Miljø- og Fødevareudvalget 2018-19 (1. samling)
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CONCLUSION ON PESTICIDES PEER REVIEW
ADOPTED: 1 February 2018
doi: 10.2903/j.efsa.2018.5178
Peer review of the pesticide risk assessment for bees
for the active substance imidacloprid considering the
uses as seed treatments and granules
European Food Safety Authority (EFSA)
Abstract
The EFSA was asked by the European Commission to perform an updated risk assessment of
neonicotinoids, including imidacloprid, as regards the risk to bees, as a follow-up of previous mandates
received from the European Commission on neonicotinoids. The context of the evaluation was that
required by the European Commission in accordance with Article 21 of Regulation (EC) No 1107/2009
to review the approval of active substances in light of new scientific and technical knowledge and
monitoring data. In this context and in accordance with Article 31 of Regulation (EC) No 178/2002,
EFSA has been previously asked by the European Commission to organise an open call for data in
order to collect new scientific information as regards the risk to bees from the neonicotinoid pesticide
active substances clothianidin, thiamethoxam and imidacloprid applied as seed treatments and
granules in the EU. The conclusions were reached on the basis of the evaluation of the supported uses
as an insecticide of imidacloprid applied as seed treatments and granules, on the new relevant data
collected in the framework of the open call organised by EFSA and on the updated literature search
performed by EFSA. The reliable endpoints, appropriate for use in regulatory risk assessment derived
from the submitted studies and literature data as well as any other relevant data available at national
level and made available to EFSA, are presented. Concerns are identified.
©
2018 European Food Safety Authority.
EFSA Journal
published by John Wiley and Sons Ltd on behalf
of European Food Safety Authority.
Keywords:
imidacloprid, peer review, risk assessment, pesticide, insecticide, neonicotinoid
Requestor:
European Commission
Question number:
EFSA-Q-2015-00772
Correspondence:
[email protected]
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EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
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Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Suggested citation:
EFSA (European Food Safety Authority), 2018. Conclusion on the peer review of
the pesticide risk assessment for bees for the active substance imidacloprid considering the uses as
seed treatments and granules. EFSA Journal 2018;16(2):5178, 113 pp.
https://doi.org/10.2903/j.efsa.
2018.5178
ISSN:
1831-4732
©
2018 European Food Safety Authority.
EFSA Journal
published by John Wiley and Sons Ltd on behalf
of European Food Safety Authority.
This is an open access article under the terms of the
Creative Commons Attribution-NoDerivs
License,
which permits use and distribution in any medium, provided the original work is properly cited and no
modifications or adaptations are made.
The EFSA Journal is a publication of the European Food
Safety Authority, an agency of the European Union.
www.efsa.europa.eu/efsajournal
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EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
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Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Summary
Imidacloprid was included in Annex I to Directive 91/414/EEC on 1 August 2009 by Commission
Directive 2008/116/EC and has been deemed to be approved under Regulation (EC) No 1107/2009, in
accordance with Commission Implementing Regulation (EU) No 540/2011, as amended by Commission
Implementing Regulation (EU) No 541/2011. A specific conclusion has been issued by European Food
Safety Authority (EFSA) on the risk assessment for bees as regards the authorised uses applied as
seed treatments and granules.
The specific provisions of the approval were amended by Commission Implementing Regulation (EU)
No 485/2013, to restrict the uses of clothianidin, thiamethoxam and imidacloprid, to provide for specific
risk mitigation measures for the protection of bees and to limit the use of the plant protection products
containing these active substances to professional users. In particular, the uses as seed treatment and
soil treatment of plant protection products containing clothianidin, thiamethoxam or imidacloprid have
been prohibited for crops attractive to bees and for cereals except for uses in greenhouses and for
winter cereals. Foliar treatments with plant protection products containing these active substances have
been prohibited for crops attractive to bees and for cereals with the exception of uses in greenhouses
and uses after
flowering.
Furthermore, the European Commission requested EFSA to provide conclusions
concerning an updated risk assessment for bees for clothianidin, thiamethoxam and imidacloprid, taking
into account all uses other than seed treatments and granules, including foliar spray uses as mentioned
in recital 7 of Commission Implementing Regulation (EU) No 485/2013. EFSA
finalised
its conclusion on
the risk assessment for bees as regards all uses other than seed treatments and granules in July 2015.
It was a specific provision of the Commission Implementing Regulation (EU) No 485/2013 that the
applicant was also required to submit to the European Commission further ecotoxicological studies by
31 December 2014. The outcomes of the peer review of the confirmatory data assessment were
reported in a Technical Report and a conclusion published in 2016.
Furthermore, according to recital 16 of Regulation (EU) No 485/2013, within 2 years from the date
of entry into force of that Regulation, the European Commission foresees to initiate without undue
delay a review of the new scientific information available.
For this purpose, with reference to Article 31 of Regulation (EC) No 178/2002 and in accordance
with Article 21 of Regulation (EC) No 1107/2009, the European Commission requested EFSA to
organise an open call for data in order to collect new scientific information as regards the risk to bees
from the neonicotinoid pesticide active substances clothianidin, thiamethoxam and imidacloprid applied
as seed treatments and granules in the European Union (EU).
The European Commission requested EFSA to provide conclusions concerning an updated risk
assessment for bees for the three neonicotinoids (namely clothianidin, imidacloprid and
thiamethoxam), taking into account:
the new relevant data collected in the framework of the specific open call for data
any other new data from studies, research and monitoring activities that are relevant to the
uses under consideration
the EFSA Guidance Document on the risk assessment of plant protection products on bees
(Apis
mellifera, Bombus
spp. and solitary bees)
EFSA also considered the data available from a systematic literature review performed in June
2016, in order to collect all published scientific literature relevant for the current evaluation.
Risk assessments were performed for honeybees, bumblebees and solitary bees according to the
EFSA guidance document on the risk assessment of plant protection products on bees. For exposure
via residues in pollen and nectar, where a higher tier (Tier-3) risk assessment could be performed, a
low risk was concluded for some crops for honeybees. However, when all the bee groups (honeybees,
bumblebees and solitary bees) are considered, a high risk was concluded or it was concluded that a
low risk was not demonstrated for all the uses assessed.
For the exposure via residues from dust drift, a low risk was concluded for some crops for honeybees.
However, when all the bee groups (honeybees, bumblebees and solitary bees) are considered, a high risk
was concluded or it was concluded that a low risk was not demonstrated for all the uses assessed.
For exposure via water consumption, a low risk to honeybees was concluded for all uses via residues
in puddles or via surface water. A low risk to honeybees was concluded for residues in guttation
fluid
for
the uses to winter cereals, sugar beet and potatoes. A high risk was concluded for all other uses.
Refer to Table
19
in the main text of the conclusion for crop-specific conclusion achieved at each
assessment tier.
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Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Table of contents
Abstract.................................................................................................................................................
Summary...............................................................................................................................................
Background
...........................................................................................................................................
The active substance and metabolites......................................................................................................
Assessment............................................................................................................................................
1.
Uses assessed
.........................................................................................................................
Summary of the data considered in this conclusion
....................................................................
2.
3.
Principles and assessment criteria.............................................................................................
3.1.
Aim of the assessment.............................................................................................................
Tier-1
.....................................................................................................................................
3.2.
3.2.1.
Selection of the endpoints........................................................................................................
3.3.
Refinement of the exposure
.....................................................................................................
Residues in pollen and nectar...................................................................................................
3.3.1.
3.3.1.1.
Data evaluation and selection...................................................................................................
3.3.1.2.
Calculation of refined shortcut values........................................................................................
3.3.1.3.
Estimation of the exposure assessment goal..............................................................................
3.3.2.
Dust drift and deposition..........................................................................................................
Weeds in the
field
...................................................................................................................
3.3.3.
3.3.4.
Residues in water sources........................................................................................................
3.4.
Refinement with higher tier experiments
...................................................................................
Building up the lines of evidence
..............................................................................................
3.4.1.
3.4.2.
Integrating the lines of evidence
..............................................................................................
4.
Outcome of the risk assessment: toxicity endpoints
...................................................................
Standard endpoints
.................................................................................................................
4.1.
4.2.
Additional sublethal laboratory data
..........................................................................................
5.
Outcome of the risk assessment
...............................................................................................
Risk assessments for seed treatment products...........................................................................
5.1.
5.1.1.
Risk via systemic translocation in plants
residues in nectar and pollen (treated crop scenario
and succeeding crop scenario)
.................................................................................................
5.1.1.1.
Tier-1 risk assessment
.............................................................................................................
5.1.1.2.
Exposure assessment for the treated and succeeding crop scenarios...........................................
5.1.1.3.
Tier-2 risk assessment
.............................................................................................................
5.1.1.4.
Tier-3 risk assessment (weight of evidence)
..............................................................................
5.1.1.4.1.
Weight of evidence higher tier risk assessment for honeybees
....................................................
5.1.1.4.2.
Weight of evidence higher tier risk assessment for bumblebees
..................................................
5.1.1.4.3.
Solitary bees
...........................................................................................................................
5.1.2.
Risk from contamination of adjacent vegetation via dust drift (field margin and adjacent crop scenario)
5.1.2.1.
Tier-1 risk assessment
.............................................................................................................
5.1.2.2.
Exposure assessment for the
field
margin and adjacent crop scenario
.........................................
5.1.2.3.
Tier-2 risk assessment
.............................................................................................................
5.1.2.4.
Tier-3 risk assessment
.............................................................................................................
5.1.3.
Risk via water consumption......................................................................................................
5.1.3.1.
Guttation water.......................................................................................................................
5.1.3.2.
Puddle water
..........................................................................................................................
5.1.3.3.
Surface water
.........................................................................................................................
5.2.
Risk assessments for granule
...................................................................................................
Risk via systemic translocation in plants
residues in nectar and pollen
......................................
5.2.1.
5.2.1.1.
Tier-1 risk assessment for treated crop scenario, weed scenario and succeeding crop scenario
.....
5.2.1.2.
Exposure assessment for the treated crop, succeeding crop scenarios and for
flowering
weeds.....
5.2.1.3.
Tier-2 risk assessment
.............................................................................................................
5.2.1.4.
Tier-3 risk assessment
.............................................................................................................
Risk from contamination via dust drift.......................................................................................
5.2.2.
5.2.2.1.
Tier-1 risk assessment
.............................................................................................................
5.2.2.2.
Exposure assessment for the
field
margin and adjacent crop scenario
.........................................
5.2.2.3.
Tier-2 risk assessment
.............................................................................................................
5.2.2.4.
Tier-3 risk assessment
.............................................................................................................
5.2.3.
Risk via water consumption......................................................................................................
5.2.3.1.
Guttation water.......................................................................................................................
5.2.3.2.
Puddle water
..........................................................................................................................
1
3
6
7
7
7
9
9
9
10
10
10
11
11
13
13
14
14
14
15
15
18
19
19
21
22
22
22
22
23
25
26
26
30
33
33
33
35
35
35
36
36
37
37
38
38
38
38
38
39
39
39
40
40
40
40
40
40
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Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
5.2.3.3.
Surface water
.........................................................................................................................
Overall conclusion
...................................................................................................................
6.
6.1.
Seed treatment uses
...............................................................................................................
6.2.
Granular uses..........................................................................................................................
Overview of the concerns identified for each representative use considered.................................
7.
References.............................................................................................................................................
Abbreviations
.........................................................................................................................................
Appendix A
List of supported uses
........................................................................................................
Appendix B
Overview of endpoint types and related relevance class assigned within the scope of the
present risk assessment
..........................................................................................................................
Appendix C
Tier-1 risk assessment based on EFSA (2013c)
.....................................................................
Appendix D
Measured residue values and RUD values used for calculation of exposure assessment goals
..
Appendix E
Residue intake in higher tier studies providing reliable Class 1 and Class 2 endpoints
..............
Appendix F
Tier-3 lines of evidence
.......................................................................................................
Appendix G
List of study references
......................................................................................................
Appendix H
Used compound codes
.......................................................................................................
40
40
40
42
50
50
51
53
54
59
72
74
81
108
113
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Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Background
Imidacloprid was included in Annex I to Directive 91/414/EEC
1
on 1 August 2009 by Commission
Directive 2008/116/EC
2
and has been deemed to be approved under Regulation (EC) No 1107/2009
3
,
in accordance with Commission Implementing Regulation (EU) No 540/2011
4
, as amended by
Commission Implementing Regulations (EU) No 541/2011
5
. A specific conclusion has been issued by
European Food Safety Authority (EFSA) on the risk assessment for bees as regards the authorised uses
applied as seed treatments and granules (EFSA, 2013a).
The specific provisions of the approval were amended by Commission Implementing Regulation
(EU) No 485/2013
6
, to restrict the uses of clothianidin, thiamethoxam and imidacloprid, to provide for
specific risk mitigation measures for the protection of bees and to limit the use of the plant protection
products containing these active substances to professional users. In particular, the uses as seed
treatment and soil treatment of plant protection products containing clothianidin, thiamethoxam or
imidacloprid have been prohibited for crops attractive to bees and for cereals except for uses in
greenhouses and for winter cereals. Foliar treatments with plant protection products containing these
active substances have been prohibited for crops attractive to bees and for cereals with the exception
of uses in greenhouses and uses after
flowering.
Furthermore, the European Commission requested
EFSA to provide conclusions concerning an updated risk assessment for bees for clothianidin,
thiamethoxam and imidacloprid, taking into account all uses other than seed treatments and granules,
including foliar spray uses as mentioned in recital 7 of Commission Implementing Regulation (EU)
No 485/2013. EFSA
finalised
its conclusion on the risk assessment for bees as regards all uses other
than seed treatments and granules in July 2015 (EFSA, 2015).
It was a specific provision of the Commission Implementing Regulation (EU) No 485/2013 that the
applicant was also required to submit to the European Commission further ecotoxicological studies by
31 December 2014. The outcomes of the peer review of the confirmatory data assessment were
reported in a Technical Report (EFSA, 2016a) and a conclusion (EFSA, 2016b)
finalised
in 2016.
Furthermore, according to recital 16 of Regulation (EU) No 485/2013, within 2 years from the date
of entry into force of that Regulation, the European Commission foresees to initiate without undue
delay a review of the new scientific information available.
For this purpose, with reference to Article 31 of Regulation (EC) No 178/2002
7
and in accordance
with Article 21 of Regulation (EC) No 1107/2009, in February 2015, the European Commission
requested EFSA to organise an open call to collect new scientific information as regards the risk to
bees from the neonicotinoid pesticide active substances clothianidin, thiamethoxam and imidacloprid
applied as seed treatments and granules in the European Union (EU) (EFSA, 2014b) and then,
following a second mandate received in November 2015, EFSA was requested to provide conclusions
concerning an updated risk assessment for bees for the three neonicotinoids (namely clothianidin,
imidacloprid and thiamethoxam).
The new relevant data collected in the framework of the open call for data and any other new data
from studies, research and monitoring activities relevant for the uses under consideration were taken
into account. To address the mandate, EFSA also considered the data available from a previous
systematic literature review, outsourced in 2013 (Fryday et al., 2015). Furthermore, an update of this
systematic review was performed in June 2016, in order to collect all published scientific literature
1
2
3
4
5
6
7
Council Directive 91/414/EEC of 15 July 1991 concerning the placing of plant protection products on the market. OJ L 230,
19.8.1991, p. 1–32, as last amended.
Commission Directive 2008/116/EC of 15 December 2008 amending Council Directive 91/414/EEC to include aclonifen,
imidacloprid and metazachlor as active substances. OJ L 337, 16.12.2008, p. 86–91.
Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 October 2009 concerning the placing of
plant protection products on the market and repealing Council Directives 79/117/EEC and 91/414/EEC. OJ No L 309,
24.11.2009, p. 1–50.
Commission Implementing Regulation (EU) No 540/2011 of 25 May 2011 implementing Regulation (EC) No 1107/2009 of the
European Parliament and of the Council as regards the list of approved active substances. OJ L 153, 11.6.2011, p. 1–186.
Commission Implementing Regulation (EU) No 541/2011 of 1 June 2011 amending Implementing Regulation (EU) No 540/2011
implementing Regulation (EC) No 1107/2009 of the European Parliament and of the Council as regards the list of approved
active substances. OJ L 153, 11.6.2011, p. 187–188.
Commission Implementing Regulation (EU) No 485/2013 of 24 May 2013 amending Implementing Regulation (EU) No 540/
2011, as regards the conditions of approval of the active substances clothianidin, thiamethoxam and imidacloprid, and
prohibiting the use and sale of seeds treated with plant protection products containing those active substances. OJ L 139,
25.5.2013, p. 12–26.
Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying down the general
principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in
matters of food safety. OJ L 31, 1.2.2002, p. 1–24.
6
EFSA Journal 2018;16(2):5178
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Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
relevant for the current evaluation (EFSA, 2018a). The EFSA guidance document on the risk
assessment of plant protection products on bees (EFSA, 2013c) was used for the current evaluation as
requested in the mandate.
A consultation on the evaluation and preliminary conclusions of EFSA on the risk assessment for
bees was conducted with Member States via a written procedure in September 2017. The preliminary
draft conclusion drawn by EFSA, together with the points that required further consideration in the
assessment, as well as the specific issues raised by Member States following the consultation were
discussed at the Pesticides Peer Review Experts’ Meeting 166 on ecotoxicology in October 2017. Details
of the issues discussed together with the outcome of these discussions were recorded in the meeting
report. After the expert meeting, EFSA
finalised
the conclusions and launched a second written
procedure on the
final
draft in December 2017–January 2018 in order to provide their comments on
those parts of the conclusions and supporting documents that have been amended following the Peer
Review Meeting. The compiled comments were considered by EFSA and are published as part of the
background documents to the conclusions.
In addition, key supporting documents to this conclusion are the Technical Report on the evaluation
of data (EFSA, 2018a) and the Peer Review Report (EFSA, 2018b).
The Technical Report provides the methodology developed by EFSA relating to the evaluation of the
available data concerning their relevance for the current risk assessment and their scientific reliability.
It is composed as follows:
Technical Report on the evaluation of data (EFSA, 2018a)
Study Evaluation Notes (Appendices D–O) to the Technical Report (EFSA, 2018a).
The Peer Review Report is a compilation of the documentation developed to evaluate and address
all issues raised in the peer review, it comprises the following documents, in which all views expressed
during the course of the peer review, including minority views where applicable, can be found:
the comments received on the preliminary draft EFSA conclusion,
the report of the scientific consultation with Member State experts,
the comments received on the
final
draft EFSA conclusion.
It is recommended that this conclusion report and its background documents would not be
accepted to support any registration outside the EU for which the applicant has not demonstrated that
it has regulatory access to the information on which this conclusion report is based.
The active substance and metabolites
Imidacloprid is the ISO common name for (E)-1-(6-Chloro-3-pyridinylmethyl)-N-nitroimidazolidin-2-
ylideneamine (IUPAC).
Imidacloprid belongs to the group of neonicotinoid compounds which are used as insecticides. They
interact with the receptor protein of nicotinic acetyl choline receptors in the nerve
fibre
membrane of
insects.
The available earlier EU evaluations (EFSA, 2008, 2013a, 2015) have identified those metabolites of
imidacloprid which require consideration in a risk assessment for bees. Many of these metabolites are
several orders of magnitude less toxic to honeybees than the parent substance or had comparable
acute toxicity to imidacloprid. The single additional endpoint (which was considered as relevant and
reliable) submitted for this review has confirmed this (I.2020). However, their occurrence in pollen and
nectar is significantly lower. In the data set considered for this conclusion, some residue data were
available for metabolites imidacloprid olefin and 5-OH-imidacloprid. These new data did neither
indicate higher residue levels of the metabolites in pollen and nectar than the parent imidacloprid.
Therefore, it was considered that the risk from metabolites is covered by the risk assessment of the
parent and no separate risk assessment for metabolites is required.
Assessment
1.
Uses assessed
In accordance with the mandate received in February 2015, EFSA liaised with applicants in order to
collect feedback on the uses they would like to support for the EU market. During the open call for
data, the applicants were requested to submit information on the uses of imidacloprid (Good
Agricultural Practices), applied as a seed treatment or granule that they wish to support. In a second
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step, in December 2015, Member States were requested to validate the consolidated Good Agricultural
Practices (GAPs) from applicants, providing feedback on the authorised uses in their respective
countries. However, the risk assessment was performed for all uses supported by the applicants. Full
details of the GAPs are given in Appendix
A.
Tables
1
and
2
provide a brief summary of the critical
GAPs relevant to the risk assessment for bees. Only the highest and lowest of the maximum
application and seed treatment rates are given in Tables
1
and
2.
It has to be noted that the potato seed treatment use, as outlined by the Applicant, is an in-planter
tuber treatment. This treatment is done within the planter machine via a spray application just before
the tubers are dropped into the furrow.
Dummy pill use, as outlined by the applicant, is when a treated dead seed is sown together with an
untreated alive seed (ratio 1:1).
Some of the vegetables are harvested before the
flowering
period, unless they are grown for seed
production.
Table 1:
Crop
Spring cereals
Winter cereals
Summary of the seed treatment uses considered in this conclusion
Highest seed
Lowest seed
Highest
Lowest
application rate application rate treatment rate treatment rate Notes
(mg a.s./seed) (mg a.s./seed)
(g a.s./ha)
(g a.s./ha)
112
43
126
126
0.039
0.015
0.039
0.039
Four products,
three containing
other active
substances
(a)
Applied as a
dummy pill.
Seeds sown in
greenhouse and
transplanted at
BBCH 12 either
in the
field
or in
greenhouse
Cotton
Endive
Lettuce
Endive
Lettuce
Brassica,
flowering,
head, leafy (crops
like broccoli,
cauliflowers,
brussels sprouts,
head cabbages,
chinese cabbage,
kales)
Maize
Potato
100
104
104
89
89
90
175
104
104
120
120
90
0.63
0.8
0.8
0.8
0.8
1.5
0.84
0.8
0.8
1.2
1.2
1.5
60
120
100
180
1
No information
1
No information
Two products,
one also
containing
pencycuron
Single product
also containing
beta-cyfluthrin
Single product
also containing
beta-cyfluthrin
Four products,
three containing
other active
substances
(b)
Spring rape
9
12
0.01
0.01
Winter rape
9
12
0.01
0.01
Sugar and fodder
beet
13
117
0.1
0.9
BBCH: growth stages of mono- and dicotyledonous plants.
(a):
‘FS
373.4’ contains clothianidin, prothioconazole and tebuconazole in addition to imidacloprid.
‘FS
400’ and
‘FS
200’ contains
prothioconazole in addition to imidacloprid.
(b):
‘FS
230’ contains beta-cyfluthrin in addition to imidacloprid.
‘FS
280’ contains clothianidin and beta-cyfluthrin in addition to
imidacloprid.
‘FS
417.8’ contains tefluthrin in addition to imidacloprid.
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Table 2:
Crop
Summary of the granular uses considered in this conclusion
BBCH at the
time of
application
Highest
Lowest
application rate application rate Notes
(g a.s./ha)
(g a.s./ha)
150
150
Spread uniformly over the area with
granular application equipment,
immediately followed by sufficient
irrigation to move the active
ingredient through the thatch,
wetting the top inch soil
All crop stages
Managed
amenity turf
(golf courses,
sport grounds,
commercial
and residential
lawns)
BBCH: growth stages of mono- and dicotyledonous plants.
2.
Summary of the data considered in this conclusion
Concerning the effect data, the present conclusion makes use of different sources.
The
first
source of data was the open call for data for new scientific information as regards the risk
to bees from the use of the three neonicotinoid pesticide active substances clothianidin, imidacloprid
and thiamethoxam applied as seed treatments and granules in the EU. EFSA launched this call from
May 2015 to September 2015, as requested by the EU Commission. More details on the open call for
data are available in a dedicated Technical Report (EFSA, 2014b).
Other sources of data were the systematic literature search on the neonicotinoids and the risks to
bees that EFSA outsourced in 2013 (Fryday et al., 2015) and the related update performed by EFSA in
June 2016 (Appendix B to EFSA, 2018a).
The
first
systematic literature search comprised 546 (already screened) documents, while the update
of the literature search retrieved 874 documents. In addition, 376 contributions were received during
the open call for data. After duplicate removal, the overall initial list included 1599 documents. A title
and abstract screening step identified 680 potentially relevant documents which were then subject to
full text screening. During the full text screening, all experiments within the available documents were
identified and totalled 968. Of these experiments, 588 were critically appraised and the data extracted.
Finally, in accordance with the European Commission mandate, Member States were also further
requested to provide any monitoring data not yet available during the open call data. The data
submitted were already included in the dataset.
Full details on the collection of the available data investigating the effects and exposure of
imidacloprid to bees, together with their assessment for their reliability and relevance, are given in the
Technical Report on the evaluation of data and related appendices (EFSA, 2018a).
Furthermore, for what concern the exposure data, data already used in previous assessments
(EFSA, 2013a) were also considered, as information on residue levels was already systematically
collected and organised by EFSA during such previous assessments.
3.
3.1.
Principles and assessment criteria
Aim of the assessment
The current EU agreed level of protection for bees is to ensure that effects on colonies/populations
are negligible. This means that the exposure of the colonies/populations at the edge of the treated
fields
should not exceed a level which results in an effect greater than negligible.
As requested by the European Commission mandate, to perform the risk assessment of the three
active substances the EFSA Guidance Document on the risk assessment of plant protection products
on bees (Apis
mellifera, Bombus
spp. and solitary bees), hereafter referred to as EFSA (2013c) was
followed. The basis of the risk assessment according to EFSA (2013c) is to ensure that the specific
protection goals (SPG) for honeybees, bumblebees and solitary bees are met.
Namely:
For honeybees, to ensure that there is not a greater than 7% effect on colony strength,
including after overwintering, and the level of forager mortality does not breach the tolerable
level, for honeybee colonies located at the edge of treated
fields
which are exposed to the
90th percentile predicted exposure or less.
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For bumblebees, to ensure that there is not a greater than 7% impact on the colony for
bumblebee colonies located at the edge of treated
fields
which are exposed to the 90th
percentile predicted exposure or less.
For solitary bees, to ensure that there is not a greater than 7% effect on the population of
bees located at the edge of treated
fields
which are exposed to the 90th percentile predicted
exposure or less.
These SPGs define the problem formulation for the present assessment.
3.2.
Tier-1
According to EFSA (2013c), depending on the product formulation and the application method
under evaluation, different routes of exposure need to be considered to perform the risk assessment
to bees. The exposure from seed treatments and granular formulations in the
‘treated
crop’ and the
‘succeeding
crop’ scenarios derives from residues in pollen and nectar following translocation from
below ground (seeds or soil). The same route of exposure is considered relevant for the
‘weeds’
scenario in the case of granules application.
Concerning the surrounding area (‘field margin’ and
‘adjacent
crop’ scenarios), the most relevant
exposure is due to dust drift at the sowing (treated seeds)/application (granules).
Furthermore, a separate risk assessment for exposure via consumption of contaminated water
should be carried out for honeybees.
Details about the entire Tier-1 risk assessment scheme can be found in EFSA (2013c).
The Tier-1 risk assessment was carried out using default exposure values in accordance with EFSA
(2013c), while the selection of the toxicity endpoints is described below (Section
3.2.1).
Due to the
lack of suitable toxicity data for bumblebees and solitary bees, a surrogate endpoint was extrapolated
from the related honeybee data (assuming the endpoint is a factor of 10 lower). In this case,
throughout the present conclusion, we refer to the Tier-1 as
‘screening
Tier-1’.
3.2.1.
Selection of the endpoints
Several endpoints from laboratory studies were obtained from the data considered in this
conclusion and which had not been considered in previous EU assessments. These newer endpoints
have been considered to amend the previously agreed EU endpoints (EFSA, 2015) provided that the
following criteria were fulfilled:
The endpoint was considered as relevant for a risk assessment according to EFSA (2013c) and
the GAPs under consideration (e.g. the endpoint type, the test species and the test item were
considered as relevant);
The endpoint was assessed to be
‘Fully
reliable’ or
‘Reliable
with minor restrictions’ during the
appraisal exercise (EFSA, 2018a);
The endpoint, from a study with technical active substance, indicated higher toxicity than the
previously agreed EU endpoint for the technical active substance.
Moreover, for endpoints from formulation studies, the following criteria were considered:
the previously agreed EU endpoint originating from a formulation study was replaced only if it
was less relevant (e.g. study with a spray formulation) than the newer formulation endpoint
the previously agreed EU endpoint is a surrogate extrapolated endpoint
Where no new endpoints were available, or the criteria above were not fulfilled, the previously
agreed EU endpoints were selected for risk assessment. The data available and
final
selection of the
endpoints used for the current risk assessment are given in Section
4.
3.3.
Refinement of the exposure
Within EFSA (2013c), no stepwise approach is offered for higher tier risk assessment. Nevertheless,
among the options listed in the guidance, one possibility is to refine the exposure estimate, i.e. replace the
default values with specific values coming from higher tier exposure studies. Within the scope of this
conclusion, the risk assessment carried out with refined exposure estimates is referred to as
‘Tier-2’
. A further
refinement option given in EFSA (2013c) is to refine the assessment by the use of higher tier effect studies
performed in the
field
or under semifield conditions (see Section
3.4).
Specific exposure assessment goals
need to be determined in order to use such effect studies in a refined risk assessment, referred to as
‘Tier-3’
.
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3.3.1.
Residues in pollen and nectar
3.3.1.1. Data evaluation and selection
The newly available higher tier studies, reporting information on exposure, were evaluated in line
with the validity criteria set in the literature evaluation protocol (EFSA, 2018a) and the protocols
proposed in Appendix G of EFSA (2013c). The valid data on the residue levels occurring in nectar and
pollen for the exposure scenarios for the treated
field
and the succeeding crops in line with these
protocols were collated in a table. Residue determination in available
field
studies was assessed for
their reliability both in relation to their
field
and laboratory phases. For the
field
phase, in order to
refine the exposure, higher tier studies from at least
five
randomly selected locations in the area of use
of the substance should be conducted. This minimum of
five
randomly selected locations in the area of
use is prescribed by the guidance, to ensure that an estimate can be made of the distribution of
residues that might really be encountered by the bees. This has the aim of accounting for the different
temporal and spatial variability that occurs. In relation to the laboratory phase, the analytical methods
were examined for their adequacy for determining residues at the low levels required. In some
instances, the size of the samples collected in the
field
phase was lower than the sample size for which
the method had been validated, in such cases appropriate correction on the method validated limit of
quantification (LOQ) (for the target sample size) was applied, i.e. the LOQ was increased to account
for smaller than ideal sample availability of individual sampling events.
Measured residue levels of pollen and nectar were reported for each type of sampling matrix (i.e.
samples from the plant, from the bee, from the bee via pollen traps, from the comb and from soil). In
general, the sampling scheme which aimed to determine residues in the same matrix (either in plant
matrices or bee matrices) during the
field
studies was not exhaustive enough to guarantee that the
time dependence of the residue over the period of interest could be captured. This prevents any
analysis aimed to determine a mathematically rigorous percentile exposure value over time. Therefore,
the maximum observed in the available samples was retained as representative of the exposure in
each particular
field
experiment. This does not imply that the overall risk assessment has to be
regarded as overly conservative, since the sampling frequency pattern in the studies does not
guarantee that the actual maximum occurrence was picked up by the maximum measured in the
samples taken. Nevertheless, it is expected that the assessment based on these principles may still be
considered to represent a realistic worst-case exposure for the different substances and uses assessed.
Treated crop scenario
Regarding the
field
phases, the directly treated crop needed to be the same crop being assessed.
Appendix R of EFSA (2013c) indicates that extrapolation between the residue values from different
crops is inappropriate when substances are systemic, which is interpreted to relate to seed treatment
uses or when granules are placed with seed at the time of drilling. This is because the different
physiology of different crops, including the time from emergence to
flowering
leads to different
translocation and levels of residues in different crops. When assessing the
field
phases of the available
experiments, the most critical issues encountered were cross-contamination from
fields
in the vicinity
and/or due to historical uses in the same
field,
i.e. not resulting from the treated seeds at known
application rates. Only data from studies for which there was sufficient certainty that the residues
observed were resulting from the application being investigated as prescribed in the study design,
were retained for the exposure assessment. The presence or absence of residues measured in control
plots was not part of the decision on retention.
For the exposure assessment, the measured residue values (mg analyte/kg pollen or nectar) were
normalised for the seed loading (mg a.s./seed) resulting in Residue per Unit Dose (RUD) (where the
unit dose is 1 mg a.s./seed) to make the residues independent from the application rate used in the
studies. From one study, sometimes more than one RUD value was calculated and included in the
collation table when more than one trial was conducted within the study. A standalone trial was
defined when one or more of the following factors were different from other trials: type of formulation,
plant species, application rate, test site, period of the trial, pretreatment of the soil and test category
(i.e.
field
and semifield trials, where semifield means bees used to obtain samples were restricted to
foraging on treated plots).
According to EFSA (2013c), in order to refine the exposure, higher tier studies from at least
five
randomly selected locations in the area of use of the substance should be conducted. Therefore, a
minimum of
five
RUD values for pollen and nectar were considered necessary to perform a refined
exposure assessment for each exposure scenario for each use under consideration.
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Where the residue detected in a trial was reported to be lower than the LOQ (but greater than the
limit of detection (LOD)), as a worst-case assumption, the residue was considered to be equal to the
LOQ for the RUD calculation. In the cases that no residues were detected, the residue was considered
to be equal to the LOD for the RUD calculation.
According to EFSA (2013c), in order to perform an exposure assessment, it is preferable to use
measured RUD values for pollen and nectar collected from bees (specific for honeybees, bumblebees
and solitary bees), e.g. using pollen traps attached to honeybee hives or sampling nectar by extracting
the honey stomach from forager bees. Using the RUD values for pollen and nectar directly from the
bees aims to give a better representation of the likely exposure to bees and bee colonies by
accounting for dilution by non-contaminated pollen and nectar. Considering each bee taxon separately
is needed to account for differences in their foraging behaviour that would be expected to mean that
dilution was different between the categories. Alternatively, RUD values for pollen and nectar taken
directly from the plant can be used in the exposure assessment. However, RUD values for plant pollen
and nectar are considered to be an overestimation of the exposure to bees as dilution is not accounted
for. Therefore, if there are a sufficient number of RUD values for bee nectar and/or pollen from
field
trials, only these values were used for the exposure assessment. RUD values for pollen and nectar
from bees taken from semifield studies were considered to be representative of situations where there
was no dilution and therefore were considered together with the RUD values for plant pollen and
nectar. In the cases where RUD values were available on both bee pollen/nectar and plant pollen/
nectar from the same semifield study, the values for bees only were retained. Where less than
five
RUD values for bee pollen/nectar were available, these were combined with the RUD values for plant
pollen/nectar and bee pollen/nectar from semifield, i.e. to obtain sufficient data to perform the
exposure assessment. Figure
1
summarises the process for selecting the RUD values for the refined
exposure assessment for the treated crop scenario.
≥ 5 RUD values
from field trials with specific
bee taxa?
Refine exposure for specific
bee taxa
Yes
RUD values from plants
(fields trials)?
Yes
Combine all available RUD
values*
Yes
≥ 5 RUD values in total?
and/or
RUD values from plants
(semifields trials)?
and/or
RUD values from any
bee species from
semifields trials?
No
Cannot refine exposure for
specific bee taxa
*If RUD values from both plants and bees are available from the same semi-field trial, only retain RUDs from bees to avoid double counting.
Figure 1:
A summary of the selection process for RUD values for the refined exposure assessment for
treated crop scenario
Succeeding crop scenario
A different approach from the treated crop scenario was used for the succeeding crop scenario.
This is because the residues in the succeeding crop scenario are less dependent on the physiology of
the treated crop but are instead mainly driven by the active substance concentration in soil and by the
physiology of the successive crop. For this reason, in the residue trials, residues in topsoil/the following
crop root zone before the planting of succeeding plant species attractive to bees had to have been
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Yes
No
No
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measured. For trials to be retained in the assessment, the residues in soil needed to be equivalent to
or higher than that estimated to occur (Predicted Environmental Concentrations (PEC)) in soil from the
uses being assessed. How such PEC were calculated is outlined in Sections
5.1.1.2
and
5.2.1.2.
Maximum residues in pollen and nectar from the retained trial sites were used to estimate exposure in
the risk characterisation, whilst following the approach for the selection of residues directly from bees
(either in open
field
or semi
field
trials) or via plant sampling as already discussed above for the
treated crop scenario. As the residues trial site selection was based just on measured soil residues, it
was not necessary for the agricultural practice or product formulation type that had been used at any
individual trial to match the uses being assessed. As trials were retained only for sites where measured
residues in soil were equivalent to or higher than the PEC soil, RUD values were not calculated.
In order to refine the exposure, residues from at least
five
trials are needed.
3.3.1.2. Calculation of refined shortcut values
The residue values selected for the refined exposure assessment for the treated crop scenario and
the succeeding crop scenarios were used to calculate new shortcut values (SVs), which represent
active substance intake per day (adults) or per developmental period (larvae). Such calculation was
performed by means of the SHVAL tool (EFSA, 2013a, 2014a). This R-based tool
fits
theoretical
distributions to the available data (e.g. residue levels, consumption rates, sugar concentration in
nectar) and then it runs Monte Carlo simulations with 1,000 iterations (see EFSA, 2014a for details).
The result of such simulation is a distribution of intake values per day (or per developmental period for
larvae). Finally, the 90th percentile of this distribution is selected as the relevant crop/substance-
specific SV. Separate simulations were carried out for each caste of each bee group (honeybee,
bumblebee and solitary bees).
No data were available to refine consumption rates or sugar concentration in nectar. Hence, for
these variables, default values as presented in Appendix J of EFSA (2013c) were used in the
simulations.
3.3.1.3. Estimation of the exposure assessment goal
Treated crop scenario
To consider the higher tier effect studies in the context of the risk assessment, the exposure within
those effects studies were compared to the expected exposure for the GAPs under consideration. For
the treated crop scenario, specific
‘exposure
assessment goals’ were estimated by transforming the
refined shortcut values used in the Tier-2 assessment. To transform the refined shortcut values to an
exposure assessment goal, the shortcut values were multiplied by the seed loading rate (in terms of
mg a.s./seed) for each use.
Figure
2
presents a general overview of the stepwise approach followed for the refinement of
exposure assessment described under Section
3.3.1
for the treated crop scenario.
SV Forag. Ac.
SV Forag. Ch.
SV Nurse
SV Larva
Study 2
Study 3
Study-specific
:
:
App Rate 2
App Rate independent
Combined intake
Residue nectar 3
Residue pollen 3
BB
App Rate 3
RUDn 3
RUDp 3
SV Adult Ac.
SV Adult Ch.
SV Larva
GAP-Specific
Study
n
Residue nectar
n
Residue pollen
n
:
App Rate
n
RUDn
n
RUDp
n
Figure 2:
General overview of the refined exposure assessment for the treated crop scenario
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SB
SV Adult
SV Larva
Forager Ac.
Forager Ch.
Nurse
Larva
Adult Ac.
Adult Ch.
Larva
Adult
Larva
Exposure assessment goals
Residue nectar 2
Residue pollen 2
RUDn 2
RUDp 2
HB
Study 1
Residue nectar 1
Residue pollen 1
:
App Rate 1
RUDn 1
RUDp 1
X
App Rate
GAP
SB
BB
HB
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Succeeding crop scenario
For the succeeding crop scenario, refined SVs were calculated by using actual residue values,
without any further normalisation for the application rate. As such, the refined SVs obtained as
described in Section
3.3.1.2
represent as well the exposure assessment goals.
Figure
3
presents a general overview of the stepwise approach followed for the refinement of
exposure assessment described under Section
3.3.1
for the succeeding crop scenario.
Study 1
Study 2
Study 3
Study-specific
Residue nectar 1
Residue pollen 1
Study
n
Residue nectar
n
Residue pollen
n
Combined intake
BB
SV Adult
SV Larva
BB
Residue nectar 2
Residue pollen 2
SV Adult Ac.
SV Adult Ch.
SV Larva
=
Adult Ac.
Adult Ch.
Larva
Adult
Larva
Figure 3:
General overview of the refined exposure assessment for the succeeding crop scenario
3.3.2.
Dust drift and deposition
According to EFSA (2013c), exposure to dust drift in the
field
margin or in adjacent crops is considered
relevant for seed treatment uses and granular formulations. In addition, for granular uses, the exposure to
dust drift is relevant for the treated crop and for the weed scenario if granules are used after emergence.
Field experiments measuring dust deposition to the horizontal ground outside the treated area at the
time of drilling seeds were available. They were considered reliable when: the quality of the treated
seed (in terms of dust content and active substance in the dust) had been measured, the drilling
machinery used was adequately described, the application rate in terms of mass of active substance per
unit treated area was adequately measured, dust deposition at different distances downwind of the
treated area was adequately determined and wind speed and direction measurements were available.
In many of these experiments, dust drift outside the boundary of the treated
field
was also measured
using vertical gauze netting. These vertical gauze results were not used further, as it was not clear how
the results reported as g a.s./ha were derived and what they represent. Also, agreed methodology is
not available on how to use or interpret such values that may have utility in estimating exposure to
field
margin vegetation or adjacent crops when measured at the individual trial sites.
No studies were available for granules.
3.3.3.
Weeds in the
field
According to EFSA (2013c), exposure to
flowering
weeds within the treated
field
is considered
relevant for uses applied as granules. Some options to refine the exposure to bees from weeds are
recommended by EFSA (2013c) (e.g. considering the proportion of the treated
field
which is covered
by
flowering
weeds, considering measured residues from crops exposed to dust from granular uses).
However, no such data were available for the granular use on amenity turf.
3.3.4.
Residues in water sources
Where the crops being assessed had experimental data where the seed loading rate was measured
and residue levels were adequately determined in sampled guttation
fluid
exuded from the treated
plants, EFSA collated the residues values.
In accordance with the recommendation of EFSA (2013c), measured residues in the guttation
fluids
exuded from the treated plant were considered for refining the assessment related to this route of
exposure relevant for honeybees. EFSA (2013c) specifies that the guttation concentration used in the
risk assessment needs to cover the 90th percentile in guttation
fluid
for the crop of concern
(considering location, growth stage and environmental conditions). For seed treatments and granules
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Exposure assessment goals
Residue nectar 2
Residue pollen 2
SV Forag. Ac.
SV Forag. Ch.
SV Nurse
SV Larva
Forag. Ac.
Forag. Ch.
Nurse
Larva
HB
SB
SB
HB
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buried with seeds, it is proposed to refine the exposure estimate by conducting (at least)
five field
studies and to measure the concentrations in guttation water.
Therefore, following EFSA (2013c), a refinement of the exposure can only be performed if at least
five field
studies are available for the same crop considering all available values added to the table of
residues values. Residues from
five field
studies were not available for any of the crops being assessed
here. However, for consistency with the confirmatory data conclusion for imidacloprid (EFSA, 2016b),
Tier-2 risk assessments have been completed using the highest guttation
fluid
residues from the
available
field
investigations for the crops where these were available.
No exposure refinement was necessary for assessing residues in puddles as using the Tier-1
exposure assessment indicated low risk (see Section
5.1.3.2).
3.4.
3.4.1.
Refinement with higher tier experiments
Building up the lines of evidence
Another approach offered by EFSA (2013c) to refine the risk assessment is to perform higher tier
effect experiments. These experiments are normally carried out under
field
or semifields conditions,
and aim at a higher environmental realism when compared to standard laboratory test.
These experiments present a wide variety of set-ups, designs and investigated endpoints.
Therefore, a weight of evidence (WoE) scheme has been developed to integrate the relevant
information from all available experiments. In order to perform a WoE risk assessment, it is
first
necessary to set the problem formulation and then identify lines of evidence which address the
problem. In the case of honeybee, bumblebee and solitary bee, risk assessments performed in
accordance with EFSA (2013c), the problem formulation is already defined by the SPGs.
Within the WoE, it was considered that each
‘line
of evidence’ corresponds to the whole set of
homogeneous endpoints measured in all available experiments. An endpoint in this context is defined
as a parameter which could be informative of a potential effect caused by an exposure to an active
substance (and its metabolites).
Within each experiment, the endpoint is identified by four dimensions:
The
magnitude
of the observed deviation from the control. For endpoints measured as time
series, the extremes of such deviation were recorded in both directions, together with a mean
deviation. In case of such endpoints like forager mortality, this dimension should also account for
the duration of a consistent deviation (e.g. increase of X% in forager mortality observed for Y
consecutive days). Deviations in both directions were classified as: no deviation, negligible, small,
medium and large deviation from the control. For this classification, the scales presented in
Table
3
were used. These scales were adapted from Appendix B of EFSA (2013c) (Protection
goals), except the scale for homing success, where the categories were arbitrarily chosen. An
example for using these scales: if the average colony strength in a honeybee study at an
observation time was 6% less in the treated group compared to the control, this was classified as
a negative negligible deviation. If, at another observation day, the colony strength in the treated
group was 16% more than in the control, this was classified as a positive medium deviation. It
has to be noted that pending on the availability of the data on the relevant endpoints (i.e.
reported details), the deviation from the control was either calculated or only estimated (e.g.
when only graphical presentation was available for the endpoint).
Scale of deviation from the control used for the weight of evidence exercise
All endpoints except mortality Forager mortality and mortality
Homing success
and homing success
in front of the hive
0%
>
0% to
<
7%
7% to
<
15%
15% to
<
35%
35%
0%
See examples in Table B1 of
Appendix B of EFSA (2013c)
See examples in Table B1 of
Appendix B of EFSA (2013c)
See examples in Table B1 of
Appendix B of EFSA (2013c)
See examples in Table B1 of
Appendix B of EFSA (2013c)
0%
>
0% to
<
10%
10% to
<
20%
20% to
<
50%
50%
Table 3:
Deviation class
No deviation
Negligible
Small
Medium
Large
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The
reliability
of the endpoint: this was established on the basis of the appraisal exercise
(EFSA, 2018a) and giving a score to each endpoint from 0 (not reliable) to 3 (fully reliable).
The reliability was used to weigh the results obtained in different experiments, and to
estimate, together with the level of consistency of the results, the level of certainty associated
with the line of evidence.
The
level of exposure:
this information is necessary to check where the level of exposure in
the experiment stands compared to the exposure assessment goal(s). Furthermore, this
information can be used to check whether a sort of exposure–response relationship can be
identified. For oral exposure to residues in pollen and nectar, residue intake (RI) values were
calculated for each caste of bee using the mean residue value on nectar and/or pollen
obtained in the effects study. A sugar content of 15% was assumed for nectar for honeybees
and bumblebees (EFSA, 2013c). In case of colony feeder studies, the sugar content of the
sugar solution specified in the study was used. If this was not available, then a sugar content
of 50% was assumed. The daily consumption values, for pollen and nectar, for each bee caste
were taken from EFSA (2013c). Where a range of consumption values were available, a range
of RI values was obtained.
The length of exposure:
this is defined as the time period in which there could have been
exposure to residues of the active substance. It is noted, that the
‘length
of exposure’ referred
to in this conclusion does not account for the subsequent consumption of food stores within
colonies/nests. In
field
and semifield studies, this corresponds to the time period the bees
could be exposed to the crop during
flowering.
For colony-feeder studies, the length of
exposure is defined by the time period during which the spiked sugar solution or pollen was
given to the bees. This information is needed to check whether the length of exposure is
realistic to that expected for the GAPs under consideration.
In order to visually illustrate these four dimensions of the endpoints and in order to help the
interpretation of a
‘line
of evidence’, graphical representations were prepared. A graphical
representation of a
‘dummy’
example (invented example for illustrative purpose) is included in Figure
4
with an explanation of each element of the
figure.
Figure 4:
Lines of evidence for a
‘dummy’
example: colony strengths of honeybees
The
figures
include the following information:
Each row in the
figure
represents a higher tier effects study. The numbers given on the left
hand side are the reference identification codes of the individual studies which can be traced
back to the reliability assessment provided in the Technical Report on evaluation of data and
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related Appendices from D to O (EFSA, 2018a). In Appendix
G
of this conclusion, an overview
is given of all reference identification codes of the individual studies cited in the conclusion. A
summary of the reference identification codes according to the different assessment streams
identified during the evaluation of the data is summarised below. Note that several studies
investigated a number of exposure levels, and therefore, these studies may be listed more
than once (e.g. the highest exposure level that caused no or small deviation from the control
and the lowest exposure level with apparent deviation from the control).
Assessment stream
All* (with interaction)
All
+
(no interaction)
Clothianidin
Imidacloprid
Thiamethoxam
Clothianidin * Imidacloprid (with interaction)
Clothianidin
+
Imidacloprid (no interaction)
Clothianidin * Thiamethoxam (with interaction)
Clothianidin
+
Thiamethoxam (no interaction)
Imidacloprid * Thiamethoxam (with interaction)
Imidacloprid
+
Thiamethoxam (no interaction)
Not substance-specific
Reference identification code
All*
All+
C.
I.
T.
C*I.
C+I.
C*T.
C+T.
I*T.
I+T.
NS
The left hand panel relates to the biological observations whilst the centre and right hand
panels relate to exposure.
For each experiment, the black solid horizontal line represents the range of the observed
deviations from the control (i.e. both negative and positive deviations). The magnitude of
these deviations is categorised as negligible, small, medium or large. When this is not
indicated, the endpoint was measured only once during the study or it was measured multiple
times, but insufficient details were reported to evaluate the variability of the endpoint in time
(e.g. only averages for the entire study duration were reported)
The position of the blue circle gives an estimation of the overall deviation (mean) from the
control for the entire duration of the study or during the year of use for those studies which
extend over the winter.
The size of the blue circle is an indication of the reliability score of the specific endpoint. A
‘fully
reliable’ endpoint gives a large circle, an endpoint which was
‘reliable
with minor
restrictions’ gives a medium-sized circle and an endpoint which was
‘reliable
with major
restrictions’ gives a small circle.
For transparency, the experiments giving endpoints which were assessed as
‘not
reliable’ have
also been included in the
figure,
but the overall deviation is represented by an X.
To help interpret the
figure,
vertical dotted lines have been added to indicate the mean overall
deviation, the mean negative deviation (if it could be calculated) and the mean positive
deviation (if it could be calculated) across all of the reliable experiments (weighted for the
reliability score of the endpoint).
In the centre panel of the
figure,
a representation of the estimated level of exposure achieved
in the experiment is given for each bee caste (i.e. ng a.s./bee per day for adult bees and ng
a.s./larvae per development period for larvae). When this is not indicated, reliable information
on the exposure level achieved in the study was not available.
The vertical lines in the centre panel of the
figure
represent the exposure assessment goal, for
each bee caste, for the GAP under consideration (see Section
3.3.1.3).
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On the right hand side of the
figure,
the length of exposure (in days) in the experiment is
represented by the red bars. The vertical purple column is the expected range of the
flowering
period for the crop under consideration
8
.
In order to conclude that the observed deviations are actual representations of a true effect caused
by the exposure to the active substance (and its metabolites), several aspects were considered for
each line of evidence.
The presence/absence of a general trend, giving more weight to results with higher reliability.
The level of consistency among experiments (similar results, exposure–response relationship
etc.)
The level of precision offered by the available experiments (width of the effect size ranges)
In principle, each line of evidence should provide a piece of information characterised by a certain
degree of strength (consistency), precision (degree of variability) and reliability.
Furthermore, in order to use the available information to conclude on the risk assessment, it is
pivotal to check the level of the exposure in the effect experiments relative to the specific exposure
assessment goals and to check whether the length of potential exposure in the effect study is within
the realistic
flowering
period for the crop (or succeeding crop) under consideration.
3.4.2.
Integrating the lines of evidence
In accordance to EFSA (2013c) and the newly available EFSA guidance document on the WoE
(EFSA Scientific Committee, 2017), the overall process should account for the relevance of the single
lines of evidence, before performing any integration.
In the scheme, there are endpoints (lines of evidence) that are directly linked to the protection
goals and have the potential to provide a straightforward response to the main issue reported in the
problem formulation (see Section
3.1).
For this reason, they are considered to be the higher class of
endpoints in terms of relevance (Class 1). These are colony/population size (valid for all species);
forager mortality (honeybees only) and all endpoints related to the reproductive output (bumblebees
and solitary bees)
Other endpoints have a rather clear conceptual link with one of the previous two (e.g. brood/
cocoon production can clearly influence colony/population strength), even if this link cannot be
explicitly quantified. These endpoints (lines of evidence) belong to Class 2 for relevance.
Other endpoints, on the contrary, may play a role in the colony/population health, but such link is
not immediate in conceptual term (e.g. average duration of foraging trips). These endpoints (lines of
evidence) belong to Class 3.
Finally, there are endpoints that do not offer any explicit link with the protection goals (e.g.
measurement of enzymatic levels at subindividual level). These endpoints are considered not relevant
(Class 4) for addressing the protection goal according to EFSA (2013c).
A proper summary of all endpoints considered in this assessment and a detailed description of their
relationship with the SPGs are available in Appendix
B.
A less detailed summary is reported in Table
4.
8
A crop-specific time window for a reasonable
flowering
period was estimating by considering: (i) feedback from Member
States; (ii) assumptions within the FOCUS scenarios; (iii) collating information reported in the present data set. For winter
oilseed rape, a reasonable
flowering
period was estimated to last between 10 and 42 days. The selected maximum is longer
than the assumptions contained in the FOCUS scenarios (maximum 28 days). During the expert meetings, some experts
pointed out that 6 weeks of
flowering
may happen, but only in exceptional years. Nevertheless, within the present data set,
flowering
between 35 and 43 days was recorded in several experiments carried out in France, the UK, Germany and Hungary.
Similarly, data were collected for spring oilseed rape and maize. The succeeding crop scenario is not represented by any
specific crop. Therefore, on the basis of all of the available information on the
flowering
period of agricultural crops, it was
decided that a reasonable
flowering
period would range from 5 to 42 days.
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Table 4:
Bee group
Honeybees
A summary of the endpoint types and the related relevance class assigned within the
scope of the present risk assessment
Relevance class
1
Family of endpoint
Colony strength
Forager mortality
Overwintering assessment
2
General mortality of individuals
Brood production
Homing success
(a)
Behavioural endpoints
Comb building
Weight of the hive
Disease
Food storage
4
Queen
Behaviour influencing exposure
Subindividual mass
Suborganism endpoints
3
Bumblebees
1
2
3
Thermoregulation capacity
Reproductive output
Colony strength
Indirect reproduction
Behaviour
Weight of the nest (colony)
Food storage
General mortality
Individual mass
Homing success
Solitary bees
4
1
2
3
Behaviour influencing exposure
Reproductive output
(b)
Indirect reproductive output
Behaviour
General mortality
(a): For the purposes of this conclusion, the endpoint
‘homing
success’ is defined as the proportion of bees returning to the hive/
colony after they were captured and subsequently released at a distance from the hive/colony.
(b): The number of solitary bee offspring emerging after winter was considered to represent the accumulation of several
preceding endpoints related to reproductive success (e.g. number of completed nests, tubes with brood, cocoon
production). Therefore, the weight of evidence focussed primarily on the number of offspring emerging after the winter.
In order to account for this hierarchical structure within the current risk assessment scheme, a
stepwise procedure was followed.
As already mentioned, the
first
step was focussing on endpoints belonging to Class 1. If the
available data are sufficient to provide a conclusive answer to the main risk assessment question, the
assessment could stop. If, on the contrary, the available information is not sufficient and/or
appropriate to provide a conclusive answer, the WoE will be extended to other levels of relevance, in
order to get a more comprehensive picture of the available data.
If the evidence in the
first
two levels of relevance (Classes 1 and 2) is not sufficient/appropriate to reach a
conclusion, it is considered unlikely that less relevant endpoints will help achieving a conclusive assessment.
4.
4.1.
Outcome of the risk assessment: toxicity endpoints
Standard endpoints
In the data set considered, there were several laboratory studies available for assessing the effects
of imidacloprid, or formulated products containing imidacloprid, on honeybees, bumblebees and
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solitary bees. Following the selection procedure given in Section
3.2.1,
it was considered whether any
of the newly available data should replace the previously EU agreed endpoints (EFSA, 2016a,b) and be
used for the Tier-1 and Tier-2 risk assessments.
Three acute contact toxicity endpoints for honeybees performed with the technical active substance
were available and resulted in lethal dose (LD
50
) values which were slightly lower than the previously
agreed endpoint. Furthermore, there were two additional studies performed with formulated products
containing imidacloprid. The lowest of the available endpoints, from study All+.1084 with the technical
active substance, was selected for risk assessment (LD
50
=
0.0251
lg/bee;
3.2 times lower than the
previously agreed EU endpoint). In this experiment, the LD
50
was only reported for an observation
period of 120 h, which is longer than the time window recommended in the OECD 214. Nevertheless,
both validity criteria reported in OECD 214 were considered respected: the mortality in the control was
still 5.8% after 120 h, and the toxicity of other tested substances (i.e.
k-cyhalothrin,
deltamethrin,
esfenvalerate) was in the expected range, providing an indication that sensitivity of the system was
appropriate, in lack of a formal positive control. Therefore, the LD
50
was considered suitable for
being used in the risk assessment. This issue was discussed and agreed during the expert meeting
(October 2017).
There were four reliable endpoints investigating the acute oral toxicity to honeybees performed with
the technical active substance and one endpoint was available from a study performed with a
formulated product. The endpoints from these studies did not indicate a higher toxicity than the
previously agreed acute oral honeybee endpoint, and therefore, this value was retained for risk
assessment. No reliable laboratory data were available to derive a chronic oral lethal dietary dose
(LDD
50
) or a no observed effect level (NOEL) value for larval development of honeybees. Therefore, the
previously EU agreed endpoints were retained for risk assessments. No NOEL value could be derived
from the available data for the development of hypopharyngeal glands (HPG) in honeybees (such
endpoint is neither available from previous assessments). It is noted, however, that an approximate
lowest observed effect level (LOEL) of 0.243 ng/bee per 10 days was estimated from one of the studies
(I.545). No data were available to assess whether the use of imidacloprid results in accumulative
effects in honeybees.
There was an acute contact toxicity endpoint (LD
50
value) for bumblebees performed with the
technical active substance and another one performed with a formulated product. The endpoints from
these studies did not indicate a higher toxicity than the previously agreed acute contact bumblebee
endpoint, and therefore, this value was retained for risk assessment. There was a single study giving
an acute oral LD
50
value for bumblebees for the technical active substance. Again, this endpoint did
not indicate a higher toxicity than the previously agreed acute oral bumblebee endpoint, and
therefore, this value was retained for risk assessment. No reliable laboratory data were available to
derive a chronic oral LDD
50
or a NOEL value for larval development of bumblebees. These values were
neither available from previous assessments.
There were no reliable and relevant toxicity data available for solitary bees nor were any data
available from previous assessments.
In accordance with EFSA (EFSA, 2013c), where data are missing, surrogate endpoints can be
calculated using toxicity data for honeybees divided by 10. Surrogate endpoints were therefore
calculated for the acute contact and oral toxicity to solitary bees and for the chronic oral toxicity to
bumblebees and solitary bees. As the available honeybee larvae endpoint had some shortcomings, it
was previously concluded that this endpoint should only be considered as
‘provisional’
(EFSA, 2016b).
Therefore, it was not considered appropriate to use this endpoint to derive surrogate endpoints for
bumblebee and solitary bee larvae.
This selection procedure resulted in the change of the surrogate acute contact endpoint for solitary
bees. As a consequence of no change in other honeybee endpoints, the other surrogate endpoints for
solitary bees and the surrogate adult chronic endpoint for bumblebee are the same as the previously
EU agreed surrogate endpoints.
On the basis of the above considerations, Table
5
summarises the toxicity endpoints selected for
the Tier-1 and Tier-2 risk assessment.
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Table 5:
Toxicity endpoints selected for lower tier risk assessments
Endpoint
LD
50
(lg a.s./bee)
LD
50
(lg a.s./bee)
10-day LDD
50
(lg a.s./bee per day)
NOEL (lg a.s./larva per
developmental period)
Honeybee
0.0251 (120 h)
0.0037 (48 h)
>
0.00282
(a)
0.00528
as provisional
(b)
Bumblebee
0.218 (96 h)
0.038 (96 h)
>
0.000282
(c)
No endpoint available
or extrapolated
Solitary bee
0.00251
(c)
0.00037
(c)
>
0.000282
(c)
No endpoint available
or extrapolated
Risk
assessment
type
Acute contact
Acute oral
Chronic oral
Larval
LD
50
: lethal dose, median; LDD
50
: lethal dietary dose, median;
(a): Endpoint set at the highest concentration tested.
(b): Endpoint determined at 7 days but only 3-day exposure during the study. Endpoint is the highest dose tested. Endpoint is
based on nominal amount of food offered to the larvae.
(c): Extrapolated from the endpoint for honeybee by using a factor of 10.
Note: from the previously EU agreed endpoints, only the acute contact endpoint for honeybees and the acute contact endpoint
for solitary bees were changed.
4.2.
Additional sublethal laboratory data
Several laboratory experiments testing sublethal effects of imidacloprid on bees were available in
the data set. The endpoints investigated encompassed a wide variety of sublethal effects. The effects
investigated in the available data set are listed in Table
6.
Table 6:
Organism
Apis cerana
Apis mellifera
Sublethal endpoints for honeybees, bumblebees and solitary bees investigated in
laboratory studies of the available data set for imidacloprid
Effect
Proboscis extension reflex (PER)
learning capacity
AChE activity
Kenyon cell depolarisation
Expression of genes
Deformed wing virus replication
Apoptosis of neurons
Hemolymph collection
Total haemocyte count
Encapsulation response
Antimicrobial activity of the haemolymph
Body weight
Food attractiveness (food preference)
Intoxication symptoms
Larvae development
Locomotion activity
Number of Nosema spores
Parameter for
flight
capacity
Parameters for individual immunity
Parameters for social immunity
Proboscis extension reflex (PER)
learning capacity
Protein content of bee head
Sperm viability
Sucrose consumption
Time spent for feeding (potential feeding)
Time spent for interacting
Wing length
Accumulation in the brain
Cytotoxicity of neurons
Mitochondrial depolarisation
Food attractiveness
Locomotion activity
Sucrose consumption
Bombus terrestris
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Organism
Melipona quadrifasciata
Effect
Locomotion activity
Parameter for
flight
capacity
Respiration
Larvae development
Larvae development
Osmia lignaria
Megachile rotundata
AChE: acetylcholinesterase.
In addition, an endpoint from a Proboscis Extension Reflex (PER) tests was available for 5-OH-
Imidacloprid on honeybees.
For most of the cases, only a single endpoint was available. However, a number of the available
experiments focussed on the so-called PER, which investigated how exposure to imidacloprid impairs
the responsiveness to a stimulus and affect memory performances. This response was studied with
different test design, such as acute contact, acute oral or chronic oral. Moreover, some of these
experiments were conducted with
Apis mellifera,
while others with
Apis cerana.
In a number of those
experiments, a no observed effect dose (NOED) (acute) or a no observed effect concentration (NOEC)
(chronic) value could be established, while in others, no effects (i.e. statistically different response
from the control) was seen at the tested doses/concentrations. The endpoints of the available acute
and chronic oral tests were rather inconsistent. However, from the results of the acute contact tests, it
may be concluded that the NOED would be between 0.5 and 1.25 ng/bee.
Another sublethal effect that was studied in several experiments was impairment of locomotion.
Again this response was studied with different test designs, such as acute contact, acute oral,
subacute oral or chronic oral. No consistent response was seen between these studies.
In several studies, it was discussed that the investigated sublethal effects at individual or
subindividual level may result in a colony/population level effect. It is acknowledged that an evident
linkage (direct or indirect) between certain sublethal endpoints and colony/population level effects
might exist. However, no appropriate information was available to establish or further describe these
links. Therefore, these endpoints could not be linked to the protection goal and they were not
considered further in the risk assessments.
5.
5.1.
5.1.1.
Outcome of the risk assessment
Risk assessments for seed treatment products
Risk via systemic translocation in plants
residues in nectar and pollen
(treated crop scenario and succeeding crop scenario)
5.1.1.1. Tier-1 risk assessment
The Tier-1 risk assessment for the representative GAPs were performed using the EFSA’s BeeTool
(v.3.) (Appendix Y of EFSA (2013c)) for honeybees and bumblebees, where suitable toxicity data were
available. A screening Tier-1 assessment was carried out for solitary bees and for the chronic adult
assessment for bumblebees as only surrogate endpoints were available. Since no toxicity data was
available for HPG development or for the larvae toxicity for non-Apis bees, no assessment was
performed for these scenarios. For potato, the application rate expressed as mass/tuber was not
available. The outcome of these calculations is summarised in Table
7.
High risk or low risk not
demonstrated is indicated for all cases since one or more combinations (categories of acute, chronic
and larva combined with the treated crop scenario and following crop scenarios) indicated a high risk.
The detailed results are included in Appendix
C.
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Table 7:
Summary of the outcome of Tier-1 and screening Tier-1 risk assessment
Honeybee
Bumblebee
‘Low’
application
rate
High risk
‘High’
application
rate
High risk
Solitary bee
‘Low’
application
rate
‘High’
application
rate
Use
‘Low’
application
rate
‘High’
application
rate
High risk
High risk
Spring and winter
cereals, cotton,
endive, lettuce,
brassicas (flowering,
head, leafy), maize,
potato, spring and
winter rape, sugar
and fodder beet
Low risk not Low risk not
demonstrated demonstrated
It is noted that endive, lettuce, brassicas, sugar and fodder beet may be harvested before they
flower.
In that case, the treated crop scenario is not relevant for those crops (low risk for that
scenario). Nevertheless, the following crop scenario indicated a high risk for those crops. For the uses
when crops are transplanted and grown in permanent greenhouses (but not transplanted in the
field
or non-permanent greenhouse), none of the scenarios are relevant (low risk for the treated crop and
for the following crop scenario). It is also noted that for potato only, the following crop scenario was
considered as no calculations were possible for the treated crop scenario.
As presented above, the Tier-1 dietary risk assessment for the treated crop and succeeding crop
scenario for all seed treatment uses under consideration indicated a high risk to honeybees and
bumblebees. By the screening assessment for solitary bees, a low risk was not demonstrated. No risk
assessment could be performed for honeybee HPG development or bumblebee and solitary bee larvae.
It is noted that for endive, lettuce and brassicas, a low risk could be concluded for uses when the
treated crop is grown continuously (including
flowering)
in permanent greenhouse.
5.1.1.2. Exposure assessment for the treated and succeeding crop scenarios
Treated crop scenario
Several reliable studies giving measured residue values in nectar and pollen originating from crops
grown from seeds treated with imidacloprid were available. For the seed treatment uses under
consideration, sufficient relevant data were available for oilseed rape only.
According to EFSA (2013c) in order to perform an exposure assessment, it is preferable to have
measured residues in pollen and nectar collected from bees. Taking the pollen and nectar directly from
the bees aims to give a better representation of the likely exposure to bees and bee colonies by
accounting for dilution by non-contaminated pollen and nectar. As regards pollen, residues from pollen
traps attached to the hive entrance are also considered. Alternatively, residues of pollen and nectar
taken directly from the plant can be used in the exposure assessment. However, residues in plant
pollen and nectar are considered to be an overestimation of the exposure to bees as dilution is not
accounted for. Residue data in pollen and nectar from bees taken from semifield studies were
considered to be representative of situations where there was no dilution and therefore were
combined with the residues from
field
studies. In case of nectar, the available residue values from bees
were combined with residue values taken directly from the plant, since a sufficient number of
measured residue values taken from the bees was not available. As regards pollen, all the available
values originated either from bees or from pollen traps. In the cases where data were available from
both bee pollen and from pollen trap, the values from bees only were taken. The residue values from
bees (including when pollen trap was used) were all from pollen and nectar collected from honeybees.
Therefore, exposure refinements were performed only for honeybees. The available data set included
two RUD values for nectar and two RUD values for pollen from studies from winter oilseed rape. As
regards spring oilseed rape, four RUD values for nectar and six RUD values for pollen were available.
The separate data for winter and spring oilseed rape were considered insufficient for separate risk
assessments for winter and spring oilseed rape according to EFSA (2013c). Therefore, the two data
sets were combined resulting in a total of six RUD values for nectar and eight RUD values for pollen.
The actual residue values used for establishing the exposure assessment goals are reported in
Appendix
E.
It is acknowledged that it is likely that RUD values for spring oilseed rape are conservative
relative to those for winter oilseed rape. However, the RUD values for winter oilseed rape do not
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necessarily cover the residue levels for spring oilseed rape as from the available data it appeared that
residues in spring oilseed rape were higher. Therefore, the refined risk assessment was performed only
for winter oilseed rape. It is noted that in several cases (four of the six RUD values for nectar and six
of the eight RUD values for pollen), insufficient information was available to work out the application
rate used in the study in terms of seed loading (mg/seed). However, assuming a thousand grain
weight (TGW), it was possible. For these cases, a TGW of 5 g was considered.
The measured residue values were normalised for the seed loading (mg a.s./seed) to give RUD
values (mg a.s./kg pollen or mg a.s./kg nectar).
Such RUD values were log-transformed before being used as input for the EFSA SHVAL tool (EFSA,
2014a). A 90th percentile SV for exposure, in terms of RI, is given as output of this tool. Simulations
were run for each bee species and each caste. Tier-1 data for pollen and nectar consumption and
sugar content in nectar were assumed. To transform the refined shortcut values to an exposure
assessment goal, the shortcut values are multiplied by the seed loading rate (in terms of mg a.s./kg
seed) for each use listed in the GAP (Appendix
A).
The resulting refined shortcut values and exposure
assessment goals for the GAP for winter oilseed rape are presented in Table
8.
Table 8:
Refined shortcut values and exposure assessment goals for honeybees for winter oilseed
rape applied as seed treatment
Refined shortcut value
(lg/bee per day or
lg/larva
per developmental period)
Acute forager
Chronic forager
Nurse
Larva
0.21
0.16
0.09
0.12
Exposure assessment goal for 0.01 mg
a.s./seed (ng/bee per day or ng/larva
per developmental period)
2.1
1.6
0.9
1.2
Succeeding crop scenario
As imidacloprid has the potential to accumulate in soil from use over successive years, this has to be
accounted for in the succeeding crop assessment. This potential for accumulation was accounted for by
calculating plateau PEC in soil following FOCUS (1997, 2006). Accordingly, the longest
field
dissipation
study single
first-order
DT
50
of 288 days (EFSA, 2008) was used to calculate an accumulated
concentration in soil assuming a soil mixing (tillage) depth of 20 cm and soil bulk density of 1.5 g/cm
3
. To
cover the representative uses under assessment, annual soil application rates of 175, 139.6 and 34.5 g/ha
were used for the calculations. The value of 175 g/ha is from continuous cropping of cotton; 139.6 g/ha
((180
+
3
9
126)/4) represents a rotation of the use on potatoes (highest dose rate 180 g/ha) followed
by 3 years of use on winter cereals (highest dose rate 126 g/ha). The value of 34.5 g/ha ((9
+
3
9
43)/4)
represents a rotation of the use on oilseed rape (lowest dose rate 9 g/ha) followed by 3 years of use on
winter cereals (lowest dose rate 43 g/ha). Accumulated soil exposure concentrations from the other uses
assessed would fall between the lower two of these three annual application rates. The accumulated PECs
in soil resulting from the assumptions outlined above are 0.0415 mg/kg, 0.033 mg/kg and 0.008 mg/kg,
respectively.
From the seed treatment uses under consideration, relevant data for the exposure assessment for
the succeeding crop were available when the succeeding crops were phacelia, winter oilseed rape,
mustard (semifield study designs) and maize (field studies, pollen collected from plants).
In these studies, the potential exposure of bees to residues in succeeding crops was investigated
based on two different approaches. In a series of studies concentrations of imidacloprid, 5-OH-
imidacloprid and imidacloprid olefin in nectar and pollen from these crops/plants attractive for bees
were measured under conditions of
‘forced’
soil residues, i.e. succeeding crops grown on soils treated
over their entire area with imidacloprid to obtain a theoretical plateau concentration of imidacloprid in
soil. In other
field
studies, the untreated succeeding crops were sown in soil with a history of several
years of use of imidacloprid, and thus exposed to so called
‘naturally
aged’ residues in the soil, the
residues analysed were the same as those in the forced studies. Apart from one new
‘forced’
study,
the data set available for this conclusion was identical to the confirmatory data package evaluated in
the EFSA conclusion in 2016 (EFSA, 2016b). In the previous peer review assessment, it was concluded
(Pesticides Peer Review Meeting 145) that the
‘forced
exposure’ is less representative of the exposure
situation under
field
conditions, where the imidacloprid residues in soil had already undergone natural
ageing processes, that make them potentially less available for plant uptake. Therefore, studies with
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‘forced’
soil residues of imidacloprid in soil were not considered further and the highest residue values
measured for pollen and nectar from the
‘natural
aged’ soil residue studies were used to refine the risk
assessment. This approach was also used in this conclusion.
In the
‘natural
aged’ soil residue experiments, where the highest residue values for pollen (2.5
lg
imidacloprid/kg maize, 1.5
lg
imidacloprid/kg phacelia, 1.3
lg
imidacloprid/kg winter oilseed rape) and
nectar (3.5
lg
imidacloprid/kg phacelia, 0.7
lg
imidacloprid/kg winter oilseed rape) were detected, the
measured soil residues were from 0.035 to 0.059 mg/kg, higher than the calculated accumulated soil
PEC of 0.033 mg/kg or 0.008 mg/kg for the potato and the oilseed rape seed treatment uses,
respectively. These soil residues were comparable to or higher than the calculated accumulated PEC of
0.0415 mg/kg for the cotton seed treatment use (see details of these PEC calculations above). These
PECplateau values cover all the GAPs considered in this conclusion. It is noted that soil residues are
independent of the GAPs for the primary crop(s) and can be used for any GAP, provided that the crop
rotation and the ageing processes are leading to soil residue levels comparable to the calculated
PECplateau values. In these
‘natural
aged’ experiments, 5-OH-imidacloprid residues were always
<
1
lg/kg
(LOQ) in pollen (phacelia) and
<
0.3
lg/kg
(LOD) in nectar. Imidacloprid olefin residues
were always
<
0.3
lg/kg
(LOD) in both pollen and nectar.
The above residue values of imidacloprid in pollen and nectar for the succeeding crop were inserted
in the EFSA SHVAL tool (EFSA, 2014a). As the refined shortcut values are independent of the GAP,
they also represent the exposure assessment goal for the succeeding crop scenario. The calculated
values are presented in Table
9.
It is noted that these values are in line with the calculated SVs for the
confirmatory data for imidacloprid (EFSA, 2016b).
Table 9:
Refined shortcut values and exposure assessment goals for honeybees and bumblebees
for the succeeding crop scenario
Refined Shortcut value
(lg/bee per day or
lg/larva
per
developmental period)
Honeybee forager acute
Honeybee forager chronic
Honeybee nurse
Honeybee larva
Bumblebee adult acute
Bumblebee adult chronic
Bumblebee larva
0.00244
0.00189
0.00101
0.00139
0.00312
0.00269
0.00065
Exposure assessment goal
(ng/bee per day or ng/larva per
developmental period)
2.44
1.89
1.01
1.39
3.12
2.69
6.5
(a)
(a): The shortcut value for bumblebee larva refers only to 1 day. In order to cover the entire developmental period by the
exposure assessment goal, the value was multiplied by 10, as recommended by EFSA (2013c)
5.1.1.3. Tier-2 risk assessment
Treated crop scenario
As explained above in 5.1.1.2, sufficient data on residues were available only for the representative
GAP for winter oilseed rape. Tier-2 risk assessments performed by using the EFSA’s BeeTool (v.3.)
(Appendix Y of EFSA (2013c)) for honeybees. In these calculations, the Tier-1 shortcut values were
replaced by the refined Tier-2 shortcut values. The outcomes of these calculations are summarised in
Table
10.
Low risk could not be demonstrated for honeybees for the winter oilseed rape use.
Table 10:
Category
Acute adult
Chronic adult
Larva
ETR: Exposure toxicity ratio.
Tier-2 risk assessment for honeybees for winter oilseed rape applied as seed treatments
Refined shortcut value
(lg/bee per day or
lg/larva
per
developmental period)
0.21
0.16
0.12
ETR for the seed
treatment rate of
0.01 mg a.s./seed
0.568
0.567
0.227
Trigger
0.2
0.03
0.2
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Succeeding crop scenario
The Tier-2 risk assessments for the succeeding crop scenarios are reported in EFSA (2016b). Those
risk assessments indicated a high risk or a high risk could not be excluded for honeybees, bumblebees
and solitary bees. The PECplateau for the GAPs considered in this conclusion are lower or comparable
to the measured soil residues considered in succeeding crop trials in EFSA (2016b). Therefore, the risk
assessments presented in EFSA (2016b) cover the risk resulting from the GAPs of this conclusion.
5.1.1.4. Tier-3 risk assessment (weight of evidence)
As discussed in Section
3.4,
a WoE approach was developed to utilise the information from the
diverse range of higher tier effect experiments that were available.
The WoE risk assessment could only be performed for the GAPs for which an exposure assessment
goal was calculated (Section
5.1.1.2).
For the use of imidacloprid as a seed treatment, exposure
assessment goals could be determined only for the treated crop scenario for winter oilseed rape
foraged by honeybees. In addition, an exposure assessment goal has also been determined for the
succeeding crop scenario for all uses of imidacloprid under consideration. These assessments are
relevant for all bee species. Consequently, the WoE approach was applied to these combinations only.
As previously discussed, the WoE exercise has two fundamental steps:
firstly,
the identification/
consideration of the lines of evidence and secondly, the integration of the lines of evidence.
5.1.1.4.1. Weight of evidence higher tier risk assessment for honeybees
There was a number of higher tier endpoints (dominated by colony feeder type studies) which had
been assessed and integrated in a WoE exercise. First, each line of evidence (i.e. Class 1 and Class 2
endpoints) were assessed and concluded for the treated crop scenario for winter oilseed rape and for
the succeeding crop scenario. The graphical representations with the interpretation of each line of
evidence specific to these two situations are presented in Appendix
F.
The second step of the WoE exercise is the integration of the lines of evidence. Tables
11
and
12
present the integration of the lines of evidence for the treated crop scenario for winter oilseed rape
and for the succeeding crop scenario, respectively.
In addition, below Table
11,
there is a brief consideration for the use on spring oilseed rape
(treated crop scenario).
It is noted that no reliable data were available for forager mortality. Therefore, no consideration for
this Class 1 endpoint is included in the integrations of the lines of evidence presented below.
Treated crop scenario
Table 11:
The integration of the lines of evidence for honeybees for the treated crop scenario for
winter oilseed rape
Refer to Appendix
F,
Section 1.1.1
A relatively high number of experiments with a realistic or severe exposure regime
indicated an overall negligible deviation from the control, while a fewer experiments
with suitable exposure indicated a larger than negligible negative deviation from the
control. Also, there was a considerable biological variability within and between the
endpoints and the endpoints indicating negligible deviation were, in general, much
more reliable
Overall, this indicated a
moderate evidence for negligible effect
Overwintering
assessment
Refer to Appendix
F,
Section 1.2.1
When the deviations from the controls of the effects on honeybee populations after
overwintering in combination with the exposure estimations of the relevant
experiments were considered, it was concluded that the available data set was rather
contradictory. Nevertheless, more weight was attributed to the available evidence
indicating more than negligible negative effects
However, some experiments that indicated negative effects had considerably longer
exposure duration than the realistic
flowering
period of oilseed rape. When the
severity of these endpoints was taken into consideration, the available evidences
become balanced and no clear trend was apparent
Overall,
this line of evidence was inconclusive
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Class 2 endpoints
Mortality in front of the
hive
Refer to Appendix
F,
Section 1.3.1
Relatively low number of reliable endpoints was available. All of these endpoints had
low reliability, but the biological variability of them was low
Only one experiment with appropriate exposure and indicating negligible effect was
available, while in two experiments with mild exposure regimes temporal, larger than
negligible negative deviations were indicated
Overall, this indicated a
weak evidence for larger than negligible effect
Brood abundance
Refer to Appendix
F,
Section 1.4.1
There was a considerable biological variability within and between the endpoints and
all the endpoints had low reliability
A slightly higher number of experiments with realistic or severe exposure regime
indicated an overall negligible (or even positive) deviation from the control, while
slightly fewer experiments with realistic or mild exposure regime indicated more than
negligible negative deviation from the control
Overall, this indicated a
weak evidence for negligible effect
Homing success
Refer to Appendix
F,
Section 1.5.1
Relatively low number of endpoints was available. All were classified as reliable with
major restrictions and in all but one case, the estimated exposure levels exceed the
exposure assessment goal for winter oilseed rape. One of these endpoints indicated a
negligible (negative) deviation from the control. The single endpoint that had an
estimated exposure level slightly below, but close to the exposure assessment goal
indicated no deviation from the control
Overall, this indicated a
weak evidence for negligible effect
Integration of lines of
Class 1 endpoints, overall, suggest a moderate evidence for negligible effects. Class 2
evidence for winter
endpoints indicated only weak evidence; overall for a negligible effect. However, data
oilseed rape
also suggested that some temporal negative effects cannot be excluded
Quantification of the effects
Uncertainty analysis
in line with EFSA
(2013c)
(À potential to make the
true risk lower
+
potential to make the
true risk higher)
Many of the available endpoints were assessed to be reliable with major
restrictions; therefore, the overall reliability of the WoE is limited
The reasons for the reliability assessment categorisation differed between the
studies
The consistency in case of many lines of evidence is low
Many of the data were not presented in sufficient detail to derive accurate
deviations from the control
Within some experiments, pre-exposure measurements revealed that some
endpoints did not start at comparable level. This initial difference was
accounted for in the derivation of the deviation from the control, but the
accuracy of the quantification in these cases is limited
Exposure in the experiments
For the overwintering assessment, the food consumption of foragers and nurse
bees were considered and the lower food consumption of resting winter bees
was not accounted for when estimating exposure in the experiments. This
might have overestimated the exposure in the experiments
The exposure level of the effect
field
experiments on crops with nectar was
calculated considering 15% sugar content of the nectar, which is the low end
value of the realistic range. This may result in an overestimation of the
estimated exposure of those experiments
+/À
+/À
+/À
+/À
+/À
+
+
++
The level of the dilution of the residue concentrations of the consumed pollen
and nectar in the colony-feeder experiments with free
flying
bees could not be
estimated from the available data
For some colony-feeder experiments where bees were fed with sugar solution,
+/À
the actual percentage of sugar was unknown and therefore assumed to be
50%. This would have an impact on the assumed consumption and in turn on
the active substance intake
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The exposure in the higher tier effect studies was estimated using mean
residue measurements. In some studies, there were values reported
<
LOD,
which were conservatively considered as 0 mg/kg. When a value was reported
to be detected but
<
LOQ, the value was considered to be between the LOQ
and LOD (average of LOQ and LOD) and the LOD was considered as half of
the LOQ
Exposure assessment goals
In several residue studies used for the exposure assessment goal, the
sampling frequency and pattern did not guarantee that the actual maximum
occurrence had been picked up
The limited number of valid residue studies available for the exposure
assessment goal, restricted the potential for the representativeness to cover
90
th
percentile exposure situations
The exposure assessment goals were calculated assuming residues equal to
the LOQ every time measured concentration were
<
LOQ. In the cases that no
residues were detected the residue was considered to be equal to the LOD
The exposure assessment goals were calculated using the maximum residue
levels measured within each trial
Since insufficient RUD values were available from winter oilseed rape to
perform an exposure assessment, the available RUD values for spring oilseed
rape were also used
For the determination of the exposure assessment goals, a 15% sugar content
of the nectar was assumed, which is the low end value of the realistic range.
This may have resulted in an overestimation of the exposure assessment goal
For overwintering assessment, the exposure assessment goal was based on
consumption from active bees and could therefore be overestimating the
actual exposure of bees during winter
Confounding factors in the experiments
In 4 of 23 higher tier studies, there was a confirmation of control
contamination with imidacloprid or with other neonicotinoids. This could
potentially mask triggering of negative effects.The presence of external
substances was also seen in the treatment, creating uncertainties about
detecting effects not due to the treatment
In half of the higher tier studies where the bees were allowed to free
flying,
there were indications for the use of different pesticides, including insecticides
(including neonicotinoids) in the landscape where the bees could forage. This
may affect both control and treatment.There is also uncertainty that this
practice could have been done also in experiments where this was not clearly
reported
Conclusion
À
+
+
À
À
À
À
À
+/À
+/À
The weight of evidence exercise with a consideration to the uncertainties of the
assessment is considered to indicate a low risk to honeybees from residues in pollen
and nectar for the treated crop scenario for winter oilseed rape. It has to be noted,
however, that the line of evidence for overwintering assessments was assessed as
inconclusive and the indirectly relevant (Class 2) endpoint of
‘mortality
in front of the
hive’ indicated a weak evidence for more than negligible effect
LOD: limit of detection; LOQ: limit of quantification; RUD: residue per unit dose.
In lack of exposure assessment goals, a similar weight of evidence exercise as for winter oilseed
rape (integration of lines of evidences obtained from realistic exposure estimations) could not be
performed for the other crops. For the same reason, it is not possible to extrapolate the risk
assessment of winter oilseed rape to the other crops except for spring oilseed rape.
It is expected, and confirmed by the available (rather limited) data for residues in pollen and nectar
(see Appendix
D),
that the residue levels in spring oilseed rape tend to be higher than in winter
oilseed rape. However, the application rate and the attractiveness of the two crops are the same. The
residue levels from spring oilseed rape studies had been considered in the assessments for winter
oilseed rape. Therefore, overall, the risk to spring oilseed rape is expected to be similar than the risk
to winter oilseed rape (i.e. low risk), noting that this includes some uncertainties due to the expected
higher residue levels.
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Succeeding crop scenario
The exposure assessment goal for the succeeding crop scenario is only marginally different from
the exposure assessment goal for winter oilseed rape (see Section
5.1.1.2).
Also, the difference
between the length of realistic
flowering
period of winter oilseed rape and any possible succeeding
crop, as considered in this conclusion (10–42 days for winter oilseed rape and 5–42 days for the
succeeding crop scenario), was not important, since all the reliable higher tier studies had more than
10 days exposure period. Therefore, the integration of the lines of evidence and the conclusion for
winter oilseed rape is equally applicable for the succeeding crop scenario. For the sake of
simplification, only the uncertainty analysis and the conclusions that are different from the assessment
for winter oilseed rape are detailed in Table
12.
All the other parts of the integration of the lines of
evidence for winter oilseed rape as presented in Table
11
are applicable for the succeeding crop
scenario.
Table 12:
The integration of the lines of evidence for honeybees for the succeeding crop scenario
Refer to Appendix
F,
Section 1.1.2
For narrative description, see Table
11
for winter oilseed rape
Overwintering
assessment
Class 2 endpoints
Mortality in front of the
hive
Brood abundance
Refer to Appendix
F,
Section 1.3.2
For narrative description, see Table
11
for winter oilseed rape
Refer to Appendix
F,
Section 1.4.2
For narrative description, see Table
11
for winter oilseed rape
Homing success
Appendix
F,
section 1.5.2
For narrative description, see Table
11
for winter oilseed rape
Integration of lines of
For narrative description, see Table
11
for winter oilseed rape
evidence for the
succeeding crop
scenario
Quantification of the effects
Uncertainty analysis
in line with EFSA
(2013c)
(À potential to make the
true risk lower
+
potential to make the
true risk higher)
Most of the available endpoints were assessed to be reliable with major
restrictions; therefore, the overall reliability of the WoE is limited
The reasons for the reliability assessment categorisation differed between the
studies
The consistency in case of many lines of evidence is extremely low
Many of the data were not presented in sufficient detail to derive accurate
deviations from the control. Therefore, only crude estimates could be used in
the lines of evidence
Within some experiments, pre-exposure measurements revealed that some
endpoints did not start at comparable level. This initial difference was
accounted for in the derivation of the deviation from the control, but the
accuracy of the quantification in these cases is limited
Exposure in the experiments
For the overwintering assessment, the food consumption of foragers and
nurse bees was considered and the lower food consumption of resting winter
bees was not accounted for when estimating exposure in the experiments.
This might have overestimated the exposure in the experiments
The exposure level of the effect
field
experiments on crops with nectar was
calculated considering 15% sugar content of the nectar, which is the low end
value of the realistic range. This may result in an overestimation of the
estimated exposure of those experiments
+/À
+/À
+/À
+/À
Refer to Appendix
F,
Section 1.2.2
For narrative description, see Table
11
for winter oilseed rape
Class 1 endpoints
Colony strength
+/À
+
+
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++
The level of the dilution of the residue concentrations of the consumed pollen
and nectar in the colony-feeder experiments with free
flying
bees could not be
estimated from the available data
For some colony-feeder experiments where bees were fed with sugar solution,
+/À
the actual percentage of sugar was unknown and therefore assumed to be
50%. This would have an impact on the assumed consumption and in turn on
the active substance intake
The exposure in the higher tier effect studies was estimated using mean
residue measurements. In some studies, there were values reported
<
LOD,
which were conservatively considered as 0 mg/kg. When a value was reported
to be detected but
<
LOQ, the value was considered to be between the LOQ
and LOD (average of LOQ and LOD), and the LOD was considered as half of
the LOQ
Exposure assessment goals
For the determination of the exposure assessment goals, a 15% sugar content
of the nectar was assumed, which is the low end value of the realistic range.
This may have resulted in an overestimation of the exposure assessment goal
For overwintering assessment, the exposure assessment goal was based on
consumption from active bees and could therefore be overestimating the
actual exposure of bees during winter
The PECplateau for the GAPs under consideration are lower than the soil
residue levels of the available residue trials. Therefore, the exposure
assessment goals are conservative for the GAPs under consideration. The only
exception was the use on cotton where the PECplateau was comparable with
the residue levels of the test soils
The exposure assessment goal was based on residue values from semifield
studies or samples taken directly from the crop, i.e. landscape dilution was not
taken into consideration
Confounding factors in the experiments
In 4 of 22 higher tier studies, there was a confirmation of control
contamination with imidacloprid or with other neonicotinoids. This could
potentially mask triggering of negative effects
The presence of external substances was also seen in the treatment, creating
uncertainties about detecting effects not due to the treatment
In half of the higher tier studies where the bees were allowed to free
flying,
there were indications for the use of different pesticides, including insecticides
(including neonicotinoids) in the landscape where the bees could forage. This
may affect both control and treatment.
There is also uncertainty that this practice could have been done also in
experiments where this was not clearly reported
Conclusion
+/À
À
À
À
À
À
+/À
The weight of evidence exercise with a consideration to the uncertainties of the
assessment is considered to indicate a low risk to honeybees from residues in pollen
and nectar for the succeeding crop scenario
It has to be noted however that the line of evidence for overwintering assessment
was assessed as inconclusive and the indirectly relevant (Class 2) endpoint of
‘mortality
in front of the hive’ indicated a weak evidence for more than negligible
effect
WoE: weight of evidence; LOD: limit of detection; LOQ: limit of quantification; PEC: predicted environmental concentration; GAP:
good agricultural practices.
5.1.1.4.2. Weight of evidence higher tier risk assessment for bumblebees
A number of higher tier endpoints (dominated by colony feeder type studies) has been assessed
and integrated in a weight of evidence exercise. First, each line of evidence (i.e. class 1 and class 2
endpoints) were assessed and concluded for the succeeding crop scenario. The graphical
representations with the interpretation of each line of evidence, which had multiple endpoints, are
presented in Appendix
F.
One of the Class 1 and the available Class 2 endpoints had only one or two
data points; therefore, no graphical representations were performed. These endpoints however are
briefly summarised in Appendix
F.
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The second step of the WoE exercise is the integration of the lines of evidence. Table
13
present
the integration of the lines of evidence for the succeeding crop scenario.
Table 13:
The integration of the lines of evidence for bumblebees for the succeeding crop scenario
Refer to Appendix
F,
Section 2.1
Only one experiment with appropriate exposure indicated negligible effect and only
one experiment with rather mild exposure regime resulted in a large-negative
deviation from the control. However, another endpoint with low exposure level but
long exposure duration also indicated negative deviation from the control
Overall, this indicated a
weak evidence for larger than negligible effect
Worker production
Refer to Appendix
F,
Section 2.2
Two experiments with appropriate exposure indicated a clear negative deviation from
the control. One of them had higher reliability than all the other endpoints, while the
other one had some uncertainties. On the other hand, three experiments could be
considered as evidence indicating no negative deviation from the controls. However,
none of them had a clearly representative or severe exposure regime. No clear trend
could be seen when all these positive and negative elements were balanced
Overall, this
line of evidence was inconclusive
Drone production
Refer to Appendix
F,
Section 2.3
Two experiments with low exposure level indicated a clear negative deviation from the
control. One of them had too long exposure length, while the other one had some
uncertainties. On the other hand, two experiments could be considered bearing some
evidences that indicate no negative deviations from the controls. However, none of
them had a clearly representative or severe exposure regime. No clear trend could be
seen when all these positive and negative elements were balanced
Overall, this
line of evidence was inconclusive
Reproductive output of
queenless microcolonies
Refer to Appendix
F,
Section 2.4
A number of endpoints with relatively low exposure levels (and one of them with a
realistic exposure length) indicated clear negative deviations from the control. No
endpoint was available indicating negligible or positive deviation from the control
Overall, this indicated a
moderate evidence for larger than negligible effect
Brood production
Refer to Appendix
F,
Section 2.5
A number of experiments indicated clearly negative deviations from the control. Five
of these experiments had a mild exposure regime. On the other hand, only two
endpoints could be considered as evidence indicating no negative deviation from the
controls. However, none of them had a clearly representative or severe exposure
regime
Overall, this indicated a
moderate evidence for larger than negligible effect
Colony strength
Refer to Appendix
F,
Section 2.6
Only two endpoints were available. The estimated exposure levels associated to these
endpoints were in the range of or lower than the exposure assessment goals for
succeeding crops. The length of the exposure was in the realistic range or only
marginally longer than the
flowering
period of succeeding crops. One of the endpoints
was considered as fully reliable. The deviation from the control was between
negligible to large negative and the mean deviation was assessed as medium
negative.
The other endpoint was considered as reliable with major restrictions. The deviation
from the control was large negative in this experiment
This indicated a
strong evidence for larger than negligible effect
Class 1 endpoints
Queen production
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Class 2 endpoints
Emergence rate
(workers)
Refer to Appendix
F,
Section 2.7
Only one endpoint was available and the estimated exposure level associated to this
endpoint was in the range of the exposure assessment goals for succeeding crops.
The length of the exposure was in the realistic range of the
flowering
period of
succeeding crops. The deviation from the control bridged from large positive to large
negative, and the mean deviation was assessed as medium negative. The endpoint
was considered as fully reliable
This indicated a
moderate evidence for more than negligible effect
Mating ability of the new Refer to Appendix
F,
Section 2.8 Only one endpoint was available originating from a
field
study on sunflower with a 9-day exposure period. No exposure estimation was
queens
available for this endpoint.
This
line of evidence was inconclusive
Integration of lines of
Class 1 endpoints, overall, suggest a moderate evidence for larger than negligible
effects.
evidence for the
This was also indicated by the single Class 2 endpoint, which was conclusive
succeeding crop
scenario
Uncertainty analysis
in line with EFSA
(2013c)
(À potential to make the
true risk lower
+
potential to make the
true risk higher)
Quantification of the effects
Many of the available endpoints were assessed to be reliable with major
restrictions; therefore, the overall reliability of the WoE is limited
+/À
The reasons for the reliability assessment categorisation differed between the
+/À
studies
For some colony-feeder experiments where bees were fed with sugar solution,
+/À
the actual percentage of sugar was unknown and therefore assumed to be
50%. This would have an impact on the assumed consumption and in turn on
the active substance intake
The level of the dilution of the residue concentrations of the consumed pollen
and nectar in the colony-feeder experiments with free
flying
bees could not be
estimated from the available data
In some colony-feeder studies, the amount of the offered food (i.e. the spiked
sugar solution) was not ad libitum. In one
field
study, non-spiked food was
offered to the colonies after the exposure phase. These may lead to excessive
dilution of the residue concentrations
In a few colony-feeder studies, some avoidance to the feeding solution had
been reported
Exposure in the experiments
The exposure in the higher tier effect studies was estimated using mean residue
measurements. In two
field
experiments, which were on potato (i.e. relevant
only for pollen), there were values reported
<
LOD, which were conservatively
considered as 0 mg/kg. When a value was reported to be detected but
<
LOQ,
the value was considered to be between the LOQ and LOD
Exposure assessment goals
The exposure assessment goal was based on residue values from semifield
studies or samples taken directly from the crop, i.e. landscape dilution was not
taken into consideration
The PECplateau for the GAPs under consideration are lower than the soil
residue levels of the available residue trials. Therefore, the exposure
assessment goals are conservative for the GAPs under consideration. The only
exception was the use on cotton where the PECplateau was comparable with
the residue levels of the test soils
++
+
+/À
À
À
À
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Confounding factors in the experiments
In a few cases of the higher tier studies, there was a confirmation of control
contamination with imidacloprid or with other neonicotinoids. This could
potentially mask triggering of negative effects
In some experiments, pollen collected by honeybees without sufficient
information on potential residue contamination was offered to the colonies.
Potential presence of external substances creates also uncertainties about
detecting effects not due to the treatment
In many of the higher tier studies where the bees were allowed to free
flying,
there were indications for the use of different pesticides, including insecticides
(including neonicotinoids) in the landscape where the bees could forage. This
may affect both control and treatment.
There is also uncertainty that this practice could have happened also in
experiments where this was not clearly reported
Conclusion
+/À
+/À
The weight of evidence exercise with a consideration to the uncertainties of the
assessment is considered to indicate a high risk to bumblebees from residues in pollen
and nectar for the succeeding crop scenario
WoE: weight of evidence; LOD: limit of detection; LOQ: limit of quantification; PEC: predicted environmental concentration; GAP:
good agricultural practices.
5.1.1.4.3. Solitary bees
No higher tier studies were available for solitary bees.
5.1.2.
Risk from contamination of adjacent vegetation via dust drift (field
margin and adjacent crop scenario)
5.1.2.1 Tier-1 risk assessment
The Tier-1 risk assessment for the representative GAPs were performed by using the EFSA’s BeeTool
(v.3.) (Appendix Y of EFSA, 2013c) for honeybees and bumblebees, where suitable toxicity data were
available. A screening Tier-1 assessment was carried out for solitary bees and for the chronic adult
assessment for bumblebees as only surrogate endpoints were available. Since no toxicity data were
available for HPG development nor for the larvae toxicity for non-Apis bees, no assessment was
performed for these scenarios.
It was assumed that a deflector was used during the seed drilling. The potato seed treatment use
is an in-planter tuber treatment via a spray application. Therefore, no dust formation was considered
for this use.
The outcome of these calculations is summarised in Tables
14
and
15.
A low risk is indicated only if
all categories (acute, chronic and larva) for all the relevant scenarios resulted in low risk. When one or
more combinations (categories of acute, chronic and larva combined with the relevant scenarios)
indicated a high risk than high risk or low risk not demonstrated (for Tier-1 screening assessments) is
indicated in the table below. The detailed results are included in Appendix
C.
Table 14:
Summary of the outcome of Tier-1 and screening Tier-1 risk assessment for the contact
route of exposure
Honeybee
Use
‘Low’
application
rate
High risk
‘High’
application
rate
High risk
Bumblebee
‘Low’
application
rate
High risk
‘High’
application
rate
High risk
Solitary bee
‘Low’
application
rate
Low risk not
demonstrated
‘High’
application
rate
Low risk not
demonstrated
Spring
cereals,
cotton,
endive,
lettuce,
brassicas
(flowering,
head, leafy)
and maize
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Honeybee
Use
‘Low’
application
rate
‘High’
application
rate
High risk
Low risk with
deflector
Low risk with
and without
deflector
Not relevant
(Low risk)
Bumblebee
‘Low’
application
rate
Low risk with
deflector
Low risk with
deflector
Low risk with
and without
deflector
Not relevant
(Low risk)
‘High’
application
rate
High risk
Low risk with
deflector
Low risk with
and without
deflector
Not relevant
(Low risk)
Solitary bee
‘Low’
application
rate
Low risk not
demonstrated
Low risk not
demonstrated
Low risk with
and without
deflector
Not relevant
(Low risk)
‘High’
application
rate
Low risk not
demonstrated
Low risk not
demonstrated
Low risk with
deflector
Not relevant
(Low risk)
Winter cereal High risk
Spring and
winter rape
Sugar and
fodder beet
Potato
Low risk with
deflector
Low risk with
and without
deflector
Not relevant
(Low risk)
Table 15:
Summary of the outcome of Tier-1 and screening Tier-1 risk assessment for the dietary
route of exposure
Honeybee
Bumblebee
‘Low’
application
rate
High risk
‘High’
application
rate
High risk
Solitary bee
‘Low’
application
rate
Low risk not
demonstrated
‘High’
application
rate
Low risk not
demonstrated
Use
‘Low’
application
rate
‘High’
application
rate
High risk
High risk
Spring and
winter
cereals,
cotton,
endive,
lettuce,
brassicas
(flowering,
head, leafy),
maize
Spring and
winter rape
Sugar and
fodder beet
Potato
High risk
Low risk with
and without
deflector
Not relevant
(Low risk)
High risk
Low risk with
deflector
Not relevant
(Low risk)
Low risk not
demonstrated
Low risk not
demonstrated
Not relevant
(Low risk)
Low risk not
demonstrated
Low risk not
demonstrated
Not relevant
(Low risk)
Low risk not
demonstrated
Low risk with
deflector
Not relevant
(Low risk)
Low risk not
demonstrated
Low risk not
demonstrated
Not relevant
(Low risk)
Since no dust formation is expected from the use on potato, a low risk was concluded for the
field
margin and adjacent crop scenario for this use. Accounting for both contact and oral exposure, a low
risk to honeybees for the
field
margin and adjacent crop scenario was indicated to sugar beet and
fodder beet. It is noted that the endpoint for larvae was only considered to be provisional, a reliable
endpoint for HPG is not available and there was no assessment of the potential for accumulative
effects available. Nevertheless, the provisional risk assessment is considered sufficient to conclude a
low risk for this particular crop and scenario, but it would be prudent to update the risk assessment
when further data are available. The screening level assessment performed for bumblebees and for
the high application rate for solitary bees was not sufficient to demonstrate a low risk. A low risk was
indicated for solitary bees for the low application rate of sugar beet and fodder beet. For spring and
winter rape, a high risk to honeybees was indicated and a low risk to bumblebees and solitary bees
was not demonstrated with a screening assessment. For all other seed treatment uses under
consideration, a high risk to honeybees and bumblebees was indicated and a low risk to solitary bees
was not demonstrated with a screening assessment. No risk assessment could be performed for
bumblebee and solitary bee larvae.
It is noted that for endive, lettuce and brassicas, a low risk could be concluded for uses when the
treated crop is sown in permanent greenhouse.
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5.1.2.2. Exposure assessment for the
field
margin and adjacent crop scenario
In addition to the data set al.ready used in a previous EFSA conclusion (EFSA, 2016b), results from
dust drift trials measuring imidacloprid in dust deposition outside the drilled
field
originating from
treated seed at the time of drilling were available for winter barley (two experimental sites), winter
wheat (two experimental sites) and winter oilseed rape (one experimental site). All these experiments
were carried out with the same type of pneumatic seed driller (Accord DL No. 009190). Information on
the presence or absence of a deflector and the deflector type was not provided.
In the two winter barley trials, seed dustiness was characterised with mean measured Heubach values
of 0.093 g/10
5
seeds and 0.076 g/10
5
seeds. For seeds treated at 0.031 mg/seed with drilling rate
3,312,699–3,317,593 treated winter barley seeds/ha, residues in petri dishes placed on the ground were
12.63–12.81 mg/ha at 3 m and 17.04–22.00 mg/ha at 1 m from the edge of the drilled area. For seeds
treated at 0.024829 mg/seed with drilling rate 3,535,405 treated winter barley seeds/ha, residues in
petri dishes were 10.584 mg/ha at 3 m and 16.589 mg/ha at 1 m.
In the two winter wheat trials, seed dustiness was characterised with mean measured Heubach
values of 0.062 g/10
5
seeds and 0.064 g/10
5
seeds. For seeds treated at 0.03096 mg/seed with
drilling rate 4,588,640–4,603,114 treated winter wheat seeds/ha, residues in petri dishes were 8.53–
13.976 mg/ha at 3 m and 13.424–16.047 mg/ha at 1 m. For seeds treated at 0.025619 mg/seed with
drilling rate 4,314,833 treated winter wheat seeds/ha, residues in petri dishes were 8.953 mg/ha at
3 m and 11.202 mg/ha at 1 m.
In a winter oilseed rape trial, seed dustiness was characterised with mean measured Heubach
values of 0.0006 g/10
5
seeds. For seeds treated at 0.01136–0.01137 mg/seed with drilling rate
649,877–672,332 treated oilseed rape seeds/ha, residues in petri dishes were 3.214 mg/ha at 3 m
and 2.934 mg/ha at 1 m at one trial plot. At the second plot, concentrations were
<
2.934 mg/ha
(LOQ).
As these trials only represent one seed drill type and two experiments for each crop, with these
seed batch quality measured dustiness (Heubach determinations), it was considered not credible to
use them to replace the Tier-1 values of the guidance. Therefore, no credible refined exposure
assessment for contamination in
field
margins and adjacent crops could be performed.
In addition to the dust deposition
field
trials, information on dustiness of neonicotinoid treated
seeds was available.
In the open call for data information was provided on the measurement of the dust content of
oilseed rape and maize seeds (Heubach values); and in most cases for oilseed rape, also information
on active ingredient content in the dust (Heubach a.i. values) was provided from seed samples from
seed merchants. Dust was quantifiable/present in all seed batches tested. In maize seed, measured
dust was just reported to be significantly below the industry standard of below 3 g dust/100 kg seed.
Oilseed rape seeds treated in 2013 from 326 seed treatment sites had a 90th percentile total dust
Heubach value of 0.192 g/700,000 seeds. These values for Heubach a.i. were 6 mg/700,000 seeds for
clothianidin (156 sites), 1.4 mg/700,000 seeds for imidacloprid (52 sites) and 7.8 mg/700,000 seeds
for thiamethoxam (104 sites).
Heubach a.i. values in seed samples from an additional 10 different seed treatment facilities also
where seed was treated in 2013 were 0.21, 0.27, 0.33, 0.46, 0.6, 0.96, 1.29, 1.3, 8.9 and 16.6 mg/
700,000 seeds for clothianidin.
As all these results are from the same year, so they did not provide any information on dustiness of
the seed being supplied to farmers in different years and whether dust levels have reduced in recent
years. It is clear that the Heubach a.i. values can be variable. It is clear that reducing the dust content
of seed to be treated as well as any dust produced during the treatment process as well as any that
might be generated during storage and transport of seed is a good target for improved risk
management. However, with the information available in this review, it was not possible to account for
this in any refined exposure and/or risk characterisation.
5.1.2.3. Tier-2 risk assessment
Since the available higher tier data for the exposure characterisation was not considered to be
sufficient for a refinement, no Tier-2 risk assessment could be performed.
5.1.2.4. Tier-3 risk assessment
Only two higher tier effect studies were available. In the study I.848, winter barley seeds treated
with imidacloprid were drilled in
fields,
which were surrounded by
flowering
Phacelia tanacetifolia
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where honeybee colonies were located. Class 1 and Class 2 endpoints (colony strength, brood
abundance, mortality in front of the hive) were investigated. The brood abundance and the colony
strength were very similar in the control and treatment group (with only a few percent deviation on
average) with no statistical difference. The data on mortality in front of the hive indicated a constant
higher mortality rate in the treated
field
than in the control (although this was the case in the pre-
exposure period, as well). There were some periods when the mortality in the treated group was
notably higher (up to a factor of 2, and in two cases, the available statistical analysis indicated a
significant difference). However, the average number of dead bees was generally low, generally
<
10 bee/day.
In the study C*I.1324, sugar beet pills treated with clothianidin (0.60 mg/pill), imidacloprid
(0.30 mg/pill) and beta-cyfluthrin (0.08 mg/pill) were drilled in the
field.
The sugar beet pills were also
treated with the fungicides thiram and hymexazol. Class 1 and Class 2 endpoints (colony strength,
colony strength after overwintering, brood abundance, mortality in front of the hive) were
investigated.
Overall, the colony strength during the season (i.e. until before the winter) and the mortality in
front of the hive had similar trends to the control, although the maximum negative deviation from the
control for the colony strength was marginally above the 7% (7.3%). No negative deviation was
observed on the colony strength after the winter. The data on brood abundance indicated some
fluctuations,
it varied between small-positive to medium-negative deviation from the control.
All the endpoints from both studies were assessed as reliable with major restrictions. Moreover, in
the study on sugar beet, other insecticides, including clothianidin, were used. Overall, the information
available for the Tier-3 assessment was not considered to be sufficient for a robust conclusion on the
risk via dust drift.
5.1.3.
Risk via water consumption
5.1.3.1. Guttation water
The risk assessment based on water solubility indicated a high risk. The detailed results are
included in Appendix
D.
It should be highlighted that the EFSA evaluation of the confirmatory data for imidacloprid and
clothianidin (EFSA, 2016b,c) concluded that the exposure of honeybees from contaminated guttation
fluids
in the crops considered therein (winter cereals, sugar beet and potatoes) was of low relevance.
Such conclusion was confirmed during the expert meeting related to this assessment (Pesticide Peer
Review Meeting 166), despite the experts acknowledged that such an assessment was based on
studies presenting major limitations. On the basis of this, no risk assessment from exposure to
contaminated guttation
fluids
was carried out, and a low risk was concluded for winter cereals, sugar
beet and potatoes. In addition, considering this, a low risk was concluded for fodder beets.
In addition, it is noted that for endive, lettuce and brassicas, a low risk could be concluded for uses
when the treated crop is grown continuously in permanent greenhouse.
Higher tier assessment for crops other than winter cereals, sugar beet and potatoes
Valid reliable
field
studies (two trials in Italy) investigating imidacloprid, 5-OH imidacloprid and
imidacloprid olefin residues in guttation water collected from maize were available. As would be
expected, highest residues occurred when plants were small (interval from drilling to guttation
fluid
sampling was short). The highest residues determined were up to 222 mg imidacloprid/L from an
application rate of 1.25 mg/seed and 47 mg imidacloprid/L from an application rate of 0.5 mg/seed.
This small data set was considered not sufficient for selecting a 90th percentile exposure value as
suggested by EFSA (2013c). Therefore, in line with the consideration of the experts at the meeting for
the confirmatory data for imidacloprid (EFSA, 2016b), the maximum measured concentrations were
considered to perform a refined risk assessment for maize. The refined calculations are presented in
Table
16.
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Table 16:
Tier-2 risk assessment to honeybees exposed via consumption of contaminated guttation
fluids
Water
consumption
(lL/bee or
lL/larva)
11.4
11.4
111
Measured
concentration
in guttation
fluid
(lg/lL)
Bee type
Category
ETR
Trigger
Maize
Honeybee forager
Honeybee forager
Honeybee larva
Acute
Chronic
Larva
0.222
684
897
4,667
>
0.2
>
0.03
>
0.2
ETR: Exposure toxicity ratio.
On the basis of this Tier-2 assessment, a low risk could not be concluded for maize.
No higher tier effect studies were available for crops other than winter cereals, potato or sugar
beet; therefore, no further assessments were performed.
5.1.3.2. Puddle water
It was not necessary to perform exposure modelling to predict residues of imidacloprid in puddles
as the concentrations in surface runoff calculated by any version of the PRZMsw tool are always
negligible when seeds are drilled below the soil surface. Consequently, a low risk to honeybees from
residues in puddles for the seed treatment uses under consideration is concluded following EFSA
(2013c) that indicates that concentrations in runoff water as calculated by PRZMsw are an appropriate
estimate of puddle water concentrations. Experts from member states noted that the EFSA (2013c)
approach might represent a best case as cultivation following harvesting of the treated crop
redistributes soil residues, such that concentrations at the soil surface will be present to desorb into
puddles. PRZM calculations as prescribed by FOCUS surface water do not account for this as the
FOCUS PRZM tool and FOCUS surface water runoff scenarios do not account for soil cultivation.
5.1.3.3. Surface water
PEC in surface water were calculated at Step 3 following FOCUS surface water (2001) guidance and
the FOCUS tools SWASH 5.3, SPIN 2.2, MACRO 5.5.4, PRZMsw 3.3.2 and TOXSWA 4.4.3. for the active
substance imidacloprid. The PECs were calculated for the GAPs on potatoes and winter cereals.
Substance input values were selected in accordance with generic guidance for FOCUS surface water
scenarios from the list of endpoints of EFSA (2008). The laboratory geomean single
first-order
DT
50
for
soil used was 117.7 days and that for water was 67 days with a value of 1,000 days (default) used for
sediment. The geomean KFoc of 209.5 mL/g (KFom 121.5 mL/g) arithmetic mean 1/n 0.8 were used
as input in the simulations. The option soil incorporation was selected and the application window was
set in line with the planting dates specified at each scenario for winter cereals and potatoes. For PRZM
CAM 8 was selected, i.e. that the incorporation was at a specific depth with 4 cm which is applicable
for cereals and represents a conservative approach regarding surface runoff for potatoes. The highest
PEC surface water calculated with this approach was 0.075
lg/L
for the D6 ditch scenario from the use
on winter cereals. From the simulations for potatoes, the highest PEC surface water was 0.042
lg/L
for the D4 stream scenario. For these uses where seeds are drilled and granules are incorporated
below the soil surface, concentrations in surface runoff as calculated by PRZMsw are always negligible.
Therefore, as for puddle water (see
5.1.3.2),
concentrations in the FOCUS surface water bodies are
also always characterised as negligible for the FOCUS surface water runoff scenarios, when the option
soil incorporation is selected.
Exposure toxicity ratio (ETR) calculations with the above-mentioned water concentrations resulted
in a low risk to all honeybee castes (for details of the calculations see Appendix
D).
As no toxicity
endpoint was available for the HPG development, a risk assessment could not be performed for this
scenario. However, considering the notable margin of safety (two orders of magnitude in the chronic
risk assessment) obtained in these assessments, a low risk was concluded for this scenario, as well.
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5.2.
5.2.1.
Risk assessments for granule
Risk via systemic translocation in plants
residues in nectar and pollen
This route of exposure is relevant for the treated crop scenario, for the weed and for the
succeeding crop scenario.
5.2.1.1. Tier-1 risk assessment for treated crop scenario, weed scenario and succeeding
crop scenario
The Tier-1 risk assessments for the representative GAPs were performed by using the EFSA’s
BeeTool (v.3.) (Appendix Y of EFSA, 2013c) for honeybees and bumblebees, where suitable toxicity
data were available. A screening Tier-1 assessment was carried out for solitary bees and for the
chronic adult assessment for bumblebees as only surrogate endpoints were available. Since no toxicity
data was available for HPG development or for the larvae toxicity for non-Apis bees, no assessment
was performed for these scenarios.
The outcome of the calculations is summarised in Table
17.
A high risk or low risk not
demonstrated (for Tier-1 screening assessments) is indicated in the Table
17
since all combinations
(categories of acute, chronic and larva combined with the relevant scenarios) indicated a high risk. The
only exception is for the treated crop scenario, but only when the application is done after the
flowering
period of the crop. The detailed results are included in Appendix
C.
It is however to be noted
that turf is typically a mix of different plant species that may
flower
in different periods. Moreover, turf
may be mowed during the vegetative season and shortly after mowing, turf may
flower
again.
Therefore, this scenario (application is done after the
flowering
of the crop) has a limited applicability
for this use. During the experts meeting (October 2017), some Member States highlighted that
country-specific authorisations of some products are limited to some specific categories that are
generally considered as
‘highly
managed amenity turf’. That includes generally low abundance of
weeds and regular mowing of the
field,
which makes the
field,
in general, unattractive to bee species.
Therefore, in the Member States where granular uses on amenity vegetation are authorised, this issue
should be further considered. Moreover, it is noted that typically amenity vegetation is grown for
several years on the same
field.
Therefore, the succeeding crop is typically a real vegetation growing
from the same root system. The Tier-1 calculations for succeeding crop refer to the situations when
the amenity vegetation is removed as a result of the preparation of a seed bed to plant an attractive
following crop.
Table 17:
Summary of the outcome of Tier-1 and screening Tier-1 risk assessment for the dietary
route of exposure
Honeybee
Use
‘Low’
application
rate
‘High’
application
rate
Bumblebee
‘Low’
application
rate
‘High’
application
rate
Solitary bee
‘Low’
application
rate
‘High’
application
rate
Managed amenity turf
High risk
Low risk not demonstrated
5.2.1.2. Exposure assessment for the treated crop, succeeding crop scenarios and for
flowering
weeds
No new data that could be used for an exposure refinement for the treated crop scenario and for
the weed scenario were available for the evaluation of the GAPs for granular formulations.
As the concentrations in pollen and nectar in succeeding crops are considered to be independent of
the GAP and formulation type, the available information as assessed in Section
5.1.1.2
(for the seed
treatment uses) are also applicable to the granular uses under consideration.
5.2.1.3. Tier-2 risk assessment
As no refined exposure assessment for residues in pollen and nectar for the treated crops scenario
or
flowering
weeds scenario or information on weed coverage was available, no Tier-2 risk assessment
could be performed for these scenarios.
The risk assessments performed under Section
5.1.1.3
(for the seed treatment uses) are also
applicable to the granular use under consideration. A low risk for the succeeding crop scenario could
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not be demonstrated with the available exposure refinements. It is noted, however, that the
succeeding crop scenario is relevant only for situations when the amenity vegetation is removed as a
result of the preparation of a seed bed to plant an attractive following crop.
5.2.1.4. Tier-3 risk assessment
Treated crop scenario
Only one higher tier study was available (I.462) for granular uses. In this study, the effects on
bumblebee colonies (Bombus
impatiens)
were investigated in semifield conditions in the USA. The
cages were set up in grassland with
flowering
white clovers. A granular formulation (Merit 0.5 G) was
applied by hand, and shortly after the treatment, the plots were irrigated. From the most relevant
endpoints (Class 1 and Class 2), only colony strength and brood production were studied. At the end
of the study, on average, 26% less workers were counted in the treated group. Contrary, the number
of brood chambers was 43% higher than in the control group. The endpoints were considered as
reliable with major restrictions.
Therefore, the information available for the Tier-3 assessment was not considered to change the
conclusion of the Tier-1 risk assessment.
Weed scenario
No higher tier data were available for the weed scenario. However, the assessments and
conclusions for the treated crop scenario are considered also applicable for the weed scenario.
Succeeding crop scenario
As the concentration in pollen and nectar in succeeding crops is considered to be independent of
the GAP and formulation type, the weight of evidence risk assessment performed under
Section
5.1.1.4
(for the seed treatment uses) is also applicable to the granular uses of imidacloprid
under consideration. It is noted that the succeeding crop scenario is relevant only for situations when
the amenity vegetation is removed as a result of the preparation of a seed bed to plant an attractive
following crop.
5.2.2.
Risk from contamination via dust drift
This route of exposure is relevant for the
field
margin and adjacent crop scenarios. In addition, this
route of exposure is relevant for the treated crop scenario and for the weed scenario after emergence
for the use in managed amenity turf.
5.2.2.1. Tier-1 risk assessment
The Tier-1 risk assessments for the representative GAPs were performed by using the EFSA’s
BeeTool (v.3.) (Appendix Y of EFSA, 2013c) for honeybees and bumblebees, where suitable toxicity
data were available. A screening Tier-1 assessment was carried out for solitary bees and for the
chronic adult assessment for bumblebees as only surrogate endpoints were available. Since no toxicity
data was available for HPG development or for the larvae toxicity for non-Apis bees, no assessment
was performed for these scenarios.
The outcome of the calculations is summarised in Table
18.
A high risk or low risk not
demonstrated (for Tier-1 screening assessments) is indicated in Table
18,
since all combinations
(categories of acute, chronic and larva combined with the relevant scenarios) indicated a high risk (for
both the contact route of exposure and the dietary route of exposure). The detailed results are
included in Appendix
C.
Table 18:
Summary of the outcome of Tier-1 and screening Tier-1 risk assessment for the contact
route of exposure and the dietary route of exposure
Honeybee
Use
‘Low’
application
rate
‘High’
application
rate
Bumblebee
‘Low’
application
rate
‘High’
application
rate
Solitary bee
‘Low’
application
rate
‘High’
application
rate
Managed amenity turf
High risk
Low risk not demonstrated
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5.2.2.2. Exposure assessment for the
field
margin and adjacent crop scenario
No new data on dust drift deposits of granular formulations containing imidacloprid were available
for this evaluation. Therefore, no refined exposure assessment for contamination in
field
margins and
adjacent crops could be performed.
5.2.2.3. Tier-2 risk assessment
As no refined exposure assessment for dust drift was available, no Tier-2 risk assessment could be
performed.
5.2.2.4. Tier-3 risk assessment
No new higher tier data investigating the effects to bees from dust drift generated during the
application of granules in accordance with the use on amenity turf were available. Therefore, no Tier-3
risk assessment was performed.
5.2.3.
Risk via water consumption
5.2.3.1. Guttation water
The risk assessment based on water solubility indicated a high risk. The detailed results are
included in Appendix
C.
Higher tier assessment
No new valid data were submitted for refining the risk to bees from exposure to guttation
fluid
from the granular uses.
5.2.3.2. Puddle water
It was not necessary to perform exposure modelling to predict residues of imidacloprid in puddles
as the concentrations in surface runoff calculated by any version of the PRZMsw tool are always
negligible when granules are buried or otherwise incorporated (i.e. by watering) below the soil surface.
Consequently, a low risk to honeybees from residues in puddles for the granular uses under
consideration is concluded following EFSA (2013c) that indicates that concentrations in runoff water as
calculated by PRZMsw are an appropriate estimate of puddle water concentrations.
5.2.3.3. Surface water
The assessments and the conclusion as presented in Section
5.1.3.3
(for the seed treatment uses)
are applicable for the granular uses, as well. Therefore, a low risk to honeybees from residues in
surface water for the granular uses under consideration was concluded.
6.
Overall conclusion
The conclusion of the risk assessment to bees for the uses of imidacloprid as seed treatment is
summarised below, considering the different scenarios. It should be highlighted that for the seed
treatment uses, the weed scenario was not considered relevant, in agreement with EFSA (2013c).
For the crop-specific conclusion achieved at each assessment tier, please refer to Table
19.
The
assessments included in this conclusion considered the risk to bees from imidacloprid as active
substance only. It should be noted that formulation products containing imidacloprid may also contain
other insecticides including clothianidin, as shown in the GAP table in Appendix
A.
6.1.
Seed treatment uses
Risk via systemic translocation in plants
residues in nectar and pollen
Treated crop scenario
A risk assessment was carried out for all the uses with the exception of the use on potato. For
potato, no information was available on the amount of imidacloprid sprayed to the individual tubers.
Therefore, the assessment could not be
finalised
for the treated crop scenario for potato. A high risk
at the Tier-1 was concluded for all the other crops and for all bee groups. It should be noted that, in
lack of specific toxicity data, a high risk for solitary bees was identified using only surrogate toxicity
estimation based on honeybee data. It should also be noted that vegetable crops and sugar and
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fodder beets may be harvested before they
flower.
In that case, the treated crop scenario is not
relevant for those crops (low risk for the treated crop scenario). Vegetable crops may be grown
continuously in permanent greenhouse. A low risk could be concluded for those situations.
The availability of residue data for winter oilseed rape allowed carrying out a Tier-2 risk assessment
for honeybees. The Tier-2 risk assessment resulted in a high risk.
A Tier-3 risk assessment was also carried out for the use on winter oilseed rape, using data from
colony-feeder, semifield and
field
experiments. The Tier-3 risk assessments resulted in a low risk. This
was extrapolated to spring oilseed rape; therefore, a low risk was concluded for both winter and spring
oilseed rape for the treated crop scenario.
Succeeding crop scenario
A high risk at Tier-1 was concluded for all crops and all bee groups. It should be noted once again
that, in lack of specific toxicity data, a high risk for solitary bees was identified using only surrogate
toxicity estimation based on honeybee data. Vegetable crops may be grown continuously in permanent
greenhouse. A low risk could be concluded for those situations.
The availability of residue data allowed carrying out a Tier-2 risk assessment for the succeeding
crop scenario. The Tier-2 risk assessment resulted in a high risk for all the uses. As for the Tier-1
assessments, in lack of specific toxicity data, a high risk for solitary bees was identified using only
surrogate toxicity estimation based on honeybee data.
A Tier-3 risk assessment was also carried out for honeybees and bumblebees, using data from
colony-feeder, semifield and
field
experiments that were available for honeybees and bumblebees. The
Tier-3 risk assessments resulted in a low risk for honeybees. For bumblebees, a high risk was indicated
by the risk assessments.
Risk from contamination of adjacent vegetation via dust drift
Field margin and adjacent crop scenarios
A risk assessment was carried out for all the uses with the exception of the use on potato. The use
on potato was an in-planter tuber spraying; therefore, it was considered that there is no dust emission
from this use. A high risk at the Tier-1 was concluded for all the other crops and for all bee groups
with the exception of the uses on sugar and fodder beets. For the use with the lowest application rate
on sugar and fodder beets, a low risk was indicated by the Tier-1 risk assessment for solitary bees
considering that a deflector was used. The use with the highest application rate resulted in a high risk.
A low risk was indicated for both the lowest and the highest application rates for honeybees. In case
of the highest application rate, the use of a deflector was taken into consideration. It should be noted,
however, that toxicity data for the HPG development and data on accumulative toxicity were not
available.
It is noted that for endive, lettuce and brassicas, a low risk could be concluded for uses when the
treated crop is sown in permanent greenhouse.
As already mentioned above, in lack of specific toxicity data, a high risk for solitary bees was
identified using only surrogate toxicity estimation based on honeybee data. The high risk identified for
bumblebees for the uses on spring and winter oilseed rape and on sugar and fodder beets was based
on surrogate toxicity data.
The available data did not allow performing any refined risk assessment for exposure via dust drift.
Risk via consumption of contaminated water
Guttation
fluids
A low risk to honeybees was concluded for the uses on winter cereals, potato and sugar beet in
agreement with the evaluation of the confirmatory data for imidacloprid (EFSA, 2016b) and
clothianidin (EFSA, 2016c) and confirmed during the expert meeting related to this assessment. The
conclusion on sugar beet was extrapolated to fodder beet; therefore, a low risk was also concluded for
fodder beet.
For all other crops, a low risk to honeybees could not be demonstrated using the screening
assessment based on the solubility of imidacloprid.
However, it is noted that for endive, lettuce and brassicas, a low risk could be concluded for uses
when the treated crop is grown continuously in permanent greenhouse.
An exposure refinement could be considered for maize. The refined risk assessments indicated a
high risk to honeybees.
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Puddle water
A low risk is concluded to honeybees from residues in puddles for the seed treatment uses under
consideration.
Surface water
PECs in surface water considering FOCUS surface water modelling at Step 3 were calculated for the
uses under evaluation. The risk assessments considering these PECs resulted in a low risk to
honeybees. It is noted that no toxicity endpoint was available for the HPG development and data on
accumulative toxicity were not available.
6.2.
Granular uses
Only one use on granular formulation was considered in this assessment: the use on amenity turf.
Risk via systemic translocation in plants
residues in nectar and pollen
Treated crop scenario
A high risk at the Tier-1 was concluded. It should be noted that, in lack of specific toxicity data, a
high risk for solitary bees was identified using only surrogate toxicity estimation based on honeybee
data. It should also be noted that a low risk could be concluded for highly managed amenity turf
where regular mowing of the crop takes place.
The available data did not allow performing any refined risk assessment.
Weed scenario
A high risk at the Tier-1 was concluded. It should be noted that, in lack of specific toxicity data, a
high risk for solitary bees was identified using only surrogate toxicity estimation based on honeybee
data. It should also be noted that a low risk could be concluded for highly managed amenity turf,
which, in general, has a low abundance of attractive weeds and where regular mowing takes place.
The available data did not allow performing any refined risk assessment.
Succeeding crop scenario
A high risk at the Tier-1 was concluded. It should be noted that, in lack of specific toxicity data, a
high risk for solitary bees was identified using only surrogate toxicity estimation based on honeybee
data. Moreover, it is noted that typically amenity vegetation is grown for several years on the same
field.
Therefore, the succeeding crop is typically areal vegetation growing from the same root system.
The Tier-1 calculations for succeeding crop refer to the situations when the amenity vegetation is
removed as a result of the preparation of a seed bed to plant an attractive following crop.
The availability of residue data allowed carrying out a Tier-2 risk assessment for the succeeding
crop scenario. The Tier-2 risk assessment resulted in a high risk. As for the Tier-1 assessments, in lack
of specific toxicity data, a high risk for solitary bees was identified using only surrogate toxicity
estimations based on honeybee data.
A Tier-3 risk assessment was also carried out for honeybees and bumblebees, using data from
colony-feeder, semifield and
field
experiments that were available for honeybees and bumblebees. The
Tier-3 risk assessments resulted in a low risk for honeybees. For bumblebees, a high risk was indicated
by the risk assessments.
Risk from contamination of adjacent vegetation via dust drift
Field margin and adjacent crop scenarios
A high risk at the Tier-1 was concluded.
The available data did not allow performing any refined risk assessment for exposure via dust drift.
Risk via consumption of contaminated water
Guttation
fluids
A low risk to honeybees could not be demonstrated using the screening assessment based on the
solubility of imidacloprid.
The available data did not allow performing any refined risk assessment.
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Puddle water
A low risk is concluded to honeybees from residues in puddles for the seed treatment uses under
consideration.
Surface water
The risk assessment considering FOCUS surface water PECs resulted in a low risk to honeybees. It
is noted that no toxicity endpoint was available for the HPG development and data on accumulative
toxicity were not available.
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Table 19:
A summary of the conclusions for the tiered risk assessment
Honeybee
Treated crop
scenario
Treated crop
scenario
Succeeding
crop
Bumblebee
Treated crop
scenario
Succeeding
crop
Solitary bee
Succeeding
crop
R2
R2
R2
R2
R2
R2
R2
R2
R2
R2
Guttation
fluid
Adjacent
crop
Adjacent
crop
Surface
water
Field
margin
Field
margin
Spring cereals
(112–126 g
a.s./ha,
0.039 mg
a.s./seed)
Winter cereals
(43–126 g
a.s./ha,
0.015–0.039 mg
a.s./seed)
Cotton (100–
175 g a.s./ha,
0.63–0.84 mg
a.s./seed)
Endive and
lettuce
field
use
(104 g a.s./ha,
0.8 mg a.s./seed)
Harvested after
flowering
Endive and
lettuce
field
use
(104 g a.s./ha,
0.8 mg a.s./seed)
Harvested before
flowering
Tier 1
Tier 2
Tier 3
Tier 1
Tier 2
Tier 3
Tier 1
Tier 2
Tier 3
Tier 1
Tier 2
Tier 3
R1
N/R
R1
R1
R1
R1
L
R1
R1
L
R1
R1
L
R1
R1
L
R2
L
L
R1
N/R
R1
R1
R1
R1
R1
R1
R1
R1
R1
R1
R1
R1
R1
R1
R2
N/R
Field
margin
R2
R2
R2
R2
R2
Puddle
water
Use
Tier
R1
N/R
R1
R1
L
L
L
R1
N/R
R1
R1
R2
N/R
R1
N/R
R1
R1
R2
L
L
R1
N/R
R1
R1
R2
N/R
R1
N/R
R1
R1
R2
L
L
R1
N/R
R1
R1
R2
N/R
Tier 1
Tier 2
Tier 3
L
N/R
R1
R1
R1
R1
L
R2
L
L
L
N/R
R1
R1
R1
R1
R1
L
N/R
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Adjacent
crop
R2
R2
R2
R2
R2
Weed
scenario
Weed
scenario
Weed
scenario
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Honeybee
Treated crop
scenario
Treated crop
scenario
Succeeding
crop
Bumblebee
Treated crop
scenario
Succeeding
crop
Solitary bee
Succeeding
crop
R2
R2
R2
R2
L
Guttation
fluid
Adjacent
crop
Adjacent
crop
Surface
water
Field
margin
Field
margin
Endive, lettuce
and Brassica
(a)
,
transplanted from
non-permanent
greenhouse to
field
or to non-
permanent
greenhouse,
harvested after
flowering
Endive, lettuce
and Brassica
(a)
,
transplanted from
non-permanent
greenhouse to
field
or to non-
permanent
greenhouse,
harvested before
flowering
Endive, lettuce
and Brassica
(a)
,
transplanted from
non-permanent
greenhouse to
permanent
greenhouse,
harvested before
or after
flowering
Tier 1
Tier 2
Tier 3
R1
N/R
R1
R1
R1
R1
L
R2
L
L
R1
N/R
R1
R1
R1
R1
R1
R2
N/R
Field
margin
R2
R2
R2
Puddle
water
Use
Tier
Tier 1
Tier 2
Tier 3
L
N/R
R1
R1
R1
R1
L
R2
L
L
L
N/R
R1
R1
R1
R1
R1
L
N/R
Tier 1
Tier 2
Tier 3
L
N/R
R1
R1
L
L
L
L
L
N/R
R1
R1
L
L
N/R
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45
EFSA Journal 2018;16(2):5178
Adjacent
crop
R2
R2
R2
Weed
scenario
Weed
scenario
Weed
scenario
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2009981_0046.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Honeybee
Treated crop
scenario
Treated crop
scenario
Succeeding
crop
Bumblebee
Treated crop
scenario
Succeeding
crop
Solitary bee
Succeeding
crop
R2
R2
R2
R2
L
R2
R2
Guttation
fluid
Adjacent
crop
Adjacent
crop
Surface
water
Field
margin
Field
margin
Endive, lettuce
and Brassica
(a)
,
transplanted from
permanent
greenhouse to
field
or to non-
permanent
greenhouse,
harvested after
flowering
Endive, lettuce
and Brassica
(a)
,
transplanted from
permanent
greenhouse to
field
or to non-
permanent
greenhouse,
harvested before
flowering
Endive, lettuce
and Brassica
(a)
,
transplanted from
permanent
greenhouse to
permanent
greenhouse,
harvested before
or after
flowering
Maize (60–100 g
a.s./ha, 1 mg
a.s./seed)
Tier 1
Tier 2
Tier 3
R1
N/R
L
L
R1
R1
L
R2
L
L
R1
N/R
L
L
R1
R1
R1
R2
N/R
Field
margin
L
L
L
R2
Puddle
water
Use
Tier
Tier 1
Tier 2
Tier 3
L
N/R
L
L
R1
R1
L
R2
L
L
L
N/R
L
L
R1
R1
R1
L
N/R
Tier 1
Tier 2
Tier 3
L
N/R
L
L
L
L
L
L
L
N/R
L
L
L
L
N/R
Tier 1
Tier 2
Tier 3
R1
N/R
R1
R1
R1
R1
L
R2
R1
L
L
R1
N/R
R1
R1
R1
R1
R1
R2
N/R
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46
EFSA Journal 2018;16(2):5178
Adjacent
crop
L
L
L
R2
Weed
scenario
Weed
scenario
Weed
scenario
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0047.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Honeybee
Treated crop
scenario
Treated crop
scenario
Succeeding
crop
Bumblebee
Treated crop
scenario
Succeeding
crop
Solitary bee
Succeeding
crop
R2
R2
R2
R2
R2
R2
R2
R2
R2
R2
R2
R2
R2
R2
Guttation
fluid
Adjacent
crop
Adjacent
crop
Surface
water
Field
margin
Field
margin
Potato (120–
180 g a.s./ha)
Spring rape (9–
12 g a.s./ha,
0.01 mg a.s./
seed)
Winter rape (9–
12 g a.s./ha,
0.01 mg a.s./
seed)
Sugar and fodder
beet (13 g a.s./
ha, 0.1 mg a.s./
seed)
Harvested after
flowering
Sugar and fodder
beet
(13 g a.s./ha,
0.1 mg a.s./seed)
Harvested before
flowering
Sugar and fodder
beet
(117 g a.s./ha,
0.9 mg a.s./
seed), harvested
after
flowering
Tier
Tier
Tier
Tier
Tier
Tier
1
2
3
1
2
3
X
N/R
R1
L
R1
R1
L
R1
N/R
R1
R1
R1
R1
L
R1
R1
L
R1
R1
L
R1
R1
L
L
L
L
X
N/R
R2
L
L
R1
N/R
R2
R2
R1
R1
R1
R1
R1
R1
R1
R1
R1
R1
R1
R1
X
N/R
R2
N/R
Tier 1
Tier 2
Tier 3
Tier 1
Tier 2
Tier 3
N/R
R1
R1
R2
L
L
R1
N/R
R2
R2
R2
N/R
Field
margin
R2
L
L
R2
Puddle
water
Use
Tier
N/R
L
L
L
L
L
R1
N/R
R2
R2
R2
N/R
Tier 1
Tier 2
Tier 3
L
N/R
L
L
R1
R1
L
L
L
L
L
N/R
R2
R2
R1
R1
R1
L
N/R
Tier 1
Tier 2
Tier 3
R1
N/R
L
L
R1
R1
L
L
L
L
R1
N/R
R2
R2
R1
R1
R1
R2
N/R
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47
EFSA Journal 2018;16(2):5178
Adjacent
crop
R2
L
L
R2
Weed
scenario
Weed
scenario
Weed
scenario
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0048.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Honeybee
Treated crop
scenario
Treated crop
scenario
Succeeding
crop
Bumblebee
Treated crop
scenario
Succeeding
crop
Solitary bee
Succeeding
crop
R2
R2
R2
(c)
R2
R2
(c)
R2
Guttation
fluid
Adjacent
crop
Adjacent
crop
Surface
water
Field
margin
Field
margin
Sugar and fodder
beet
(117 g a.s./ha,
0.9 mg a.s./
seed), harvested
before
flowering
Managed amenity
turf (golf courses,
sport grounds,
commercial and
residential lawns)
(150 g a.s./ha)
‘Highly’
managed
amenity turf (golf
courses, sport
grounds,
commercial and
residential
lawns)
(b)
(150 g a.s./ha)
Tier 1
Tier 2
Tier 3
L
N/R
L
L
R1
R1
L
L
L
L
L
N/R
R2
R2
R1
R1
R1
L
N/R
Field
margin
R2
R2
R2
Puddle
water
Use
Tier
Tier 1
Tier 2
Tier 3
R1
R1
R1
R1
R1
(c)
R1
L
R2
L
L
R1
R1
R1
R1
R1
(c)
R1
R1
R2
R2
Tier 1
Tier 2
Tier 3
L
L
R1
R1
R1
(c)
R1
L
R2
L
L
L
L
R1
R1
R1
(c)
R1
R1
L
L
L: A low risk is concluded for the risk assessment (for the
field
margin and adjacent crop scenario for the seed dressing uses, the use of a deflector was considered).
R1: A high risk is concluded on the basis of the assessment.
R2: A low risk cannot be demonstrated as a result of the assessment (screening-type risk assessment or incomplete conclusion at Tier-3).
X: Assessment not
finalised
(lack of exposure or endpoint for effects).
Empty grey box: no assessment.
N/R: scenario not relevant.
(a): The application rates for endive and lettuce are 89–120 g a.s./ha, 0.8–1.2 mg a.s./seed and for brassicas (flowering, head, leafy) 90 g a.s./ha, 1.5 mg a.s./seed). Brassicas (flowering, head,
leafy) includes crops like broccoli, cauliflowers, Brussels sprouts, head cabbages, Chinese cabbage and kales.
(b): Member States highlighted during the peer review that country-specific authorisations of some products are limited to some specific categories that are generally considered as
‘highly
managed amenity turf’. That includes generally low abundance of weeds and regular mowing of the
field,
which makes the
field,
in general, unattractive to bee species.
(c): Amenity vegetation is typically grown for several years on the same
field.
Therefore, the succeeding crop is typically areal vegetation growing from the same root system. The risk assessment
for succeeding crop refers to the situations when the amenity vegetation is removed as a result of the preparation of a seed bed to plant an attractive following crop.
www.efsa.europa.eu/efsajournal
48
EFSA Journal 2018;16(2):5178
Adjacent
crop
R2
R2
R2
Weed
scenario
Weed
scenario
Weed
scenario
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0049.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Overall appraisal of the uncertainty related to the risk assessment
In order to reach the aforementioned conclusions on the risk assessment of imidacloprid,
clothianidin, and thiamethoxam, EFSA has considered a large number of documents, reporting very
diverse experiments, where many heterogeneous endpoints were measured under different conditions
and using different methodologies.
One of the most relevant outputs of this complex exercise is to account for the uncertainty related to
the overall assessment. At the lower tier (e.g. Tier-1 and screening), this is accounted for by the use of
conservative estimates which is particularly important when standard Tier-1 parameters have been
extrapolated from more worse-case situations (e.g. in cases where data were lacking for a particular
crop). On the contrary, as acknowledged in EFSA (2013c), there are several routes of exposures which
are not covered by the risk assessment scheme (e.g. insect honeydew, exposure via soil).
At higher tiers (Tier-2 and Tier-3), the uncertainty starts to act in two opposite ways, and it is
worth breaking it up in different factors, whose relative importance can be investigated more in detail.
Several factors were identified as source of uncertainty when establishing the revised shortcut values
and exposure assessment goals. Some of them indicated that the estimated exposure assessment goals
might be overestimated with respect to the actual exposure to bees (e.g. calculation of the exposure
assessment goals using the maximum value from each trial, assuming residues equal to the LOQ every
time they were
>
LOQ), consequently have the potential to decrease the actual risk in comparison with
the present assessment. On the contrary, other factors may act in the opposite way (e.g. the sampling
frequency was insufficient to ensure that the peak residue was captured, limited number of residue trials
resulting in a lower capacity to ensure that the 90th percentile determination was captured).
Similar factors were identified as source of uncertainty for the estimates of exposure within the
effect experiments. For some sources of uncertainty which were applicable to both the calculation of
the exposure assessment goals and the estimated exposure within the experiments, it was ensured
that the same assumption was equally applied to both. In this way, the uncertainty is balanced, e.g.
the same percentage of sugar content in nectar was assumed for both the exposure assessment goal
and the estimated exposure in the experiments.
Other sources of uncertainty are related to the quantification of the effects. In this case, the
direction of the uncertainty is rarely identifiable, as the uncertainty itself is linked to low reliability of
the experimental design/methodology and to the lack of precision in reporting the results.
Finally one of the most important sources of uncertainty is related to the presence of
‘confounding
factors’ in most of the higher tier experiments, particularly those performed under
field
conditions. As
an example, other chemicals (i.e. herbicides, fungicides, acaricides or other classes of insecticides)
were often applied to both the treatments and the control plots in line with standard
field
practises.
Nevertheless, the relative influence that exposure to these substances might have on the bees in the
control and in the treatment is unknown.
Furthermore, putting together the information from all
field
experiments considered for the present
risk assessment review (encompassing imidacloprid, clothianidin, and thiamethoxam), EFSA noted that
in more than 40% of the cases (15 experiments of 35), some matrices collected from the controls
(e.g. from hives, plants, or soils) were contaminated with at least one neonicotinoid substance.
Contamination of controls was sometimes even indicated in experiments where bee colonies were
exposed via contaminated sugar solutions.
It is worth noting that, in the large majority of the cases, the residue analysis only focused on the
substance used in the treatment and on its metabolites. There were only six studies where residues for
a wider range of neonicotinoid substances were investigated. Five of these experiments reported
residues of substances not included in the study design at quantifiable concentrations. Cross-
contamination from substances other than the test item resulted in some cases in residue levels
comparable to those due to the applied treatment.
Similar issues had been already pointed out by EFSA in relation to other studies not included in the
present review (EFSA, 2013a,b).
This
finding
can be explained considering that neonicotinoids substances have been largely used in
Europe for several years and on a wide range of crops. Furthermore, neonicotinoids insecticides are
persistent in the environment, particularly in soil. EFSA (2008) reported
field
DT
50
value ranging from
104 to 228 days for imidacloprid. For the other two substances, some DT
50
values are reported in the
respective EU review reports (European Commission, 2006a,b). The mean/median DT
50
values
reported therein are 156 days for clothianidin and 174 days for thiamethoxam. It might be worth
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49
EFSA Journal 2018;16(2):5178
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2009981_0050.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
noting that the main soil metabolite of thiamethoxam is clothianidin, so the DT
50
of the active
substance alone is not fully representative of the whole exposure time-variable profile.
It is important to note that this
finding
has implications on different aspects of the present Tier-3
risk assessment for the treated crop and succeeding crops scenarios. Firstly, it impaired the reliability
of some experiments where contamination of controls was recorded. Furthermore, it creates high
uncertainty around the reliability of the results for those studies where either residue measurements
were not available or, as in the vast majority of the studies, where substances other than the test item
were not properly investigated. In general, this
finding
highlights a general disadvantage about the use
of
field
studies for addressing the risk assessment. It exposed a source of uncertainty related to the
biological observations from
field
studies, particularly for their interpretation and their reliability when
used in the risk assessment.
It is very likely that one cause of the control contamination/cross-contamination recorded in the
available studies was due to applications performed during previous years on the control plots.
Other sources may be from other treated crops or contaminated plants in the landscape. It is
acknowledged that the same mechanism had the potential to artificially increase the exposure in the
‘treated’
groups of the experiments, thus potentially amplifying effects expected from the treatment alone.
Nevertheless, widespread use of these substances makes this situation likely to occur in the environment,
and the data should not necessarily be disregarded as uninformative for the present risk assessment.
7.
Overview of the concerns identified for each representative use
considered
Summary of concerns for each scenario according to the risk assessment scheme in EFSA
(2013c)
Honeybee
X
X
X
X
X
Bumblebee
X
X
X
X
X
Solitary bee
X
X
X
X
X
Table 20:
Use
Spring cereals
Winter cereals
Cotton
Endive and lettuce,
field
use,
Harvested before or after
flowering
Endive, lettuce, Brassica, sown in or transplanted to non-
permanent greenhouse,
Harvested before or after
flowering
Endive, lettuce, Brassica, sown and grown in permanent
greenhouse,
Harvested before or after
flowering
Maize
Potato
Spring rape
Winter rape
Sugar and fodder beet
Harvested after
flowering
Sugar and fodder beet
Harvested before
flowering
Managed amenity turf,
‘highly’
managed amenity turf
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
References
EFSA (European Food Safety Authority), 2008. Conclusion regarding the peer review of the pesticide risk
assessment of the active substance imidacloprid. EFSA Journal 2008;6(5):148, 120 pp.
https://doi.org/10.
2903/j.efsa.2008.148r
EFSA (European Food Safety Authority), 2013a. Conclusion on the peer review of the pesticide risk assessment for
bees for the active substance imidacloprid. EFSA Journal 2013;11(1):3066, 58 pp.
https://doi.org/10.2903/j.
efsa.2013.3066
EFSA (European Food Safety Authority), 2013b. Evaluation of the FERA study on bumblebees and consideration of
its potential impact on the EFSA conclusions on neonicotinoids. EFSA Journal 2013;11(6):3242, 20 pp.
https://doi.org/10.2903/j.efsa.2013.3242
www.efsa.europa.eu/efsajournal
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EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0051.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
EFSA (European Food Safety Authority), 2013c. EFSA Guidance Document on the risk assessment of plant
protection products on bees (Apis
mellifera, Bombus
spp. and solitary bees). EFSA Journal 2013;11(7):3295,
268 pp.
https://doi.org/10.2903/j.efsa.2013.3295
EFSA (European Food Safety Authority), 2014a. A small application developed in R for the estimation of the
residue intake rate for certain bee species under given conditions: the SHVAL tool. EFSA supporting publication
2014;11(7):EN-623, 15 pp.
https://doi.org/10.2903/sp.efsa.2014.EN-623
EFSA (European Food Safety Authority), 2014b. Technical report on the open call for new scientific information as
regards the risk to bees from the use of the three neonicotinoid pesticide active substances clothianidin,
imidacloprid and thiamethoxam applied as seed treatments and granules in the EU. EFSA supporting
publication 2014;11(10):EN-903, 8 pp.
https://doi.org/10.2903/sp.efsa.2014.EN-903
EFSA (European Food Safety Authority), 2015. Conclusion on the peer review of the pesticide risk assessment for
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https://doi.org/10.2903/j.efsa.2015.4210
EFSA (European Food Safety Authority), 2016a. Technical report on the outcome of the consultation with Member
States, the applicant and EFSA on the pesticide risk assessment for imidacloprid in light of confirmatory data.
EFSA Supporting Publication 2016;13(6):EN-1038, 62 pp.
https://doi.org/10.2903/sp.efsa.2016.EN-1038
EFSA (European Food Safety Authority), 2016b. Conclusion on the peer review of the pesticide risk assessment for
the active substance imidacloprid in light of confirmatory data submitted. EFSA Journal 2016;14(11):4607, 39 pp.
https://doi.org/10.2903/j.efsa.2016.4607
EFSA (European Food Safety Authority), 2016c. Conclusion on the peer review of the pesticide risk assessment for
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https://doi.org/10.2903/j.efsa.2016.4606
EFSA (European Food Safety Authority), 2018a. Evaluation of the data on clothianidin, imidacloprid and
thiamethoxam for the updated risk assessment to bees for seed treatments and granules in the EU. EFSA
supporting publication 2018:EN-1378, 31 pp.
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EFSA Scientific Committee, Hardy A, Benford D, Halldorsson T, Jeger MJ, Knutsen HK, More S, Naegeli H,
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Fryday S, Tiede K and Stein J, 2015. Scientific services to support EFSA systematic reviews: lot 5 Systematic
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and the risks to bees. EFSA supporting publication 2015:EN-756, 656 pp.
Abbreviations
1/n
k
a.s.
AChE
BBCH
slope of Freundlich isotherm
wavelength
active substance
acetylcholinesterase
growth stages of mono- and dicotyledonous plants
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BW
DT
50
EC
50
EEC
ETR
FOCUS
GAP
HPG
HQ
ISO
IUPAC
K
Foc
LD
50
LDD
50
LOD
LOEL
LOQ
mm
NOEC
NOED
NOEL
OECD
PEC
PEC
soil
PER
ppm
RI
RUD
SMILES
SPG
SVs
TGW
WoE
body weight
period required for 50% dissipation (define method of estimation)
effective concentration
European Economic Community
exposure toxicity ratio
Forum for the Co-ordination of Pesticide Fate Models and their Use
Good Agricultural Practice
hypopharyngeal glands
hazard quotient
International Organization for Standardization
International Union of Pure and Applied Chemistry
Freundlich organic carbon adsorption coefficient
lethal dose, median; dosis letalis media
lethal dietary dose; median
limit of detection
lowest observed effect level
limit of quantification
millimetre (also used for mean measured concentrations)
no observed effect concentration
no observed effect dose
no observed effect level
Organisation for Economic Co-operation and Development
predicted environmental concentration
predicted environmental concentration in soil
Proboscis Extension Reflex
parts per million (10
À6
)
residue intake
residue per unit dose
simplified molecular-input line-entry system
specific protection goal
shortcut values
thousand grain weight
weight of evidence
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MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
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Appendix A
List of supported uses
Appendix
A
can be found in the online version of this output (‘Supporting information’ section):
https://doi.org/10.2903/j.efsa.2018.5178
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MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
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Appendix B
Overview of endpoint types and related relevance class
assigned within the scope of the present risk assessment
Specie
Honeybee
Endpoint as defined in the
study/study evaluations
Family of
endpoint
Colony strength
Relevance to the
protection goal
Directly relevant. These
endpoints have a direct link
to the protection goal as the
correct entity was studied
Relevance
Class
1
Colony strength
Number of frames with
bees present
Forager mortality (far
from the hive)
Overwinter success
Overwintering
Overwintering (colony
strength)
Overwintering survival
Forager mortality
Overwintering
assessments
Mortality (in front of the
General mortality of Indirectly relevant. These
individuals
endpoints have an obvious,
hives)
but not quantified
Worker longevity
conceptual link to the
Foraging lifespan
protection goal (e.g.
Queen survival
Brood production
Brood development
(time)
Brood production (comb
area with eggs, larvae,
pupae)
Brood termination rate
Capped brood
Drone cells
Larvae mortality
Worker production
(yes/no)
2
mortality measured in front
of the hives consist of
forager mortality, but also
includes an unknown
proportion of mortality of in-
hive bees and do not include
forager mortality occurred in
the
field)
Homing failure
Homing success
Number of bees
returning to the hive
Number of returning
foragers
Homing success
Behavioural
Activity index
endpoint
Behaviour
Queen
flight
activity
Duration of foraging trip
Duration of the foraging
bouts
Flight activity (bees
exiting the hive)
Flight behaviour
Foraging/flight intensity
Learning ability/capacity
Mean time between
flights
Number of
flights
per
bee per day
Number of foraging
bouts
Indirectly relevant. These
endpoints likely have a link
to the protection goal, but
this link is not clear and not
quantified (e.g. a
detrimental effect on the
foraging behaviour may
contribute to the weakening
of the colony, but the link
between the two entities is
unknown)
3
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Specie
Endpoint as defined in the
study/study evaluations
Family of
endpoint
Relevance to the
protection goal
Relevance
Class
Number of visits to the
feeder
Time to
first
foraging
Time to
first
foraging
trip
Total
flight
time per bee
Swarming events
Pollination efficiency
Comb cell production
Comb construction
Comb building
Hive weight (including
Weight of the hive
hive, combs, food etc.)
Hive weight (including
hive, wax, food stores
etc.)
Weight gain of the hives
Disease
Varroa mite count
(prevalence)
Viral load of Black
queen cell virus (BQCV)
Viral load of Deformed
wing virus (DWV)
Viral load of Israeli
acute paralysis virus
(IAPV)
Food storage
Honey storage (area/
weight)
Pollen storage
Queen
Queen
Queen
Queen
rearing success
supersedure
survival
flight
activity
Food storage
Queen
Behaviour
Food consumption
influencing
Guttation
fluid
use
Quantity of taken syrup
exposure
Suborganism
Expression of AChE
endpoint
gene
Expression of genes
Apoptosis of neurons
Assessment of HPG
Lipid content of royal
jelly
Total haemocyte count
Encapsulation response
Not relevant. These
endpoints have no explicit
link to the protection goals
4
Ovary weight of queens
Subindividual mass
Queen subindividual
reproductive system
Thermoregulation
capacity
Thermoregulation
capacity
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Specie
Bumblebee
Endpoint as defined in the
study/study evaluations
Family of
endpoint
Colony strength
Relevance to the
protection goal
Directly relevant. These
endpoints have a direct link
to the protection goal as the
correct entity was studied
Relevance
Class
1
Colony strength
Number of foragers
Brood production (comb
Reproductive
area with eggs, larvae,
output
pupae)
Male vs. queen
production
Number of brood
Drone production
Egg production
No. of drones
No. of young queens
and queen brood cells
Produced queens (BB)
Produced workers (BB)
Queen production
Queens produced
Worker production
Worker/males produced
Reproductive output
[queenless
microcolonies]
Emergence rates
Mating ability
Total cast biomass
Queen mortality
Indirect
reproduction
Foraging/flight intensity
Behaviour
Learning ability
Duration of
flower
visit
(mean)
Duration of the foraging
bouts
Duration of the foraging
bouts for pollen only
Flower visitation rate
(flowers/bee per
minute)
Foraging time
Nectar load size
Number of forager
carrying pollen
Number of foraging
bouts
Number of foraging
days
Number of switches
between
flower
varieties
Pollen load size
Indirectly relevant. These
endpoints have an obvious,
but not quantified
conceptual link to the
protection goal (e.g.
emergence contributes to
the reproductive success,
but alone does not
determine the reproductive
output)
Indirectly relevant. These
endpoints likely have a link
to the protection goal, but
this link is not clear and not
quantified (e.g. a
detrimental effect on the
foraging behaviour may
contribute to the weakening
of the colony, but the link
between the two entities is
unknown)
2
3
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Specie
Endpoint as defined in the
study/study evaluations
Family of
endpoint
Relevance to the
protection goal
Relevance
Class
Solitary bee
Proportion of visit to a
certain
flower
variety
Time between
flower
visits
Visited
flowers
Learning ability (PER)
Hive weight (including
Weight of the nest
hive, wax, food stores
(colony)
etc.)
Weight gain of the hives
Honey storage (area/
weight)
Pollen storage
Food collection
Food storage
General mortality
Worker longevity
Dead bees (in the nest)
Death rate
Forager age
Forager mortality (far
from the hives)
Mortality (in front of the
hives)
Worker mortality
Queen mortality (old
queens)
Queen longevity
Mortality
Dead larvae
Homing success
Number of returning
foragers
BW (of individuals)
Weight of newly
emerged bees
Average bee weight
Cocoon weight
Worker size
Homing success
Individual mass
Quantity of taken syrup
Behaviour
Sugar water collection
influencing
exposure
Not relevant. This endpoint
has no explicit link to the
protection goals
Directly relevant. These
endpoints have a direct link
to the protection goal as the
correct entity was studied
4
Emergence after winter
Reproductive
output
Hatching success
Offspring failure
Overwinter success
Overwintering
(hatching)
Cell production
Completed nests
Nest occupation
Number of tubes with
brood cells
1
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Specie
Endpoint as defined in the
study/study evaluations
Family of
endpoint
Relevance to the
protection goal
Relevance
Class
Offspring (cocoon)
production
Reproduction rate
Undeveloped eggs and
larvae
Cocoon weight
Offspring weight
Sex ratio after
emergence
Cocoon sex
Indirect
Indirectly relevant. These
reproductive output endpoints have an obvious,
but not quantified
conceptual link to the
protection goal
Indirectly relevant. These
endpoints likely have a link
to the protection goal, but
this link is not clear and not
quantified (e.g. a
detrimental effect on the
foraging intensity may have
an indirect effect on the
reproductive success, but
the link between the two
entities is unknown)
2
Foraging/flight intensity
Behaviour
Forager mortality
General mortality
3
AChE: acetylcholinesterase; BW: body weight.
Notes: Colony survival length was assessed in a single experiment C.1290. As it is a Class 1 endpoint, in principle it should have
been considered further in the assessment. However, as the endpoint was assessed to be unreliable, no further consideration
was given to this endpoint type.
Non-Apis bee monitoring was assessed in a single experiment C.1184. As it is a Class 1 endpoint, in principle it should have been
considered further in the assessment. However, as the endpoint was assessed to be unreliable, no further consideration was
given to this endpoint type.
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Appendix C
Tier-1 risk assessment based on EFSA (2013c)
Contact exposure and exposure to consumption of contaminated pollen and nectar
1) Seed treatment
Spring cereals 112 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ: hazard quotient.
Bumblebee
HQ
5.1
Trigger
2.3
Solitary bee
HQ
441.8
Trigger
2.6
HQ
44.2
Trigger
14
Spring cereals 112 g a.s./ha, 0.039 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
Chronic
Succeeding crop
Treated crop
Field margin
Adjacent crop
Larva
Succeeding crop
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR: exposure toxicity ratio.
Bumblebee
ETR
0.03
0.19
0.16
2.65
4.15
23.20
18.87
309.79
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1.05
6.89
8.28
148.32
1.38
9.04
10.87
194.61
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
0.13
1.11
1.10
21.19
0.17
1.14
1.11
21.45
0.01
0.46
0.45
8.48
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Winter cereals 43 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ
17.0
Trigger
14
Bumblebee
HQ
2.0–19.5*
Trigger
2.3
Solitary bee
HQ
169.6
Trigger
2.6
HQ: hazard quotient.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013c.
Winter cereals 43 g a.s./ha, 0.015 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
Succeeding crop
Chronic
Treated crop
Field margin
ETR
0.05
0.43
0.42
8.14
0.06
0.44
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
Bumblebee
ETR
0.01
0.07
0.06
1.02
1.60
8.91
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
Solitary bee
ETR
0.41
2.65
3.18
56.95
0.53
3.47
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
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Honeybee
Category
Scenario
Adjacent crop
Succeeding crop
Larva
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR
0.42
8.23
0.01
0.18–1.77*
0.17–1.72*
3.26
Trigger
0.03
0.03
0.2
0.2
0.2
0.2
Bumblebee
ETR
7.25
118.94
Trigger
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
4.17
74.72
Trigger
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA (2013c).
Spring and Winter cereals 126 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ: hazard quotient.
Bumblebee
HQ
5.7
Trigger
2.3
Solitary bee
HQ
497.0
Trigger
2.6
HQ
49.7
Trigger
14
Spring and Winter cereals 126 g a.s./ha, 0.039 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
Chronic
Succeeding crop
Treated crop
Field margin
Adjacent crop
Larva
Succeeding crop
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR
0.13
1.25
1.24
23.84
0.17
1.28
1.24
24.13
0.01
0.52
0.50
9.55
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Bumblebee
ETR
0.03
0.21
0.18
2.98
4.15
26.10
21.23
348.51
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1.05
7.75
9.32
166.86
1.38
10.17
12.22
218.94
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
Cotton 100 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
field
margin
HQ: hazard quotient.
Bumblebee
HQ
7.8
Trigger
2.3
Solitary bee
HQ
677.3
Trigger
2.6
HQ
67.7
Trigger
14
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Cotton 100 g a.s./ha, 0.63 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
Succeeding crop
Chronic
Treated crop
Field margin
Adjacent crop
Succeeding crop
Larva
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR: exposure toxicity ratio.
Bumblebee
ETR
14.92
0.29
0.24
2.37
1742.55
35.15
28.44
276.60
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
834.32
10.44
12.48
132.43
1094.68
13.70
16.37
173.76
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
119.19
1.68
1.66
18.92
120.64
1.73
1.67
19.15
47.73
0.70
0.68
7.58
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Cotton 175 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ: hazard quotient.
Bumblebee
HQ
13.6
Trigger
2.3
Solitary bee
HQ
1185.3
Trigger
2.6
HQ
118.5
Trigger
14
Cotton 175 g a.s./ha, 0.84 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
Chronic
Succeeding crop
Treated crop
Field margin
Adjacent crop
Larva
Succeeding crop
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR: exposure toxicity ratio.
Bumblebee
ETR
19.89
0.50
0.42
4.14
2323.40
61.51
49.76
484.04
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1112.43
18.28
21.84
231.76
1459.57
23.98
28.65
304.08
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
158.92
2.94
2.91
33.11
160.85
3.02
2.92
33.51
63.64
1.23
1.18
13.26
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
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Endive 104 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ: hazard quotient.
Bumblebee
HQ
8.1
Trigger
2.3
Solitary bee
HQ
704.4
Trigger
2.6
HQ
70.4
Trigger
14
Endive 104 g a.s./ha, 0.8 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop*
Field margin
Adjacent crop
Succeeding crop
Chronic
Treated crop*
Field margin
Adjacent crop
Succeeding crop
Larva
Treated crop*
Field margin
Adjacent crop
Succeeding crop
ETR
151.35
1.75
1.73
19.68
153.19
1.80
1.73
19.91
60.61
0.73
0.70
7.88
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Bumblebee
ETR
18.95
0.30
0.25
2.46
2212.77
36.55
29.57
287.66
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1059.46
10.86
12.98
137.73
1390.07
14.25
17.03
180.71
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
*: Not relevant when the crop is harvested before it
flowers.
Note: The
‘Leafy
vegetable’ scenario was considered in these calculations above.
Lettuce 104 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ: hazard quotient.
Bumblebee
HQ
8.1
Trigger
2.3
Solitary bee
HQ
704.4
Trigger
2.6
HQ
70.4
Trigger
14
Lettuce 104 g a.s./ha, 0.8 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop*
Field margin
Adjacent crop
Chronic
Succeeding crop
Treated crop*
Field margin
Adjacent crop
Larva
Succeeding crop
Treated crop*
Field margin
ETR
2.59
1.75
1.73
19.68
3.40
1.80
1.73
19.91
0.30
0.73
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
Bumblebee
ETR
18.95
0.30
0.25
2.46
85.11
36.55
29.57
287.66
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
Solitary bee
ETR
1059.46
10.86
12.98
137.73
28.37
14.25
17.03
180.71
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
www.efsa.europa.eu/efsajournal
62
EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0063.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Honeybee
Category
Scenario
Adjacent crop
Succeeding crop
ETR
0.70
7.88
Trigger
0.2
0.2
Bumblebee
ETR
Trigger
0.2
0.2
Solitary bee
ETR
Trigger
0.2
0.2
ETR: exposure toxicity ratio.
*: Not relevant when the crop is harvested before it
flowers.
Maize 60 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
field
margin
HQ: hazard quotient.
Bumblebee
HQ
4.7
Trigger
2.3
Solitary bee
HQ
406.4
Trigger
2.6
HQ
40.6
Trigger
14
Maize 60 g a.s./ha, 1.0 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
Succeeding crop
Chronic
Treated crop
Field margin
Adjacent crop
Succeeding crop
Larva
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR: exposure toxicity ratio.
Bumblebee
ETR
0.79
0.17
0.14
1.42
106.38
21.09
17.06
165.96
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
27.03
6.27
7.49
79.46
35.46
8.22
9.82
104.26
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
3.24
1.01
1.00
11.35
4.26
1.04
1.00
11.49
0.38
0.42
0.41
4.55
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Maize 100 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ: hazard quotient.
Bumblebee
HQ
7.8
Trigger
2.3
Solitary bee
HQ
677.3
Trigger
2.6
HQ
97.7
Trigger
14
Maize 100 g a.s./ha, 1.0 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
succeeding crop
ETR
3.24
1.68
1.66
18.92
Trigger
0.2
0.2
0.2
0.2
Bumblebee
ETR
0.79
0.29
0.24
2.37
Trigger
0.036
0.036
0.036
0.036
Solitary bee
ETR
27.03
10.44
12.48
132.43
Trigger
0.04
0.04
0.04
0.04
www.efsa.europa.eu/efsajournal
63
EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0064.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Honeybee
Category
Chronic
Scenario
Treated crop
Field margin
Adjacent crop
Larva
Succeeding crop
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR: exposure toxicity ratio.
Bumblebee
ETR
106.38
35.15
28.44
276.60
Trigger
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
35.46
13.70
16.37
173.76
Trigger
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
4.26
1.73
1.67
19.15
0.38
0.70
0.68
7.58
Trigger
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Potato 120 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ
N/R
Trigger
14
HQ
N/R
Bumblebee
Trigger
2.3
HQ
N/R
Solitary bee
Trigger
2.6
N/R: not relevant; HQ: hazard quotient.
Potato 120 g a.s./ha
(application rate expressed as mg a.s./tuber was not available)
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
scenario
Treated crop
Field margin
Adjacent crop
Succeeding crop
Chronic
Treated crop
Field margin
Adjacent crop
Succeeding crop
Larva
Treated crop
Field margin
Adjacent crop
Succeeding crop
N/R: not relevant; ETR: exposure toxicity ratio.
Bumblebee
ETR
N/R
N/R
2.84
N/R
N/R
331.91
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
N/R
N/R
158.92
N/R
N/R
208.51
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
N/R
N/R
22.70
N/R
N/R
22.98
N/R
N/R
9.09
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Potato 180 g a.s./ha
Acute contact exposure
HQ
Honeybee
scenario
Field margin
HQ
N/R
Trigger
14
HQ
N/R
Bumblebee
Trigger
2.3
Solitary bee
HQ
N/R
Trigger
2.6
N/R: not relevant; HQ: hazard quotient.
www.efsa.europa.eu/efsajournal
64
EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0065.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Potato 180 g a.s./ha
(application rate expressed as mg a.s./tuber was not available)
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Feld margin
Adjacent crop
Chronic
Succeeding crop
Treated crop
Field margin
Adjacent crop
Larva
Succeeding crop
Treated crop
Field margin
Adjacent crop
Succeeding crop
N/R: not relevant; ETR: exposure toxicity ratio.
Bumblebee
ETR
N/R
N/R
4.26
N/R
N/R
497.87
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
N/R
N/R
238.38
N/R
N/R
312.77
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
N/R
N/R
34.05
N/R
N/R
34.47
N/R
N/R
13.64
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Spring and winter rape 9 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ
2.4–23.7*
Trigger
14
Bumblebee
HQ
0.3–2.7*
Trigger
2.3
Solitary bee
HQ
23.7
Trigger
2.6
HQ: hazard quotient.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013c.
Spring and winter rape 9 g a.s./ha, 0.01 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
Succeeding crop
Chronic
Treated crop
Field margin
Adjacent crop
Succeeding crop
Larva
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR
1.89
0.06–0.59*
0.06–0.61*
1.70
1.91
0.06
0.06
1.72
0.76
0.02
0.02
0.68
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Bumblebee
ETR
0.24
0.01–0.1*
0.01–0.09*
0.21
27.66
1.24
1.04
24.89
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
13.24
0.37
0.46
11.92
17.38
0.48
0.60
15.64
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013c.
www.efsa.europa.eu/efsajournal
65
EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0066.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Spring and winter rape 12 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ
3.2–31.6*
Trigger
14
Bumblebee
HQ
0.4–3.6*
Trigger
2.3
Solitary bee
HQ
31.6
Trigger
2.6
HQ: hazard quotient.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013a.
Spring and winter rape 12 g a.s./ha, 0.01 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
Field margin
Adjacent crop
Chronic
Succeeding crop
Treated crop
Field margin
Adjacent crop
Larva
Succeeding crop
Treated crop
Field margin
Adjacent crop
Succeeding crop
ETR
1.89
0.08–0.79*
0.08–0.81*
2.27
1.91
0.08
0.08
2.30
0.76
0.03–0.33*
0.03–0.33*
0.91
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Bumblebee
ETR
0.24
0.01–0.14*
0.01–0.12*
0.28
27.66
1.66
1.39
33.19
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
13.24
0.49
0.61
15.89
17.38
0.65
0.80
20.85
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013c.
Sugar and fodder beet 13 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ
0.0–0.2*
Trigger
14
Bumblebee
HQ
0.00–0.002*
Trigger
2.3
Solitary bee
HQ
0.2–1.6*
Trigger
2.6
HQ: hazard quotient.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013c.
Note: The
‘Sugar
beet’ scenario was considered for both the sugar beet and the fodder beet crops.
Sugar and fodder beet 13 g a.s./ha, 0.1 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category Scenario
Acute
Treated crop**
Field margin
Adjacent crop
Succeeding crop
Chronic
Treated crop**
Field margin
Adjacent crop
Succeeding crop
ETR
18.92
0.00–0.00*
0.00–0.00*
2.46
19.15
0.00–0.00*
0.00–0.00*
2.49
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
Bumblebee
ETR
2.37
0.00–0.00*
0.00-0.00*
0.31
276.60
0.01
0.01
35.96
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
Solitary bee
ETR
132.43
0.00–0.02*
0.00–0.03*
17.22
173.76
0.00–0.03*
0.00–0.04*
22.59
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
www.efsa.europa.eu/efsajournal
66
EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0067.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Honeybee
Category Scenario
Larva
Treated crop**
Field margin
Adjacent crop
Succeeding crop
ETR
7.58
0.00–0.00*
0.00–0.00*
0.98
Trigger
0.2
0.2
0.2
0.2
Bumblebee
ETR
Trigger
0.2
0.2
0.2
0.2
Solitary bee
ETR
Trigger
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013c
**: Not relevant when the crop is harvested before it
flowers
Note: The
‘Sugar
beet’ scenario was considered for both the sugar beet and the fodder beet crops.
Sugar and fodder beet 117 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin
HQ
0.1–1.4*
Trigger
14
Bumblebee
HQ
0.0–0.2*
Trigger
2.3
Solitary bee
HQ
1.4–14.0*
Trigger
2.6
HQ: hazard quotient.
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013c
Note: The
‘Sugar
beet’ scenario was considered for both the sugar beet and the fodder beet crops.
Sugar and fodder beet 117 g a.s./ha, 0.9 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category Scenario
Acute
Treated crop**
Field margin
Adjacent crop
Chronic
Succeeding crop
Treated crop**
Field margin
Adjacent crop
Larva
Succeeding crop
Treated crop**
Field margin
Adjacent crop
Succeeding crop
ETR
170.3
0.00–0.04*
0.00–0.04*
22.14
172.3
0.00–0.04*
0.00–0.04*
22.40
68.2
0.00–0.01*
0.00–0.01*
8.86
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Bumblebee
ETR
21.3
0.00–0.01*
0.00–0.01*
2.77
2489.3
0.07
0.06
323.62
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1191.9
0.02–0.22*
0.03–0.27*
154.95
1563.8
0.03
0.04
203.30
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio;
*: The higher value reflects a scenario sowing without deflector as considered in EFSA, 2013c
**: Not relevant when the crop is harvested before it
flowers
Note: The
‘Sugar
beet’ scenario was considered for both the sugar beet and the fodder beet crops.
2) Seed treatment as dummy pill uses
Brassica,
flowering,
head, leafy, Endive, Lettuce, 90 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
Field margin*
HQ
61.0
Trigger
14
HQ
7.0
Bumblebee
Trigger
2.3
Solitary bee
HQ
609.6
Trigger
2.6
HQ: hazard quotient.
*: Not relevant when the application is done in permanent greenhouse.
www.efsa.europa.eu/efsajournal
67
EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0068.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Brassica,
flowering,
head, leafy, 90 g a.s./ha, 1.5 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
Chronic
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
Larva
Treated crop
(a,b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
Bumblebee
ETR
35.53
0.26
0.21
2.13
4148.94
31.63
25.59
248.94
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1986.49
9.40
11.23
119.19
2606.38
12.33
14.74
156.38
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
283.78
1.51
1.50
17.03
287.23
1.55
1.50
17.23
113.64
0.63
0.61
6.82
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
(a): Not relevant when the crop is harvested before it
flowers.
(b): Not relevant when the crop is grown in permanent structure greenhouse.
(c): Not relevant when the application is done in permanent greenhouse.
Endive, Lettuce 89 g a.s./ha
Acute contact exposure
HQ
Honeybee
Scenario
field
margin*
HQ
60.3
Trigger
14
HQ
6.9
Bumblebee
Trigger
2.3
Solitary bee
HQ
602.8
Trigger
2.6
HQ: hazard quotient.
*: Not relevant when the application is done in permanent greenhouse.
Endive, 89 g a.s./ha, 0.8 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Chronic
Succeeding crop
(b)
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Larva
Succeeding crop
(b)
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
ETR
151.35
1.50
1.48
16.84
153.19
1.54
1.48
17.04
60.61
0.62
0.60
6.74
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Bumblebee
ETR
18.95
0.26
0.21
2.11
2212.77
31.28
25.31
246.17
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1059.46
9.29
11.11
117.86
1390.07
12.19
14.57
154.65
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
(a): Not relevant when the crop is harvested before it
flowers.
(b): Not relevant when the crop is grown in permanent structure greenhouse.
(c): Not relevant when the application is done in permanent greenhouse.
Note: The
‘Leafy
vegetable’ scenario was considered in the calculations above.
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Lettuce, 89 g a.s./ha, 0.8 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
(a),(b)
Field margin
Adjacent crop
(c)
Chronic
Succeeding crop
(b)
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Larva
Aucceeding crop
(b)
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
(c)
Bumblebee
ETR
18.95
0.26
0.21
2.11
85.11
31.28
25.31
246.17
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1059.46
9.29
11.11
117.86
28.37
12.19
14.57
154.65
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
2.59
1.50
1.48
16.84
3.40
1.54
1.48
17.04
0.30
0.62
0.60
6.74
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
(a): Not relevant when the crop is harvested before it
flowers.
(b): Not relevant when the crop is grown in permanent structure greenhouse.
(c): Not relevant when the application is done in permanent greenhouse.
Endive, Lettuce, 120 g a.s./ha
Acute contact exposure
HQ
Honeybee
scenario
field
margin*
HQ
81.3
Trigger
14
HQ
9.4
Bumblebee
Trigger
2.3
Solitary bee
HQ
812.7
Trigger
2.6
HQ: hazard quotient.
*: Not relevant when the application is done in permanent greenhouse.
Endive, 120 g a.s./ha, 1.2 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category
Acute
Scenario
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
Chronic
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
Larva
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
ETR
227.03
2.02
2.00
22.70
229.79
2.07
2.00
22.98
90.91
0.84
0.81
9.09
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
Bumblebee
ETR
28.42
0.34
0.29
2.84
3319.15
42.18
34.12
331.91
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1589.19
12.53
14.97
158.92
2085.11
16.44
19.65
208.51
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
(a): Not relevant when the crop is harvested before it
flowers.
(b): Not relevant when the crop is grown in permanent structure greenhouse.
(c): Not relevant when the application is done in permanent greenhouse.
Note: The
‘Leafy
vegetable’ scenario was considered in these calculations above.
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Lettuce, 120 g a.s./ha, 1.2 mg a.s./seed
Acute, chronic and larvae oral exposure
ETRs
Honeybee
category
Acute
scenario
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
Chronic
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
Larva
Treated crop
(a),(b)
Field margin
(c)
Adjacent crop
(c)
Succeeding crop
(b)
Bumblebee
ETR
28.42
0.34
0.29
2.84
127.66
42.18
34.12
331.91
Trigger
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.2
0.2
0.2
0.2
Solitary bee
ETR
1589.19
12.53
14.97
158.92
42.55
16.44
19.65
208.51
Trigger
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.2
0.2
0.2
0.2
ETR
3.89
2.02
2.00
22.70
5.11
2.07
2.00
22.98
0.45
0.84
0.81
9.09
Trigger
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.2
0.2
0.2
0.2
ETR: exposure toxicity ratio.
(a): Not relevant when the crop is harvested before it
flowers.
(b): Not relevant when the crop is grown in permanent structure greenhouse.
(c): Not relevant when the application is done in permanent greenhouse.
3) Granular uses
Managed amenity turf, 150 g a.s./ha
Acute contact exposure
HQ
Honeybee
scenario
treated crop
weeds
field
margin
BBCH
10
10
All stages
HQ
597.6
597.6
573.7
Trigger
14
14
14
Bumblebee
HQ
68.8
68.8
66.1
Trigger
2.3
2.3
2.3
Solitary bee
HQ
5976.1
5976.1
5737.1
Trigger
2.6
2.6
2.6
BBCH: growth stages of mono- and dicotyledonous plants; HQ: hazard quotient.
Acute, chronic and larvae oral exposure
ETRs
Honeybee
Category Scenario
Acute
Treated crop
BBCH
<
10
70
10–69
Weeds
Field margin
All stages
All stages
ETR
28.38
0.00
92.43
45.00
14.40
13.86
28.38
28.72
0.00
92.55
46.28
14.81
13.88
28.72
Trigger
0.2
0.2
0.2
0.2
0.2
0.2
0.2
0.03
0.03
0.03
0.03
0.03
0.03
0.03
Bumblebee
ETR
3.55
0.00
13.26
7.70
2.46
1.99
3.55
414.89
0.00
1579.79
941.49
301.28
236.97
414.89
Trigger
0.036
0.036
0.036
0.036
0.036
0.036
0.036
0.0048
0.0048
0.0048
0.0048
0.0048
0.0048
0.0048
Solitary bee
ETR
198.65
0.00
693.24
279.73
89.51
103.99
198.65
260.64
0.00
909.57
367.02
117.45
136.44
260.64
Trigger
0.04
0.04
0.04
0.04
0.04
0.04
0.04
0.0054
0.0054
0.0054
0.0054
0.0054
0.0054
0.0054
Adjacent crop
All stages
(a)
Succeeding crop
All stages
Chronic
Treated crop
<
10
70
10–69
All stages
All stages
All stages
Weeds
Field margin
Adjacent crop
Succeeding crop
(a)
All stages
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Honeybee
Category Scenario
Larva
Treated crop
BBCH
<
10
70
10–69
Weeds
Field margin
Adjacent crop
Succeeding crop
(a)
Bumblebee
ETR
Trigger
0.2
0.2
0.2
0.2
0.2
0.2
0.2
Solitary bee
ETR
Trigger
0.2
0.2
0.2
0.2
0.2
0.2
0.2
ETR
11.36
0.00
37.50
18.75
6.00
5.63
11.36
Trigger
0.2
0.2
0.2
0.2
0.2
0.2
0.2
All stages
All stages
All stages
All stages
BBCH: growth stages of mono- and dicotyledonous plants; ETR: exposure toxicity ratio.
(a): This scenario refers to the situations when the amenity vegetation is removed as a result of the preparation of a seed bed to
plant an attractive following crop.
Tier-1 Screening
Risk from residues in guttation
fluid
All outdoor
field
uses
Honeybee
Category
Acute
Chronic
Larva
Water uptake
11.4
lL/bee
per day
11.4
lL/bee
per day
111
lL/larva
per 5 days
ETR
1,889
1,338
9,279
Trigger
0.2
0.03
0.2
ETR: exposure toxicity ratio.
Note: calculations based on the water solubility of 613 mg/L (demineralised water, pH 5.5, 20°C), EFSA, 2008.
Tier-1
Risk from residues in surface water
All outdoor
field
uses (represented by winter cereals)*
Honeybee
Category
Acute
Chronic
Larva
Water uptake
11.4
lL/bee
per day
11.4
lL/bee
per day
111
lL/larva
per 5 days
ETR
0.0002
0.0003
0.0016
Trigger
0.2
0.03
0.2
ETR: exposure toxicity ratio.
*: Represented by the highest PEC surface water of 0.075
lg/L,
which was calculated for the D6 ditch scenario from the use on
winter cereals.
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Appendix D
Measured residue values and RUD values used for calculation of exposure assessment goals
Exposure
assessment
goal
Study
type
Field
Field
Semifield
Semifield
Field
Field
Field
Field
Field
Field
Semifield
Semifield
Field
Field
Maximum
Seed
measured
loading
residue value
mg/seed
mg/kg
0.0191
0.0105
(a)
0.0398
0.0398
0.0211
(a)
0.01
(a)
0.0488
(a)
0.0488
(a)
0.0191
(a)
0.0105
(a)
0.0398
0.0398
0.0211
(a)
0.01
(a)
<
0.0003
<
0.0008
<
0.0015
<
0.005
0.009
<
0.0008
<
0.001
0.0076
<
0.0003
<
0.0002
<
0.005
<
0.005
0.01
<
0.0002
Crop
Matrix
Site
RUD mg/kg
Reference
Honeybee pollen Winter oilseed
rape
for winter
oilseed rape
Spring oilseed
rape
Sorted oilseed rape pollen from foragers
Pollen from pollen trap
Pollen from foragers
Pollen from foragers
Sorted oilseed rape pollen from foragers
Pollen from pollen trap
Pollen from pollen trap
Sorted canola pollen from pollen trap
Germany
Poland
Germany
Germany
Germany
Poland
Canada
USA
Germany
Poland
Germany
Germany
Germany
Poland
0.015707
0.07619
0.037688
0.125628
0.42654
0.08
0.02049
0.155738
0.015707
0.019048
0.125628
0.125628
0.473934
0.02
I.1094
All+.1080
E 370 1548-8
E 370 1553-4
I.1095
All+.1080
110403 CAN/US
110403 CAN/US
I.1094
All+.1080
E 370 1548-8
E 370 1553-4
I.1095
All+.1080
Honeybee
Winter oilseed
nectar for winter rape
oilseed rape
Spring oilseed
rape
Nectar from foragers
Nectar from
flowers
Nectar from
flowers
Nectar from
flowers
Nectar from foragers
Nectar from
flowers
RUD: residue per unit dose.
(a): Seed loading in terms of mg a.s./seed not provided in the study and could not be calculated from the available information. The RUD was therefore calculated assuming thousand grain weight
(TGW) of 5 g/1,000 seeds.
Reference
Exposure
assessment
goal
Crop
Matrix
No of sampling
events during
flowering
Tot No
samples
4
20
2
2
LOQ
lg/kg
0.3
0.8
5
5
Range
lg/kg
<
0.3
<
0.8
<
1.5
<
5
No
samples
LOQ
4
20
2
2
No
samples
No samples
>
LOQ
10
>
10
lg/kg
lg/kg
0
0
0
0
0
0
0
0
I.1094
All+.1080
E 370 1548-8
E 370 1553-4
Honeybee pollen Winter
oilseed
for winter
rape
oilseed rape
Sorted oilseed rape
3
pollen from foragers
Pollen from pollen trap 4, from 3 to 4
day duration
Pollen from foragers
Pollen from foragers
2
2
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Reference
Exposure
assessment
goal
Crop
Matrix
No of sampling
events during
flowering
Tot No
samples
4
20
2
2
3
6
Not reported
Not reported
5
6
LOQ
lg/kg
0.3
0.8
1
1
0.3
0.2
5
5
0.3
0.2
Range
lg/kg
<
0.3–9
<
0.8
<
1
<
1–7.6
<
0.3
<
0.2
<
5
<
5
<
0.3–10
<
0.2
No
samples
LOQ
1
20
2
1
3
All
All
All
0
All
No
No samples
samples
>
LOQ
10
>
10
lg/kg
lg/kg
3
0
0
1
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
I.1095
All+.1080
110403 CAN/US
110403 CAN/US
I.1094
All+.1080
E 370 1548-8
E 370 1553-4
I.1095
All+.1080
LOQ: limit of quantification.
Spring
oilseed
rape
Sorted oilseed rape
3
pollen from foragers
Pollen from pollen trap 4, from 3 to 4
day duration
Pollen from pollen trap 2
Sorted canola pollen
2
from pollen trap
Honeybee nectar Winter
oilseed
for winter
rape
oilseed rape
Spring
oilseed
rape
Nectar from foragers
Nectar from
flowers
Nectar from
flowers
Nectar from
flowers
Nectar from foragers
Nectar from
flowers
3
‘Several
times’
Not reported
Not reported
3
‘Several
times’
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Appendix E
Residue intake in higher tier studies providing reliable Class 1 and Class 2 endpoints
Mean residue
values/test
concentration/
test dose
Pollen:
2.7
lg/kg;
nectar
0.75
lg/kg
Forager
ng/bee
per day
Min
0.16
max
0.64
Nurse
ng/bee
per day
Min
0.188
max
0.282
Larva
ng/bee per
developmental period
Min
0.301
max
0.302
The exposure length was
11 days. Mean residue for pollen
was calculated from
five
samples
(includes positive
findings,
but
also values
<
LOD). Mean
residue for nectar was derived
from LOQ and LOD
The exposure length was
18 days. Mean residue was
calculated from
five
samples
(includes positive
findings,
but
also values
<
LOQ)
The exposure length was 15
days. Mean residues for pollen
and nectar were derived from
LOQ and LOD
The exposure length was
11 days. Mean residue for pollen
was calculated from
five
samples
that consisted of values
<
LOD
and
<
LOQ). All values for nectar
was
<
LOD
The exposure length was
11 days. Mean residue for pollen
was calculated from
five
samples
(includes positive
findings,
but
also values
<
LOD). Mean
residue for nectar was derived
from a positive sample and from
a value
<
LOD
Notes
Organism Reference Type
Exposure
Honeybee
I.1498
Field
Pollen/nectar
from
sunflower
field
I.2043
Field
Pollen from
maize
field
1.51
lg/kg
0
0
0.01
0.018
0.002
0.003
I.2044
Field
I.2045
Field
Pollen/nectar
from
sunflower
field
Pollen/nectar
from winter
oilseed rape
field
Pollen:
2.18
lg/kg;
nectar:
1.05
lg/kg
Pollen:
0.13
lg/kg;
nectar:
0.0
lg/kg
0.224
0.896
0.252
0.376
0.419
0.42
0
0
0.0008 0.0016
0.0002
0.0003
I.2046
Field
Pollen/nectar
from spring
oilseed rape
field
Pollen:
2.2
lg/kg;
nectar:
5.0
lg/kg
1.067
4.267
1.148
1.693
1.983
1.984
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Organism Reference Type
Exposure
Mean residue
values/test
concentration/
test dose
12.5 ppb
Forager
ng/bee
per day
Min
0.8
max
3.2
Nurse
ng/bee
per day
Min
0.85
max
1.25
Larva
ng/bee per
developmental period
Min
1.485
max
1.485
The exposure period was
42 days. Intake obtained with
default consumption values and
50% sugar content
The exposure period was 42
days. Intake obtained with
default consumption values and
50% sugar content
The exposure period was
42 days. Intake obtained with
default consumption values and
50% sugar content
Exposure period was 84 days.
Intake obtained with default
consumption values and 67%
sugar content (pollen patties
consisted pollen and sugar
syrup)
Exposure period was 84 days.
Intake obtained with default
consumption values and 67%
sugar content (pollen patties
consisted pollen and sugar
syrup)
Exposure period was 84 days.
Intake obtained with default
consumption values and 67%
sugar content (pollen patties
consisted pollen and sugar
syrup)
Notes
I.163
Colony Sugar syrup
feeder
I.163
Colony Sugar syrup
feeder
25 ppb
1.6
6.4
1.7
2.5
2.97
2.97
I.163
Colony Sugar syrup
feeder
50 ppb
3.2
12.8
3.4
5
5.94
5.94
I.362
Colony Pollen patties 5
lg/kg
feeder
0.24
0.96
0.29
0.43
0.45
0.45
I.2017
Colony Pollen patties 5
lg/kg
feeder
0.24
0.96
0.29
0.43
0.45
0.45
I.2017
Colony Pollen patties 100
lg/kg
feeder
4.78
19.10
5.73
8.66
9.02
9.07
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Organism Reference Type
Exposure
Mean residue
values/test
concentration/
test dose
0.5
lg/kg
Forager
ng/bee
per day
Min
0.032
max
0.128
Nurse
ng/bee
per day
Min
0.034
max
0.05
Larva
ng/bee per
developmental period
Min
0.059
max
0.059
The exposure period was
33 days. Intake obtained with
default consumption values and
50% sugar content
The exposure period was
33 days. Intake obtained with
default consumption values and
50% sugar content
The exposure period was
63 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
The exposure period was
63 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
Notes
I.411
Colony Sugar syrup
feeder
I.411
Colony Sugar syrup
feeder
5
lg/kg
0.32
1.28
0.34
0.5
0.594
0.594
I.843
Colony Sugar syrup
feeder
400
lg/kg
25.6
102.4
27.2
40.0
47.52
47.52
I.843
Colony Sugar syrup
feeder
20
lg/kg
1.28
5.12
1.36
2
2.376
2.376
C+I.844
I.178
Colony Sugar syrup
feeder
Colony Sugar syrup
feeder
136
lg/L
100 ppb
8.704
6.4
34.816
25.6
9.248 13.6
16.157
16.157
Acute exposure regime. Intake
obtained with default
consumption values and 50%
sugar content
Acute exposure regime. Intake
obtained with default
consumption values and 50%
sugar content
Acute exposure regime. Test
dose provided by the study
authors
I.178
Colony Sugar syrup
feeder
500 ppb
32
128
C+I.423
Colony Sugar syrup
feeder
7.5 ng/bee
7.5
7.5
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Organism Reference Type
Exposure
Mean residue
values/test
concentration/
test dose
11.25 ng/bee
Forager
ng/bee
per day
Min
11.25
max
11.25
Nurse
ng/bee
per day
Min
max
Larva
ng/bee per
developmental period
Min
max
Acute exposure regime. Test
dose provided by the study
authors
Acute exposure regime. Test
dose provided by the study
authors
Acute exposure regime. Test
dose provided by the study
authors
Notes
C+I.423
Colony Sugar syrup
feeder
Colony Sugar syrup
feeder
Colony Sugar syrup
feeder
Colony Sugar syrup
feeder
C+I.1244
1.5 ng/bee
1.5
1.5
C+I.1244
6 ng/bee
6
6
I.2025
20 ppb
0.889
3.556
0.944
1.389
1.65
1.65
I.1455-II
Colony Sugar syrup
feeder
6.1 ppb
0.390
1.562
0.415
0.610
0.725
0.725
The exposure length was
39 days feeding. Intake obtained
with default consumption values
and 72% sugar content was
assumed (honey was used)
The exposure length was
84 days feeding. Intake obtained
with default consumption values
and 50% sugar content. Study
authors estimated an adult
consumption of 0.12 ng/bee per
day
The exposure period was
11 weeks (77 days). Intake
obtained with default
consumption values and 50%
sugar content
The exposure period was
28 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
Bumblebee C+I.1248
Colony Sugar syrup
feeder
10 ppb
1.46
2.98
4.76
4.76
I.475
Colony Sugar syrup
feeder
10 ppb
1.46
2.98
4.76
4.76
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Organism Reference Type
Exposure
Mean residue
values/test
concentration/
test dose
19.2 ppm
(0.0192 mg/g)
Forager
ng/bee
per day
Min
3314
max
6303
Nurse
ng/bee
per day
Min
max
Larva
ng/bee per
developmental period
Min
11117
max
16723
The exposure period was
30 days. Intake obtained with
default consumption values and
with 72% sugar content of the
syrup assumed (honey)
The exposure period was
42 days. Intake obtained with
default consumption values and
40% sugar content
Notes
I.2019
Colony Pollen/sugar
feeder syrup
I.2004
Colony Sugar syrup
feeder
10 ppb
1.825
3.725
5.95
5.95
I.787
Colony Sugar syrup
feeder
0.15 ppb
0.0219
0.0447
0.0714
I.787
Colony Sugar syrup
feeder
1.44 ppb
0.21024
0.42912
0.68544
The exposure period was
14 days. Intake obtained with
default consumption values and
50% sugar content was
assumed. The 0.15 ppb is a
calculated EC
10
values from the
series of test concentrations
0.68544 The exposure period was
14 days. Intake obtained with
default consumption values and
50% sugar content was
assumed. The 1.44 ppb is a
calculated EC
50
values from the
series of test concentrations
0.60452 The exposure period was
13 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
46.8384 The exposure period was
14 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
0.0714
I.788
Colony Sugar syrup
feeder
1.27 ppb
0.18542
0.37846
0.60452
I.2051
Colony Sugar syrup
feeder
98.4 ppb
14.3664
29.3232
46.8384
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Organism Reference Type
Exposure
Mean residue
values/test
concentration/
test dose
7 ppb
Forager
ng/bee
per day
Min
0.1862
max
0.2121
Nurse
ng/bee
per day
Min
max
Larva
ng/bee per
developmental period
Min
0.721
max
2.765
The exposure period was
84 days. Intake obtained with
default consumption values
The exposure period was 84
days. Intake obtained with
default consumption values
The exposure period was
84 days. Intake obtained with
default consumption values.
The exposure period was
85 days. Intake obtained with
default consumption values and
with 75% sugar content of the
syrup. Study authors calculated a
residue consumption of 2.15
ng/bee per day for adults
The exposure period was
85 days. Intake obtained with
default consumption values and
with 75% sugar content of the
syrup. Study authors calculated a
residue consumption of 4.81
ng/bee/day for adults
The exposure period was
14 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
The exposure period was
14 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
Notes
I.937
Colony Pollen
feeder
Colony Pollen
feeder
Colony Pollen
feeder
Colony Pollen/sugar
feeder syrup
I.2052
7 ppb
0.1862
0.2121
0.721
2.765
I.2052
30 ppb
0.798
0.909
3.09
11.85
I.1386
Pollen: 6 ppb;
syrup: 10 ppb
1.1329
2.1685
3.7913
5.5433
I.1386
Colony Pollen/sugar
feeder syrup
Pollen: 16 ppb;
syrup: 25 ppb
2.8589
5.4515
9.5813
14.2533
I.1505
Colony Pollen/sugar
feeder syrup
Pollen: 6 ppb;
syrup: 0.7 ppb
0.2618
0.3904
0.9512
2.7032
I.1505
Colony Pollen/sugar
feeder syrup
Pollen: 12 ppb;
syrup: 1.4 ppb
0.5236
0.7808
1.9024
5.4064
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Organism Reference Type
Exposure
Mean residue
values/test
concentration/
test dose
10 ppb
Forager
ng/bee
per day
Min
1.46
max
2.98
Nurse
ng/bee
per day
Min
max
Larva
ng/bee per
developmental period
Min
4.76
max
4.76
The exposure period was
77 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
The exposure period was
77 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
The exposure period was
43 days. Intake obtained with
default consumption values and
50% sugar content was
assumed
The exposure length was
17 days. Mean residue for pollen
was calculated from three
samples (includes positive
findings,
but also values
<
LOD).
Mean residue for nectar was
derived from a positive sample
and from a value
<
LOD
The exposure length was
15 days. Mean residue for pollen
was calculated from
five
samples
(includes positive
findings,
but
also values
<
LOQ). Mean
residue for nectar was derived
from a positive sample and from
values
<
LOQ
Notes
I+T.931
Colony Sugar syrup
feeder
I+T.2015
Colony Sugar syrup
feeder
10 ppb
1.46
2.98
4.76
4.76
C+I.2017
Colony Sugar syrup
feeder
2.1 ppb
0.3066
0.6258
0.9996
0.9996
I.724
Field
Pollen from
potato
field
0.37
lg/kg
0.0098
0.0112
0.0381
0.1462
I.725
Field
Pollen from
potato
field
0.77
lg/kg
0.0204
0.0232
0.0790
0.3028
LOD: limit of detection; LOQ: limit of quantification.
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Appendix F
Tier-3 lines of evidence
The graphical representation of the lines of evidence for the treated crop scenario for winter oilseed
rape for honeybees and the succeeding crop scenario for honeybees and bumblebees.
F.1
F.1.1.
Honeybees
Colony strength (Class 1 endpoint)
Three
figures
are presented for the treated crop scenario (winter oilseed rape) and one for the
succeeding crop scenario. All of them are based on the same data set (colony strength for honeybee
colonies), but with slightly different setups in order to help the interpretation of the data. These
differences are explained in the title of the
figures.
The general interpretation is relevant for all
figures
for honeybee colony strength.
General interpretation
Altogether 20 endpoints were available, but eight of them were considered as non-reliable.
The biological variability of many of the reliable endpoints was considerably high and in many
cases
fluctuated
both negatively and positively relative to the control
There is also variability between the experiments. The mean deviation from the control ranged
from negligible to medium negative
Exposure estimation and information on the exposure lengths was available for all reliable
experiments.
No dose–response pattern could be seen when all reliable endpoints are considered
Two experiments had more than one test concentrations. In one of them, a dose–response trend
could be observed, while this was not that clear in the other experiment (I.2017)
F.1.1.1.
Winter oilseed rape
Figure F.1:
Summary of the observed deviations for honeybee colony strength for seed treatment
use to winter oilseed rape
all available endpoints are indicated in the order of the
magnitude of mean deviation, scale for exposure level aligned to the available data
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Figure F.2:
Summary of the observed deviations for honeybee colony strength for seed treatment
use to winter oilseed rape
only the reliable endpoints are indicated in the order of the
magnitude of mean deviation, scale for exposure level aligned to the exposure
assessment goals (zoom in to the relevant part)
Figure F.3:
Summary of the observed deviations for honeybee colony strength for seed treatment
use to winter oilseed rape
only the reliable endpoints are indicated in the order of the
magnitude of the exposure estimation, scale for exposure level aligned to the available
data
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Interpretation for the treated crop scenario for the winter oilseed rape use
Indications for larger than negligible effect
The maximum negative deviation from the controls
was larger than negligible in eight experiments.
Although in four of these cases, the exposure was
too long or the estimated exposure was somewhat
higher than the exposure assessment goal, the
exposure regime of four experiments was not
unrealistically severe (I.2046, low dose of I.163,
I.2044, I.2045)
Considering the mean deviations from the control, it
was more than negligible in the negative direction in
case of three experiments (I.2044, I.2045, high dose
of I.163). Although in one of these cases, the
estimated exposure was somewhat higher than the
exposure assessment goal, the exposure regimes of
the other two experiments represented the lower
end of the realistic exposure situations (or even
below for I.2045)
Indications for lack of larger than negligible effect
The maximum negative deviation from the controls was
not larger than negligible in four experiments. Although
two of them represented a rather low exposure regime, in
the other two cases (I.1455-II, I.411), the exposure
regime, in general, was not too mild (and one of the
studies had an unrealistically long exposure)
Nine endpoints indicated negligible mean deviation from
the control. Although, two of them (I.2043, I.1498)
represented a rather low exposure regime, seven of them
had a realistic or severe exposure regime;
five
of these
seven were considered as reliable with minor deviations
The available evidence indicating not more than negligible deviation from the control has more weight than has
the evidence indicating more than negligible negative deviation from the control.This is because a relatively high
number of experiments with a realistic or severe exposure regime indicated an overall negligible deviation from
the control, while a fewer experiments with suitable exposure indicated a negative deviation from the control.
Also, there was a considerable biological variability and the endpoints indicating negligible deviation were, in
general, much more reliable.Overall, this indicates a
moderate evidence for negligible effect
F.1.1.2
Succeeding crop
Figure F.4:
Summary of the observed deviations for honeybee colony strength for seed treatment
use to the succeeding crop scenario
only the reliable endpoints are indicated in the
order of the magnitude of mean deviation, scale for exposure level aligned to the
exposure assessment goals (zoom in to the relevant part)
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Interpretation for the succeeding crop scenario
The exposure assessment goals for the succeeding crop scenario are only marginally different from the exposure
assessment goals for winter oilseed rape (see Section
5.1.1.2).
Also, when the exposure length of the
experiments is compared to the range of expected
flowering
period, only marginal differences could be identified
between the
figures
for the succeeding crop scenario and for the winter oilseed rape. Therefore, the indications
for effects and for lack of effects with the overall balancing as presented for winter oilseed rape above is equally
applicable for the succeeding crop scenario
F.1.2.
Overwintering assessment (Class 1 endpoint)
Two
figures
are presented below for the treated crop scenario (winter oilseed rape) and one for the
succeeding crop scenario. All of them are based on the same data set (colony strengths of honeybee
colonies after overwintering), but with slightly different setups in order to help the interpretation of the
data. These differences are explained in the title of the
figures.
The general interpretation is relevant
for all
figures
for overwintering assessment.
It is noted that the colony strength after overwintering was calculated by considering the colony
strength of the dead colonies as 0. This was however done only for those studies where detailed data
on the individual colonies were available (i.e. it was possible to identify which and how many hives
were lost during the winter and what was the colony strength of the colonies that survived the
winter).
In addition, there were some experiments where the overwintering survival was studied, but not by
measuring the colony strength after overwintering. These experiments are briefly summarized further
below and an integration of all the information on overwintering is provided.
General interpretation
Altogether nine endpoints were available, but four of them were considered as non-reliable
The variability between the reliable endpoints was very high; ranged from large positive to large
negative deviation from the controls
Exposure estimation and information on the exposure lengths was available for all the reliable
experiments
No dose–response pattern could be seen when all reliable experiments are considered
Within the experiments with more than one test concentration, a dose response trend could be
observed (considering the mean effects)
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F.1.2.1.
Winter oilseed rape
Figure F.5:
Summary of the observed deviations for honeybee colony strength after overwintering for
seed treatment use to winter oilseed rape
all available endpoints are indicated in the
order of the magnitude of the deviation from the control, scale for exposure level aligned
to the available data
Figure F.6:
Summary of the observed deviations for honeybee colony strength after overwintering for
seed treatment use to winter oilseed rape
only the reliable endpoints are indicated in
the order of the magnitude of deviation from the control, scale for exposure level aligned
to the exposure assessment goals (zoom into the relevant part)
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Interpretation for the treated crop scenario for the winter oilseed rape use
Indications for larger than negligible effect
Two endpoints indicated more than negligible negative
deviation from the control. Although one of them had
high exposure level, the high dose of the experiment
I.411 had comparable but somewhat lower estimated
exposure than the exposure assessment goal and the
length of the exposure was in the realistic range of the
flowering
period. This endpoint was considered as
reliable with major restrictions
Indications for lack of larger than negligible
effect
Three experiments indicated not more than negligible
negative deviation from the control. Although one of
them had too low exposure level, in the other two
cases the exposure regime, in general, was not mild.
These two endpoints were considered as reliable with
minor restrictions
The available evidence indicating not more than negligible deviation from the control has more weight than has
the evidence indicating more than negligible negative deviation from the control
This is because only one experiment with a realistic exposure regime indicated more than negligible negative
deviation from the control, while two experiments with suitable exposure indicated not more than negligible
negative deviation from the control. In addition, both of these two endpoints were more reliable than the one
with the more than negligible negative deviation
Overall, this indicates a moderate evidence for negligible effect
In addition, as reported above, there were three colony-feeder experiments (I.2017, I.843 and
I.362) where the overwintering success was studied, but not by measuring the colony strength after
overwintering. In these studies, the proportion of the successfully overwintered test colonies were
reported.
In the experiment I.843, honeybee colonies (n = 4) were fed by spiked sugar syrup at different
concentrations over a period of 9 weeks. For the next spring, all but one treated colonies died
while from the control, only one of the four colonies died. A slight overall tendency suggested
that the effect may have started earlier with the higher concentration. The endpoint was
assessed as
‘reliable
with minor restrictions’. The estimated exposure levels for the lowest test
concentration (40
lg/kg,
four of four colonies died) were forager
1.28–5.12 ng/bee per day,
nurse
1.36–2.0 ng/bee per day, larva
2.38 ng/larva per developmental period.
In the experiment I.362, over a 12-week period, spiked diet patties (pollen and sugary
solution) were offered to honeybee colonies (n = 10) with different concentrations. For
overwintering success, a decreasing trend with increasing concentration was found (although it
was statistically different only in case of the highest test concentration). All control hives
successfully overwintered. The endpoint was assessed as
‘reliable
with minor restrictions’.
The estimated exposure levels for the lowest test concentration (5
lg/kg,
2 of 10 colonies
died) were forager
0.32–1.28 ng/bee per day, nurse
0.37–0.53 ng/bee per day, larva
0.6 ng/larva per developmental period.
In the experiment I.2017 similar methodology was used as in the experiment I.362 (note:
I.2017 and I.362 are from the same publication). Three of the seven control colonies died and
four of the seven treated colonies (at each concentration) died for the next spring. The
endpoint was assessed as
‘reliable
with major restrictions’. The estimated exposure levels for
the lowest test concentration (5
lg/kg)
are the same as reported above for study I.362.
Taking the estimated exposure levels for the highest test concentration (100
lg/kg,
same
effect than at the lowest or at the middle concentration) were forager
6.4–25.6 ng/bee per
day, nurse
7.45–11.2 ng/bee per day, larva
12.0–12.1 ng/larva per developmental period.
An overall integration of the eight available and reliable experiments, which investigated the
overwintering, is presented below.
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Reference
Exposure estimation
ng/bee per day
(for simplification, it is
indicated only for foragers)
0.032–0.128
0.32–1.28
0.32–25.6
Exposure
length
Reliability
(day)
33
33
84
Description of effect/
deviation from control
I.411
I.411
I.2017
Reliable with major No more than negligible
restrictions
deviation from the control
Reliable with major Medium negative deviation
restrictions
from the control
Reliable with major No clear tendency (negative
restrictions
effect cannot be excluded nor
confirmed)
Reliable with minor Clear tendency for a negative
restrictions
effect
Reliable with minor No more than negligible
restrictions
negative deviation from the
control
Reliable with minor Clear negative effect
restrictions
Reliable with minor Large positive deviation from
restrictions
the control
Reliable with minor Large negative deviation from
restrictions
the control
I.362
I.1455-II
0.32–1.28
0.39–1.56
84
84
I.843
I.163
I.163
1.28–5.12
1.6–6.4
3.2–12.8
63
42
42
Note: the exposure assessment goal for foragers is 2.1–1.6 ng/bee per day (acute and chronic, respectively) and the realistic
flowering
duration of winter oilseed rape was considered as 10–42 days.
No dose–response pattern could be seen when all the endpoints are considered together. Estimated
exposures to honeybee castes of the lower dose of experiment I.411 were too low when compared to
the exposure assessment goal. No clear conclusion could be drawn from experiments I.2017.
Experiments I.362, I.843 and high dose of I.411 indicated a clear negative effect on honeybee
populations after overwintering. The estimated exposure of these experiments was at around or
somewhat below the exposure assessment goal. The high dose of the experiment I.163 also indicated
a clear negative effect; however, the exposure level of this endpoint was somewhat higher than the
exposure assessment goal. In the remaining two experiments, such negative effects were not present.
Experiment I.1455-II had only a negligible negative deviation from the control. The estimated
exposure of this experiment was comparable, but somewhat below the exposure assessment goal. The
low dose of the experiment I.163 had a realistic worst-case exposure regime and resulted in a large-
positive deviation from the control. Considering the deviations from the controls in combination with
the exposure estimations, it can be concluded that the available data set is contradictory. Nevertheless,
it may be considered that the available evidence indicating more than negligible negative effects has
more weight. However, two of the four experiments that indicated clear negative effects had
considerably longer exposure duration than the realistic
flowering
period of oilseed rape (I.362 and
I.843). When the severity of these two endpoints is taken into consideration, the available evidences
become balanced and no clear trend is apparent. Therefore,
this line of evidence is inconclusive.
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F.1.2.2.
Succeeding crop
Figure F.7:
Summary of the observed deviations for honeybee colony strength after overwintering for
the succeeding crop scenario
only the reliable endpoints are indicated in the order of
the magnitude of deviation from the control, scale for exposure level aligned to the
exposure assessment goals (zoom in to the relevant part)
Interpretation for the succeeding crop scenario
The exposure assessment goals for the succeeding crop scenario are only marginally different from the exposure
assessment goals for winter oilseed rape (see Section
5.1.1.2).
Also, when the exposure length of the
experiments is compared to the range of expected
flowering
period, only marginal differences could be identified
between the succeeding crop scenario and for the winter oilseed rape. Therefore, the indications for effects and
for lack of effects with the overall balancing as presented for winter oilseed rape above based on colony strength
after overwintering is equally applicable for the succeeding crop scenario
The integration of the additional experiments and the
final
conclusion on this line of evidence as presented for
winter oilseed rape above is also applicable for the succeeding crop scenario
F.1.3.
Mortality in front of the hive (Class 2 endpoint)
One
figure
is presented below for each of the treated crop scenario (winter oilseed rape) and for
the succeeding crop scenario. All of them are based on the same data set (honeybee mortality in front
of the hives). The general interpretation is relevant for both
figures.
General interpretation
Altogether 10 endpoints were available, but
five
of them were considered as non-reliable
All the
five
reliable endpoints were considered as reliable with major restrictions
The biological variability of all the reliable endpoints was very low; all the mean deviations from
the controls during the experiments were in the negligible range as well as the mean of the
extreme deviations
Exposure estimation and information on the exposure lengths was available for all the reliable
experiments
Dose–response analysis cannot be performed due to the very low variability between the reliable
endpoints
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F.1.3.1.
Winter oilseed rape
Figure F.8:
Summary of the observed deviations for honeybee mortality in front of the hives for the
succeeding crop scenario
only the reliable endpoints are indicated, scale for exposure
level aligned to the available data
Interpretation for the treated crop scenario for the winter oilseed rape use
Indications for larger than negligible effect
The maximum negative deviation from the controls
was larger than negligible in two experiments and
the exposure regimes of these two experiments
represented the lower end of the realistic exposure
situations (or even below for I.2043)
Indications for lack of larger than negligible effect
The maximum negative deviation from the controls was
not larger than negligible in three experiments. One of
these experiments (I.2046) had exposure estimations
which are in the range of the exposure assessment goal.
The exposure lengths of this study fell in the realistic
range of the
flowering
period, although tend to be at the
lower edge of this range
Considering the mean deviations from the control, all the
reliable studies fell in the negligible range. Only one of
these experiments (I.2046) had exposure estimations
which are in the range of the exposure assessment goal
The available evidence indicating not more than negligible deviation from the control has somewhat lower weight
than has the evidence indicating more than negligible negative deviation from the control. This is because only
one experiment with appropriate exposure indicated negligible effect, while in two experiments with mild
exposure regime, a temporal negative deviation was indicated. All the endpoints had low reliability, but the
biological variability was low
Overall, this indicates a
weak evidence for larger than negligible effect
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F.1.3.2
Succeeding crop
Figure F.9:
Summary of the observed deviations for honeybee forager mortality in front of the hives
for the succeeding crop scenario
all endpoints are indicated, scale for exposure level
aligned to the available data
Interpretation for the succeeding crop scenario
The exposure assessment goals for the succeeding crop scenario are only marginally different from the exposure
assessment goals for winter oilseed rape (see Section
5.1.1.2).
Also, when the exposure length of the
experiments is compared to the range of expected
flowering
period, only marginal differences could be identified
between the
figures
for the succeeding crop scenario and for the winter oilseed rape. Therefore, the indications
for effects and for lack of effects with the overall balancing as presented for winter oilseed rape is equally
applicable for the succeeding crop scenario
F.1.4.
Brood abundance (Class 2 endpoint)
Three
figures
are presented below for the treated crop scenario (winter oilseed rape) and one for
the succeeding crop scenario. All of them are based on the same data set (brood abundance of
honeybee colonies), but with slightly different setups in order to help the interpretation of the data.
These differences are explained in the title of the
figures.
The general interpretation is relevant for all
figures
for honeybee brood abundance.
F.1.4.1.
Winter oilseed rape
General interpretation
Altogether 22 endpoints were available, but eight of them were considered as non-reliable
All the 14 reliable endpoints were considered as reliable with major restrictions
The biological variability of several reliable experiments was considerable high, in some cases
fluctuated
both negatively and positively relative to the control
There was also variability between the studies. The mean deviation from the control ranged from
medium negative to medium positive. The number of endpoints on both the negative and the
positive sides were balanced and all had the same reliability score. The mean of the mean
overall deviations during the duration of the studies is in the negligible range. This line is very
close to the zero line and the lines of the extreme deviations are also close to the edges of the
negligible deviation range
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General interpretation
Exposure estimation was available for all of them and also, information on the exposure lengths
was available for all reliable studies
No dose–response pattern could be seen when all reliable experiments are considered
Within the experiments with more than one test concentration, a dose–response trend could be
observed (considering the mean effects)
Figure F.10:
Summary of the observed deviations for honeybee brood abundance for seed treatment
use to winter oilseed rape
all available endpoints are indicated in the order of the
magnitude of mean deviation, scale for exposure level aligned to the available data
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Figure F.11:
Summary of the observed deviations for honeybee brood abundance for seed treatment
use to winter oilseed rape
only the reliable endpoints are indicated in the order of the
magnitude of mean deviation, scale for exposure level aligned to the exposure
assessment goals (zoom in to the relevant part)
Figure F.12:
Summary of the observed deviations for honeybee brood abundance for seed treatment
use to winter oilseed rape
only the reliable endpoints are indicated in the order of the
magnitude of the exposure estimation, scale for exposure level aligned to the exposure
assessment goals (zoom into the relevant part)
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Interpretation for the treated crop scenario for the winter oilseed rape use
Indications for larger than negligible effect
The maximum negative deviation from the controls
was larger than negligible in eight experiments.
Three of these experiments had low estimated
exposure compared to the exposure assessment goal
in combination with exposure lengths which
represent the lower end of the realistic range of the
flowering
period. An additional experiment from this
set (low dose of I.163) had a realistic worst-case
exposure regime
Considering the mean deviations from the control, it
was more than negligible in the negative direction in
case of four experiments
The exposure regimes in three of these four
experiments were not unrealistically severe and one
of these had a very low exposure estimation when
compared to the exposure assessment goal
Indications for lack of larger than negligible effect
The maximum negative deviation from the controls was
not larger than negligible in six experiments. One of these
experiments (high dose of I.2017) had a very severe
exposure regime and another one had a realistic worst-
case exposure estimation (I.2046). In addition, another
one (low dose of I.2017) had a relatively low estimated
exposure, but in combination with a very long exposure
duration
Ten experiments indicated negligible or positive mean
deviation from the control. Although, some of them
represented a rather low exposure regime, four of them
had higher or comparable exposure estimation than the
exposure assessment goal. Three of these four had an
exposure period considerable longer than the realistic
flowering
period. An additional experiment (low dose of
I.2017) with lower exposure estimate than the exposure
assessment goal also had a long exposure period
The available evidence indicating not more than negligible deviation from the control has somewhat more weight
than has the evidence indicating more than negligible negative deviation from the control
This is because a slightly higher number of experiments with a realistic or severe exposure regime indicated an
overall negligible (or even positive) deviation from the control, while slightly fewer experiments with realistic or
mild exposure regime indicated more than negligible negative deviation from the control. There was a
considerable biological variability and all the endpoints had low reliability
Overall, this indicates a
weak evidence for negligible effect
F.1.4.2.
Succeeding crop
Figure F.13:
Summary of the observed deviations for honeybee brood abundance for the succeeding
crop scenario
only the reliable endpoints are indicated in the order of the magnitude
of mean deviation, scale for exposure level aligned to the exposure assessment goals
(zoom in to the relevant part)
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Interpretation for the succeeding crop scenario
The exposure assessment goals for the succeeding crop scenario are only marginally different from the exposure
assessment goals for winter oilseed rape (see Section
5.1.1.2).
Also, when the exposure length of the
experiments is compared to the range of expected
flowering
period, only marginal differences could be identified
between the
figures
for the succeeding crop scenario and for the winter oilseed rape. Therefore, the indications
for effects and for lack of effects with the overall balancing as presented for winter oilseed rape above is equally
applicable for the succeeding crop scenario
F.1.5.
Homing success (Class 2 endpoint)
Two
figures
are presented below for the treated crop scenario (winter oilseed rape) and one for the
succeeding crop scenario. All of them are based on the same data set (homing success of honeybee
foragers), but with slightly different setups in order to help the interpretation of the data. These
differences are explained in the title of the
figures.
The general interpretation is relevant for all
figures
for homing success.
General interpretation
Six endpoints were available from three experiments; all were considered as reliable with major
restrictions
These endpoints were derived from three studies; from each of them, results from two test
concentrations are presented. In all cases, the highest test concentration indicating no or the
smallest deviation from the control and the next higher test concentration was selected.
Exposure estimation was available for all the endpoints
When all the six endpoints are considered, some, but not entirely clear dose–response pattern is
indicated (note: for one study, range of doses are indicated; it is considered that the lower edge
of the ranges are more relevant since the homing
flight
experiments do not lasts all day long)
Within each experiment, a dose–response trend was observed
F.1.5.1.
Winter oilseed rape
Figure F.14:
Summary of the observed deviations for homing success of honeybee foragers for seed
treatment use to winter oilseed rape
endpoints in the order of the magnitude of
deviation from control, scale for exposure level aligned to the available data
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Figure F.15:
Summary of the observed deviations for homing success of honeybee foragers for seed
treatment use to winter oilseed rape
endpoints in the order of the magnitude of
deviation from control, scale for exposure level aligned to the exposure assessment goal
(zoom in to the relevant part)
Interpretation for the treated crop scenario for the winter oilseed rape use
The estimated exposure levels considerably exceed the exposure assessment goal for winter oilseed rape in all,
but one case. These
five
endpoints included the lower test concentration from the experiment I.178, which
indicated a negligible deviation from the control. The only endpoint that had an estimated exposure level close
but slightly below the exposure assessment goal indicated no deviation from the control. The endpoints were
classified as reliable with major restrictions
Overall, this indicates a
weak evidence for negligible effect
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F.1.5.2.
Succeeding crop
Figure F.16:
Summary of the observed deviations for homing success of honeybee foragers for the
succeeding crop scenario
endpoints in the order of the magnitude of deviation from
control, scale for exposure level aligned to the exposure assessment goal (zoom in to
the relevant part)
Interpretation for the succeeding crop scenario
The exposure assessment goal for the succeeding crop scenario is only marginally different from the exposure
assessment goal for winter oilseed rape (see Section
5.1.1.2).
Therefore, the interpretation of the available
evidences and the conclusion as presented for winter oilseed rape above are also applicable for the succeeding
crop scenario
F.2.
F.2.1.
Bumblebees
Queen production (Class 1 endpoint)
Two
figures
are presented below for the succeeding crop scenario. Both are based on the same
data set (queen production of queenright bumblebee colonies), but with slightly different setups in
order to help the interpretation of the data. These differences are explained in the title of the
figures.
The general interpretation is relevant for both
figures.
General interpretation
Six reliable endpoints were available, all were assessed as reliable with major restrictions
There was a high variability between the experiments. The deviation from the control ranged
from large positive to large negative
Exposure estimation was available for all, but one and information on the exposure lengths was
available for all experiments
No dose–response pattern could be seen when all endpoints are considered
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Figure F.17:
Summary of the observed deviations for queen production of bumblebees for the
succeeding crop scenario
endpoints in the order of the magnitude of deviation from
control, scale for exposure level aligned to the available data
Figure F.18:
Summary of the observed deviations for queen production of bumblebees for the
succeeding crop scenario
endpoints in the order of the magnitude of the exposure
estimation, scale for exposure level aligned to the available data
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Interpretation of the line of evidence
Indications for larger than negligible effect
Two endpoints indicated more than negligible negative
deviation from the control. Although one of them had
an unrealistically long exposure (when compared to
the realistic range of the
flowering
period of any
succeeding crop), the other one had a realistic
exposure length falling to the lower end of the range
of the
flowering
period of succeeding crops.
The estimated exposures of both of them were well
below the exposure assessment goals
Indications for lack of larger than negligible
effect
Three experiments with exposure estimation indicated
positive deviation from the control. Although two of
them had too low exposure levels, the exposure
estimations of one of them (C+I. 1248) was reasonable
close to the exposure assessment goals (but were
somewhat below) in combination with a very long
exposure length that was far beyond the realistic range
of the
flowering
period of any succeeding crop
The available evidence indicating not more than negligible deviation from the control has less weight than has
the evidence indicating more than negligible negative deviation from the control
One experiment with appropriate exposure indicated negligible effect and also only one experiment with rather
mild exposure regime resulted in a large negative deviation from the control. However, there was another
endpoint with low exposure level indicating similar results. This experiment (I.937) was not considered to be
suitable to fully support the negative trend due to its very long exposure length. However, it was considered as a
weak indication for a likely negative effect at realistic exposure situation
Overall, this indicates a
weak evidence for larger than negligible effect
F.2.2.
Worker production (Class 1 endpoint)
Two
figures
are presented below for the succeeding crop scenario. Both are based on the same
data set (worker production of queenright bumblebee colonies), but with slightly different setups in
order to help the interpretation of the data. These differences are explained in the title of the
figures.
The general interpretation is relevant for both
figures.
General interpretation
Nine reliable endpoints were available, all, but one was assessed as reliable with major
restrictions
There was a high variability between the experiments. The deviation from the control ranged
from large positive to medium negative
Exposure estimation was available for all, but one and information on the exposure lengths was
available for all experiments
No dose–response pattern could be seen when all endpoints are considered
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Figure F.19:
Summary of the observed deviations for worker production of bumblebees for the
succeeding crop scenario
endpoints in the order of the magnitude of deviation from
control, scale for exposure level aligned to the available data
Figure F.20:
Summary of the observed deviations for worker production of bumblebees for the
succeeding crop scenario
endpoints in the order of the magnitude of the exposure
estimation, scale for exposure level aligned to the available data
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Interpretation of the line of evidence
Indications for larger than negligible effect
The maximum negative deviation from the controls
was larger than negligible in two experiments out of
the three, where the effect was studied at more than
one observation day. In both cases, the exposure
levels were below the exposure assessment goals,
although one of them had a very long exposure
period
The mean deviation from the control was negative
and larger than negligible in three experiments and
two of them had exposure estimations (lower dose of
I.1505, I.475). The exposure estimation for both of
them was lower than the exposure assessment goal
in combination with exposure lengths falling in the
realistic range of the
flowering
period of any
succeeding crop. One of these experiments was
considered as reliable with minor restrictions
Indications for lack of larger than negligible effect
The maximum negative deviation from the controls was
not larger than negligible in one out of those three
experiments, where the effect was studied at more than
one observation day. When compared to the exposure
assessment goal, this experiment had a realistic exposure
level for the larvae in combination with a very long
exposure period
Six endpoints indicated negligible mean deviation from the
control or positive deviation from the control. Although
three of them had too low estimated exposure, in case of
the other three (C+I.1248, high dose of I.1505, I.2052) at
least the estimations for larvae were close to or
overlapped the respective exposure assessment goal.
Moreover, two of these three had very long exposure
period
Results from the two test concentrations of experiment
I.1505 are not consistent; the lower dose resulted in the
negative deviation from the control indicating some
uncertainties to consider this deviation as true effect
The available evidence indicating not more than negligible deviation from the control has not more, neither less
weight than has the evidence indicating more than negligible negative deviation from the control. Although the
available evidence indicating more than negligible negative deviations based on maximum deviations has slightly
more weight than has the evidence indicating not more than negligible deviation, overall this type of evidence
has a low weight (three experiments only). Considering the mean deviations, two experiments with appropriate
exposure indicated a clear negative deviation from the control. One of them had higher reliability than all the
other endpoints, while the other one bears some uncertainties. On the other hand, three experiments could be
considered as evidence indicating no negative deviation from the controls. However, two of them had somewhat
low exposure levels (but reasonable close to the exposure assessment goal at least for larvae) and the third one
had a high enough exposure level only for larvae. The lengths of the exposure of these experiments were either
realistic or considerable longer than the realistic range of the
flowering
period of any succeeding crop. No clear
trend could be seen when all these positive and negative elements were balanced
Therefore,
this line of evidence is inconclusive
F.2.3.
Drone production (Class 1 endpoint)
Two
figures
are presented below for the succeeding crop scenario. Both are based on the same
data set (drone production of queenright bumblebee colonies), but with slightly different set-ups in
order to help the interpretation of the data. These differences are explained in the title of the
figures.
The general interpretation is relevant for both
figures.
General interpretation
Six reliable endpoints were available, all were assessed as reliable with major restrictions
There was variability between the experiments. The deviation from the control ranged from
medium positive to large negative
Exposure estimation and information on the exposure lengths was available for all experiments
No dose–response pattern could be seen when all endpoints are considered
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Figure F.21:
Summary of the observed deviations for drone production of bumblebees for the
succeeding crop scenario
endpoints in the order of the magnitude of deviation from
control, scale for exposure level aligned to the available data
Figure F.22:
Summary of the observed deviations for drone production of bumblebees for the
succeeding crop scenario
endpoints in the order of the magnitude of the exposure
estimation, scale for exposure level aligned to the available data
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Interpretation of the line of evidence
Indications for larger than negligible effect
The deviation from the control was large negative
for two experiments and the exposure estimation
was lower than the exposure assessment goal in
both cases. Although the exposure length was too
long for one of these experiments, the exposure
lengths of the other one (lower dose of I.1505) was
in the realistic range of the
flowering
period of any
succeeding crop
Indications for lack of larger than negligible effect
Four endpoints indicated a positive mean deviation from
the control. Although all of them had too low estimated
exposure, in one case (high dose of I.1505) at least the
estimations for larvae were close to the respective
exposure assessment goal and another one had a very
long exposure period
Results from the two test concentrations of experiment
I.1505 are not consistent; the lower dose resulted in the
negative deviation from the control indicating some
uncertainties to consider this deviation as true effect
The available evidence indicating not more than negligible deviation from the control has not more neither less
weight than has the evidence indicating more than negligible negative deviation from the control.
Two experiments with low exposure level indicated a clear negative deviation from the control. One of them had
too long exposure length, while the other one bears some uncertainties. On the other hand, two experiments
could be considered bearing some evidences that indicate no negative deviations from the controls. However,
both of them had relatively mild exposure regimes. Overall, all the available evidences have very low weight and
no clear trend could be seen when they were balanced
Therefore,
this line of evidence is inconclusive
F.2.4.
Reproductive output of queenless microcolonies (Class 1
endpoint)
One
figure
is presented below for the succeeding crop scenario.
The endpoints in the available experiments with queenless microcolonies were reported in different
ways: (1) brood production (i.e. drone brood cells) or (2) drone production (number of adult drones)
or (3) both of these two reported separately or (4) both of the two, but reported as a combined
endpoint (brood cell
+
adults). Because of this and since all brood cells contain male larvae in this type
of study, when both endpoints were reported separately, they were summed up.
General interpretation
Altogether seven endpoints were available, but two of them were considered as non-reliable
All the
five
reliable endpoints were considered as reliable with major restrictions
The variability between the reliable endpoints was rather low; the deviations from the control
ranged from small to large negative
Exposure estimation and information on the exposure lengths was available for all the reliable
experiments
Meaningful dose–response analysis cannot be performed due to the low variability between the
reliable endpoints
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Figure F.23:
Summary of the observed deviations for drone production of queenless bumblebee
colonies for the succeeding crop scenario
Interpretation of the line of evidence
Indications for larger than negligible effect
All endpoints have larger than negligible negative
deviation from the control, three of the
five
have large
deviations, and there are no endpoints with negligible
or positive deviation from the control
Indications for lack of larger than negligible
effect
The experiment with the highest exposure estimation
(above the exposure assessment goal) and longest
exposure period indicated the smallest deviation from
the control, while all the other experiments with
milder exposure regime had larger deviations from the
control
One of the experiments (I.788) had a low exposure
level in combination with a realistic exposure length
compared to the range of the
flowering
period of
succeeding crops (in fact the exposure length was at
the lower end of this range). Although the length of
exposure was too long for three other endpoints, the
exposure levels of these experiments were also lower
than the exposure assessment goal
The available evidence indicating not more than negligible deviation from the control has less weight than has
the evidence indicating more than negligible negative deviation from the control
This is because there were a number of endpoints with relatively low exposure levels and one of them with a
realistic exposure length, which endpoints indicated clearly negative deviations from the control. In addition, no
endpoint exists, which would indicate negligible or positive deviation from the control
Overall, this indicates a
moderate evidence for larger than negligible effect
F.2.5.
Brood production (Class 1 endpoint)
Three
figures
are presented below for the succeeding crop scenario. Both are based on the same
data set (brood production of queenright bumblebee colonies), but with slightly different set-ups in
order to help the interpretation of the data. These differences are explained in the title of the
figures.
The general interpretation is relevant for both
figures.
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General interpretation
Twelve reliable endpoints were available, all but one were assessed as reliable with major
restrictions
There was some variability between the experiments. The deviation from the control ranged
from medium positive to large negative
Exposure estimation and information on the exposure lengths was available for all experiments
No dose–response pattern could be seen when all endpoints are considered
Figure F.24:
Summary of the observed deviations for brood production of bumblebees for the
succeeding crop scenario
endpoints are indicated in the order of the magnitude of
mean deviation, scale for exposure level aligned to the available data
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Figure F.25:
Summary of the observed deviations for brood production of bumblebees for the
succeeding crop scenario
endpoints are indicated in the order of the magnitude of
mean deviation, scale for exposure level aligned to the exposure assessment goals
(zoom in to the relevant part)
Figure F.26:
Summary of the observed deviations for brood production of bumblebees for the
succeeding crop scenario
endpoints in the order of the magnitude of the exposure
estimation, scale for exposure level aligned to the exposure assessment goals (zoom in
to the relevant part)
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Interpretation of the line of evidence
Indications for larger than negligible effect
The maximum negative deviation from the controls
was larger than negligible in one experiment out of
the three, where the effect was studied at more than
one observation day. The exposure level was below
the exposure assessment goals, although it had a
very long exposure period
Indications for lack of larger than negligible effect
The maximum negative deviation from the controls was
not larger than negligible in two of those three
experiments, where the effect was studied at more than
one observation day; these two endpoints are originating
from the same experiment, they are two test
concentrations
Although the results from the two test concentrations are
not consistent in terms of dose–response trend, they
provide an indication for not more than negligible
deviation from the control at realistic exposure level for
the larvae (high dose) compared to the exposure
assessment goal in combination with a very long exposure
period
The mean deviation from the control was larger than Only two endpoints (from the same experiment) indicated
negligible in 10 experiments and the exposure
no negative mean deviation from the control. Although
estimation for eight of them was lower than the
one of them had too low estimated exposure, for the
exposure assessment goal. For
five
of these
others the exposure estimations for larvae overlapped the
experiments, the exposure lengths fell in the realistic respective exposure assessment goal. Moreover, both of
range of the
flowering
period of any succeeding crop them had a very long exposure period
The available evidence indicating not more than negligible deviation from the control has less weight than has
the evidence indicating more than negligible negative deviation from the control
This is because only two endpoints (from the same experiment) indicated no negative deviation from the
controls and only one of them had a high enough exposure level and this was only for the larvae. Nevertheless,
the lengths of the exposure of these experiments were considerable longer than the realistic range of the
flowering
period of any succeeding crop. On the other hand, a number of experiments indicated clearly negative
deviations from the control. Five of these experiments had a mild exposure regime
Overall, this indicates a
moderate evidence for larger than negligible effect
F.2.6.
Colony strength (Class 1 endpoint)
Only two endpoints were available for colony strength. The deviation from the control in the
experiment I.2004 ranged from negligible to large negative deviation and the median effect (over the
study duration) was assessed as a medium negative effect. The endpoint was considered as fully
reliable. The estimated exposure level was 1.83–3.73 ng/bee per day for workers and 5.95 ng/larva
per developmental period for larva (the exposure assessment goal for workers is 2.69–3.12 ng/bee per
day and for larvae is 6.5 ng/larva per developmental period). The length of the exposure was at the
higher end, but within the realistic range of the
flowering
period of any succeeding crop.
The deviation from the control in the experiment C+I.2017 was a large-negative deviation. The
endpoint was considered reliable with major restrictions. The estimated exposure level was
0.31–0.63 ng/bee per day for workers and 0.99 ng/larva per developmental period for larva (the
exposure assessment goal for workers is 2.69–3.12 ng/bee per day and for larvae is 6.5 ng/larva per
developmental period). The length of the exposure was higher than the realistic range of the
flowering
period of any succeeding crop, but only with 1 day.
Overall, this indicated a
strong evidence for larger than negligible effect.
F.2.7.
Emergence rate (Class 2 endpoint)
Only one endpoint was available for emergence rate (I.2004). The deviation from the control
bridged from large positive to large negative and the median effect (over the study duration) was
assessed as a medium-negative effect. The estimated exposure level was 1.83–3.73 ng/bee per day
for workers and 5.95 ng/larva per developmental period for larva (the exposure assessment goal for
workers is 2.69–3.12 ng/bee per day and for larvae is 6.5 ng/larva per developmental period). The
endpoint was considered as fully reliable. The length of the exposure was at the higher end, but within
the realistic range of the
flowering
period of any succeeding crop.
This indicated a
moderate evidence for larger than negligible effect.
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F.2.8.
Mating ability of the new queens (Class 2 endpoint)
Only one endpoint was available for mating ability (I.1388). This experiment, which was a
field
study on sunflower, indicated a negligible (negative) deviation from the control. The endpoint was
considered as reliable with major restrictions. No exposure estimation was possible. The length of the
exposure was 9 days.
Due to the lack of information on the exposure of the single endpoint that was available, this
line
of evidence is considered to be inconclusive.
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Appendix G
List of study references
Exp. ID
110403
CAN/US
All+.2003
Doc.ID
Author
distiller
N/A
Scott-Dupree, CD; Spivak, MS;
Bruns, G; Blenskinsop, C;
Nelson, S
Pohorecka K, Skubida P,
Miszczak A, Semkiw P, Sikorski
P, Zagibajlo K, et al.
Pohorecka K, Skubida P,
Miszczak A, Semkiw P, Sikorski
P, Zagibajlo K, et al.
Study title
The impact of Gaucho and TI-435 seed-treated Canola on
honeybees,
Apis mellifera
L
Year
2001
Type
Appendix
to EFSA
(2018a)
File name
EFSA
(2013a)
All
+
field
Residues Study
evaluation
notes
Field
M
1080
Residues of Neonicotinoid Insecticides in Bee Collected Plant
2012
Materials from Oilseed Rape Crops and their Effect on Bee Colonies
Residues of Neonicotinoid Insecticides in Bee Collected Plant
2012
Materials from Oilseed Rape Crops and their Effect on Bee Colonies
2015
2013
All+.1080
1080
Residues M
All
+
Residues
All
+
Lab
C+I_Field
All+.1084
C+I.1081
1084
1081
Poquet Y, Kairo G, Tchamitchian Wings as a new route of exposure to pesticides in the honeybee
S, Brunet J-L, Belzunces LP
Pohorecka K, Skubida P,
Effects of exposure of honeybee colonies to neonicotinoid seed
Semkiw P, Miszczak A, Teper D,
Sikorski P, et al.
Schneider CW, Tautz J,
Gruenewald B, Fuchs S
Scholer J, Krischik V
RFID Tracking of Sublethal Effects of Two Neonicotinoid
Insecticides on the Foraging Behavior of
Apis mellifera
Chronic Exposure of Imidacloprid and Clothianidin Reduce Queen
Survival, Foraging, and Nectar Storing in Colonies of
Bombus
impatiens
Lab
Field
M
G
C+I.1244
C+I.1248
1244
1248
2012
2014
Colony
feeders
Colony
feeders
Colony
feeders
Colony
feeders
Colony
feeders
G
G
C+I_Colony
feeders
C+I_Colony
feeders
C+I_Colony
feeders
C+I_Colony
feeders
C+I_Colony
feeders
C+I.2017
926
C+I.423
423
Moffat C, Pacheco JG, Sharp S,
Samson AJ, Bollan KA, Huang J,
et al.
Fischer J, Mueller T, Spatz A-K,
Greggers U, Gruenewald B,
Menzel R
Lu C, Warchol KM, Callahan RA
Chronic exposure to neonicotinoids increases neuronal vulnerability 2015
to mitochondrial dysfunction in the bumblebee (Bombus
terrestris)
Neonicotinoids Interfere with Specific Components of Navigation in 2014
Honeybees
Sub-lethal exposure to neonicotinoids impaired honeybees
winterization before proceeding to colony collapse disorder
2014
G
G
C+I.844
844
G
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Exp. ID
C*I.1324
Doc.ID
Author
distiller
1324
Staffel J; Luckmann J
Study title
Assessment of Potential Impacts on Honeybee Colony
Development, their Hibernation Performance and Concurrent
Monitoring of Aerial Dust Drift During the Sowing Operation of
Poncho Beta Plus - Treated Sugar Beet Pills with Typical
Commercial Vacuum-Pneumatic Sowing Technology, Directly
Adjacent to Full-Flowering Phacelia tanacetifolia in Germany
Residue levels of imidacloprid and imidacloprid metabolites in
nectar, blossoms and pollen of summer rape cultivated on soils
with different imidacloprid residue levels and effects of these
residues on foraging honeybees. Laacher Hof 1999
Residue levels of imidacloprid and imidacloprid metabolites in
nectar, blossoms and pollen of summer rape cultivated on soils
with different imidacloprid residue levels and effect of these
residues on foraging honeybees
Determination of Side-effects of SeedOprid 600 FS coloured
treated Seeds of Winter Oil-Seed Rape on Honeybees (Apis
mellifera
L.) in the
field
in Germany 2011/2012
Determination of Side-effects of SeedOprid 600 treated Seeds of
Spring Oil-Seed Rape on Honeybees (Apis
mellifera
L.) in the Field
in Germany 2011
Effects of sublethal doses of crop protection agents on honeybee
(Apis
mellifera)
global colony vitality and its potential link with
aberrant foraging activity
Sub-lethal effects of imidacloprid on bumblebees,
Bombus
terrestris
(Hymenoptera: Apidae), during a laboratory feeding test
Year
2014
Type
Field
Appendix
to EFSA
(2018a)
H
File name
C*I Field
E 370 1548-8 N/A
Schmuck, R; Schoening, R;
Schramel, O
1999
Residues Study
evaluation
notes
Residues N/A
EFSA
(2013a)
E 370 1553-4 N/A
Schmuck, R; Schoening, R;
Schramel, O
2007
EFSA
(2013a)
I.1094
1094
Probsting A
2012
Residues E
I residues
I.1095
1095
Probsting A
2011
Residues E
I residues
I.137
137
I.1386
I.1388
I.1455 - Part
I and II
1386
1388
1455
Belien T, Kellers J, Heylen K,
Keulemans W, Billen J, Arckens
L, et al.
Tasei JN, Lerin J, Ripault G
Tasei JN, Ripault G, Rivault E
2009
Colony
feeders
Colony
feeders
field
Colony
feeders
E
I colony
feeders
I colony
feeders
I
field
I colony
feeders
2000
2001
2014
E
E
E
Hazards of imidacloprid seed coating to
Bombus terrestris
(Hymenoptera: Apidae) when applied to sunflower
van der Steen JC, Hok-Ahin and De invloed van imidacloprid en de interactie met gereduceerd
Cornelissen B
stuifmeelaanvoer op de vitaliteit en de overwintering van
bijenvolken. Translation from Dutch: The influence of imidacloprid
and the interaction with reduced pollen supply on the vitality and
overwintering of honeybee colonies
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Exp. ID
I.1498
Doc.ID
Author
distiller
1498
Wehner A
Study title
Year
Type
Field
Appendix
to EFSA
(2018a)
E
File name
2.I
field
I.1505
I.163
I.178
1505
163
178
Whitehorn PR, O’Connor S,
Wackers FL, Goulson D
Bocksch S
Bortolotti L, Montanari R,
Marcelino J, Medrzycki P, Maini
S, Porrini C
Bryden J, Gill RJ, Mitton RAA,
Raine NE, Jansen VAA
Hecht-Rost
2013
Determination of Side-effects of SeedOprid 600 FS coloured
treated Seeds of Sunflower on Honeybees (Apis
mellifera
L.) in the
Field in Italy 2012
Neonicotinoid Pesticide Reduces Bumblebee Colony Growth and
2012
Queen Production
Honeybee brood and colony level effects following Imidacloprid
intake via treated artificial diet in a
field
study in North Carolina
Effects of sub-lethal imidacloprid doses on the homing rate and
foraging activity of honeybees
Chronic sublethal stress causes bee colony failure
A residue study with Nuprid 600 FS treated maize seed,
investigating residues in crops, soil and honeybee products in
Germany 2007
Assessment of Chronic Sublethal Effects of Imidacloprid on
Honeybee Colony Health
Effect of reduced risk pesticides for use in greenhouse vegetable
production on
Bombus impatiens
(Hymenoptera: Apidae)
Learning performances of honeybees (Apis
mellifera
L) are
differentially affected by imidacloprid according to the season
Risk posed to honeybees (Apis
mellifera
L. Hymenoptera) by an
imidacloprid seed dressing of sunflowers
2014
2003
Colony
feeders
Colony
feeders
Colony
feeders
E
E
E
I colony
feeders
I colony
feeders
I colony
feeders
I colony
feeders
I semifield
I.2004
I.2016
201
553
2013
2009
Colony
E
feeders
Semifield E
I.2017
I.2019
I.2020
I.2025
I.2043
362
501
340
1243
1092
Dively GP, Embrey MS, Kamel A,
Hawthorne DJ, Pettis JS
Gradish AE, Scott-Dupree CD,
Shipp L, Harris CR, Ferguson G
Decourtye A, Lacassie E,
Pham-Delegue MH
Schmuck R, Schoning R,
Stork A, Schramel O
Probsting A
2015
2010
2003
2001
Colony
feeders
Colony
feeders
Lab
Colony
feeders
Field
E
E
E
E
E
I colony
feeders
I colony
feeders
I Lab
I colony
feeders
I
field
I.2044
1093
Probsting A
Determination of Side-effects of SeedOprid 600 FS coloured
2011
treated Seeds of Maize on Honeybees (Apis
mellifera
L.) in the
Field in Germany 2011
2011
Determination of Side-effects of SeedOprid 600 FS coloured
treated Seeds of Sunflower on Honeybees (Apis
mellifera
L.) in the
Field in Germany 2011
Determination of Side-effects of SeedOprid 600 FS coloured
treated Seeds of Winter Oil-Seed Rape on Honeybees
(Apis
mellifera
L.) in the
field
in Germany 2011/2012
2012
Field
E
I
field
I.2045
1094
Probsting A
Field
E
I
field
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Exp. ID
I.2046
Doc.ID
Author
distiller
1095
Probsting A
Study title
Determination of Side-effects of SeedOprid 600 treated Seeds of
Spring Oil-Seed Rape on Honeybees (Apis
mellifera
L.) in the Field
in Germany 2011
Repression and Recuperation of Brood Production in
Bombus
terrestris
Bumblebees Exposed to a Pulse of the Neonicotinoid
Pesticide Imidacloprid
Effects of novel pesticides on bumblebee (Hymenoptera: Apidae)
colony health and foraging ability
Year
2011
Type
Field
Appendix
to EFSA
(2018a)
E
File name
I
field
I.2051
787
Laycock I, Cresswell JE
2013
Colony
feeders
Colony
feeders
Colony
feeders
Colony
feeders
E
I colony
feeders
I colony
feeders
I colony
feeders
I colony
feeders
I semifield
I colony
feeders
I Lab
I.2052
I.362
I.411
937
362
411
Morandin LA, Winston ML
Dively GP, Embrey MS, Kamel A,
Hawthorne DJ, Pettis JS
Faucon JP, Aurieres C,
Drajnudel P, Mathieu L, Ribiere
M, Martel AC, et al.
Gels JA, Held DW, Potter DA
Gill RJ, Ramos-Rodriguez O,
Raine NE
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E
E
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Assessment of Chronic Sublethal Effects of Imidacloprid on
2015
Honeybee Colony Health
Experimental study on the toxicity of imidacloprid given in syrup to 2005
honeybee (Apis
mellifera)
colonies
Hazards of insecticides to the bumblebees
Bombus impatiens
(Hymenoptera: Apidae) foraging on
flowering
white clover in turf
Combined pesticide exposure severely affects individual- and
colony-level traits in bees
2002
2012
I.462
I.475
I.545
462
475
545
Semifield E
Colony
feeders
Lab
E
E
I.724:
724
Monceren BB
(1)
I.725:
Monceren
(BB2)
I.787
725
Sublethal doses of imidacloprid decreased size of hypopharyngeal 2013
Hatjina F, Papaefthimiou C,
Charistos L, Dogaroglu T, Bouga glands and respiratory rhythm of honeybees
in vivo
M, Emmanouil C, et al.
Klein O
A Field Study to Evaluate Effects of Monceren G on the Bumblebee 2014
(Bombus
terrestris
L; Hymenoptera, Apidae) in Potato in Southern
Germany in 2014
Klein O
Field Study to Evaluate Effects of Monceren G on the Bumblebee
(Bombus
terrestris
L; Hymenoptera, Apidae) in Potato in Southern
Germany in 2014
Repression and Recuperation of Brood Production in
Bombus
terrestris
Bumblebees Exposed to a Pulse of the Neonicotinoid
Pesticide Imidacloprid
Effects of imidacloprid, a neonicotinoid pesticide, on reproduction
in worker bumblebees (Bombus
terrestris)
In situ replication of honeybee colony collapse disorder
2014
Field
E
I
field
Field
E
I
field
787
Laycock I, Cresswell JE
2013
Colony
feeders
Colony
feeders
Colony
feeders
E
I colony
feeders
I colony
feeders
I colony
feeders
I.788
I.843
788
843
Laycock I, Lenthall KM, Barratt
AT, Cresswell JE
Lu C, Warchol KM, Callahan RA
2012
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E
E
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MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0112.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Exp. ID
I.848
Doc.ID
Author
distiller
848
Luckmann J, Staffel J
(L mentioned in Appendix to
EFSA, 2018a)
Study title
Assessment of Potential Impacts on Honeybee Colony
Development, their Hibernation Performance and Concurrent
Monitoring of Aerial Dust Drift During the Sowing Operation of
Imidacloprid FS 350A G - Treated Winter Barley with Typical
Commercial Pneumatic So
Effects of novel pesticides on bumblebee (Hymenoptera: Apidae)
colony health and foraging ability
Risk assessment for side effects of neonicotinoids against
bumblebees with and without impairing foraging behaviour
Sensitivity of non-target arthropods and beneficial fungal species
to chemical and biological plant protection products: results of
laboratory and semifield trials
Risk assessment for side effects of neonicotinoids against
bumblebees with and without impairing foraging behaviour
Reconciling laboratory and
field
assessments of neonicotinoid
toxicity to honeybees
Year
2014
Type
Field
Appendix
to EFSA
(2018a)
E
File name
I
field
I.937
I+T.2015
937
931
Morandin LA, Winston ML
Mommaerts V, Reynders S,
Boulet J, Besard L, Sterk G,
Smagghe G
Sterk G, Heuts F, Merck N,
Bock J
2003
2010
Colony
feeders
Colony
feeders
Colony
feeders
Colony
feeders
Colony
feeders
Field
E
L
I colony
feeders
I+T. Colony
feeder
I+T. Colony
feeder
I+T. Colony
feeder
I+T. Colony
feeder
T*I
field
I+T.2029
I+T.2031
I+T.931
1341
2003
L
L
L
931
Mommaerts V, Reynders S,
Boulet J, Besard L, Sterk G,
Smagghe G
Henry M, Cerrutti N, Aupinel P,
Decourtye A, Gayrard M,
Odoux J-F, et al.
2010
I*T.583
583
2015
K
www.efsa.europa.eu/efsajournal
112
EFSA Journal 2018;16(2):5178
MOF, Alm.del - 2018-19 (1. samling) - Endeligt svar på spørgsmål 445: Spm. om, hvorvidt Miljøstyrelsens vurdering i forbindelse med dispensation fra brug af neonikotinoider til sukkerroer udelukkende baserer sig på Aarhus Universitets landbrugsfaglige vurdering, til miljø- og fødevareministeren
2009981_0113.png
Peer review of the pesticide risk assessment for bees of the active substance imidacloprid
Appendix H
Used compound codes
Code/trivial
name
5-OH-
imidacloprid
Chemical name/SMILES notation
(2E)-1-[(6-chloropyridin-3-yl)methyl]-5-hydroxy-N-
nitroimidazolidin-2-imine
[O-][N+](=O)/N=C2\NCC(O)N2Cc1cnc(Cl)cc1
N
Cl
N
Structural formula
O
N
N
+
O
NH
HO
O
N
N
N
N
+
Imidacloprid
olefin
(2E)-1-[(6-chloropyridin-3-yl)methyl]-N-nitro-1,3-dihydro-
2H-imidazol-2-imine
[O-][N+](=O)/N=C2\NC=CN2Cc1cnc(Cl)cc1
O
NH
Cl
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EFSA Journal 2018;16(2):5178