1. Decision-making process on the status of neonicotinoid insecticides for seed treatment in Slovenia Katarina Groznik, Ministry of Agriculture and Environment Workshop on neonicotinoid insecticides and honeybees Belgrade, 13 February 2012

2. Content  Introduction  Treated oilseed rape  Insecticides and treated maize seed - regulatory and risk management measures  Conclusion

3. Introduction (1) MAY 2008  Prohibition the placing on the market and use of insecticides for seed treatment registered in Slovenia with active substances clothianidin, thiamethoxam and imidacloprid.  Prohibition the placing on the market of maize seed, oilseed rape and sugar beet seed, treated with active substances clothianadin, thiamethoxam and imidacloprid.

4. Introduction (2)  Poncho FS 600 Rdeč (clothianidin 60%) – maize and sugar beet seed  Cruiser 350 FS (thiamethoxam 35 %) – maize seed  Cruiser 70 WS (thiamethoxam 70 %) – sugar beet seed  Gaucho FS 350 (imidacloprid 35 %) – maize seed  Gaucho WS 70 (imidacloprid 70 %) – sugar beet seed

5. Introduction (3)  The decision was taken as an emergency measure due to unexpected bee poisoning during the sowing of insecticide treated maize seed.  The reason for the incident was not known at the time.

6. Introduction (4)  With further investigation and information from Germany (same problem with massive bee poisoning) and also Austria it was established that insecticide dust from treated seed could present risk for bees.  Insecticides dust from the seed depends on quality of seed dressing and the type of seed drills (dust particles emitted by pneumatic (vacuum) machines.

7. Exposure of dust during drilling: most (but not all) of the dust are soil particles

8. Treated oilseed rape (1)  Review of the seed dressing and sowing machines concluded, that sowing of treated oilseed rape with technically sound seed drills presents no risk of contamination to surrounding fields and of threat for bees, because: The treatment of oilseed rape is different and of higher quality than treatment of maize seed. Oilseed rape is small and covered with several layers containing insecticides or fungicides and adhesive (pelleted seed)

9. Treated oilseed rape (2) Coating is harder and more resistant to mechanical damage, so release of dust from treated oilseed rape is negligible. Treated oilseed rape contains smaller amount of insecticides than treated maize seed. For sowing of oilseed rape different drills are used than for maize sowing, such with the direct flow of air along with the seed into the ground, so any possible dust from the seed is immediately buried together with the seed into the soil.

10. Treated oilseed rape (3) AUGUST 2008  Prohibition for oilseed rape was withdrawn and the oilseed rape treated with neonicotinoid insecticides was again allowed to be used in Slovenia.

11. Insecticides and treated maize seed  There was a need for further investigation and activities, so the prohibition of neonicotinoid insecticides for seed treatment and treated maize seed remained in force at the time.  Until the end of 2008, close cooperation and exchange of information were held by the German authorities and preparation of measures for the whole chain, from PPP companies and seed industry to farmers, for possible re-use of treated maize seed.

12. Insecticides and treated maize seed – Measures 1. Additional requirements for marketing and use of treated seed:  Ensuring a high quality of treated seed  Labelling of treated seed  Proper handling of treated seed 2. Mitigation measures to reduce dust emmission and dispersion 3. Reduction of the use of seeds treated with insecticides 4. Information and training 5. Monitoring program 6. Increased control

13. 1. Additional requirements for marketing and use of treated seed (1) A. Amendments to the Rules on the marketing of cereal seed B. Amendments to the Rules on the responsibilities of users of PPPs C. Introduction of new method for quality control of treated seeds.

14. 1. Additional requirements for marketing and use of treated seed (2) A. The amendments to the Rules on the marketing of cereal seed  Seed can be treated only with the PPP, which is registered for seed treatment in at least one EU Member State.  Seed should be treated as provided for in the instruction for the use of PPP, which is in accordance with the authorisation of PPP, so that sowing and handling with treated seed do not result in unacceptable risk to human and animal health.

15. 1. Additional requirements for marketing and use of treated seed (3)  Each package of treated seed should have an additional label, on which is written: names of active substances contained in the PPP, with which the seed was treated applied dose of PPP to the seed unit or per unit weight of seed mandatory instructions for the user of treated seed – “Sowing should be carried out in accordance with good agricultural practice in a way that prevents PPP dust from the seed on neighbouring plots, taking into account wind speed and direction.”

16. 1. Additional requirements for marketing and use of treated seed (4) B. Amendments to the Rules on the responsibilities of users of PPPs Requirements for seed companies:  Seeds may be treated with PPP only in appropriate devices for treatment of seed material in accordance with legal requirements.  Seeds may be treated only by natural and legal persons who are registered for the preparation of seeds for placing on the market.  Seed which has been treated with insecticides shall not be re-treated with the same or additional PPPs.

17. 1. Additional requirements for marketing and use of treated seed (5) Requirements for farmers:  Handling with treated seeds in bags should be done in such a way to prevent mechanical damage of seed and packaging, and the falling away the coating of the treated seeds.  During the filling of sowing machine, the dust that fell away from the treated seeds, should not be shake out of the bags.  Empty bags and waste dust in bags should be disposed of in accordance with the legislation on waste.

18. 1. Additional requirements for marketing and use of treated seed (6)  Unused treated seed should be stored until the next sowing season with a label in a well-closed bags or disposed of in accordance with the regulations on waste.  Before the sowing of treated seed the warnings and notices on the label about personal safety, protecting the environment and animals should be carefully read and strictly followed at sowing.

19. 1. Additional requirements for marketing and use of treated seed (7) C. Introduction of new method for quality control of treated seeds  Minimum standard for treated seed: 4 g of dust/100 kg of seeds  Testing of dust from treated seed with Heubach method  Testing is performed with the Heubach machine in the laboratory in the dust-free chamber, at certain temperature (20 -25oC) and relative humidity (30 -50 %). Analytical scale on 5 decimal places must be ionized and free of vibration.

20. Heubach Dustmeter

21. 2. Mitigation measures to reduce dust emission and dispersion (1)  Sowing of maize seed treated with PPP that are dangerous to bees, may be performed with the vacuum pneumatic seed drill only when they are equipped with a device (deflector) that reduces the dust particles from the treated seed in a stream of pre-eminent air in the surroundings.

22. Seed drill with pipe deflector

23. 2. Mitigation measures to reduce dust emission and dispersion (2)  Sowing should be carried out in accordance with good agricultural practice in a way that prevents PPP dust from the seed on neighbouring plots, taking into account wind speed and direction.  The farmer must keep records on treated seed.

24. 3. Reduction of the use of seeds treated with insecticides  Proposal for special permit valid for 120 days with limitation of use to farmers on infected areas with the western corn rootworm (Diabrotica virgifera virgifera) and with some additional requirements.

25. 4. Information and training (1)  The amendments to the Rules on the training of users of PPP:  Re-introduction of obligation for users of PPP to refresh the knowledge on PPP every 5 years.  Completion of training programs with greater emphasis on protecting the environment and the bees.  More emphasis on the practical demonstration of handling and preparation for the use of PPPs.

26. 4. Information and training (2)  Comprehensive information of all parties concerned (PPP companies, seed industry, farmers, bee keepers, public).  Information exchange with Commission to reach further harmonisation within the EU.

27. 4. Information and training (3)  Ministry of Agriculture, Forestry and Food with cooperation of advisory service issued a Manual with instructions for sawing of treated corn seed (40.000 copies)  Ministry of Agriculture, Forestry and Food in cooperation with Phytosanitary Administration prepared and issued: a leaflet on proper and safe use of plant protection products a leaflet on general information on plant protection products

28. 4. Information and training (4)  Agriculture and Forestry Chamber of Slovenia made an information campaine for farmers on the proper use of treated corn seed through the publications of articles in specialised agricultural newspapers and within trainings provided by agricultural advisory service.

29. Manual with instructions The components of the conventional vacuum pneumatic seed drills and way of operation.

30. Manual with instructions Outlet air is diverted to the side (arrows in the photo) in conventional vacuum pneumatic seed drill and insecticide dust particles can be released into the surrounding area. Testing the effects of drilling machines modification (Julius Kühn Institute, 2009).

31. Manual with instructions Moderen vacuum pneumatic seed drills and way of operation.

32. Manual with instructions Amazone factory set for diverting the outlet sir stream directly into the soil.

33. Manual with instructions Factory set for the modification of six or four row seed drill Gaspardo. Handcrafted set for modification of six row seed drill, a domestic product of Dolinar.

34. Manual with instructions

36. 5. Experiment and risk assessment  Experiment to determine the impact of pollen from maize, which seed had been treated with neonicotinoid insecticides, on honeybees.  Risk assessment of neonicotinoid insecticides for seed treatment was made according to new data provided by PPP companies.

37. 6. Increased control  Control measures for producers of treated seed  Good seed coating practice of seed producers was audited  Control of labelling provisions  Sampling and examination of abrasion (Heubach test)  Restrictions of the use of insecticide treated seed in maize to Diabrotica.

38. Insecticides and treated maize seed – decision (1) FEBRUARY 2009  On the basis of mentioned measures to reduce the risk of treated maize seed to honeybees, which were presented also to Slovenian beekeeper association, the prohibition was changed in restriction use of neonicotinoid insecticides for maize seed and treated maize seed.

39. Insecticides and treated maize seed – decision (2)  Only Poncho FS 600 rdeč (clothianidin 60%) and Cruiser 350 FS (thiamethoxam) were allowed to be on the market and use for 120 days in accordance with requirements in the permit.  Marketing of treated maize seed was allowed on the basis of permit with requirements for records keeping.

40. Conclusion  At the end of 2009 approval of registration for Poncho and Cruiser.  No problems with bees in relation to maize seed treated with neonicotinoid insecticides in 2009 and 2010 in Slovenia.  In May 2011 in north-east part of Slovenia (Prekmurje) massive bee poisoning with clothianidin and again a decision on the prohibition of placing on the market and use of neonicotinoid insecticides for seed treatment and treated corn and rape seed.

41. Thank you for your attention!