Bee Safety – the Need for a Feasible and Meaningful Approach
Today, I had a headache and took some medicine to ease the pain. In the same way that medicines help cure our illnesses and injuries, plants rely on crop protection products (or pesticides) to protect them from harmful pests which can weaken, damage or kill them. These pests can reduce a farmers’ yield or crop quality in the process and, subsequently, the amount of healthy, nutritious food that makes it to our supermarket shelves and onto our plates.
And as with human medicines, plant medicines are regulated very strictly. Not only should a pesticide be an effective “medicine” for the crop, it mustn’t pose any unacceptable risks to wildlife, plants and the environment in which it is used.
To ensure this, each new pesticide requires many years of testing to meet the highest standards of safety, at a cost of some hundred million euros, before it can be used. Perhaps the fastest-growing area of regulatory research involves bee risk assessment, mainly driven by an increased public awareness of the importance of bees as pollinators, which made policy makers even more cautious when it comes to pesticide regulation.
With the world population expected to exceed nine billion people by 2050, the demand for innovative tools to help ensure we all have enough to eat has never been more urgent. This will require both the use of modern pesticides to help farmers manage destructive pests and the protection of pollinators that contribute to our food productivity. Protecting crops and ensuring bee safety is not an “either-or” option but rather a “must” where they need to go hand-in-hand.
So what is done to ensure a pesticide use is safe for pollinators? Ensuring a product’s safety to pollinators starts early in its development and continues throughout the registration process – and even continues years after it enters the market. Early screening tests indicate an inherent hazard to bees, which can range from essentially non-toxic to highly toxic, depending, for instance, on the active ingredient. Most insecticides are inherently toxic to bees; which is not surprising if you consider that they are purposely designed to kill insects, and bees are insects. It is important, however, to recognize that hazard alone does not determine actual risk. Risk is defined by the potential hazard (or toxicity) of something multiplied by exposure to it. Consider wine, for example, if you drink an excessive amount at one time, the risk to your health increases dramatically and it is possible to kill yourself. However, if you only indulge in a small glass of wine once a week, the risk to your health is relatively low and you may consider it “safe”.
As the development process continues and the ways a pesticide will be used are fully identified, additional steps help to assess its potential risk to bees when being used as intended. Any risks can be effectively mitigated for through the product label which not only includes sufficient safe-use guidance for a farmer to follow but also states mandatory use instructions, to avoid harm to pollinators. Only after the bee safety of a product can be clearly shown, related to the intended uses, will it be approved for use on the market. Additionally, farmers’ should adopt best management practices, with emphasis on product stewardship and good communication between beekeepers and farmers further enhances pollinator protection.
The relatively low number of harmful bee incidences, as reported in incident monitoring programs established, for instance, in Canada, Germany, the UK and the USA, is a testament to the rigor and effectiveness of the current safety procedures which are in place.
Most of today’s regulatory research on pollinator safety has focused on the interaction between pesticides and honey bees (Apis mellifera). The latter is the most important single pollinator of agricultural crops even, perhaps surprisingly, in regions where it is not a native insect. In addition, honey bees are currently far easier to rear and handle than many other bee species. The regulatory protection goal looks at the overall colonies, not the individual bees, as honey bees live together and act as a collective (superorganism).
Some countries are considering requesting studies on pollinators other than honey bees (non-Apis species), which presents an entirely different set of challenges for new product development and registration, as each bee species is different and has its own characteristics. With more than 20,000 bee species in the world, it is not possible, from a practical point of view, to develop testing protocols for all of them. As such, new research is addressing in particular those which can readily be reared in sufficient quantities for testing, including bumble bee (Bombus spp) and certain solitary bee (e.g. Osmia spp) species. The number of studies required to assess the risk potential of pesticides has grown at an amazing rate in recent years and has led to more thorough bee testing and risk assessment. And new study protocols will evolve as our understanding of bee biology and behavior advances.
That said, the above example for new testing requests illustrates the urgent need to distinguish between what is theoretically ideal and what is feasible and – even more importantly – meaningful. Which brings me to the new draft Bee Guidance Document for Europe, put forward by EFSA in 2013. After four years, this document, which triggered the neonicotinoid restrictions, is still not approved by EU Member States as its underlying principles do not provide a realistically feasible way forward for the assessment of risks to bees. If applied consistently, the extremely conservative approach and unrealistic levels of protection they are aiming for would result in a denial of registration for most pesticides, including those used in organic agriculture, as it would be impossible to put in practice the tests they are requesting, making it unworkable. Methods for many of the new studies proposed have not been developed or validated yet and it could take years before this can be done, if it is feasible at all. I seriously question the usefulness of some of these new requirements, which in my view must be resolved if agriculture and apiculture are to coexist.
In the end, what we need is a workable, practical and yet protective approach for bee risk assessment in the EU that is based on solid scientific principles. This approach has to take agricultural production and the protection of bees into account. Unreasonable and unnecessary over-protection may result in the loss of many important agricultural pesticides around the world which protect the quality and yields of the food we eat and which have been approved on the basis of sophisticated testing and risk assessment. Bearing in mind that current incident monitoring results present a reassuring picture in terms of impact of pesticides on bee health, it is essential that regulators come to a consensus on how best to conduct meaningful risk assessments that will allow for the protection of crops and at the same time protect the health of bees.