to the market cannot have unacceptable effects on the environment. Based on this regulation, BeeLife believes that colonies should be able to develop and reproduce to their full potential and the question to define the SPGs should be reframed to "Does a pesticide X reduce the strength and functionality of bumble bee colonies?".

• In theory, following the Member States decision, the approaches to define Specific Protection Goals for honey bees and wild bees should be different.

What is the difference between EFSA's approach taken for honey bees and wild bees?

• Despite EFSA definition by the “control” group as a group with no exposure at all to pesticides, field studies for regulatory purposes accept the treatment of control groups with pesticides. The only precaution to be taken into consideration is that the pesticide used for the control is not the same as the one tested. This method involves that tested wild bees from control parcels are also exposed to pesticides. Representatives from industry have confirmed this.

Following these facts: Why does EFSA accept data from control groups for the determination of “natural/background variability” thresholds if it cannot be excluded that the control group was exposed to pesticides?

Why does EFSA accept this bias in its assumption? The natural/background mortality should be based on data coming from a landscape that is favourable for wild pollinators (e.g. natural areas).

The establishing 10% of losses in the honey bee colony size from pesticides is already highly problematic. First, it contradicts scientifically sound risk assessment. In 2013, EFSA proposed a 7% acceptable value based on scientific evidence for pesticide risk assessment. Other new studies in the field demonstrated the feasibility of detecting up to 5% impact of pesticides in colony strength [3]. Nonetheless, co-signatories of a letter published in 2021, in Nature assert that the only genuinely acceptable level of impact from pesticides would be 0% [4].

Wild bees are even more vulnerable than honey bees (as they don't have beekeepers supporting them),

BeeLife European Beekeeping Coordination demands the EU Member States not to copy the process they made for honey bees, we require to set 0% as an acceptable level of loss for bumble bees and solitary bees due to pesticide exposure.

Timeline of the process

2009

- Regulation (EC) No 1107/2009 concerning the placing of plant protection products on the market

2011

- COMMISSION REGULATION (EU) No 546/2011 implementing Regulation (EC) No 1107/2009 of the European Parliament and of the Council as regards uniform principles for evaluation and authorisation of plant protection products

2013

- Guidance on the risk assessment of plant protection products on bees (Apis mellifera, Bombus spp. and solitary bees)

- EFSA propose a 7% acceptable value based on scientific evidence for pesticide risk assessment

2019

- European Commission asks the EFSA to revise the "Guidance on the risk assessment of plant protection products on bees (Apis mellifera, Bombus spp. and solitary bees)

2020

- EFSA publishes a supporting analysis for risk managers consultation on Specific Protection Goals (SPGs) for bees - Analysis of background variability of honey bee colony size

2021

- EU agriculture ministers define the Specific Protection Goal (SPG) at 10% for honey bees (= the maximum threshold of acceptable loss on colony strength for honey bees due to pesticides is 10%)

2022

- EFSA publishes a technical analysis - "Analysis of the evidence to support the definition of Specific Protection Goals (SPGs) for bumble bees and solitary bees"

- EU Member States are discussing harmonised SPGs for bumble bees and solitary bees

[1] EFSA - Jan 2022, Analysis of the evidence to support the definition of Specific Protection Goals for bumble bees and solitary bees

[2] REGULATION (EC) No 1107/2009 concerning the placing of plant protection products on the market

[3] Osterman J et al. 2019. "Clothianidin seed-treatment has no detectable negative impact on honeybee colonies and their pathogens". Nature Communications, 10(1): 692.

[4] Fisher, A. 2021. "Protect pollinators — reform pesticide regulations." Nature 595, 172. https://doi.org/10.1038/d41586-021-01818-x