Guest blog – The flight of the neonicotinoids by Matt Shardlow

Bombus humilis Canvey (c) Sam Ashfield

Matt Shardlow is the Chief Executive of the Invertebrate Conservation Trust Buglife. Buglife is the only organisation in Europe committed to saving all invertebrates; the charity has twenty four members of staff and a growing portfolio of conservation projects.  The charity’s priorities include the sustainable management of brownfield sites; saving endangered Biodiversity Action Plan Priority species; putting bees and flowers back into the countryside; saving key sites for bugs from destruction, and improving the health of freshwater ecosystems.  Matt is chair of the Wildlife and Countryside Link (WCL) Legal Strategy Group and is a Country Diary columnist in the Guardian newspaper.  Before leaving to set up Buglife in 2002 he was at the RSPB.


“Where the bee sucks,

neonicotinoid insecticides

in a cowslip’s bell lie,

in fields purple with lavender,

yellow with rape,

and on the sunflower’s up turned face;”


From Ariel, by Carol Ann Duffy, 2011


There is a growing pile of research papers showing that neonicotinoids cause injury to bees; reducing locomotion, feeding and reproduction profoundly.   In the face of this Defra and its advisors have proffered increasingly flimsy reasons why what happens in laboratories may not happen in the field.

However, swift EU action now has the potential to resolve this chronic threat to our pollinators.

Unfortunately, despite the UK Government’s complacency on the issue up until now, Owen Paterson is reported to be about to take firm action to try to block EU measures designed to stop our pollinators from tumbling out of the skies.


The turning point?

The publication of the European Food Safety Authority’s new risk assessments for Imidacloprid, Clothianidin and Thamiethoxam was a watershed.  They determined a high risk to honeybees from exposure via dust drift when the seeds are planted, and via residues in nectar and/or pollen.  In addition Thamiethoxam was also identified as high risk for exposure via guttation fluid (sap that comes out of the leaves of plants at night and can be sipped by insects).

The report also concluded that “the risk assessment for pollinators other than honey bee…. could not be finalised on the basis of the available information.”

In response the European Commission has followed the letter of the law and proposed a new piece of legislation that would introduce a partial ban on the three neonicotinoids.  They could no longer be used on crops that are ‘attractive to bees’; they could not be sown during the summer, to avoid dust clouds poisoning flying bees; and garden use would be stopped.  This would start on 1 July 2013, to be reviewed after two years.

While a very significant step in the right direction, this partial ban does not address risks to pollinators from drinking guttation fluid from the leaves of treated plants, which will usually be fatal; it does not address concerns about the effects of neonicotinoids on soil and aquatic life; nor does it ensure that concentrations do not build up in soils and pollute subsequent flowering crops.  And of course there are two newer generation neonicotinoids – Acetamiprid and Thiacloprid that are not covered by these bans and may be subject to a subsequent risk assessment by the EFSA.


The UK is still not convinced!

It seems that the UK, Germany and Spain may vote against the ban on 25th February, if they do so then they only need to persuade one or two smaller countries to abstain for the vote will be lost and the EU ban will be in jeopardy.

Although wild pollinators will still be exposed to some risks if the partial ban is in place, the level of exposure will be very significantly reduced – this partial ban would be a great step forward.

Buglife, Soil Association, Client Earth, Pesticides Action Network, Friends of the Earth, Wildlife Trusts, RSPB, Butterfly Conservation, Woodland Trust, and Wildfowl and Wetlands Trust are all working together to try to persuade the UK to see sense and vote for the ban.


We need your help, urgently.


Please write to your MP this week urging them to persuade Owen Paterson to vote YES to the ban – template here –

Together we can make the neonicotinoid threat fly away.


More Information…..

I know from previous airings of this issue on this blog that the highly informed and land management minded readership will have more questions about this – here is my attempt to answer them.


Don’t the concerns stem from a little accident in Germany a few years ago?

There was an ecological disaster in Germany on one weekend in May 2008.  Dozens and dozens of beekeepers throughout the Rhine valley watched their colonies suffer c.60% devastation – who knows how many wild pollinators died!  Bayer was quick to claim that the Clothianidin had not been properly attached to the seeds and that this was a mistake that could never happen again.  However, not all bee-keepers are convinced, many believe that the concentrations on the seeds had been boosted to deal with an infestation of root worm and that due to weather conditions all farmers planted on the same weekend rather than spread out over a couple of weeks.  They believe that it was this coincidence that created an observable event across a large area.  This event may not have been noticed if it had been spread out over a longer period.

Whatever really happened on that weekend in Germany, we do know that the dust produced when treated seeds are planted does kill bees and still does so despite the much promoted new deflectors that were supposed to resolve the problem – two scientific papers are convincing on this point.

The scientific evidence regarding what happens to honeybees and bumblebees when exposed to ‘field levels’ of the chemicals in pollen and nectar is also convincing, they get very ill, catch diseases and are unable to reproduce effectively.


Why is there controversy?

Multinational pesticide companies with their single-minded focus on increasing their own profits and share dividends are a strong single issue lobby.

They have millions of pounds to spend to convince decision makers that pesticides are good and that the science is controversial.  The UK media likes controversy and is not confident with science, so it is quite easy to spread the notion that the science is uncertain and that more increasingly complex (and unfeasible) scientific tests are required before action can be taken.


Why should we conserve wild pollinators?

Actually I hope not many of you ask this, if you do then it may be enough to say that they are worth at least £510 million/yr to British agriculture and most wildflowers would die out without them.

Why in that case, you may ask, is their health not a higher priority?  The pesticide companies are getting a firm grip on the input side of farming.  Most farmers consult an agronomist about what crops to plant and what pesticides to use, the agronomist is usually working for the pesticide companies on a commission basis.

Neonicotinoid seed treatments enable the pesticide companies to control not just which chemicals the farmer purchases, but also which seeds are bought, which other chemicals used, etc.  – they are well on the way to capturing the input market.

It is no coincidence that wild pollinators do not pay commission to agronomists and also feature much less prominently in their advice.  When farmers and the public underestimate the value of wild pollinators then the political system will also be behind the curve.


Should we apply the Precautionary Principle?

The precautionary principle is well established in plant protection products legislation; because waiting until after the environment has been gravely damaged before taking action is not a sensible response.

Given that 94% of the scientific research published in the last three years has indicated a higher environmental risk than previously declared, and that Neonicotinoids were first used 15 years ago it is arguably no longer precautionary action!


Pesticides – are they always necessary?

I have been surprised by how little published information there is about agricultural pests and their impact.

Take the Pollen beetle for instance: a little black beetle that feeds on pollen and is targeted by neonicotinoid pesticide manufacturers.  One might think there would be plenty of science showing the damage the species was causing.  Not a bit of it, instead one finds a paper that shows that Oil Seed Rape is more than capable of simply replacing buds damaged by Pollen beetles – yield is not reduced.

Why then is there an industry established to destroy the Pollen beetle, how did it move from the category of ‘pollinator’ to ‘pest’?  The story goes that one year, in the not too distant past, in Germany, there were exceptional numbers of Pollen beetles, enough to mean that the local Oil Seed Rape was unable to produce enough replacement buds and yield was reduced.  A pesticide was developed to be active in the flowers and was marketed on the basis of being a prophylactic insurance.  Many agronomists advise its use because they are paid to do so and farmers often follow their agronomist’s advice.

Basically, the UK has a ‘reach for the poison’ approach to crop management, we under-use crop rotation and natural predators.  The principles of Integrated Pest Management are not compatible with the use of systemic pesticides.  In addition, the presence of neonicotinoids in 1.2 million hectares of UK crops for the whole growing season, every year, is a recipe for resistance.

The Millennium Ecosystem Assessment shows that the introduction of neonicotinoids to Oil Seed Rape cultivation did not significantly increase UK yields.  Also we have seen neonicotinoid product authorisation documents that include studies where the control plot had higher yields than the insecticide treatment plot.

Of course there are some pests that will, unless treated, reduce yields.  Pest control is best done by informed and aware farmers monitoring the levels of pests in their crops and applying the most specific solution when a developing problem is detected.


Will we be able to feed ourselves in a post–neonicotinoid agricultural system?

A retraction of neonicotinoids is likely to result in a range of farming practice responses.   Because yet another group of miracle chemicals has been revealed to be environmentally damaging, some farmers may decide now is the time to go organic!  Older pesticides such as pyrethroids will be used In many fields, in some no insecticide will be necessary, in others a different crop will be grown, and in the longer term new techniques and chemicals will no doubt be developed.

It is legitimate to ask if pyrethroids, the most likely direct replacement, are more or less damaging than neonicotinoids, but an empirical answer is not available.  Pyrethroids are sprayed so are likely to be present in the air and crop for a shorter period than systemic neonicotinoids, which are present for the full life of the crop, neonicotinoids are more persistent in soil (pyrethroids < 100 days, neonicotinoids up to 6900 days), and, therefore, have a greater potential to accumulate in the environment.  Neonicotinoids are about 200x more toxic to bees on an acute oral basis, although predicting exactly what happens in the field at different concentrations of active ingredient is very difficult indeed.  While pyrethroids are subject to spray drift, neonicotinoids create toxic dust clouds when planted.  Pyrethroids are thought to be more toxic to aquatic organisms than the neonicotinoids, requiring buffer zones.

There are other pesticides that could be used as alternatives, including biopesticides  (biological control).

The potential for new and innovative products to directly replace neonicotinoids was recognised by Defra in its written evidence to the on-going House of Commons Environmental Audit Committee inquiry into neonicotinoids.

Crucially, there have been no reports of drops in yields in countries where neonicotinoids have been banned.


Final thoughts

In the 1960s it became morally unacceptable to use pesticides that destroyed wild bird populations (which incidentally do not help us to feed ourselves) understandably it is now becoming morally unacceptable to destroy populations of helpful pollinators.

Farming was productive before neonicotinoids and will be productive when they are withdrawn.

This case raises serious doubts about the lack of transparency of the authorisation process, the weak quality and narrow breadth of the studies done before toxins are authorised, and the time it takes the regulators to accept new information.

There should be fierce competition to produce and sell the most effective and environmentally benign pesticides.  Instead the information that would enable such competition is kept secret by pacts between pesticide companies and national governments.

However, the immediate problem is that the UK may vote against the EC proposal and then there may be no action at all to restrict risky uses of neonicotinoids – please help


49 Replies to “Guest blog – The flight of the neonicotinoids by Matt Shardlow”

  1. This is singularly the MOST important conservation battle right now. (Well… That and our declining swift population of course – put a box up everyone, just ten Weeks to go).
    It’s an absolute disgrace how DEFRA are pretending otherwise, rolling their eyes and whistling around the subject. An international disgrace, with potentially incredibly serious consequences for us.
    If we lose our pollinators, we lose full stop.

    This subject has the potential to make bTB seem completely trivial.

    1. You are correct – it IS the most important conservation battle. Your dilemma over whether the decline of the Swifts is not really a dilemma – it is part of the same battle. Neonics are used on over 4 million acres of UK crops and they effectively destroy every single aphid, bee, bumblebee, hoverfly, butterfly, lacewing and beetle above the ground over that entire area. But it doesn’t stop there. Over 95% of the neonic poison applied to the seeds of wheat, barley, oilseed rape, potatoes etc – is NOT absorbed into the plant – rather it leaches into the soil. There is a mass of evidence that it kills almost all earthworms, slugs, beetles and soil invertebrates.
      It is not just crops either. neonics are used on millions of acres of domestic lawns, golf courses, school playing fields, rose gardens and in the entire horticultural/ garden centre trade.

      Since they have effectively wiped almost all insect life from the face of the countryside – is it any wonder that insectivorous birds have disappeared from the fields like ‘snow off a dkye’.

      Please download and read this article: ‘our Toxic Countryside’ here:

      Graham White
      Friends of the Bees

      1. Graham – thanks very much for your comment.

        I would be surprised, very surprised, if the use of neonics is the one and only cause of farmland bird declines in the UK or elsewhere where they are used. For one thing, my understanding is that the bird declines started and were extreme before neonics became widely used in the UK – but I may be wrong.

        I am not suggesting that neonics are not a problem – just that there are many problems.

  2. Email sent this morning.

    If you can get an article or link on the Buglife Facebook page I will gladly share although I will put out a share on this blog for now.

  3. Thanks for the blog. We are fully supportive of the neonicotinoid ban.

    I would like to remind everyone that buying organic bread, cereals, biscuits, porridge oats etc will mean that these grains are planted without any neonicotinoid use as they are not used in organic systems. As importantly check the provenance of your purchases. If you are buying imported grains then you are effectively exporting the environmental benefit that your purchase creates.

    Stimulating the UK organic cereal market would be a huge boost to all invertebrates as not only are the toxin pesticides banned but organic farming systems provide far more feeding opportunities for bees as clover is grown to build fertility and greater biodiversity exists within crops.

  4. This is an excellent article by Matt Shardlow that dispels a number of key myths.

    I’d like to add to Matt’s brilliant analysis:

    This page looks at patents containing neonicotinoids, which are very revelaing: e.g. when a patent claims to kill lepidoptera (butterflies and moths)

    Readers may not be aware that the regulatory test guidelines for pesticides are devised primarily by industry – the EPPO, which for example, produces flawed field study guidelines such as EPPO 170:

    Building on Matt’s point about field tests vs lab tests – do read this page – an example of how FERA/DEFRA treated a flawed field test vs a quality lab study that looked at oral toxicity from guttation:

    This is actually a letter, but gives some insight into the question about the legality of neonicotinoids:

    As Matt says, a restriction to neonics is good, but not enough for other insects, ground dwelleds etc – and Thiacloprid, Fipronil, etc will remain on the market for a while:

    Finally, when you hear the industry spouting that there are countries where neonics are used, Varroa isn’t present, and they have healthy bees. Take this with a pinch of salt. One example: Australia:

  5. Matt (and Mark) – thank you for a superb blog, and for publicising the campaign. I have gladly sent the template letter with a few bits and pieces from the blog thrown in.

  6. Graham. I’ve read the second sentence of your comment (the dilemma dilemma bit) a few times now and still don’t understand you. Dilemmas aside, the use of neonicotinoids is but one factor in the demise of our UK breeding swifts. Habitat loss (breeding habitat) is as important. More so, in fact, it might seem.
    Nevertheless the neonicotinoids controversy is THE conservation battle at present. Thanks for agreeing with me on that.

  7. Matt,

    Can I make a few points about your blog today which leads on very interestingly from your good comments on the bog a few days ago where I first responded to your post.

    I think the first thing to say is that even as an arable farmer I am broadly sympathetic to your cause actually. We can’t farm without pollinators as you rightly pointed out despite these wildly picked figures we always see about trying to put a monetary value on benefits which are really impossible to quantify. My issue is really one of attempting to point out the detail in what can be an oversimplified response to a very complex picture.

    I think a total ban, regardless of circumstances, ignoring timings of application, crop type etc. is wrong. We could get into the detail on this but I think it’s enough to point out that broad scale use in say flowering or green bud stage in oilseed rape is of far greater concern than say seed treatment on maize due both the timings of application and the vast disparity between the areas of the two crops grown in the UK. This is not meant to be an unpleasant critic but unfortunately pressure groups like you own organisation tend to go for the simplest argument possible as it is the easiest message to get across. In my option this can be very damaging as I think I pointed out in a previous post when the EU adopted their Thematic Strategy on the sustainable use of pesticides in 2006-2009. This was out of proportion and very damaging to UK and EU production levels. I think you are in danger of repeating the same mistake although, as I said I do think you have a very valid point about the harm these chemicals can do in some circumstances.

    Although I have a great deal of respect for your knowledge on this subject and your commitment to seeing an improvement in the situation I am going to have a small go, in a very polite way, at some of your statements on the blog today about the alternatives.

    “It is legitimate to ask if pyrethroids, the most likely direct replacement, are more or less damaging than neonicotinoids, but an empirical answer is not available”


    “Why then is there an industry established to destroy the Pollen beetle, how did it move from the category of ‘pollinator’ to ‘pest’?”

    Pyrethroids such as cypermethrin and deltamethrin are extremely damaging to aquatic life and tend to be used in broad scale arable farming at times when soils are at or near 100% capacity. If a complete ban comes in on neonicotinoids then the rates of use of pyrethroids is going to increase both as a direct alternative and as a result of increased does rates to combat the well-known issues with resistance, especially in pollen beetle. It’s not correct to imply that pollen beetle damage is an industry myth. Damage to buds in the crop that are unopened can be quite severe in some circumstances where flowing has been delayed by cold weather. Rape is an early flowering crop with a very extended flowering and pod fill period, the crop emphatically dose not recover from this damage but it is up to an integrated pest management approach on farm to access the right circumstances to apply an insecticide. In some cases flowering occurs soon after the threshold for treatment of pollen beetles is achieved and the beetles move to the open flowers and no treatment is needed, in other cases a very reduced rate of insecticide is used to delay the problem in order to give the crop time to develop.

    “Of course there are some pests that will, unless treated, reduce yields. Pest control is best done by informed and aware farmers monitoring the levels of pests in their crops and applying the most specific solution when a developing problem is detected.”

    Agreed totally, just said it above but why then would a reduced rate of a noetic not be more preferable to say an OP ? Obviously used correctly it would be so why lobby for a total ban ?

    “Will we be able to feed ourselves in a post–neonicotinoid agricultural system?”

    Yes of course we can, that is not a valid argument against a ban but your view on sustained production levels within the UK and EU is a little dismissive. There will ultimately be someone somewhere who will have to pay the price. It may well not be us as we are a developed country who can afford to import food stuffs however the same is not true of poorer nations. We have already seen a massive increase in soft commodity prices worldwide; Indeed this year we have gone from being a net exporter of wheat to the rest of the world to importing wheat, several million tons this year so far.

    “Farming was productive before neonicotinoids and will be productive when they are withdrawn”

    Sorry that’s not going to be agreed by me, it’s a massive oversimplification of the issues and completely ignores the issues to do with resistance to all pesticides and the plant breeding which has occurred in the past decades to improve natural resistant to plant pathogens. Arable farming is a constant evolution of husbandry and agronomy to maximize yields using the best products available. Farming will not be as productive if you revert back to previously agronomic practices as these will be totally ineffective against modern strains of fungus, pests and weed problems. Maybe this is acceptable as a balance between productivity and environmental production, personally it is for me as lower yields, lower costs and higher commodity prices makes good senses business wise. It is the model used by the organic sector after all. Whether it’s the moral answer given the global food situation remains to be seen.

    Finally good luck with your campaign, please don’t feel that there is not an unsympathetic ear in the industry as that is wrong. Just a valid concern as to the very difficult practicalities of a total ban. Arable farmers do have a good track record, often unsung and un-acknowledged, of listening to concerns on pesticide use. The industry put in place the VI, or voluntary initiative, for operator training and sprayer mot’s a large part of which is involved with environmental protection. We are way ahead of the rest of the EU on this. We have had the recent initiative on OP’s with the extended limits to the buffer zones and the metaldehyde voluntary reduction in the max applied dose and massively improved awareness and operator training in its use for slugs.

    1. Dear Julian

      Good points and challenges.

      A complete ban or a partial ban
      For Buglife to agree that a particular use was acceptable we would need to be confident that that use would not damage the environment if widely adopted (it is difficult to justify authorising a use on the basis that the current crop area is small, because it may get large!). As set out above, the EFSA was unable to rule out a high risk to wild pollinators from several current uses. Buglife has reviewed the science and we can’t be certain that any of the current neonicotinoid uses are environmentally safe. Given the uncertainties about impacts on pollinators, soil fauna and aquatic life, are you able to say with certainty that any neonicotinoid use is safe?

      Buglife has no dogmatic opposition to any pest control method, if certain uses of certain neonicotinoids were shown to be environmentally safe then we would change our position.

      Aquatic impacts
      Neonicotinoids are not saints in water either, indeed they are more soluble, more water mobile and more persistent than pyrethroids, but little is known about their toxicity to non-target freshwater organisms and potential effects on freshwater ecosystems.

      Alexander, Heard & Culp (2008) found that mayflies showed a reduction in reproductive success when exposed to concentrations of imidacloprid as low as 0.1 µg/l and Alexander et al. (2007) found that imidacloprid levels reduced survival, feeding and egestion mayflies and aquatic worms at concentrations between 0.5 and 10 µg/l. Beketov and Liess (2008) found that aquatic insects were significantly more sensitive to Thiacloprid than the Daphnia that is used to assess risk to aquatic environments – 50% of three insect species died when concentration in the water were between 5 and 7 µg/l.

      There has been widespread contamination of Dutch surface waters with imidacloprid, with concentrations regularly exceeding the Maximum Tolerable Risk levels and up to 200 µg/l, in France levels over 1000 µg/l have been detected, and imidacloprid was detected in 67 samples (89%) of Californian surface water and concentrations exceeding the safety benchmark in 19% of samples (Starner 2012).

      Look at the figures above again – concentrations of neonics hundreds of times above the levels known to have severe lethal and sub lethal effects are being recorded in EU waterbodies. Unfortunately these insecticides are not routinely monitored in the UK waterbodies.

      In Japan neonicotinoids are licenced for use on paddy fields – which seems frankly insane – local entomologists claim that dragonflies, which used to be abundant in the paddy fields, are now rarely seem. The 2013 paper by Jinguji et al. explains why there are no dragonflies anymore –

      Neonics and Integrated Pest Management
      Neonicotinoids are not widely authorised for spraying on arable fields, probably in part because of fears of water pollution (the dust cloud issue has only recently been understood). Thiacloprid for pollen beetles (Biscaya) is one of the exceptions. My understanding is that it is not currently possible to buy OSR seed that has not been pre-treated so there is currently no IPM farmer choice with OSR. With seed treatments the farmer is unable to monitor pest levels within year and then use the neonicotinoids; they are prophylactic rather than curative.

      Pollen beetles
      Your experience of pollen beetles as a pest is very interesting, thank you for sharing, and I would like to know more. I am interested to know how you judge that pollen beetles are responsible for any yield loss, what damage do you observe? How can you tell that the damaged buds have not been replaced by the plant? The scientific paper showing that rape can cope with considerable loss, up to 35%, of buds by replacing them with new buds is here – Williams and Free 1979

      Do you have any ideas why your experience differs from that of these scientists? Do you think that we have delayed the timing of rape seed planting and that this may make damage more likely? Perhaps the massive increase in the prevalence of OSR means that what was previously a pollinator has become a pest?

      If you are farmer or scientist with Pollen beetle experience current or historic please do add a comment.

      Feeding ourselves
      The picture is further complicated by the fact that rather than feeding us much of the OSR crop is industrial and is displacing food production. If the proposed partial ban reduces the amount of OSR grown then there may be more food produced!

      Industry claims
      Having had experience of this type of issue before, when we successfully campaigned against the use of cypermethrin as a sheep dip, I am used to pesticide companies making outrageous claims about what will happen if they can no longer sell their toxins. In my experience the doom scenarios do not materialise because farmers and others are considerably more resourceful and adaptable than the companies would have us believe.

      Hence my faith that we can find ways forward that will enable wildlife and food production to coexist very successfully. A belief bolstered by the fact that all the real world data on yields/ha that I have seen do not show increases when neonicotinoids were introduced and have not shown reductions when they have been withdrawn.

      Thanks again, perhaps we will turn our attention to slugs and molluscicides next!


  8. I wrote to my MEPs and have received the fairly predictable reply from Julie Girling, Conservative.

    Dear Mr Unwin

    Thank you for your email regarding pesticides and honeybee health. There has been a lot of media activity in recent weeks following the publication of an EFSA (European Food Safety Authority) review, on 16th January, of neonicotinoid pesticides. Last week the European Commission announced proposals for partial bans on the use of these pesticides across Europe.

    I personally believe that a ‘ban’ of clothianidin, imidacloprid and thiamethoxam is premature and disproportionate. There are a number of reasons for this. First of all the EFSA review (;
    utm_medium=infocus&utm_campaign=beehealth) not only identified some risks at different levels of exposure to bees, but also identified a number of data gaps. Consequently many aspects of the reviews could not be concluded. As a result I feel at this stage that a more thorough review of these products should be carried out, most particularly field trials which would give us a broader view of the real impacts.

    I am mindful that many people believe that action should be taken on the basis of the Precautionary Principle, and have cited improving health and survival rates amongst bees in Slovenia and other areas which already have a ban. I have searched in vain for any evidence of this claim and I simply cannot find any. I do not believe that enough evidence exists to support the Commission’s proposals and I am deeply worried that many will “take their eyes off the ball” and neglect research on the other issues affecting pollinating insects such as varroa, nosema, monoculture and many more. I believe we need to be cautious when imposing such bans or restrictions of use, after all there is a reason that these products are on the market and used by framers and growers throughout the EU. Their purpose is quite clear, they are designed to kill insects that attack crops and affect the yield. Our work should concentrate on strict enforcement of conditions of use to eliminate unintended consequences for our bees. So we must carefully consider the economic and practical consequences of a ban, or restriction for the users. These pesticides are used on maize, oilseed rape, potatoes, sugar beet, sunflower, cereals and many other crops.

    We also need to be aware that banning these products will only take away one of the many factors affecting honeybee health. The threat of the varroa mite, fungal diseases such as nosema ceranae, lack of forage and climate change will still exist, and will still affect and contribute to colony collapse disorder (CCD). More will need to be done regardless of a ban in coming years to save and protect these vital pollinators. I will continue to call for more research spending.

    Yours sincerely

    Julie Girling
    MEP for the South West of England & Gibraltar Chief Whip of the UK Conservative Party Delegation in the European Parliament Agriculture and Rural Development Environment, Public Health & Food Safety Fisheries

    Email: [email protected]

    Elections can’t come soon enough.


    1. Dear Bill

      Many thanks for helping. This is a standard response, we are currently putting together a standard response to their standard response so keep an eye on the Buglife website.

      I imagine you asked questions about wild pollinators and have got answers about domestic honeybees to start with!

      Varroa and Nosema ceranae do not affect wild pollinators.

      The law (Regulation (EC) No 1107/2009) says this:-

      “the objective of protecting human and animal health and the environment should take priority over the objective of improving plant production”

      “The provisions of this Regulation are underpinned by the precautionary principle in order to ensure that active substances or products placed on the market do not adversely affect human or animal health or the environment. In particular,
      Member States shall not be prevented from applying the precautionary principle where there is scientific uncertainty as to the risks with regard to human or animal health or the environment posed by the plant protection products to be authorised in their territory.”

      Does their proposed approach sound lawful to you?

      Mark says below that we make the decisions through our elected representatives, but it is difficult to imagine that many for Julie Girling’s constituents would share the views expressed here. I do however know a number of pesticide industry employees who would express very similar opinions.


  9. Horse meat more newsworthy than dead bees – that says so much about human beings. With the list of disasters piling up at DEFRA’s door Mr Paterson will end up being so busy he’ll get it all mixed up and we’ll be culling bees, banning horses and testing neonicotinoid pesticides for bTB.
    Totally support more organic production – I try very hard to get British organic food, its not easy and its often expensive. But it can be done.
    The reply from the MEP on the banning of neonicotinoid pesticides is such a standard blurb – it reads like a marketing manual. There was a time when governments didn’t seem to need any scientific research upon which to form their policies, these days there is never enough of it. Someone needs to explain to them that research never gives anyone ‘an answer’ – what it gives you is a range of possibilities and probabilities. It is up to you to understand these and interpret them – to make an informed decision. Research doesn’t = decision.
    One thing is incredibly obvious to me [and always has been] – toxic substances designed to kill living things are destroying the fabric of our ecosystems. In doing this we are destroying the life support system of the planet and the longer our pathetic politicians refuse to face this fact, the more certain it is that we will cause our own extinction. In view of the enormity of this probability banning some of the nastiest pesticides currently in use seems a very easy and painless step to take. We just need a few people capable of taking the decision. We are drowning in government by committee.

    Twitcher in the Swamp in current British Wildlife is well worth a read – and a chuckle. I think he’s been following Mark’s blogs!

    1. Diapensia – you do. But rather indirectly through electing MPs and then expressing your views to them.

      1. Hello Mark, thats strange, I thought Thatcher said she wanted this country to be like america. America is run by big business. Did we have a referendum to give people power to the public. I think I missed it.

        1. Unfortunately here in the states the EPA administrators are ex Monsanto employees and our voice means nothing, we are free to do as they say.

  10. Pingback: Why is Bee Decline Not a National Emergency? « Set You Free News
  11. Dear Matt,

    Thank you for your response, you will not be surprised that I don’t agree with all of what you say but I hope that you will be pleased that I think you have made some very valid points.

    To answer or expand very briefly on the pollen beetle points you raised; Biscaya use (and I’m impressed by your detailed knowledge of your subject by the way) is relatively recent in green bud stage oilseed rape and has come about as a result of resistance to pyrethroids so I would suggest that it might be a bit early to say what long term effects it has or will have. I haven’t had time to read your links on this (I will do latter) but it would be perfectly possible to see a yield increase caused by pollen beetle in some circumstances. This is due to the canopy management effect that pests, nutrition, weather and plant populations per square meter can cause. There is an optimum canopy that will intercept light best to maximise yield; in a situation where the canopy is too large pests etc. can actually be beneficial in reducing the canopy down closer to the optimum. Conversely a backward crop can managed forward by treatment, Biscaya for instance, to improve the crop structure. The agronomic decision making structure can be complex but I will agree that as commodity prices have risen, in fact in oilseed rape trebled, the cost/benefit ratio does change.

    Just to round up on this I would like to come back on the issue of polarisation of views which I touched on before. I see this as one of the biggest mistakes that we are making at the moment both in terms of food production and the environment. Groups on both sides are boxing themselves into positions which are going to prove untenable long term. The classic example of this is the Soil Association. I keep a very close agronomic eye on what goes on in the organic sector, I would be mad not to given the work that they are doing but the difference is that as a conventional farmer I have the ability within my sector to adopt some of their practises should I wish to. (looking very carefully at the moment at the French work on cover crops to suppress grass weeds for instance). They of course do not have that ability and have to work within very set almost ideological frameworks. The GM debate is another example. Why do I have to applied massive doses of herbicides and insecticide to sugar beet when there is a perfectly proven GM beet available in the US which would reduce that burden to almost nothing ? I lose a least 20 tns of beet yield per hectare through herbicide damage, enough to put the entire headland, boundary zone, into a nectar pollen mix and still exceed my current performance.

    Enough ranting !

    Again thank you for your views and your knowledge, I take it very much on board. Mark has my details on his system I would imagine, we welcome anyone from almost all the NGO’s and certainly yours, on the operation should you wish to get a farming experience on the ground. I will hide the sprayers if you visit !

    Kind regards Julian

  12. “If the proposed partial ban reduces the amount of OSR grown then there may be more food produced!”

    The residue from crushing OSR is a valuable animal feedstuff – so we do eat it indirectly as well as in cooking oil. Removing OSR from arable rotations is likely to see it substituted by something else – like wheat for ethanol production. Or even worse, sugar beet or potatoes for ethanol. We need to be careful what we wish for.

    Pollen beetle seems to be everyone’s preoccupation – in my experience cabbage stem flea beetle is a worse problem. Never seen it? Grow radishes or rocket, then you will. OSR may recover from pollen beetle attack by producing more buds – not difficult for an indeterminate – but there is no mechanism for recovering from reduced plant population. No neonic seed treatment – post-emergence flea beetle control using SP, followed by pollen beetle control using SP at flowering. Two spray trips, which are costly and OMG! hit the carbon accounting rather badly. Just sayin’ like.

    Here’s a thought – no SPS payment for biofuel crops (or sugar), and no export subsidies either. Weeping, wailing and gnashing of teeth in the Shires, but much of the incentive to grow OSR is removed. I’d go further, and ban it from shallow soils over chalk and limestone – it needs a load of N and has an appalling N-leaching coefficient. And then there’s the yellowists who hate it on the grounds of its unnaturalnessness (but they just lurve the pastel blue of linseed). All in all it’s a bit of a disaster crop. Pity it’s the most profitable combineable crop we have.

  13. On the subject of agronomists it is becoming more and more common for farmers to employ an independent agronomist who is not tied to any particular agrochemical distributor. That way they can shop around for the cheapest quotes and be in a better position to question the use of a given pesticide at all. Some farmers such as myself have become qualified themselves to do their own agronomy with the ‘BASIS’ qualification.

    In all my years growing oilseed rape I have never applied an insecticide for pollen beetle. We certainly get plenty in the crop, but numbers rarely build up, in my part of the country anyway, to levels that need to be controlled. That’s not to say they can’t do significant damage, particularly to backward crops, but routine monitoring and observing control thresholds closely allows us to limit their use. Overuse of insecticides leads to resistance, so it’s in our interest not to use insecticides excessively. The HGCA have recently updated the threshold guidelines for control and are a very helpful tool for deciding if treatment is needed. Indeed as one of their researchers said at a recent meeting, once the crop reaches 10% flower, the pollen beetle ceases to be our enemy and becomes our friend.

    There is no doubting that neonicotinoids can pose a risk to bees, but they don’t seem to be affecting all invertebrate life as some people suggest. Our neonicotinoid treated oilseed rape is full of insects at harvest, and I have witnessed dozens of swifts swooping down over the trailers of rapeseed to catch the flea beetles that jump from the surface of the pile. Our soils also still have plenty of earthworms too, evident in the number of gulls, rooks, buzzards, herons and everything else that follow the plough. And don’t mention slugs. After nearly two decades of neonicotinoid use on and off on our farm, the slug population is as healthy as ever!

  14. Not a lot in your blog that I disagree with, Matt. But it does concern me that all this focus on neonicotinoids as a single issue will be seen as an easy fix by government when a broader reform of farming practises is what’s really required. As you know, the decline of wild bees and other pollinators can be tracked back to long before the introduction of neonicotinoids. Any talk about this being the single most important conservation battle is short sighted hyperbole.

    Lynn Dicks has written an interesting piece on the subject of rhetoric, lies and over-the-top claims in Nature online:

    All the best,


    1. Jeff – welcome and thank you. I agree that in this case, perhaps more than others, the hyperbole from some has slowed down the coalition of concern that is needed to make progress. which is not to say that there is no problem – but it is important to say that there are other problems too.

        1. We do of course need to address a whole range of single issues to rescue our wildlife. Just because there are ‘other problems’ this is no reason not to tackle ‘some problems’ and I am sure you would not suggest this.

          Lynn’s article is interesting as although it agrees that a ban would reduce the risk to bees, it then dedicates over four times more space to highlighting instances where proponents of environmental caution may have over-claimed (not Buglife I hasten to add) than the space given to the over-claiming of the pesticides companies. This does not reflect my experience of the debate in which inconvenient facts are routinely deflected by unsubstantiated propaganda. Perhaps we expect this of big business and don’t criticise it, perhaps we should?

          Buglife has always taken a science led approach to the issue, mixed in with our knowledge of the ecology of the species involved. However, there have been others who have been claiming widespread corruption and collusion amongst businesses, scientists and regulators.

          These claims can be a big turn off, but after working on the issue for years you would have to have your eyes shut not to sense the huge persuasive power of the vast scale of funding that the pesticides industry dishes out to scientists in the field.

          It would be naive to think that scientists, even with their best intentions, are immune from susceptibility to money and power.

          Let’s look at Nature as an example. Yes they have published papers that have produced difficult results for the pesticides industry, but when they do so they give industry funded scientists prior views of the papers and then allow them to include critical opinions in the very same issue to counteract the articles. Nature has also parroted a press release put out by Bayer criticising EFSA in a move that is either grossly naive or biased – – and in which those working for a sustainable future for pollinators are characterised as ‘bee botherers’ (which might even be worse than being accused of being a bee fashion victims by Lynn Dicks).

          Nature then produced an whole edition sponsored by Bayer – – I wonder how much money exchanged hands.

          Here is a link to Buglife’s efforts to solve another single issue – wildflower loss –


          1. Hi Matt,

            I don’t doubt Buglife’s good intentions or its willingness to use scientific evidence, and I’ll leave Lynn to argue her case on what she was or was not saying.

            But I will respond to the point that you made about “corruption” by scientists funded by large companies. You seem to be implying that Juliet Osborne’s News and Views commentary was an industry-sponsored counter attack on the Gill et al. paper. Is that really what you believe? How well do you know Juliet? She’s a thoughtful, careful scientist who weighs up evidence before making decisions. The final section of her commentary reads:

            “this single study does not provide a full explanation for bee declines, nor a definitive answer to questions about how to change pesticide regulations. But its convincing and detailed data set highlights the appropriateness of including bumblebees in agrochemical risk assessments and, more broadly, the need for a better understanding of pesticide-exposure landscapes.”

            How can that possibly be interpreted as (in your words) “critical opinions in the very same issue to counteract the articles”.

            Science should be about discussion and debate, not dogma, and certainly not cherry picking evidence to suit a case (on either “side”).



  15. Dear Jeff

    I certainly don’t think that Juliet Osborne is corrupt and I don’t think I said that either.

    I said that “there have been others who have been claiming widespread corruption and collusion amongst businesses, scientists and regulators.” And that “These claims can be a big turn off”. I find them a turn off myself, indeed when I have criticised weak papers that claim to link CCD to pesticides, when they do no such thing, I have been subject to the accusations myself! Such accusations are usually unrealistic and over-simplistic.

    We are social animals driven in part by reward. It is not far-fetched to think that this results, even in scientific minds and communities, in a certain resistance to change and the formation of particular world views. I don’t think this is corruption, for me corruption is when people know they are doing wrong and do so deliberately. Power can be exerted in much more subtle and subconscious ways than corruption.

    The current pesticide industry strategy is to establish that the science is uncertain and there is a need for more science to be done before any action is taken. This is unfortunately also the position of many scientists, albeit with different motivations. The effect is the same, toxic neonicotinoids continue to be used, wild pollinators are being affected and wildly high concentrations are being found in freshwater habitats.

    You are right we probably should not cherry pick evidence from Juliet’s paper, but as it is behind an expensive firewall here are a few alternative quotes from it:-

    “chosen concentrations …… may not reflect what farmers actually use in best or common practice”

    “There are simply not sufficient field data available on the variable spatial and temporal distribution of pesticides on or in plant material, nor on bee foraging choices, to make useful comparisons between field and experimental exposure”.

    “their study should stimulate further exploration”

    “the balance between protecting crops from pest damage and protecting pollinators needs further consideration”

    Juliet is a thoughtful, careful scientist who weighs up evidence and who receives significant funding from Syngenta. It is the editorial process at Nature that I am questioning, as well as publishing scientific papers they are also publishing pesticide industry sympathetic News and Views and press releases – why are they doing this?

    Discussion and debate are usually good things, but we have been discussing and debating for four years now and if the pesticides companies get their way we will continue to do so until the next generation of pesticides arrives .

    The law says that if we don’t have confidence that pesticides are safe for the environment they should be suspended. The law does not say that we should keep pumping money into science until there is a definative answer.


  16. Matt,

    If you are correct in your assertion, Nature’s editorial policy (as you see it) still requires complicit scientists to write the commentaries. Regardless of what we call it, you seem to think that because an article has been written by a scientist funded by an agrochemical company, it will be biased. It’s easy to see conspiracies everywhere but where is the evidence? We’ve recently published a series of papers about biodiversity on restored landfill sites, which compare favourably with comparable nature reserves; you can find PDFs here:

    Now, this was funded by SITA through their Environmental Trust. Does that mean that our findings are suspect and “pro-landfill”?

    Anyway, this is all a bit of a side issue. As I said, not much I disagreed with you about in your blog. If we apply the precautionary principle then there’s a strong case for withdrawing neonics until we know more. But my concern over how this might be spun by government, as the answer to pollinator declines, still stands.


  17. No, Jeff, not seeing conspiracies – that’s people getting together in secret and deliberately determining a course of action. I hope we are just seeing the subtly persuasive effects of power and money on human beings.

    When formal committees meet to discuss this sort of issue then those who stand to benefit financially from the decision have to leave the room. There are obviously degrees and the placing of steel walls between interest and influence is not always beneficial as interest and knowledge are also often correlated.
    However, I question the purpose of placing an opinion article that puts out the industry message – more research required – next to a scientific paper that shows that:-

    “two pesticides (neonicotinoid and pyrethroid) at concentrations that could approximate field-level exposure impairs natural foraging behaviour and increases worker mortality leading to significant reductions in brood development and colony success.”

    The fact that the author declares competing financial interests “J.L.O. has a research project partly funded by Syngenta”. Does not explain why Nature felt that it was appropriate to include such an opinion piece in the first place.

    Whatever the outcome on neonicotinoids are not about to stop promoting the need to understand and resolve a range of threats to wild pollinators.

    CEO Buglife

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