EFSA public consultation response
The Bumblebee Conservation Trust (the Trust) was pleased to have the opportunity to comment on the European Food Safety Authority's (EFSA) public consultation on the Risk Assessment of Plant Protection Products on bees (Apis mellifera, Bombus spp. and solitary bees).
The Trust welcomed the Terms of Reference which began to address previous serious inadequacies in risk assessment. Notably, the Terms of Reference required impacts on bumblebees and solitary bees to be assessed, in addition to impacts on honeybees. It was also a requirement that assessments determined long-term, sub-lethal and synergistic effects.
Regrettably, the Guidance Document fell well short of adequately implementing the requirements laid down in the Terms of Reference. Throughout the Guidance Document, the different (annual) lifecycle of bumblebees was overlooked. The consultation document assumed that honeybees could be used as a proxy for bumblebees, which is ecologically both inappropriate and misleading. The consultation recommended that only short-term lethal effects triggered more comprehensive testing; this is counter to the precautionary principle and in contrast with the Terms of Reference's requirement to rule out long-term and sub-lethal effects prior to licensing products.
In responding to this consultation, the Trust stressed that good scientific methodology should be used to implement the precautionary principle. Cost and time-saving measures should not prejudice the rigorousness of testing protocols. The Trust looks forward to seeing and commenting on a revised draft.
To read our response in full, click here.