There is no evidence that there is no evidence.

30 Replies to “There is no evidence that there is no evidence.”

1. I am not sure that the Chief Scientist’s argument (if I understood him correctly) was very strong when he made the point that oil-seed rape needs pollinators, rape crops continue to flower and set seed ergo there is no problem with neonics harming pollinators. The fact that there are still enough pollinators flying about to pollinate the crop does not mean there is not a decline going on and who is to say that there will not be a collapse somewhere down the line?
   In both the Leeds General Infirmary case and the Neonicotinoid case the available data are less clear cut than one might hope to have to base a decision on. The difference is that in the case of the hospital a precautionary approach was applied.

   1. Jonathan – I agree that that part of Ian Boyd’s argument was weak.

      1. What are neonicnoids (@ 00:07)?

         OK – “neonicotinoids” is a bit of a mouthful, especially if you are a springtail, but I’d expect the Chiefio to be on top of his brief.

2. More a case Jimmy Saville used to work here! And in the same line. Lets wait till the bees are dead and then do something.

3. Mark, you really are wide of the mark on this one; if you are seriously interested in getting ‘up to speed’ on this vital issue I am happy to brief you – but you are repeating the pesticide-lobby’s arguments almost verbatim.

   The evidence for neonicotinoids being the primary cause of the death of over 10,000,000 bee colonies worldwide is not finely balanced or equivocal. The European Food Safety Agency report was written by a panel of over 20 of the most eminent toxicology and bee-science experts from almost every country in Europe. It considered more than 50 peer reviewed reports and concluded that the scientific evidence was overwhelming.

   The best online library of current research is held by Small Blue Marble here:

   http://smallbluemarble.org.uk/research/

   Buglife – In 2009, the specialist invertebrate conservation charity produced a ‘definitive’ assessment of the evidence from dozens of peer-reviewed studies; see here:
   http://smallbluemarble.org.uk/wp-content/uploads/2011/11/Buglife-neonics-report.pdf

   They have just reviewed and updated their findings. They concluded (abstract):

   “Methods
   We have reviewed the 41 papers and put them into two categories –
   1) Study suggests worrying environmental impacts above and beyond what was known when we produced our 2009 report
   2) Study suggests no effect or an effect that indicates that environmental impacts are lower than expected. In addition a number of papers were considered where either the outcome was not conclusively in category 1 or 2 or the experimental
   methodology was flawed or clearly not relevant to the real world.

   Results
   Of the 33 papers that could be categorised 31 (94%) of the papers contained evidence that neonicotinoids would or could have significant
   environmental impacts above and beyond what was previously known. Only two (6%) of the studies provide reassuring evidence that
   neonicotinoids are not damaging the environment or not likely to damage the environment.

   1
   Kindemba V. 2009.The Impact of Neonicotinoid Insecticides on Bumblebees, Honey Bees and OtherNon-target Invertebrates.Buglife – The
   Invertebrate Conservation Trust, Peterborough, UK. ”

   See recent update from Buglife here:

   http://www.buglife.org.uk/Resources/Buglife/A%20review%20of%20recent%20research%20relating%20to%20the%20impact%20of%20neonicotinoids%20on%20the%20environment.pdf

   The impact of neonics on birds has also been recently confirmed in a high-level science study by the eminent eco-toxicologist Dr Pierre Mineau and Cynthia Palmer, from the American Bird Conservancy. They studied five factors which may have contributed to the massive collapse of bird species in agricultural areas across the entire USA: habitat loss, agricultural intensification, climate change – and pesticides.
   They concluded that the only correlation which explained the bird-losses, with a high degree of consistency in geography and time, was the application of neonicotinoid pesticide.

   http://smallbluemarble.org.uk/wp-content/uploads/2011/11/Mineau-Palmer-2013-The-Impact-of-the-Nations-Most-Widely-Used-Insecticides-on-Birds.pdf

   Their report offers a much better explanation of why Europe has lost 300 million birds in less than 20 years, and why 19 species of UK farmland birds have declined by between 50% and 80% since neonics were introduced. Yes there are many factors involved, but the annihilation of the vast biomass of most invertebrate life from our arable croplands (above and belopw ground) is the best hypothesis which explains the known facts.

   The following agencies and BGOs are all united in supporting the EU Commission’s proposed ban on these hypertoxic wildlife-killing pesticides: RSPB, 47 Wildlife Trusts, The Scottish and Welsh Wildlife Trusts, The Soil Association, Friends of the Bees, Friends of the Earth, Pesticide Action Network UK, Buglife, The Womens Institute, plus The European Science Agency, The European Food Safety Agency, The European Parliament, the German Professional Beekeepers Association, The French National Union of Beekeepers, plus the national Science advisory panels and Govenments of: France, Spain, Holland, Italy, Slovenia, Poland etc.

   On the other side of the science debate, ‘spreading doubt about the science’ we have Bayer, Syngenta, the NFU, the Crop Protection Association, . . .and apparently Mark Avery?

   Why are you taking such a scientifically untenable position?

   1. Graham – I don’t know how you get from what I wrote to what you wrote. Maybe a little more attention to the detail is needed from you.

4. It is always difficult to have 100% certainties and the obvious question is where we draw the line. There are some classic examples that have long since gone so far into folklore that they are held up as clear-cut evidence. The best example is the Mammal Society’s data on cat predation*. Even putting aside the fact that the data was derived from estimates (a point clearly made in the presentation), the figures for birds taken are well within the annual productivity of just 30 species. However, it is amazing how easy it is to start an argument when talking about how the work has been interpreted amongst birders and conservationists.

   * The figures for small mammals whilst still estimates, are actually more of a concern than the estimates for birds taken.

5. As you say you “don’t know much more about the details of this issue…” why then do you pontificate about it? More than 30 scientific reports in the last 15 years show significant evidence that neonicotinoids kill bees, and not just in laboratories. These deadly insecticides passed through the grossly inadequate regulatory process because the tests then in use were inappropriate, and having passed them, the government is demanding ‘incontrovertible proof’ of damage before they will consider a ban. Luckily, they are likely to be overruled by the EU invoking the precautionary principle.
   Considering insects are the food of many of the birds you have worked so hard to defend, perhaps you should do your homework before muddying the waters? I suggest you start with Dr Henk Tennekes’ book, A Disaster In The Making.

6. Dear Mark,

   I am willing to send you a pdf of my book “Disaster in the Making’ if you would be so kind to send me an email (info(at)toxicology.nl)

7. “Why are you taking such a scientifically untenable position?”

   Our host doesn’t appear to have taken a position. In contrast to OP (how splendidly deterministic is that!), who has.

   Here’s a concern I have. A very small proportion of neonic a.i. is reported as taken up via seedling roots from seed treatments and the rest – 97%? – stays in the soil. What effect is there on non-target soil invertebrates?

   Who has pension funds invested in Bayer et al.?

   1. I urge you to read the following 3 page paper by Caroline Cox
      http://www.pesticide.org/get-the-facts/pesticide-factsheets/factsheets/imidacloprid

      Effects on Birds
      Imidacloprid’s acute toxicity to birds varies widely among bird species. However,
      it is “highly toxic” to certain species including house sparrow, Japanese
      quail, canary, and pigeon.
      The median lethal dose (LD 50) dose that kills half of a test population) for all these species is less than 50 mg/kg.

      Based on these tests, EPA’s Ecological Effects Branch concluded that the agency’s “levels of concern” were exceeded for both non-endangered
      and endangered songbirds

      Imidacloprid causes abnormal behaviour at doses less than 1/5 that which causes
      death. House sparrows fed a granular imidacloprid product showed symptoms
      of incoordination, lack of responsiveness, and inability to fly at doses of 6 mg/kg.

      At doses of 12 mg/kg diarrhoea and immobility were added to the observed symptoms. Even birds for whom imidacloprid is not highly toxic, mallard ducks for example, show these symptoms. Symptoms were observed in mallards at all imidacloprid doses used in tests submitted to EPA as part of the registration process.

      Other problems caused by imidacloprid in birds include eggshell thinning
      (at exposures of 61 mg/kg), decreased weight (at exposures of 150 ppm in
      food), and reduced egg production and hatching success (at exposures of 234 ppm
      in food).

      French veterinarians have found dead and poisoned partridges in agricultural
      fields following use of imidacloprid treated seed and verified that the birds’
      symptoms matched those caused by imidacloprid, residues of which were found in the crop, gizzard, and liver of these birds.
      ENDS

      http://yubanet.com/usa/New-Report-Charges-EPA-Ignored-Staff-Warnings-Approved-Widespread-Use-of-Dangerous-Pesticides_printer.php
      Cynthia Palmer, author of the recent American Bird Conservancy Study writes:

      “A single corn kernel coated with a neonicotinoid can kill a songbird,” Palmer said. “Even a tiny grain of wheat or canola treated with the oldest neonicotinoid — called imidacloprid — can fatally poison a bird. And as little as 1/10th of a neonicotinoid-coated corn seed per day during egg-laying season is all that is needed to affect reproduction.”

8. I did get brimstone in my garden at the weekend, Mark. Hope you get better soon so you get to see the next…

9. Hi Mark and Filbert,
   I apologise if I have overstated my case, but seriously – suggesting that there is any room for real scientific ‘doubt’ over the issue of neonics and bees is simply not credible. We are in EXACTLY the same situation that Derek Ratcliffe faced in 1962 (?) when he had proved, beyond all reasonable doubt, that DDT was killing peregrines, other raptors and birds by the millions. Ratcliffe proved that DDT was present in eggs which failed to hatch; he proved it was present in chicks found dead in the nest and he provide it was present in eggshells – and that the eggshells were abnormally thin, leading to broken eggs during incubation. There was not a scintilla of scientific doubt on the part of Ratcliffe and the Nature Conservancy Council that DDT was the direct cause of peregrine deaths. However, when I interviewed him in 1997, he told me that although agricultural use was banned in most developed countries, beginning with Hungary in 1968 then in Norway and Sweden in 1970, Germany and the United States in 1972 – it was not banned in the United Kingdom until 1984. That is almost a quarter of a century after Ratcliffe had proved that it was killing birds and the pesticide industry was able to ‘sow doubt’ and lobby the govt intensively to keep the profits rolling in. Millions of birds died which need not have died. Even worse, every single human being in the UK still has DDT in their bodyfat today – even though this organochlorine has not been used on any crop since 1984 – 29 years ago. That is how persistent it is in the environment.

   Neonics are also organochlorines and they have the extreme persistence in soil which all organochlorines have. The 96% which passes from treated seeds of wheat, barley, OSR, potatoes, peas, beans etc – into the soil – persists for up to 4 years; one study in America found a ‘half life’ of clothianidin of 19 years! It is ‘illegal’ under EU law for a pesticide to be licensed if it persists for more than 120 days – so why were the neonics licensed? Because cynical-apologists like Ian Boyd claim that this extreme pesticide persistence, although ‘environmentally damaging’, the damage was not ‘unnacceptable’ – see his evidence to the Parliamentary Inquiry. Joan walley’s committee have castigated Boyd and Defra for their ‘extreme complacency’.

   Please see these two articles, both of which I sent to Mark at time of publication:

   OUR TOXIC COUNTRYSIDE – NEONICOTINOID PESTICIDES & BEE DEATHS
   https://docs.google.com/open?id=0B7FCgF0BwlDGN25iTHoxdlhabms

   ‘ITS THE BIRDS AS WELL AS THE BEES’
   https://docs.google.com/file/d/0B7FCgF0BwlDGcFpmZXpmeS0wUE0/edit?usp=sharing

   1. Graham – I read the EAC report – that’s why I referenced it in my blog.

   2. For the record, neonics are NOT “also organochlorines”. They’re not even closely related chemically.

10. OK then they have banned it in other countries? what do they use in its place? Is it effective?
    That is one of the main planks of the defense surely, that other things are worse.
    ???

11. The French appointed its highest level of state-inquiry in 1999 – the Comite Sceintifique et Technique (the equivalent of a Royal Commission) to look into why a million bee colonies had been killed. Neonicotinoids were the only plausible hypothesis and the independent lab studies all confirmed the extreme (scarcely believable) toxicity of neonics for bees and pollinators. One desert spoon (5mls) of imidacloprid dissolved in 1000 metric tonnes of water will kill any bee or insect which comes into contact.

    S, in 2000, the French banned the use of Imidacloprid on OSR, Maize and Sunflowers; they have never rescinded the ban despite 13 years of lobbying by Bayer and Syngenta. I do not know what they replaced the neonics with. Sunflowers were apparently known in the past as ‘the crop which has no enemies’ – and no pesticides were normally applied. So Bayer saw a market opportunity. The new strategy is to gain control of ALL seed companies, so that farmers have no CHOICE. They can no longer buy OSR seed in the UK that is not treated with neonics. Almost all wheat and barley comes pre-coated with clothianidin. in America, Monsanto’s dominance is almost 100% – over 100 million acres of US Maize is GM and coated with clothianidin and supplied by Monsanto’s seed division. They have bought up virtually all independent seed suppliers across the USA. Total monopoly is their goal and they are close to achieving it in America. We are next.

    1. http://www.amazon.com/Seeds-Earth-Private-Public-Resource/dp/0969014937/ref=cm_cr_pr_orig_subj

       I must buy me another copy. I seem to have lost mine. I think I hid it in 1980 after a memo circulated by senior management defined its possession as a sackable offence.

12. The “Chiefio” (niiice Filbert):
    “…At the moment, urrr, we’re not quite sure about that.”
    “…The problem is they [different studies] give different results….”

    Then for what it’s worth, I believe we should be employing a pretty simple, yes, simple precautionary approach with regards to neonics.
    Rather than (as is happening currently) we use them until we’re pretty sure that they do significantly harm pollinators in the field, we should actually ban them now (20 years too late) and better manage alternative pesticide use if necessary – until it’s proven by someone, Bayer, Syngenta, whoever… that they do not significantly harm our pollinators.

    I thought that’s how it worked with drugs and chemicals? You can’t pass a drug fit for use until its been passed safe, can you?

    You don’t licence a drug for use for 20 years and only then run clinical trials to determine whether it’s safe or not do you? (With the drug manufacturer funding those studies by the way).
    I must be missing something here. Have I missed something?

    Sorry Mark. I find the “Chiefio’s” take on this not the slightest bit refreshing.

    1. Increasing the playback speed compensates for the Mogadon effect 🙂

13. Forgive me for commenting with an earlier fb post of my own, but it seems to apply equally to Defra and the UK Government.

    “Perhaps I have missed it in all the buzz, but why is more not said about the EU not flouting its own law?

    The Lisbon Treaty says “Union policy on the environment shall… be based on the precautionary principle.”

    The accepted EU definition of the principle, cited in Wikipedia, is: “Where, following an assessment of available scientific information, there are reasonable grounds for concern for the possibility of adverse effects but scientific uncertainty persists, provisional risk management measures based on a broad cost/benefit analysis whereby priority will be given to human health and the environment, necessary to ensure the chosen high level of protection in the Community and proportionate to this level of protection, may be adopted, pending further scientific information for a more comprehensive risk assessment, without having to wait until the reality and seriousness of those adverse effects become fully apparent”.”

    Actually that quote works best at increased playback speed too. The short form is “if the evidence suggests it may be bad, don’t wait until you know for sure it’s bad before doing something about it.”

14. Alan. Thanks. A better summary of my comment I think. It should be simple.

15. “The proposal will now go through the appeals process with the European Commission free to ban the insecticides unless Member States reach a compromise within two months” (Buglife, 15 March 2013).

    One of those months is nearly up.

    The precautionary principle is written in to EU Council Directive (91/414/EEC) – The placing of plant protection products on the market – under articles 4 and 5, which include fate and distribution in the environment, particularly on unacceptable contamination of drinking- and groundwater or impact on non-target species. Authorizations may be reviewed at any time where there are contra-indications.

    See that weasel word “unacceptable”? Could that be the sticking-point? It could still be the get-out-of-jail card, even if evidence is accepted as reliable, but acceptable. That would be acceptable for a Government committed to dragging its knuckles wherever regulation is seen to threaten profit.

16. Poor old weasels get a bad rap don’t they?

17. Yes, it is a difficult call. But one thing that struck me which might make it a bit easier is that anyone making this sort of decision will surely consider track record – effectively the credit rating of the body making the decision. So how does MAFF/Defra shape up ? Tracking back over the disasters that have come to pass the answer has to be not very well – who can forget John Gummer and the beefburger ? That would affect my view on Ian Boyd’s really rather unconvincing presentation – and that is even before taking into account the weakness of an ‘we haven’t killed them yet’ argument. I do think the point he makes about alternative food sources is significant – remember that as you watch much of arable England turn yellow over the next few weeks because there is no control whatsoever over the proportion of any crop grown in any place and there are large swathes of lowland England where you’ll be wasting your time searching for the alternative nectar sources.

18. This Welsh Government draft action plan & consultation might be worth a look at for anyone with an interest… http://wales.gov.uk/consultations/environmentandcountryside/pollinator-action-plan/;jsessionid=60260527C629E0AB2C4E872B6750B1D1?lang=en

19. Of course, the ‘precautionary priniciple’ is the key principle at stake here, just as the key question is ‘why do we have a pesticide authorisation process that is so very far from being fit for protecting the environment?’

    The UK should be applying the precautionary principle to authorising uses and the EC should be applying the principle when it authorises chemicals. Both have been failing to do so, but at least the EC is taking firm steps to reduce risk levels to pollinators; one could debate if, with the balance of evidence sitting as it does today, this still constitutes a precautionary action.

    At least in their September 2012 report even Defra aknowledge that threatening pollinators is ‘unacceptable’ environmental damage:-
    “Cresswell et al, rightly assumes that a pesticide’s use is unacceptable if it seriously threatens a non-target species that contributes to human wellbeing by delivering an important ecosystem service.” http://www.defra.gov.uk/publications/files/pb13818-neonicotinoid-bees-20120918.pdf

    Some of the quality of recent research reports produced by Defra has been lamentable. Buglife will be talking to Defra further about their most recent bumblebee study and if, contrary to Defra’s conclusion that it constitutes provisional but statistically unrobust evidence of no-effect in the field, the data actually show a weak statistical effect of neonicotinoids on bumblebee health. We are also interested to hear from Defra where all the Thiamethoxam contamination came from. It was not used on the study crops but was in their pollen and nectar – so where did it come from? How much of the British countryside is also mysteriously contaminated with high levels of neonicotinoids?

    Matt Shardlow
    Buglife -CEO

    1. “This attachment is being virus checked.

       We are currently holding this attachment in quarantine until it has been virus checked. The attachment will be available at the original location shortly.”

       … is the message I see on following Matt’s link. Never seen that before …

20. “Welsh Government draft action plan & consultation”

    Without wishing to detract etc … I think this and other initiatives need to broaden and include err, ummm, – everything. Focus on pollinators may get results for pollinators but could result in thin pickings for the rest of the base of the food chain. Surely there is enough evidence collated by Buglife, Mineau and Palmer, Tennekes, van Dijk & Co to provide justification for a moratorium, at minimum. For Defra to ignore the reported effects of neonics on several insect orders, amphipods, annelids, fish, birds – is perverse.

    That’s just the biology bit – the contents of the submissions of Mason and Jepson to the EAC, published 25 March 2013, are very disturbing, imho. http://www.publications.parliament.uk/pa/cm201213/cmselect/cmenvaud/writev/668/contents.htm

    “It is a pale of dung and none may abide the odor thereof.”

    1. I think you have hit the nail very firmly on the head Filbert!

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