Brazilian Regulators Overreact to an Ongoing Study

July 8, 2013


Editor’s  Note:  CRE Brazil is regulatory watchdog located in San Paulo, Brazil. The focus of its operations is to increase the transparency of Brazilian regulatory activities. The following article is from its website,   (Portuguese)

ApiNews, a Latin American publication dedicated solely to bees (“News about bees and beekeeping from around the world”) reported on September 25, 2012:       Pesticides not yet proven guilty of causing honeybee declines 


“The impact of crop pesticides on honeybee colonies is unlikely to cause colony collapse, according to a paper in the journal Science. More research is now needed to predict the impact of widely-used agricultural insecticides, called neonicotinoids, on honeybee populations.”


On June 21, 2013 the same publication reported:


Brasil-Study Says: Pesticides Are Responsible for the Death of Bees


“The use of pesticides in plantations has been one of the most responsible for the death of bees all over the country, says a study from the Federal University of São Carlos (UFSCar) and Universidade Estadual Paulista (UNESP) in Rio Claro (SP). The Ministry of Agriculture and the Brazilian Institute of Environment and Renewable Natural Resources (IBAMA) recommend that pesticide application is not made during the bloom.”


A question which emerges is what occurred in Brazil which lead Brazilian regulators to restrict the use of pesticides given that a leading publication, read throughout Brazil, published a number of articles which demonstrated there was no definitive cause for bee health decline?


CRE Brazil contacted one of the authors who advised us that the study is ongoing. In addition they provided CRE Brazil with two interim reports, one with the following title:


Pesticides and Pollinators—Risky Business? and another which concludes:


“Various causes for this decline have been identified, including loss, destruction and degradation of habitats; reduced genetic diversity of nectar plants; pests and pathogens; competition by introduced pollinators; climate change; and pesticide use – all individually or in concert, potentially causing direct and indirect adverse effects on pollinator populations.”


Consequently the university studies in themselves provide no basis for a product restriction.


Brazil is country with the largest number of bee species in the world and is also a major food producer whose continued production is dependent on the use of pesticides.


Brazilian regulators are in need of additional information. To this end CRE Brazil is furnishing Brazilian regulatory agencies with its landmark report on the State of the Science on Bee Health Decline, please see


Major conclusions reached in the CRE study include:


— V. destructor: The Major Factor Underlying Colony Loss


— National Academy of Sciences Provides Guidance on Data Quality and Sublethal Risks


— A joint US USDA-EPA Evalution of Bee Health Decline stated:


“Acute and sublethal effects of pesticides on honey bees have been increasingly documented, and are a concern but it is not clear, based on current research, whether a pesticide exposure is a major factor associated with U.S. honey bee health declines.”


Both the Federal University of São Carlos (UFSCar) and the Universidade Estadual Paulista (UNESP) in Rio Claro have comprehensive research programs dedicated to bees.


In their continuing studies it is imperative that the universities recognize the significant research effort of the US USDA-EPA as set forth in the aforementioned CRE State of the Science paper; a comparable recognition should be made by Brazilian regulators.


CRE recommends that both the US based and the  Brazilian based researchers and regulators  initiate extensive outreach programs to share their scientific works with each other.

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