Risk management for pollinators: regulatory context, practical aspects in European and OECD countries and perspectives

Transcription

1 Risk management for pollinators: regulatory context, practical aspects in European and OECD countries and perspectives Anne Alix Biologist, analytical chemist, entomologist, ecotoxicologist European Regulatory Risk Management Leader

2 Agenda 1. Regulatory framework 2. How do we mitigate risks to pollinators? 3. Overview of risk management in OECD countries 4. Conclusions and perspectives

3 Regulatory framework for risk management 3

4 EC Regulation 1107/2009 Article 6: Conditions and restrictions Approval may be subject to conditions and restrictions including: (i) the need to impose risk mitigation measures and monitoring after use; Article 36: Examination for authorisation...and other risk mitigation measures deriving from specific conditions of use. Where the concerns of a Member State relating to human or animal health or the environment cannot be controlled by the establishment of the national risk mitigation measures referred to in the first subparagraph, a Member State may refuse authorisation of the plant protection product in its territory if, due to its specific environmental or agricultural circumstances, it has substantiated reasons to consider that the product in question still poses an unacceptable risk to human or animal health or the environment. Article 44: Withdrawal or amendment of an authorisation Where a Member State withdraws or amends an authorisation in accordance with paragraph 3,... The other Member States belonging to the same zone shall withdraw or amend the authorisation accordingly taking into account national conditions and risk mitigation measures

5 EC Regulation 547/2011 implementing Regulation (EC) No 1107/2009 of the European Parliament and of the Council as regards labelling requirements for plant protection products standard phrases for safety precautions for the protection of human or animal health or of the environment, as set out in Annex III Spe 8: Dangerous to bees./to protect bees and other pollinating insects do not apply to crop plants when in flower./do not use where bees are actively foraging./remove or cover beehives during application and for (state time) after treatment./ Do not apply when flowering weeds are present./ Remove weeds before flowering./do not apply before (state time).

6 Directive 2009/128/EC Article 5: Training 1. Member States shall ensure that all professional users, distributors and advisors have access to appropriate training by bodies designated by the competent authorities. ANNEX I : Training subjects referred to in Article 5 6. Measures to minimise risks to humans, non-target organisms and the environment Article 8: Inspection of equipment in use 1. Member States shall ensure that pesticide application equipment in professional use shall be subject to inspections at regular intervals.

7 What risks are risk mitigation measures there for? To be approved, a product must comply with the uniform principles (decision making criteria, Dir 97/57/EC) Therefore risk mitigation measures are there in order to make that the product complies with the uniform principle i.e. When risks may occur under certain circumstances, risk mitigation are implemented to avoid the occurrence of these circumstances

8 Exposure range Threshold Threshold Effect range Risk mitigation measures Uniform principles range: acceptable risks Risk range Exposure range Threshold Threshold Effect range Uniform principles range: acceptable risks Risk range Risk mitigation are implemented to avoid the occurrence of circumstances October associated 2013, Brussels to risks

9 How do we mitigate risks to pollinators?

10 In the field Labelling instructions: Spe 8: Dangerous to bees./to protect bees and other pollinating insects do not apply to crop plants when in flower./do not use where bees are actively foraging./remove or cover beehives during application and for (state time) after treatment./ Do not apply when flowering weeds are present./ Remove weeds before flowering./do not apply before (state time).

11 Labelling instructions: Spinosad: Australia: Labelling instructions Applications during flowering out of the presence of bees, or during exudates production, at specific application rates Deltamethrin: Mentions Abeilles 3a. F1 : Emploi autorisé durant la floraison en dehors de la présence d'abeilles pour une ou des application(s) à 0,5 L/ha (7,5 g deltamethrine/ha). 3b. F2 : Emploi autorisé durant la floraison en dehors de la présence d'abeilles pour une ou des application(s) à 0,42 L/ha (6,25 g deltamethrine/ha). 3c. F3 : Emploi autorisé durant la floraison en dehors de la présence d'abeilles pour une ou des application(s) à Mandatory label for Protection of Livestock with the precaution to not spray onto bees or beehives and the mention that once the spray 0,33 L/ha deposit (4,95 has g dried, deltamethrine/ha). foraging bees will not be affected. 3d. PE : Emploi autorisé au cours des périodes de production d'exsudats en dehors de la présence d'abeilles pour une New Zealand: ou des application(s) à 0,42 L/ha (6,25 g Similar statement + the following label warning: POLLINATORS: deltamethrine/ha) When applied during non-foraging periods Success Naturalyte Insect Control will not interfere with the activity of honey bees once the spray has dried. At least 3 hours drying time should occur before bee foraging is expected. At times when bees aggregate in large numbers outside the hive, ensure they are not directly contacted by the spray. No incident reported in either country

12 Generic measures All products do not need to be applied during flowering: Ex in France: Ordinance of 23 November 2004: In order to protect bees and other pollinators, the spraying of insecticides and acaricides is forbidden during flowering or during periods of exudates production. Derogations when uses during flowering are necessary: Unless, when a risk assessment allows to derogate as follows: - use authorised during flowering out the of the presence of bees - use authorised during exudates production out the of the presence of bees - use authorised during flowering and exudates production, out the of the presence of bees

13 21-Jul 23-Jul 25-Jul 27-Jul 29-Jul 31-Jul 02-Aug 04-Aug 06-Aug 08-Aug 10-Aug % maize pollen in pollen stores Reduce pollinators presence in treated crops Provide alternative food sources: field margins, sugar (honey bees). Palynological studies confirm the variety of pollen collected even in intensive agriculture area Ex: percentage of maize pollen in stored pollen, in colonies located in the middle of intensive maize area Work on formulations (e.g. repellence, as recommended during the USDA workshop in 2012, low drift technology) site 1 site 2 site 3 site 4 0

14 In the field margins What pollinators expected to be there? Flowering/non flowering crop Presence of managed bees Type of field margin Spray drift mitigation Width of the field margins

15 Buffer / non sprayed zones Very common in risk assessment for non-target arthropods and more recently honey bees Basis: testing using application rates representing spray drift Buffer zones recommended (27 out of 27 feedback during the workshop MAgPIE) Future development: spray drift measurements in field margins (MAgPIE)

16 Low spray drift nozzles Mentioned in 20 out of 27 feedback (MAgPIE workshop) Drift reduction of up to 99%, most commonly 75-95% Conventional ATR Nozzle Nozzles s efficacy certified ( ) Albuz TVI Low Drift Nozzle

17 Flowering strips Aim: provide habitat and food sources in agricultural landscapes A number of projects (extract below): EFSA colloquium on multiple stressors and ICPPR for reviews of effects on biodiversity and pollinators

18 In adjacent crops As for field margins: Mitigation of spray drift Expectations as regards the presence of pollinators (tip: are there any flowers? Is there an apiary?)

19 Overview of risk management in OECD countries

20 OECD working group Pesticide Effects on Insect Pollinators PEIP Concerns about the reported decline in native and managed pollinators in several regions of the world Uncertainty regarding the extent to which pesticides contribute to declines Challenging access to authorities information in real time to respond to reports of incidents associated with pesticide use OECD PEIP Working Group established, chaired by US and Canada with input from EFSA, Germany, Netherlands and UK Four sub-groups to investigate: Reporting of Pollinator Incidents Testing Requirements for Pollinators Regulatory Response to Potential Pollinator Risks Research

21 Theme 3: Regulatory Response to Potential Pollinator Risks Develop a mechanism for sharing risk management tools used by different countries to mitigate pollinator risks, including: precautionary labeling, use restrictions, technologies, training materials, best management practices, and integrated pest management practices

22 Survey of OECD Members Questionnaire to collect practices: Needs for risk mitigation for pollinators Label mitigation for pollinators Non-label mitigation for pollinators Responses received from 20 countries: Australia, Austria, Canada, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Japan, Korea, Latvia, Lithuania, Netherlands, New Zealand, Poland, Switzerland, UK, US

23 Results Protection of both crop pollination and pollinator biodiversity is the goal in most countries Protection of pollinators in-field and off-field is important in 75% of countries. No countries are protecting only off-field pollinators Protection for both honeybees and non-apis bees is the objective in 80% of countries; protection of other insect pollinators is also important in 50% of countries.

24 Guidance for risk mitigation measures All countries have guidance for mitigating risk to pollinators Most countries consider mitigation for direct spray application, spray drift and contaminated dusts Guidance for determining when mitigation is required is available in most countries, and of these two-thirds have guidance for determining which mitigation options are appropriate

25 Label mitigation All countries use label mitigation to manage risk to pollinators Approval restrictions (e.g. excluded crops, rate restrictions), Use restrictions (e.g. not to be used during flowering) Advisory information (e.g. avoid drift onto flowering crops/margins, close hives during application, avoid use during bee flight) Spe 8: Dangerous to bees./to protect bees and other pollinating insects do not apply to crop plants when in flower./do not use where bees are actively foraging./remove or cover beehives during application and for (state time) after treatment./ Do not apply when flowering weeds are present./ Remove weeds before flowering./do not apply before (state time).

26 Label mitigation Most countries have a mechanism for enforcing label mitigation, and restrictions (e.g. DO NOT statements) are considered legally binding Most countries do not have any formal mechanism for determining the effectiveness of label (or non-label) mitigation though intuitively most believe drift reduction and use restriction measures are effective measures to reduce risk

27 Label language - examples The pesticide is toxic to bees and other pollinating insects. Blooming plants other than potato and pea are not allowed to be sprayed with the product. Blooming peas may only be sprayed after the flying time of bees between 21 and 6 o clock. The use nearer than 60 metres to the beehives is forbidden without the beekeeper s permission The pesticide is toxic to bees and pollinating insects. The use nearer than 60 metres to the beehives is forbidden without the beekeeper s permission. Blooming currants may be sprayed after the flying time of bees between 21 and 6 o clock. The beekeepers within a radius of 3 kilometres must be informed not later than 24 hours before application Toxic to bees. Bees can be exposed to product TOXIC TO BEES. SPe 8. To protect bees and residues other pollinators pollen and/or it nectar resulting from is prohibited to spray on flowering plants. granular Three days application. before Avoid application to the application always warn beekeepers flowering whose apiary plants (or hives) are located in a radius of 2 km from the SPe treatment 8. Dangerous area to bees. To protect bees and other pollinators use after and before Toxic to bees exposed to direct treatment, 5.00 in places where: drift, or residues on flowering crops or weeds. Minimize spray drift to reduce harmful effects -there are flowering plants and/or flowering on bees in habitats close to the application weeds; site. -in places where bees are actively foraging

28 Other mitigation tools Almost all countries employ other mitigation tools used to manage risk to pollinators User training programs Training and education for pesticide applicators is mandatory in half of countries, and is mandatory for some (higher risk) pesticides; specific pollinator components may not be included in all training programs

29 Non label mitigation Education/Outreach Programs Several countries commented that education of users is crucial to mitigate risks by ensuring users better understand the label Pesticide companies often have stewardship programs contributing to education and awareness of pollinator issues Beekeepers associations often provide training and advice for beekeepers, and collaborate with governments and companies to promote communication with beekeepers Best Management Practices Pollinators may not be addressed specifically in some cases, but programs exist that will result in improved practices during pesticide applications, and thus help to protect pollinators (e.g. spray/dust drift management) Awareness campaigns Seasonal campaigns aimed October 2013, at Brussels farmers/beekeepers

30 Web based portal Portal to mirror 3 risk mitigation types Label information; to include links to country specific examples and sources for label guidance; phrases to illustrate wording for different situations Non-label information; to include links to advisory information and BMPs which focus on practices that can be encouraged to benefit pollinators and mitigate pollinator declines (e.g. ways of reducing offfield exposure, provision of managed wild flower strips to provide noncrop nectar and pollen sources Education and Training information; where available, existing training information recognized by member countries will be provided Portal to include a link to Country Laws, Policies and Guidance Including links to approved products in member countries

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32 Conclusions and perspectives

33 Conclusions Awareness on the need to mitigate risks to pollinators in the agricultural landscape Important effort to reduce pollinators exposure to pesticides Regulatory level Farm level This effort involves all stakeholders: Regulatory authorities Farmers Industry Beekeepers NGOs (e.g. NAPPC)

34 Conclusions Needs identified to develop further risk mitigation tools: Better characterize field frequentation and exposure (entomologists, palynologists) Complete the set of low spray drift nozzles Better characterize spray drift in the off-field area Keep measuring the efficacy of these risk mitigation tools on pollinators: Review of literature (ICPPR) Make recommendations Communicate

35 Perspectives European workshop Mitigating Effects of Agrochemicals in the Environment (MAgPIE) Inventory of risk mitigation measures, enforced and in development, in Europe Build a toolbox of measures ready to use Identify needs (research, legal aspects, implementation aspects) Provide recommendations when developing risk mitigation tools Build a network

36 MAgPIE expected outcome for pollinators Complete the toolbox gathered through OECD Provide the data in support of the measures proposed Forum to share experience in developing, implementing, evaluating the tools MAgPIE 2: November, INIA, Madrid, Spain Proceedings: 2014 Network: join us

37 Thanks to: The 27 Members of the OECD PEIP working group The 75 participants to MAgPIE Thank you for your attention