God save our bees!

Bees are dying at a frightening rate. Humankind - unkindly - is decimating biodiversity.

Bumble bee approaching borage plant. Bumble bee approaching borage plant. Photo: Vivian Grisogono

Bees are just one of the countless victims of relentless anti-ecological activities, including unwarranted, badly controlled use of chemical pesticides. These anti-nature policies are dictated by commercial and political interests. The world needs an urgent change of heart!

Can we do without bees and other pollinators?

Most people are aware that bees and all the other pollinators are vital for our natural resources, especially our food supply. It will be a surprise to many that bees have very little protection under existing international and European laws. This is shamefully, painfully noticeable in the regulations which are supposed to ensure that officially approved chemical pesticides are 'safe'. Insecticides are non-selective and, by definition, are extremely likely to cause harm to bees. Other types of pesticide also damage bees, for instance products based on glyphosate, probably the most widely used pesticidal substance in the world.

Very few pesticide labels warn of risks to bees. Why not?.

Authorities in the United Nations and the European Union have not paid much attention to the fate of bees over the last decades. Warnings of risks to bees are not included in the two leading lists of pesticide dangers. Rather odd, when one considers how many pesticides are known to be hazardous to our pollinators. But not so odd when one realizes just how flawed the system for chemical pesticide approval is, starting with the fact that approvals are based on industry-funded unpublished research, while contrary peer-reviewed independent studies are largely ignored until proven beyond doubt, many years later. Surely it should be the other way round?

Carpenter bee. Photo: Vivian Grisogono

Late awakening

The European Union authorities have woken up late to the fact that bees are essential and are not protected. In December 2020 that the European Chemicals Agency (ECHA) published a summary of consultation feedback 'Preliminary considerations for ECHA's guidance on the "Methodology to assess the risk to bees and other non-target arthropod pollinators from the use of biocides" '. The document states (p.6): "In current available guidance on biocides only limited references are made to risk assessment for bees and other pollinators. The guidance states that no method is currently available on how to perform the risk assessment for bees and non-target arthropod pollinators for biocides." The document highlights the confusion caused by separating pesticides into 'plant protection products' and 'biocides', with different criteria for safety requirements, on the assumption that the former are used mainly outdoors and the latter mainly indoors - which is not the case. The practice of 'fogging', which is used several times every year throughout Croatia, involves spraying chemical pesticides defined as biocides from a road vehicle or aeroplane indiscriminately across the environment in towns and rural areas.

In May 2023 the European Food Safety Authority (EFSA) published updated guidelines 'Revised guidance on the risk assessment of plant protection products on bees (Apis mellifera, Bombus spp. and solitary bees)'. Clearly the EU processes of improving theoretical measures for safeguarding bees are taking far too long. There is no sense of urgency, although the situation is critical.

Delays are costing bee lives

Pesticides have been implicated in bee losses for a long time, alongside other possible factors. Once chemical pesticides are authorized on the basis of industry-funded studies, it takes many long years for researchers to establish exact mechanisms of harm to bees and other pollinators from the various different substances. For instance, there was a focus on the damage being done by neonicotinoids, which eventually resulted in just three neonicotinoid insecticides being banned: the process took from 2013 to 2017, and even then the ban was not total. Meanwhile, it is clear that many other types of insecticide are damaging to bees, for instance sulphoxamine-based insecticides.

Bee losses: are scientific proofs needed?

Observation is quicker than scientific research and should be the leader of safety practices. A massive sudden loss of bees happened in April 2023 in Međimurje in northern Croatia when a permitted pyrethroid insecticide was used incorrectly. This was the third incident of massive bee losses in the region and there was no doubt about the link between the bee deaths and pesticide use. In a similar incident in 2022 the Agriculture Ministry confirmed that pesticide use was the culprit (links in Croatian).

The fogging practice which happens every year in Croatia is known to be harmful to bees, so it should be stopped. In June 2023 catastrophic bee losses followed aerial insecticide spraying near Osijek. Sadly, in vain so far, the Croatian Bee Association (Pčelarstvo.hr) and beekeepers have campaigned against the practice, pointing out that the fogging causes much harm and little if any benefit. (links in Croatian).

Even if there is only a suspected link between pesticides and bee losses, that should be enough to cause a revision of pesticide permits.

Bumble bee on bottle-brush flower. Photo: Vivian Grisogono

There ought to be a law...

Actually, there is a law. It's called the Precautionary Principle, which is supposed to protect the public and the environment from harm from any given policy or action. It is set out in Article 191 of the Treaty on the Functioning of the European Union (TFEU). The Precautionary Principle is supposed to be applied to chemicals (Regulation (EC) No 1907/2006 — known as REACH). However, it has been largely ignored over the years when it comes to pesticide approvals. Indeed the opposite principle seems to prevail: assume a substance is harmless, delay reviews for as long as possible, only decide a product is dangerous when forced to by the weight of accumulated evidence.

Ensuing chaos

If the Precautionary Principle had been put into practice, a lot of harm could have been avoided. It's been taking far too long for dangerous substances to be banned, when clearly they should never have been approved in the first place. Even when they are banned, the bans are often only partial or unenforceable.

These are just a few examples of the failure to apply the Precautionary Principle:

- the system of 'candidates for substitution' is totally wrong as it allows the continued use of known dangerous substances until such time as a 'safer' alternative can be found. Not to mention that, given the flaws in the approvals system, the substitute may turn out to be as bad as, or even worse than its predecessor.

- Permethrin, a pyrethroid insecticide, was discovered in 1973 and is present in a wide variety of products, despite having serious possible adverse effects for humans and the environment. It was banned as a 'plant protection product' in December 2000, following a European Commission Review Report dated July 13th 2000 which stated "In conclusion from the assessments made on the basis of the submitted information, no plant protection products containing the active substance concerned [permethrin] is (sic) expected to satisfy in general the requirements laid down in Article 5 (1) (a) and (b) of Council Directive 91/414/EEC." However as a biocide it is approved until April 30th 2026. There are about 78 permethrin-based products on the Croatian Health Ministry listing of biocidal products (August 2022), some of which have been in regular use for fogging actions in Croatia over the years.

- Cypermethrin, also a pyrethroid insecticide, was first synthesized in 1974. It was re-approved as a 'plant protection product' from 01/02/2022 - 31/01/2029, on condition that it is not used when plants of any kind are in flower (legislation 24/11/2021). There are some 53 cypermethrin-based products on the Croatian Health Ministry listing of biocides. Despite serious possible health risks besides the known risks to pollinators, cypermethrin-based products are still used for fogging actions in Croatia in 2023.

- Lindane is an organochloride insecticide, acaricide and rodenticide. The chemical was first synthesized back in 1825. It was considered generally of 'no health concern' (World Health Organization, 1991), despite indications even then to the contrary. For many years it was widely produced and used as an insecticide until the 1990s in Europe. Its use in agriculture was banned in 2009. Lindane is potentially extremely harmful to bees, the environment and humans, but it is still allowed, especially in the United States, for restricted medical use in treating scabies and lice. Despite being banned in the European Union, a 2016 European Parliament study, 'Lindane, (persistent organic pollutant) in the EU', noted in the introductory abstract: "Its persistence, bioacumulative and toxic properties, spillages from former production sites and the illegal dumping of HCH-waste, have given rise to serious concerns.." Lindane was found through tests on hair samples in a female resident of Vrisnik and a male resident of Hvar Town on Hvar Island in July 2023.

Long researches and expressions of just concern  deserve a positive conclusion

At first sight it was puzzling that substances banned in the EU were being sprayed over the Island of Hvar and elsewhere in Croatia indiscriminately. It has taken about twelve years to piece together the extent of the problems relating to current levels of chemical pesticide use. When the local and national authorities were first questioned about the use of EU-banned products in the annual fogging actions on Hvar, the response was that the substances were authorized for this use and it was all 'perfectly safe'.

Now it is obvious that, together with the disastrous flaws in the approvals processes, the discrepancy between approvals of 'plant protection products' and biocides is adding to a growing environmental catastrophe, in which bee loss is just one of the symptoms. It's only just dawning on the EU authorities that bees are not being protected, after all the years in which they have been approving bee-harming pesticides.

It's up to the law makers and pesticide users to put all this right. It can be done. Destruction of our beautiful environment is not inevitable.

But while we're waiting, what else is there to do but pray?


© Vivian Grisogono, MA (Oxon), August 1st 2023

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