Posted 15 June 2012

Advisory Committee on Pesticides to be abolished

The Advisory Committee on Pesticides


A statement dated 8th March 2012 on the ACP website asked for comments to Mark Wilson. Consultation was extended to 15th May 2012 but is now closed. "The Advisory Committee on Pesticides is an independent scientific advisory committee providing advice to Ministers. Shortly after the 2010 election, the Government announced that it would review arms-length bodies in order to reduce the numbers, costs and improve accountability. Defra have launched this consultation seeking views on the future of the ACP and the sister body covering Northern Ireland, the ACPNI. The option currently proposed is to abolish the Committee as a statutory Non-Departmental Public Body (NDPB) and to reconstitute it as a new expert scientific committee. However, the Government is willing to consider titleernative approaches and Ministers wish to consider respondents' views on their proposals before reaching a final decision."
This means that there will no longer be an independent public watch dog for pesticides.
Members appointed to the ACP, starting January 2012, included Prof Ted Lock who retired from Syngenta in 2003. There are already advertisements for new members from 2013. We have questioned Defra about this confusing chronology of events.

The Royal Commission on Environmental Pollution (created under Royal Warrant in 1970) was abolished in April 2011. It was announced by Environment Minister, Caroline Spelman: "This Government is committed to being the greenest Government ever and the Structural Reform Plan published last week sets out how Defra will play its part in achieving this"

Syngenta's Cruiser® (thiamethoxam) has been banned in France but not in the UK On June 1st, 2012 the French Agriculture Minister banned the pesticide Cruiser® (Syngenta's thiamethoxam) and the ban will take place soon. They took the new study from France by Henry et al. (published 30/03/2012 in Science) seriously: Abstract: 'Non-lethal exposure of honey bees to thiamethoxam (neonicotinoid systemic pesticide) causes high mortality due to homing failure at levels that could put a colony at risk of collapse. Simulated exposure events on free-ranging foragers labeled with an RFID tag suggest that homing is impaired by thiamethoxam intoxication. These experiments offer new insights into the consequences of common neonicotinoid pesticides used.'
The Scientific Opinion on the French research from the European Food Safety Authority (EFSA) dismissed the study. They didn't think that the bees were fed "field realistic doses" and "it would be necessary to repeat the studies with other exposure levels. Additional data would also be required to fully consider the relevance of the new research…"

However, the two documents published by the EFSA (18th April and 1st June) on Plant Protection Products and Bees cannot be called 'Scientific Opinion'. They are a cynical parody of science. As an organisation that is supposed to be protecting people and the environment in Europe, the EFSA cannot be taken seriously when it has no knowledge of the baseline levels of neonicotinoids in soil, surface and ground-water. They are using delaying tactics to protect the industry and keep the neonicotinoids on the market, just as the US EPA/SETAC Workshop was in January 2011. In fact, the recommendations for further research are very similar to those identified in the SETAC Summary Report (See Complaints to the European Ombudsman about the EFSA).


Group Active Substance
Total Area Treated (ha)1
Total Weight Applied (kg)
All Crops
All Crops
All Crops
All Crops
All Crops
All Crops


Between 2009 and 2010, thiamethoxam usage went up more than ten times.

According to Defra, the industry pays 60% of the Chemical Regulation Directorate's budget, so unfortunately Defra and the Defra Minister are unlikely to ban thiamethoxam.

A secret application by Defra and Syngenta for a GM herbicide-tolerant crop.
On the EFSA website, we discovered that: "The UK Competent Authority and Syngenta had applied for placing on the market of a GM, herbicide tolerant (glyphosate) maize GA21 for food and feed uses, import, processing and cultivation." It was adopted by the EFSA on 16 December 2011. titlehough the EFSA had said that there were no effects of human or animal hetitleh or the environment, in the body of the document, they admitted to the problems of reduction in farmland biodiversity, selection of weed communities and selection of glyphosate resistant weeds and destruction of food webs and the ecological functions they provide. Nevertheless, the EFSA approved it, but covered itself by saying "The magnitude of these potential adverse environmental effects will depend on a series of factors including the specific herbicide and cultivation management applied at farm level, the crop rotation...etc. and recommends "case-specific monitoring". How stupid can Defra be? Instead of listening to Syngenta, why did they not speak to the farmers in the US and Canada?

Northern Indiana. Giant Ragweed (3 m) resistant to glyphosate. Has to be hand-weeded
Northern Indiana. Giant Ragweed (3 m) resistant to glyphosate.
Has to be hand-weeded

Glyphosate-resistant (GR) weeds
GM herbicide tolerant crops were introduced in 1996. The first GR weed population confirmed in the US in 1998 was rigid ryegrass, infesting several thousand acres in California almond orchards. Less than a decade later, GR biotypes of nine species are now found in the US and infest millions of acres of cropland in at least 22 states. Particularly troublesome are Pigweed, Horseweed and Giant Ragweed whose infestations can sometimes cause cropland to be abandoned. Each year more pesticides, or different or older ones, including paraquat, have to be applied. In 2005, the US EPA evaluated for re-registration 2,4-D, an old herbicide and a component of Agent Orange. The US EPA determined that 2,4-D was eligible for re-registration but required certain changes to uses on the label to mitigate risk. Weed scientists say that US farmers are locked in a 'pesticide treadmill.' "The economic picture dramatically darkens for farmers combating resistant weeds under average soybean yields (36 bushels) and market prices ($6.50 per bushel). Such average conditions would generate about $234 in gross income per acre. The estimated $80 increase in 2010 costs per acre of HT soybeans would then account for one-third of gross income per acre, and total cash operating costs would exceed $200 per acre, leaving just $34 to cover land, labor, management, debt, and all other fixed costs. Such a scenario leaves little or no room for profit at the farm level."

Syngenta pays for power
In 2009 Dr Peter Campbell of Syngenta gave £1 million to fund Warwick University and Rothamsted Research "to help to improve honeybee hetitleh". Syngenta pioneered Operation Bumblebee in the UK and in 2010 announced expansion of programmes across Europe; up to €1 million over 5 years. Programmes included "What Operation Bumblebee can do for your golf course" in conjunction with STRI, a leading Sports Turf Consultancy that runs training courses for turf managers for golf, football, rugby, cricket etc. Their armamentarium of treatments includes MeritTurf (imidacloprid, Bayer). About 60% of the Chemical Regulation Directorate budget is paid for by the agrochemical industry.

Pollinator Initiative
In 2010, a £10 million Insect Pollinator Initiative was announced, part-funded by the Wellcome Trust, in order to find out the cause of steep declines in honeybees, bumblebees and hoverflies. The peer review panel membership included Dr Peter Campbell (Syngenta) David Aston, a BBKA Executive Member and neonicotinoid denier. This accounts for why there was not a single project on systemic neonicotinoid insecticides.

Hetitlehy Bees Plan Project Management Board and Scientific Evidence Advisory Group
Meetings started on 23/07/2009. In nearly three years these two Defra/Fera Committees never mentioned neonicotinoid pesticides as a possible cause of bee declines, only the Varroa mite.

The EU Directive (2009/128/EC) on the Sustainable Use of Pesticides: The UK Consultation and Government Decisions, published December 2010
The government voted every time on the side of industry. Article 10 concerns Protection of Water Courses from pesticide pollution, including establishing buffer zones to protect aquatic environments, surface and ground water. The government rejected the EU Directive Advice. Instead it said that it would "primarily seek to work with the pesticides industry" to enhance voluntary measures. It also rejected EU Directive advice to ban aerial spraying: "We do not consider that the responsible application of pesticides by aerial spraying poses an unacceptable risk to human hetitleh or the environment and, consequently, we will use the derogation." Article 11 Use of pesticides in specific sensitive areas: "We do not consider it necessary to prohibit the use of pesticides in public spaces or conservation areas or to impose new statutory controls on pesticide use in these areas."

The UK National Ecosystem Assessment
This was published by Defra in June 2011. Page 8 of the Synthesis was entitled: Changes in the past 60 years. Defra managed to rewrite the whole post-war history of the destruction of the countryside by industrial farming, without any mention of pesticides or herbicides.

Committee on Toxicity of Chemicals in Food (COT)
This is described as an independent scientific committee, appointed by Ministers. Members are asked to state conflicts of interest. There are three members from the industry who have Syngenta links; one from Syngenta and two from AstraZeneca, Syngenta's parent company, yet none of them declared any conflicts of interest.

The Foresight Future of Food and Farming Report
From the Government Office for Science; lead scientist Prof Charles Godfray, Hope Professor of Entomology at Oxford. Foreword: Sir John Beddington. See page 88 "Wheat is the most internationally-traded food crop and the single largest food import in low-income countries. A public-private partnership between Syngenta and the International Maize and Wheat Improvement Center (CIMMYT) will focus on the development and advancement of technology in wheat through joint research and development in the areas of native and GM traits, hybrid wheat and the combination of seeds and crop protection to accelerate plant yield performance. The partnership will leverage both Syngenta's genetic marker technology, advanced genetic traits platform and wheat-breeding for the high-income countries, as well as CIMMYT's access to wheat genetic diversity, global partnership network, and wheat-breeding programme targeted to the low‑income countries."

The Agrochemical Industry has forged partnerships everywhere
On World Environment Day June 2012, on the back of a supplement by Media Planet in The Independent is an article entitled "Sustainability and innovation go hand in hand" It is an interview with Dr Wolfgang Plischke, Member of the Board of Management of Bayer AG, about sustainability and partnerships.

Question: Professor Plischke, how important is sustainability to Bayer?
"I believe that sustainability goes hand in hand with future viability."
Question: How important are these partnerships to Bayer?
"We work with a broad range of partners and non-governmental organisations worldwide" (including WHO and UNEP). "We also cooperate with research institutes and universities, other companies and private and public institutions."
Question: Does this commitment pay dividends…?
"The name Bayer has a good reputation in the market for socially responsible investments"

An advertisement in 2011 for a career in Bayer: At Bayer, we'll give you a chance to make a difference by joining a team that is dedicated to changing the world with great care"

Complaint to the EU Ombudsman
On 16th May 2012 we complained to the EU Ombudsman. He had issued a press release on 17th April to say he was responding to a complaint from the Austrian Ombudsman that the European Commission had ignored new research on neonicotinoids and risk assessments for bees. He gave the European Commission until 30th June 2012 to reply. We had informed the Commissioners that the registration of clothianidin was illegal according to the Directive on Plant Protection Products (EC) 1107/2009. In Annex II, page 43, persistence in the soil, approval should not be given if the half-life in soil is greater than 120 days ('based on half-life data collected under appropriate conditions, which shall be described by the applicant').
 Here is the conditional registration document for clothianidin issued to the applicant in 2003. We attached an extract of the relevant parts. The aerobic soil metabolism half-life under a variety of soil conditions was 148-1,155 days and the terrestrial field dissipation was 277-1,386 days. We also complained that the EC was not measuring the neonicotinoids in surface and ground-water and gave them the examples where they had measured in the Netherlands 2003-2008. In New York State, as a result of measurements in 2003/2004 the Department of Hetitleh had limited the registration of imidacloprid and had not registered clothianidin at all, because of its persistence in the environment.

Today, 14/06/2012, we have had a reply from the Ombudsman. With regards to our complaint about the European Commission he says: "you turned to the Commission on 16th May 2012. The Commission therefore did not have sufficient time at its disposal to reply. I regret I have to inform you, therefore, that I am currently not entitled to deal with this aspect of your complaint."

We have replied, attaching a series of letters which we have sent to the European Commissioners over a period of 18 months.

Rosemary Mason MB, ChB, FRCA
Palle Uhd Jepsen, former Senior Adviser in Nature Conservation and Wildlife to the Danish Forest and Nature Agency