Declining European Bee Health: Banning the Neonicotinoids is Not the Answer

The issue of declining bee health has been in the public eye for some time and it still remains unsolved. The cause of the decline is complex and there is no evidence pointing to a single cause. There are some organisations which push the concept that the decline in bee populations is due to pesticides, the main focus of which is currently the class of insecticides known as the neonicotinoids. There have been recent reviews of this class of insecticides by European Food Safety Agency (EFSA), which has resulted in a call for a European wide restriction of these pesticides by the European Commission (EC). This article is an analysis of these EFSA neonicotinoid reviews and the recent published EFSA scientific opinion and draft guidance for assessing effects of pesticides on bees, which were used as a basis for these reviews. As a result of some highly publicized laboratory studies in 2012, the EC urgently commissioned EFSA to review the risk to bees from the neonicotinoids. EFSA were given a narrow mandate and the time available to complete the reviews was extremely limited. Indeed, by the time the mandate was finalized EFSA had just a few months to complete the reviews in order to meet the EC deadline. Consequently, EFSA were pushed into taking an extremely critical and highly conservative approach in their review, identifying a long list of potential data gaps and risks to bees. However, several important flaws can be identified in some of the specific risk assessments carried out (e.g. for dust and guttation), in the general methodology used (e.g. virtually discounting all field studies and weight of evidence) and the fact that the science based approach used is not yet agreed or adopted within EU, and indeed is considered very controversial by the scientific and regulatory community. As a result the EC has proposed a severe EU wide restriction on the use of the neonicotinoids as seed treatments, soil applications and foliar treatments, even though the foliar uses have not yet been reviewed by EFSA or the MSs. These restrictions must also be considered in light of the recent Humboldt Forum study which concluded that neonicotinoid pesticides make anenormous socio-economic and environmental contribution to European agriculture and the wider economy. Neonicotinoid seed treatments are the most advanced crop protection solutions available for the targeted control of extraordinarily damaging pests. Neonicotinoids are applied with dose rates typically 10–20 times lower than the best available alternatives and prevent crop losses resulting in up to 40% reduction in yield. Without these products an additional 3 million hectares of land outside Europe will need to be brought into production adding an environmental burden of 600 million tons of CO₂. It is clear that we need healthy and thriving bee populations. The sustainability of agriculture depends on this. But we also need safe, modern, and innovative pesticides like the neonicotinoids if we are to produce the food we need. Rather than focusing on potential theoretical risks to bees under worst case unrealistic conditions from pesticides, we need to develop regulatory risk assessment guidance that enables in-use field realistic assessment approaches. In this way products and practices can be developed that allow bees and pesticides to co-exist together in a sustainable agricultural production system.