This is part of the book “Stéphane Foucart et les néonicotinoïdes. The World and disinformation 1“, where I present the reasoning developed by the journalist in the corpus. What is said in this chapter is my view on what the journalist writes. All quotes are translated (by me), except the ones marked between [ ] in the french version (french quotes are to numerous to be marked in this one).
EFSA published a report in 2012 highlighting the inadequacies of the risk assessment procedures of phytosanitary products on bees, which fail to take into account, among others, sublethal effects, exposure by guttation or by dust produced by coated seeds during sowing, effects on larvae, etc. Overall, the toxicity of the substances tested is very largely underestimated. (Boesten et al. 2012) (2) (48) This laxity is measured by the annual loss of 30% of bee colonies and the rapid collapse of the entomofauna. (48)
These issues are said to be concealed by EFSA in its alerts on the toxicity of 4 NNIs in January and May 2013 (10).
a. An extreme conception of toxicity
The risk assessment tests, provided for in the EPPO document “System for the assessment of the risk of plant protection products for the environment”, take a rather extreme view of toxicity. To qualify as “low risk”, exposure to a product would simply have to be less than one-10th of the LD50 in less than 48 hours. S. Foucart shows the absurdity of this method by taking the example of cigarettes for humans: their LD50 is 150 packets. Smoking 15 packs a day would therefore be, by following this logic, “at low risk” for humans… (11)
b. Negligence for sublethal effects
The tests do not take into account either sublethal effects or chronic effects. Yet we have seen that they are very important for the NNIs. (2) (12)
c. Lack of consideration of wild pollinators
The assessment procedures would only cover honey bees and not wild pollinators. However, they are more effective: the study by B. Vaissière et coll (2013) observed that flowers visited by honey bees had 14% higher productivity, compared to nearly 100% higher for those visited by wild insects. (6) At the same time, they are even more sensitive to pesticides than honey bees, which have their organization in colonies, which protects them more than bumblebees, which live in micro-colonies or than solitary bees. A 2015 EASAC report would therefore recommend testing pesticides on wild species. (EASAC 2015) (57)
d. The procedure in case of insufficient data
Marketing Authorizations are issued after a risk assessment by EFSA, which is based on data provided by the company seeking approval. If the data is incomplete, the Commission can still grant MA using a “confirmatory data request” procedure. The product is approved, but the company will have to provide additional information at a later date. (62)
e. The distinction between scientific and regulatory consensus
There would be a fundamental problem in the fact that the “absence of proof, the difficulty or the impossibility of administering the proof are, after all, interpreted as so much proof of the absence of deleterious effects.” (66)
The case of NNIs would be an illustration of this dichotomy between scientific and regulatory consensus.
“A regulatory consensus is based on the opinions of expert agencies which judge the compliance of a product with the regulations in force. These are often anonymous opinions, not subject to peer review, based on data generally confidential and inaccessible to criticism, produced and interpreted by the manufacturers themselves.” (50)
This “science” would often be called upon, in health or environmental controversies, to “silence the protesters”:
” “It is allowed, so Science guarantees us that it is safe “is a convenient slogan, but one that ignores a huge body of work by historians and sociologists of science. ” (50)
This is how NNIs came to be considered “safe” when in fact they were very toxic. (50)
He deduces from the study showing a link between the introduction of NNIs and the collapse of a fish population in Japan (Yamamuro et coll. 2019) (59) that:
“No confidence can be placed in regulatory environmental risk assessment systems. Bankruptcy of this magnitude is simply unforgivable.” (66)
This bankruptcy would also have been highlighted by the study of Pelosi et al. (2020) showing significant bioaccumulation of imidacloprid, even though EFSA rated it as “at low risk of bioaccumulation”. (69)
“Ideally, everything should be overhauled and properly retested for the toxicity on bees of each pesticide present in the environment today, taken alone or in combination.” (47)
Page bibliography:
- Boesten, J., Bolognesi, C., Brock, T., Capri, E., Hardy, A., Hart, A., Hirschernst, K., Bennekou, S., Luttik, R., Klein, M., Machera, K., Ossendorp, B., Annette, Petersen, Pico, Y., Schaeffer, A., Sousa, J.P., Steurbaut, W., Stromberg, A., Vleminckx, C., 2012. EFSA Panel on Plant Protection Products and their Residues, scientific opinScientific Opinion on the science behind the development of a risk assessment of Plant Protection Products on bees, EFSA Journal. https://doi.org/10.2903/j.efsa.2012.2668
- EASAC. Ecosystem Services, Agriculture and Neonicotinoids. Vol. EASAC Policy report 26. EASAC, 2015. https://easac.eu/publications/details/ecosystem-services-agriculture-and-neonicotinoids/.
- Klein, Alexandra-Maria, Bernard E Vaissière, James H Cane, Ingolf Steffan-Dewenter, Saul A Cunningham, Claire Kremen, and Teja Tscharntke. “Importance of Pollinators in Changing Landscapes for World Crops.” Proceedings of the Royal Society B: Biological Sciences 274, no. 1608 (February 7, 2007): 303–13. https://doi.org/10.1098/rspb.2006.3721.
- Yamamuro, M., Komuro, T., Kamiya, H., Kato, T., Hasegawa, H., Kameda, Y., 2019. Neonicotinoids disrupt aquatic food webs and decrease fishery yields. Science 366, 620–623. https://doi.org/10.1126/science.aax3442