Review of Bee Health

Bee-ing Smart: Regulators Must Distinguish Activists’ Bad Dreams From Actual Evidence

March 13, 2013

As CRE has noted, studies need to be compliant with the Data Quality Act before they can be used or relied on by American regulators.

From: Forbes

Henry I. Miller

Important technologies commonly face opposition from various quarters – often from vested interests, societal Chicken Littles or overly precautionary regulators.  Examples include vaccination, fluoridation of water, and the genetic engineering of crop plants.

Another recent example is the targeting of a relatively new class of insecticides called neonicotinoids that are being blamed in Europe, and increasingly in the United States, for bee keepers’ difficulties in keeping their colonies healthy.

Anti-pesticide activists have been arguing for years for a ban on neonicotinoids, which are chemically related to nicotine, although they are an important innovation that can lower the amount of pesticide applied 10- to 20-fold.  The products are often applied directly to seeds, which causes the chemical to be contained within the growing plant and protects it from the predation of insect pests.  Treating seeds in this way enables farmers to use lower doses of insecticide than spraying.

Activists scored a minor “success” in January when the European Food Safety Authority (EFSA) released a report that identified neonicotinoids as a possible cause of a decline in bee populations.  But the analysis had obvious flaws.  Rather than a comprehensive evaluation of all available research, EFSA cherry-picked the studies and proceeded to their conclusion in spite of an acknowledged gap in not only the data they analyzed but their understanding of it.  The process seemed as though those involved in it – who were under intense political pressure to perform a quick risk assessment – began with preconceived notions about their conclusions.

Global bee populations have, indeed, struggled in recent years, but although researchers point to a number of possible causes, neonicotinoids are perhaps the least likely culprit. The bee protection organization COLOSS (Prevention of honey bee COlony LOSSes) compared surveys of honey bee losses in 2009 and 2010 in Europe with the rates of neonicotinoid application in the same geographical areas (in a separate survey). They found no correlation.

The main suspects for causing bee deaths are viruses and other pests acting in tandem, especially the aptly named Varroa destructor mite. These parasites attach to honeybees and appear to be “both a disseminator and activator of a number of bee viruses,” according to a report on honeybee disease in Europe by the Food and Environment Research Agency.  In countries experiencing bee decline, Varroa is a feared and growing presence among beekeepers – even if neonicotinoids are absent.  For example, in upland areas of Switzerland where neonicotinoids are not used, bee colony populations are under significant pressure from the mites; and in France, declines in the bee population in mountainous areas are similar to those on agricultural land (although neonicotinoids are commonly used in the latter but not in the former).

Conversely, where Varroa mites are not present, bee populations thrive even when neonicotinoids are heavily used.  For example, Australia, which is currently Varroa-free, boasts a thriving bee population in spite of widespread use of neonicotinoids.  In fact, their bees are so healthy that Australian beekeepers export queen bees and nucleus hives to countries with declining populations.

The problem with many of the studies that supposedly establish a link between neonicotinoids and bee deaths is that they fail to simulate the exposure levels bees are likely to encounter in the wild.  “The doses the bees are exposed to [in lab studies] are far above what a realistic field dose exposure would be,” says Dr. Cynthia Scott-Dupree, who headed a field study in Ontario, Canada that compared hives exposed to neonicotinoids with hives that were not.  She and her colleagues measured honey production, bee deaths, weight gain of colonies while foraging on canola, and insecticide residue on bees and in pollen, nectar, beeswax and honey.  No link between insecticidal seed treatments and bee health was found.

None of this real-world evidence has dissuaded environmental activists from calling for the immediate ban of these insecticides – in spite of the fact that there are often no good alternatives and a ban would cause devastating losses to agriculture.  And EU regulatory authorities – who are often readily influenced by activists – have called for Draconian restrictions on neonicotinoids; in April the 27 countries of the EU will vote on whether to accept their recommendations.

Banning neonicotinoids in spite of the persuasive evidence of their safety to bees would be both unwise and dangerous.  According to analyses performed by seed companies, in the absence of neonicotinoid seed treatment, crop yields in Europe could fall, with significant negative impacts on the EU economy and jobs.

Neither the scientific evidence nor the real-world experience with neonicotinoid seed treatments supports a ban.  Before they inflict yet another avoidable shock on their already struggling agricultural production, European regulators should “bee smart,” consult their Australian counterparts, and heed the data.

Henry I. Miller is the Robert Wesson Fellow in Scientific Philosophy and Public Policy at Stanford University’s Hoover Institution and a fellow at the Competitive Enterprise Institute. A physician and molecular biologist, he was the founding director of the Office of Biotechnology at the FDA.