Submission APP202077Poncho Votivo

3rd December 2015Apiculture Industry Technical Focus Group (AITFG)

(National Beekeepers Association (NBA) Technical Committee)

Bacillus firmus• The application has no manufacturing information;

• On the cultivation and growing of the micro-organism.• How is it quarantined during manufacture?

• There is a biosecurity risk to NZ bees, if other harmful micro-organisms piggy back a ride to NZ on shipments of Poncho Votivo.

• We acknowledge the existence of this micro-organism in NZ.• Why did Bayer not source this organism locally?

• The biggest risks to NZ bees are further importations of micro organisms that can harm our bees.

Poncho Votivo Application

• Reference 7.2E, Page 29 Application. This statement is misleading; “The key difference is that Poncho Votivo has B. firmus I-1582 added and a reduced amount of clothianidin.”True, the concentration in the drum has been reduced to 508 g/l from 600g/l

in Poncho.There is no reduction in the amount of clothianidin used on the crop as the

seed treatment rate has been increased by 20%. From 100 ml Poncho/80,000 maize seeds to 120 ml Poncho Votivo/80,000 maize seeds.There is marginally more clothianidin used per 80,000 maize seeds when

using clothianidin. Poncho Votivo 60.96 g/80,000 seeds versus Poncho 60 g/80,000 seeds.

ISO31000 Risk Management Process

Reference: Figure 1, ASNZSISO31000-2009

Missing in New ZealandThere is no EPA monitoring and review process of what is actually happening in NZ’s environment.(E & R Report Sect 6.3)

Clothianidin first registered as a seed treatment in NZ in June 1993.

“Maize flats disease” beehive losses • Beekeepers have been aware that their hives near maize crops die out

at the time of maize harvest and for some months afterwards• Major maize cropping areas that this effect has been observed –

Eastern Bay of Plenty, Gisborne plains, around Te Puke and the Waikato. • Beekeepers call it “maize flats disease”...but it appears to not be a

disease. • No conclusive explanation to date. • This is the first data from an Environmental analysis conducted by

AUT and the AITFG.

Bee Hive Losses - Poverty Bay2004Beekeeper Site Total Hives Hives lost Date affected

P Badger Ormond 30 12 Between 14/4/04 & 14/5/04

P Badger Te Karaka 14 9 Between 18/4/04 & 3/6/04

P Burt Tangihanga 60 55 Late April / May

B Savage Newmans Rd ?? ?? Numbers not recorded

Year Total 104 76

2005Beekeeper Site Total Hives

AffectedHives lost Date affected

P Badger Ormond 9 3 Between 31/3/05 & 13/4/05

P Badger Te Karaka 19 nil Moved in 24/5/05

B Foster J Holden 30 16 Between March & April0

The DataPaul Badger

Maize Crop Calendar

Oct Nov Dec Jan Feb Mar Apr May June July Aug Sept Oct

Maize Crop

PlantingTreated Seed Crop growing

Grain HarvestTime of bee hive

lossesStubble

Planting

2015 Survey n = 4 n =

45

Sampling DatesFirst Survey: June 29th – Stubble and soil samples n= 4Second Survey: September 29th & 30th – Soil samples n=45n = number of samples tested

First survey

• ‘Jump the fence’ samples taken on 29th June• One single stubble plant analysed and 3 soil samples.• Chemicals detected

Sample Analysis ClothiandinStubble of maize Hills Labs

#1444176< 0.02 mg/kg

Soil sample 1 AUT 35 ng/g wet weightSoil Sample 2 AUT 30 ng/g wet weight

Soil Sample 3 AUT 30 ng/g wet weight

8

9Site 151

Site 111Site 121

Site 176

Site 121

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Second survey• September 29/30th this year soil samples were taken from 9 maize stubble paddocks. • Paddocks were not selected on any basis of past history. We did not survey

growers/owners first to determine the history of the seed treatments used.• Paddocks sites have been mapped by latitude and longitude.• 5 samples were randomly removed from each paddock. Wet areas were avoided.

Uncultivated stubble areas were preferred – but some paddocks had been cultivated – see photos.

• Samples were removed by a trowel, depth of sample 150mm, diameter of sample 50mm. We used a normal soil fertility test selection method (Ravensdown).

• Each sample is more than 10 metres from the next one.• Each sample is packed in a marked plastic bag, kept in a chilly bin and delivered to

the lab on 1st October.

9/11/2015

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School of Applied SciencesAnalytical Laboratory• Supervised by Dr Chris Pook,

Chemical Ecologist• Neonicotinoid residues extracted

from soil and analysed by liquid chromatography with tandem mass spectrometry (LC-MS/MS).

9/11/2015

Analysis of neonicotinoid residues in soil samples

5/11/2015

Dr Chris Pook, AUT

Results are in nanograms of clothianidin a.i. per gram wet weight of soil

Site Paddock sample number Samplesn

clothianidin Mean ng/g

clothianidin SD ng/g

Matamata 101 5 17.5 12.06Awakeri 111 5 4.7 2.74

Poroporo 121 5 11.2 4.63TeTeko 131 5 2.8 0.55

Poroporo 151 5 2.1 2.4Whakatane 161 5 2.5 2.4

TePuke 171 5 3.8 0.8Te Puke 176 5 2.2 0.35

Gisborne C1 5 26.7 46.48

Instrument Detection Limit 0.44

calculated 03-11-15

©2015

This data is Copyright of Auckland University of Technology. ©2015Publication is not authorised without the permission of the Copyright holder.

The analysis presented in these results is being repeated to verify the results. The chart is the Phase 1 testing results only.

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Survey Results• No organophosphates or carbamate chemicals detected.• All samples taken when analysed showed both clothianidin and imidacloprid. • We did not look for the metabolites of clothianidin. • We did not survey growers/owners first to determine the history of the seed

treatments used. • We did expect to find some non contaminated paddocks. This chemicals

seem to be widespread in the environment.• Persistence of these neonicotinoids in these NZ soils is we believe significant.

11 months after date of sowing. • There is enough chemical in this environment to give a lethal dose to a bee,

which weighs 0.1 to 0.12 grams.

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Future Plans – continue the study.• Complete Phase 2 – check and verify the test results achieved to date. • Two more stages are planned;• Stage 2 Return to these same paddocks at harvest

• Introduce hives to the area prior to harvest and monitor the harvest and period immediately after.

• Sample and test – soils, stubble, beehive (nectar, wax and bees), for pesticides. • Observe bee foraging behaviour in the stubble.

• Stage 3 – repeat Stage 1 testing (repeat these tests in September 2016).

• A funding requirement of $20,000 is required to complete the project. All donations gratefully received. See me afterwards.

9/11/2015

77A Control – Application Rate• EPA has set a maximum seed treatment rate of 120ml / 80,000 maize seeds.

Okay for maize, what about grass seed and forage brassicas?• This is the extra amount of Poncho Votivo released for a farmer sowing maize at

maximum recommended rate versus 80,000 seeds /hectare.Seed Company Min Seeds per

hectareMax Seeds per

hectare% Poncho

VotivoAbove min

EPA 80,000 None

Corson Seed 80,000 120,000 50% +

Pacific Seeds 80,000 115,000 44% +

Pioneer Seeds 88,000 110,000 27.5% +

The EPA needs to use an Environmental Exposure Limit for soils as the control

Request for the EPA

• The EPA to encourage the use of NZ environmental testing when conducting a risk assessment. • Apply to clothianidin an Environmental Exposure Limit (EEL) for soils. • Review the use of neonicotinoids with respect to their use.

Is the prophylactic use of these pesticide widespread?What needs to be done so use of these products for curative purposes?

• Have the EPA make better decisions with NZ data in their risk assessments.

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Acknowledgements

• Apiculture Industry Technical Focus Group (AITFG) (NBA Technical Committee)• Beekeepers; Mossops Honey, Whai Hua Bees, Barry Foster for

providing samples, history of problem and introductions.• Farmers and Maize contractors who permitted sampling of their

paddocks.• AUT School of Applied Science for funding the research to date.• Dr Chris Pook and Iana Gritcan for conducting the scientific analysis.