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Posted 30 May 2012

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The European Commission broke its own laws when it registered clothianidin

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To: Commissioners Dalli, Ciolos and Potocnik and Vice-President Ashton

In December 2010, we wrote to all the Environmental Protection Agencies about Dr Henk Tennekes’ work: “Systemic Insecticides: a disaster in the making”. In 2010, Tennekes showed that neonicotinoids bind irreversibly to nicotinic acetylcholine receptors in the brain and can produce effects at any concentration level provided the exposure time is sufficiently long. He had shown that, as the imidacloprid levels increased in Dutch surface water from 2003 to 2008, so invertebrate numbers had declined and populations of insect-dependent birds had decreased, some to near extinction. The Agencies ignored our points about water contamination, insects and birds. They only addressed the subject of bees. Throughout our correspondence with European Commission Civil Servants, the US EPA, the UK Chemical Regulation Directorate and the Australian Pesticides and Veterinary Medicines Authority, all have maintained that there was no evidence that the neonicotinoid insecticides were harmful to bees.  However, are the Commissioners aware 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’).

The full conditional registration document for clothianidin issued to the applicant in 2003. We attach 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. However in a USEPA document in 2005, on a 10th type of soil (Fuguay loamy sand) the extrapolated half-life was 6,931 days (19 years). This figure was omitted, but other EPAs have also recorded soils in which there was no dissipation. Persistence in the environment is a characteristic of all the chloronicotinyl family of pesticides, since chlorine does not occur in nature. Thiamethoxam, introduced in 1998, is metabolised to clothianidin, but we could find no information about its half-life in soil.

All have a potential for leaching into surface- and ground-water. In fact they are highly toxic to aquatic invertebrates and instructions are emphatic about never contaminating water bodies. But every flooding incident, of which there have been many, spreads them further, to pollute other areas of land unintentionally. No-one is monitoring levels in water. The US Geological Survey NAWQA program (National Water Quality) does not include the neonicotinoids in its list of pesticides being monitored, nor does the European Commission.  In 2003/2004 New York State (NYS) insisted on monitoring, but initially they found that Bayer was monitoring from areas where imidacloprid was little used. Subsequently, NYS found that levels in private wells, golf courses and at tree injection sites were giving cause for concern, so they limited the use of imidacloprid and did not register clothianidin.

Industry has managed to divert the world’s attention by concentrating on the subject of bees. By this strategy, they have avoided revealing the sinister aspects of these insecticides.  In every global ecosystem in which they are being used, invertebrates are silently being destroyed. The neonicotinoids also act on mammalian nicotinic Acetylcholine Receptors, so humans are being insidiously poisoned. In 2000 it was considered that the selective nature of their binding (i.e. less affinity than in insects) made them safe for human exposure. But no-one anticipated the extent of their global use, or the fact that our protection agencies wouldn’t be taking precautions by monitoring levels in water or soil. Over the last 20 years or so, the shift in pest management has moved away from reactive to prophylactic (like humans receiving permanent antibiotic treatment). Many fungicides, pesticides and herbicides are now applied to the seeds before sowing, including those of GM crops. In the US in 2010, 88m acres of maize, 77m acres of soya and 53m acres of wheat were treated. In England in 2010, about one third of arable land was treated with neonicotinoid insecticides out of a total cropped acreage of about 9.9m acres and some fields had up to four applications of various pesticides.

Now, without being made aware of it, or being given any choice, the public can be exposed to the neonicotinoids in almost any environment. So it is not only the factory or farm workers who are at risk. Wealth and power will not protect you from the scourge of these toxins because, with more than 20 years of continuous use, they are now everywhere. Imidacloprid was used in an anti-flea pet product as early as 1986; the Bayer Garden Provado® range are used against vine weevil and lawn grubs; various chemicals are applied to golf courses, playing fields, amenity areas and conservation areas. They are used on garden bulbs, in some compost and on indoor and outdoor plants. Residues in food are increasing because of their persistence in the soil. Beekeepers cannot take precautions against those applied to seeds of arable crops, since the plant is toxic for the whole of the flowering period. Pregnant women are unable to avoid exposure, because the chemicals could be anywhere.

There is now a significant amount of independent evidence (see attached doc) that there are many toxic effects of individual neonicotinoids on mammals, (including man) either by direct exposure, or on their offspring (in early gestation the foetus will be barely more than insect size). Scientific papers have demonstrated DNA damage to male reproductive organs, reduction in sperm quality and quantity, teratogenesis, long-term neurobehavioural effects and immune system suppression. Genotoxic and cytotoxic effects have been shown on human peripheral blood lymphocytes in vitro and a specific a specific anatomical and physiological connection was proved between the nicotinic acetylcholine anti-inflammatory receptors in the human central nervous system, via the vagus nerve, to the innate immune system which protects against infection and tissue injury. The first study to provide prospective data on farmer workers in the Bordeaux area of France (1997-98 and 2001-03) suggested long-term cognitive effects of chronic exposure to pesticides and raised the issue of evolution towards dementia. Office of National Statistics figures for the UK found that the number of children dying from brain tumour in 2007 was 33% higher than in 2001; in contrast, child deaths from leukaemia were 39% lower than in 2001. In fact, brain tumours have now replaced leukaemia as the commonest cause of childhood death. Canada has reported the same. In March 2009, the charity Brain Tumour UK reported that 40,000 brain tumour patients each year were missing from the official statistics. In the US, prenatal and childhood exposure to pesticides has emerged as a significant risk factor for neurodevelopmental disorders, including learning disabilities, dyslexia, mental retardation, attention deficit disorder and autism; these are now affecting 5-10% of 4 million children. In the US, childhood and young adult cancers have increased over the last 15-30 years; acute lymphocytic leukaemia (by 10%), brain cancer (by 40%) and testicular cancer (by 68%). In a UK study in 2010, pesticide exposure of the foetus was linked to later childhood cancer. In the last 35 years the following have increased; non-Hodgkin’s lymphoma has more than doubled; testicular cancer has doubled; breast cancer in women has increased by two thirds and in men has quadrupled; prostate cancer has tripled.

Farmers are unaware that each year they are paying the agrochemical companies for seeds coated with prophylactic pesticides, residues of which can remain in the soil from previous years. However, the greatest price they pay is that of endangering the health of their families. 

On 17th April 2012, the EU Ombudsman P. Nikiforos Diamandouros launched an investigation into bee mortality, following complaints by the Austrian Ombudsman Board, alleging that the Commission has failed to take into account new scientific evidence associating bee mortality with the neonicotinoid insecticides. They have asked the Commission to submit evidence by June 30th 2012. This is not the only independent scientific evidence that the Commission has ignored. In March 2012, the EU Ombudsman and the MEPs exposed conflicts of interest within the European Food Standards Authority in terms of registration of GE crops and Roundup®. However, it is too late; the damage has already been done. The EFSA (at Monsanto’s request) has raised the MRLs (maximum residue levels) for glyphosate in lentils, wheat and GM soya, resulting in residues far above the legal limit. Herbicide resistance to glyphosate-tolerant GM soya in the US has resulted in farmers having to spray greater and greater amounts to control super-weeds. In addition, glyphosate is used for drying grain. In order for Monsanto to retain a market for its GM crops in Europe, it was necessary for the EFSA to increase European MRLs; which it has done.

Why has the EC ignored requests from independent scientists who warned about the toxic effects of Roundup® on humans, at the low levels found in the environment? Why was Dr Graciela Gomez, an Argentinian lawyer, turned away when she came to petition the EU in March 2012 about Roundup® Ready Soya which was associated with congenital birth defects, reproductive problems and cancers in the South American rural communities? She was told that glyphosate wouldn’t be reassessed in the EU until 2015 (instead of 2012). Were the Commissioners aware that Judge Giovanni Conti has ordered Monsanto to pay back about 6.2bn euros to Brazil’s 5m soya farmers? The Danish Center for Pig research is investigating GM Soya in animal feed after a number of farmers have experienced problems with congenital defects in lambs, calves and piglets. An observant Danish pig farmer, whose pigs had chronic health problems, was feeding his pigs GM Roundup Ready soya and drying his grain with glyphosate. He has researched the problem extensively. He said: “We have had 13 malformed piglets (about one in 700) born over the last nine months, most of them live-born.” Without telling his stockman, he changed the feed to non-GM soya. The stockman noticed the improvement in chronic piglet diarrhoea and bloated sow problems within days.

On 30th December 2011 Geoffrey Lean, Environment Correspondent of the Telegraph, marked the end of the UN’s Year of Chemistry. “The usually cautious US President’s Cancer Panel has reported that synthetic chemicals can cause grievous harm and that the number of cancers for which they are responsible had been grossly underestimated. The Standing Committee of European Doctors, including the BMA, added: “Chemical Pollution represents a serious threat to children, and to Man’s survival.” Michael Taylor, a former Vice President of Monsanto who has previously worked in the FDA and the USDA, is now President Obama’s adviser on the FDA. It is possible that the President has not been informed.

We would like confirmation that these documents have been received and that they have been read, in full, by the Commissioners. In due course, we hope to receive a reply.

Yours sincerely

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

 

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