[Pollinator] Fwd: Another comment RE: Bee protection group (bumblebee) under fire for f...
Ladadams at aol.com
Ladadams at aol.com
Wed Aug 1 14:40:29 PDT 2012
____________________________________
From: Rainer.Krell at FAO.ORG
To: ICPBR at LISTSERV.UOGUELPH.CA
Sent: 8/1/2012 2:01:34 P.M. Pacific Daylight Time
Subj: Another comment RE: Bee protection group (bumblebee) under fire for
failing to fight pesticide "armageddon."
Dear Peter and all,
Many thanks for all the info and discussion.
Just a thought – could not help myself to not comment:
This is not a court of law where any chemical is safe until proven beyond
any doubt of its damage capacity and risk.
(Releasing just any kind of chemical, tested or not, into any environment
is not a basic human right.)
All this calling on better science is fine and acceptable as logical
linear thinking – which science is good at. It does however, not solve the basic
problem of increased rates of environmental intoxication; first of all,
because most decisions are not made based on scientific probabilities, they
only inform the decision making process. If decisions really would be taken
based on thorough science and science would serve decision making for the
best solutions (for all), then the appropriate methodology for a life
support system would be the reverse of what it is right now. We would test a
chemical for whether it is good for the environment and whether it
simultaneously fulfils a number of additional requirements among which could be the
balancing of insect species in an agricultural field.
In addition, the problem is not good or bad science or insufficient science
, the problem is that products are put out in the field (or environment)
before being tested thoroughly for their negative effects. While it should
be the other way around. Using the same linear approach, one would use all
this science and collaboration and perfecting of the methods and tests
before putting the chemical out there, and only do it if it tests safe and
beneficial to the whole life process in the environment and human bodies.
Such an approach would be perfectly safe and acceptable, if it were not
for different commercial interests from the chemical producer’s side. Also
because, these new chemicals are not at all needed by the agricultural
producers. There are plenty of other non-toxic alternatives available (still),
thus we can well wait for another decade or two to perfect scientific methods
and test more.
It is however commercial interests that have been pushing, for many
decades, the whole thinking into a different direction, i.e. that of more
effective and better chemicals (assumed safe until proven toxic by non-producer
financed laboratories/institutions) to resolve systemic problems of
inappropriate, and ill-adapted production systems and production thinking. The
agricultural field is not an industrial assembly plant, nor is the human body a
sophisticated machine. Once we overcome these outdated industrial era
concepts we might also come to accept the inadequacy of the a-chemical-to-fix-it
mentality at all levels, be they producers, processors, industry,
politicians, scientists, or consumers.
Systems thinking is not a panacea and there is more, but giving it at
least a try at all levels would us get a little further and more in step with
our technical, chemical and biological (and also mental) capacities. The
precautionary principle, for example, is not anti-industry, it is pro-human
evolution. In my opinion it would do good if all participants in this game
would every now and then revisit their intrinsic or basic values, not
necessarily those currently accepted by their employers, on the basis of which
they think and act.
Such thinking would also do good to enter into the new risk assessment
methodologies.
Even in the darkest tunnel there is still hope to find a light, if one
keeps on moving and following those inner-most guiding principles. And
hopefully the first light is not the one of the on-coming train.
Rainer Krell
(A personal thought, not one representing in any form an opinion of my
employer)
From: International Commission on Plant-Bee Relations
[mailto:ICPBR at LISTSERV.UOGUELPH.CA] On Behalf Of Miles, Mark (M)
Sent: 01 August 2012 15:10
To: ICPBR at LISTSERV.UOGUELPH.CA
Subject: Re: Bee protection group (bumblebee) under fire for failing to
fight pesticide "armageddon."
Dear Peter
thank you for sharing and bringing this issue to light. I have been
active in the “Bee protection group” for the past 10 years and I have given up
much of my time to support sensible scientific innovation and understanding
of the risk of pesticides to bees. I think is it sad that such articles
misrepresent all the excellent work done by the group. In my view the worst
criticisms come from the press and NGO pressure groups with claims that
industry undermine the group. This is not true, the industry members are
typically experienced and concern scientists not anti-environmentalists. There
have been unhelpful articles which have claimed that pesticide companies
are running ICPPR – this is not true – the group is also comprised of
representatives of authorities (e.g. UK CRD, US EPA, NL CTgB, Fr ANESS, CAN PMRA
etc) and many academics. In fact the pesticide companies actually sponsor
the meetings to enable and subsidize participation of authorities and
academics. Recent articles in the French press have also criticized the work.
This has been lead by a small number of people who are part of an
anti-pesticide lobby. They have attended the meetings the meetings in Bucharest and
Wageningen, where as you know the ICPPR works on consensus. They are also
welcome to spare time to contribute scientifically to the working groups
and are members of some working groups. It seems perhaps the consensus
system does not allow them to achieve all their goals within the group. Clearly
the same is true for industry.
Other so called “criticism” by the recent EFSA opinion is a list of
scientific concerns relating to certain test designs. These views are based on
an opinion and not an analysis of the data, regulatory system or anything
else. The ICPPR groups could answers these points by analysing existing
data and indeed there are groups on larval/brood testing, the performance and
evaluation of semi-field and field test as well as bee monitoring. Again,
the NGO and authorities are a large part of these groups. I have started
to analyse tunnel test data and recently presented it a SETAC world meeting
in Berlin May 2012. More should be done on this and there are people
already working in the area. I agree there is much work to be done but it must
be achieved through science; by analysis of existing data and ring testing
new appropriate methods. This in turn needs a thorough investigation into
how these end points can feed into a regulatory risk assessment scheme.
This requires time and expertise and that expertise lies with all the
stakeholders, including industry as we own a lot a data that could be analysed.
Finally, recently the EU commission have issued the new data requirements,
which include far more testing for bees (including larval test, chronic
exposure and sub-lethal effects). Also mentioned are additional formal
considerations for systemic products, dust and granules. In addition there has
been a very important SETAC Pellston meeting which will be used to
development the new guidance for use in North America – I can only hope that out of
this comes some kind of across region harmonisation.
I call for the Bee protection group to stand up and defend their work
over the years and actively support it with scientific analysis. Where
deficiencies are noted the groups can work to addressing them and recommend
updates and revisions.
I do however take the findings of the bumblebee work where queen
production was reduced and would be in favour of understanding the mechanism in more
detail (including testing other chemicals) and then taking steps to
understand the actual exposure of these pollinators to see if the effects are
reproduced at environmentally relevant levels.
I look forward to many more years of working towards protecting both bees
and crops!
Best regards
Mark
From: International Commission on Plant-Bee Relations
[_mailto:ICPBR at LISTSERV.UOGUELPH.CA_ (mailto:ICPBR at LISTSERV.UOGUELPH.CA) ] On Behalf Of Peter
Kevan
Sent: 30 July 2012 18:25
To: _ICPBR at LISTSERV.UOGUELPH.CA_ (mailto:ICPBR at LISTSERV.UOGUELPH.CA)
Subject: Bee protection group (bumblebee) under fire for failing to fight
pesticide "armageddon."
It seems that we are at ICPPR are also coming under some fire in Europe,
though not as seriously as for the bumblebee conservation group in UK. We
need to be cautious to the extent that the neonicotinoid debate is emotional
and scientific. I have not been following it for a number of years, but
ICPPR should reserve its assessments to consideration of scientific data.
Cheers, Peter
_http://www.heraldscotland.com/news/environment/bee-protection-group-under-f
ire-for-failing-to-fight-pesticide-armageddon.18271390_
(http://www.heraldscotland.com/news/environment/bee-protection-group-under-fire-for-failing-to-f
ight-pesticide-armageddon.18271390)
=
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