This is part of the book “Stéphane Foucart et les néonicotinoïdes. The World and disinformation 1“ where I show the journalist misinforms (= false or misleading statements) the reader. One of the myths he develops is that the regulatory response against NNIs has been delayed by industry influence. 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).

S. Foucart also exaggerates the date on which we would have been aware of the toxicity of NNIs. For him, action should have been taken as soon as the beekeepers were alerted, in 1994 (which is also the date of marketing of seeds coated with the NNIs…) or in 2003, with the publication of the CST report (Doucet-Personeni et coll., 2003). In reality, these elements were far from being able to justify a ban.

Did we know since 1994?

First of all, the journalist presents the dangerousness of the NNI as something obvious, which should have been recognized from the first alerts of beekeepers in 1994 (45) (54). First of all, it should be noted that this date is a bit strange, since this is the year that the Gaucho was marketed in France. We are talking about the start of commercialization, therefore with a very limited market penetration rate. I have not found a reference to this date other than in a UNAF article from 2013. Gil Rivière Wekstein traces them back to 1995 in his book on the NNI. (Rivière Wekstein 2006)

For a certainty that should have determined the action of health agencies, it seems a little light …

Either way, placing these alerts as something that should have reflected scientific certainty does not make sense. People’s perception of the “effects” is often very misleading. For example, many people complain about side effects from installing Linky meters. Others will claim that homeopathy cures them. More recently, unvaccinated people complain of pathologies in the presence of unvaccinated people. Should we ask for a moratorium? Should we believe everything people say on the pretext that very occasionally it turns out to be about right? Shouldn’t this have resulted, for S. Foucart, in the ban of the vaccine against covid-19, given the many side effects denounced (invented) by many popular movements?

Did we know since 2003? The CST report

The journalist mentions a lot (8) (9) (13) (31) (45) (46) (56) the report issued by the CST in 2003 (Doucet-Personeni et al., 2003):

“Yet such an opinion could have been formulated by EFSA on the basis of scientific knowledge available ten years ago. […] In its report, delivered in September 2003, the CST had already firmly concluded that imidacloprid (marketed under the name Gaucho) presented an unacceptable risk to bees. […] It took more than a decade to be convinced that organizing the permanent presence, on millions of hectares, of the most powerful insecticides ever invented could possibly have an effect on these insects that are bees.” (9)

“The first is that of wasted time. A decade ago, an expert report commissioned by Jean Glavany, then Minister of Agriculture, concluded that imidacloprid posed an unacceptable risk to bees. It also showed that the standard risk assessment tests were unsuitable for the methods of application of the new molecules (seed coating, etc.). By taking this 2003 report seriously, we could have avoided much of what has happened since.” (13)

I went to see said report. Here is the conclusion of his synthesis (I highlight in bold):

“In the current state of our knowledge, according to the scenarios developed to assess exposure and according to the uncertainty factors chosen to assess the hazards, the PEC / PNEC ratios obtained are cause for concern. They agree with the field observations reported by many beekeepers in large crop areas (corn, sunflower), concerning the mortality of foragers (scenario 4), their disappearance, their behavioral disorders and certain winter mortalities (scenario 5). ).

As a result, the coating of Gaucho® sunflower seeds leads to a significant risk for bees of different ages, with the exception of pollen ingestion by foragers when making balls (scenario 3).

As regards the Gaucho® coating of corn seeds, the PEC / PNEC ratio is, as for sunflower, worrying in the context of pollen consumption by nurses, which could lead to increased mortality of those. – here and to be one of the elements of the explanation of the weakening of the populations of bees still observed in spite of the ban of Gaucho® on sunflowers.

Finally, since other factors may contribute to the weakening of bee colonies, more research should be done on the frequency, mechanisms and causes of these symptoms.”

Doucet-Personeni et al., 2003, p.11

They end up offering additional work:

“The report should be gradually enriched with future work by members of the CST metrology sub-group. It will be:

• Carry out a risk assessment of the same type as that carried out for imidacloprid, for fipronil.

• Analyze the other factors involved in bee losses (diseases, beekeeping and agricultural practices, genetic varieties for cultivated and treated plants, influence of terpenes, etc.) in close collaboration with the network sub-group

• Make an inventory of bee disorders observed in other countries.”

Doucet-Personeni et al., 2003, p.12

You can see that we are very far from an inflammatory report. I did not find the words “unacceptable risk” in the report.

In addition, the report suffers from some criticism. According to Gil Riviere-Wekstein (2006), Gerald Arnold was of questionable impartiality and had a central position in the CST. It was his team that would have defined the studies to be taken into account. (p.240 et seq.) and that its sorting would have resulted in excluding most of the industrial studies and retaining “almost all” of those by J-M. Bonmatin. The agricultural journalist brings other criticisms that I think are credible. He also reports the comments made by Hervé Gaymard (Minister of Agriculture at the time of the CST report and the resulting ban on imidacloprid) in an inverview given to VSD on November 18, 2004 and which can be found quoted in a parliamentary motion for a resolution:

“In the case of the Regent and the Gaucho, there was a media frenzy which was undoubtedly not foreign to the regional elections of 2004. But the problem is that scientific studies now say that this mortality of the bees would not be due only to the incriminated pesticides, and there, not a word in any newspaper of 20 hours. There are indeed double standards. Why would these new studies be less reliable than the others that led me to ban the two pesticides? And I can reveal to you that they show that the excess mortality of bees is also observed in departments where these products have not been used “.”

Gerald Arnold seems to mock the multifactorial analysis of colony collapse (whereas, as we do we have seen, this clearly seems to be the state of scientific knowledge). Gil Riviere-Wekstein speaks in more detail about this person and his arrival in the CST (2006, p.137-142). Without going further into this controversy, it brings serious evidence that this report was not undisputed.

Was it obvious ?

Regarding the danger of NNI, it should first be noted that almost all the studies cited by S. Foucart… are after 2010 (61 out of 67). Before that date, he only mentions the CST studies (2003-2005) and:

  • Suchail 2001: “Discrepancy between acute and chronic toxicity induced by imidacloprid and its metabolites in Apis mellifera”, observing chronic toxicity at doses 60 to 6000 times lower than those producing the same effect in acute intoxication studies.
  • Sur and Stork 2003, “Uptake, translocation and metabolism of imidacloprid in plants”, on the fact that plants take up only a small part of imidacloprid.
  • Greatti 2003, “Risk of environmental contamination by the active ingredient imidacloprid used for corn seed dressing. Preliminary results”, dealing with NNI contamination through dust from corn seedlings.
  • Girolami 2009, “Translocation of Neonicotinoid Insecticides From Coated Seeds to Seedling Guttation Drops: A Novel Way of Intoxication for Bees”, on bee exposure to NNIs through corn guttation.

Almost all of them focus on imidacloprid and not on NNIs in general and are only laboratory studies. Also, these are just a few studies on a few aspects. In short, nothing to do with a “scientific consensus” or even a certainty “beyond reasonable doubt”.
This is all the more clear if we read the CST report (Doucet-Personeni et al. 2003):

“Only 2 studies of repeated administration of oral imidacloprid have been validated. One leads to an LD50 of 12 pg / bee over 10 days (Suchail, 2001), the other to an NOEC of 1700 pg / bee / 10 days (Decourtye, 2000). Studies of chronic oral intoxication by the metabolites of imidacloprid also give divergent results with an LD50 of 12 pg / bee over 10 days for all metabolites or an NOEC between 2740 and 8000 pg / bee over 10 days. 10 days for urea derivative and 6 chloronicotinic acid.”

Doucet-Personeni et al., 2003, p.8 (idem p.54)

This is just one example, which highlights the cherry picking of S. Foucart (who only speaks of Suchail’s study and never of Decourtye’s study, strangely). More broadly, the entire CST report is very measured, even if it shows that there were real risks to be studied.

Finally, AFSSA had monitored, between 2002 and 2005, 120 bee colonies in 24 beehives and had found “no statistical relationship between the presence of residues and the adult and larval bee populations, nor with mortality. colonies”. (Aubert, Faucon and Chauzat 2008) On the contrary, there was a strong presence of “Varroa destructor, viruses and concurrent diseases such as nosemosis.” (Faucon and Chauzat 2008) In addition, they observe the frequent presence of tau-fluvalinate and coumaphos, in particular in waxes (Aubert, Faucon and Chauzat 2008, p.12), two insecticides:

“Coumaphos is an acaricide used for the treatment of varroasis. It has been frequently found in beekeeping matrices with the exception of Eure and Yonne. The official coumaphos-based veterinary medicinal product (Perizin®) was not available in France during this investigation. Homemade preparations have been made from Asuntol®, a medicine used to treat dogs. »

Aubert, Faucon et Chauzat 2008, p.15

Without contesting the toxicity of imidacloprid and fipronil, which were banned in the European Union, the science was clearly not fixed at the time.
Thus, the author absolutely does not demonstrate that the health authorities should have given credit to the (alleged) UNAF alerts in 1994, nor that the dangerousness of NNIs was clearly demonstrated in 2003.

On the subject, I invite you to read the very interesting book by Gil Rivière-Wekstein, “Bees, the ecological imposture”, published in 2006 and which speaks a lot about this period and how the NNI became a controversial subject.

What are the scientists saying?

We consistently find in the scientific literature on the causes of pollinator decline the idea that the latter is multifactorial (Potts 2010, p.348; Oldroyd 2007). Even studies cited by the journalist point to the existence of doubts:

“The contribution of neonicotinoid insecticide seed dressing to pollinator decline remains controversial (Potts et al. 2010, 2016 ; Blacquière et al. 2012; European Union 2012 ; EFSA 2013a, b, c ; Godfray et al. 2014, 2015).”

Hokkanen et al. 2017

The uncertainty is evident in this passage, yet it comes from an article co-authored by Dave Goulson and Jean-Marc Bonmatin (two of the researchers most often cited / interviewed by S. Foucart):

“All viruses and other pathogens that have been linked to colony collapse have been found to be present year-round also in healthy colonies [78]. That colonies remain healthy despite the presence of these infectious agents, supports the theory that colony collapse may be caused by factors working in combination.Farooqui [79] has analysed the different hypotheses provided by science when searching for an explanation of Colony Collapse Disorder (CCD). Research points in the direction of a combination of reciprocally enhancing causes. Among those, the advance of neonicotinoid insecticides has gained more weight in light of the latest independent scientific results [80,81,82].”

Van der Sluijs et al. 2013

These ([80,81,82]), would be three articles published… in 2012 (Henry et al., 2012; Whitehorn et coll., 2012; Stokstad 2012). When we read the Farooqui article in question, we are struck by its moderation:

« Abnormality in biogenic amines-mediated neuronal signaling impairs their olfactory learning and memory, therefore foragers do not return to their hive – a possible cause of CCD [Colony Collapse Disorder]. This overview is an attempt to discuss a hypothetical link among biogenic amines-based pesticides, olfactory learning and memory, and CCD.”

Farooqui 2012

We are VERY far from the register of evidence and consensus. We are talking about “possible cause” and discussing a “hypothetical link”.

Recall that the journalist called this posture piece of language for pesticide producers (to vilify a 2008 AFSSA study). It was actually the state of research…

A questionable correlation

Finally, let’s respond to another element that S. Foucart uses to allege or imply that the link is obvious: the correlation between the “decline” of pollinators and the arrival of NNIs and the idea that this correlation is an important clue. (35) However, several things question. First of all, it does not control any variables. Take for example the evolution of bee colonies which, although it is not an indicator providing direct information on the state of pollinators, since it is largely determined by variables other than the mortality of hives, is often used. (Ex: van Engelsdorp and Meixner 2010). As soon as you take a step back, you see a very different reality from what the journalist describes:

« Statistics demonstrate declines in 1947–1972 and 1989–1996, and a recent drop in 2005. Reports from industry journals suggest higher rates of winter kill in honey bee colonies since the advent of the parasitic mite Varroa destructor in the 1980s, causing temporary shortages of healthy honey bee colonies (for early season almond pollination) that are not captured by the NASS data. »

National Research Council 2007, p.3

« The decline from 1985 to 1996 is likely linked to the occurence of the tracheal mite, Acarapis woodi (first detected in 1984) and to the Varroa destructor mite (first detected in 1987) » .

National Research Council 2007, p.40

Note that here we can see the strength of cherry picking. If you only look at the evolution after 1990, on the one hand you have the feeling of an overall decline and on the other hand it appears as a novelty (whereas the decline between 1946 and 1972 is much more spectacular and constant). In fact, the number of colonies was stable between 1995 and 2004.

The journalist often comments on short durations, which allow this cherry picking to be fully expressed. Only once has he taken a step back:

“The diversity of wild pollinator species has been halved in 120 years” and “the visit rate of a small flower endemic to this region of North America has been reduced by four during this period.” (6)

He only referred to this study once …

Another problem is the disconnect between the data he shows and the idea that NNIs are persistent. Indeed, NNIs did not enter the phytosanitary market instantly, they increased little by little. In addition, if they were truly persistent, the dose in the environment should increase exponentially: on the one hand due to the increase in treated surfaces and on the other hand due to the accumulation of these treatments in the environment.

The toxic effects should therefore also accelerate very strongly as the use of NNIs spread. This fact is never tested. On the contrary, none of the variations mentioned by the journalist seems to respond to this logic.

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