Imidacloprid (Ectosan Vet/BMK08/Ectosan): EIR Review

Information requested

Original request - 202300356303

“Please provide information relating to Imidacloprid.

Please include information and data relating to environmental risk assessments, field trials, commercial use, safety tests, spillages, waste discharges, residues testing, consumer safety, purification and validation.

Please include information relating to Ectosan Vet, Ectosan, BMK08 and any other names which Benchmark have called the Imidacloprid formulation proposed for use in salmon farming.

Specifically, please advise if validation is available for the analytical method used to determine Imidacloprid concentrations in post treatment water prior to discharge.
In addition, and quite specifically, information is sought on the following:

• Validation protocol for method as performed at point of use (on boat)
• Validation report as above
• Validation protocol for the entire purification system including variation of such parameters such as, (but not restricted to; temperature, salinity, organic loading in treatment waters
• Validation report for above
• Validation status for the purification system when used as a ‘double treatment’. This latter point is off interest because the water that is being purified will be quite different between treatment 1 and treatment 2

Please include via this FOI reply any information obtained by whistleblowers or any discussions of information posted on social media such as Twitter.

Finally, please include any information relating to the use of Imidacloprid at Ardtoe marine research laboratory in Scotland and any other research facilities.”

Response

Further to my letter of 6 July 2023, I have now completed my review of our response to your request under the Environmental Information (Scotland) Regulations 2004 (EIRs) for:

“Please provide information relating to Imidacloprid.

Please include information and data relating to environmental risk assessments, field trials, commercial use, safety tests, spillages, waste discharges, residues testing, consumer safety, purification and validation.

Please include information relating to Ectosan Vet, Ectosan, BMK08 and any other names which Benchmark have called the Imidacloprid formulation proposed for use in salmon farming.

Specifically, please advise if validation is available for the analytical method used to determine Imidacloprid concentrations in post treatment water prior to discharge.
In addition, and quite specifically, information is sought on the following:

• Validation protocol for method as performed at point of use (on boat)
• Validation report as above
• Validation protocol for the entire purification system including variation of such parameters such as, (but not restricted to; temperature, salinity, organic loading in treatment waters
• Validation report for above
• Validation status for the purification system when used as a ‘double treatment’. This latter point is off interest because the water that is being purified will be quite different between treatment 1 and treatment 2

Please include via this FOI reply any information obtained by whistleblowers or any discussions of information posted on social media such as Twitter.

Finally, please include any information relating to the use of Imidacloprid at Ardtoe marine research laboratory in Scotland and any other research facilities.”

We would like to apologise for the delay responding to your request. This request involved cross-directorate working that required coordination with colleagues that work in animal health, pesticides and chemical areas of the Scottish Government.

The scope and wording of the request meant that a high number of documents were captured in our initial search. Ensuring these documents received a thorough review was a priority and took up a substantial amount of staff time.
I have concluded that it was reasonable for the response to your request above to consider this request to be only relevant to the aquaculture industry given that the specific information requested was in the context of salmon farming. However, in light of your review request received, we sought clarification dated 13 June 2023 to ask if the request was for information the Scottish Government may hold pertaining to the use of Imidacloprid in terrestrial uses as well. You answered to confirm that the request was broader than the use of imidacloprid in the marine environment alone. I have therefore concluded that a different decision should be substituted.

Due to the clarification provided, this was treated as a new request from you (see below) and further searches were conducted. Where relevant, information relating to previous requests was reviewed in light of the new request and passage of time. Information is now to be provided to you and I enclose the information with this response.

Your request

You asked for:

“Please include only environmental information in relation to Imidacloprid: i.e. any information pertaining to ecological impacts, environmental risk assessments and toxicology.

• Please includes information on validation
• Please include only information from 1 January 2018.”

Response to your request

1. I enclose a copy of some of the information you requested – see documents 1 to 8 attached. While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because exceptions under regulations 10(4)(e) (internal communications), and 10(5)(e) (confidentiality of commercial or industrial information), and 11(2) Personal Information of a Third Party of the EIRs applies to that information. The reasons why these exceptions apply are explained in the Annex to this letter (Annex D).

2. Extracts provided

A question and answer regarding Imidacloprid was included in a document titled “FINAL BRIEFING PACK RAI Committee - Aquaculture Specific Session - 10 May 2023”. Relevant extract provided in Annex A.

A ministerial briefing titled “Wellboat Order ECCLR Committee briefing for Ms Gougeon” included a question and answer on the use of Ectosan in September 2020. The same question and answer were included in a different briefing titled “Briefing – Mr Ewing – Salmon Farming in Scotland – REC Committee – 2 December 2020”. The same text was used in both documents, which has been extracted and included in Annex B.

Imidacloprid is listed in table of chemical regulation which relates to human health and the environment titled “Copy of CDB-38-07 GB CLP Pipeline Paper- Annex 1”. The relevant extract is provided in Annex C.

3. Of the information reviewed, 48 items relating to salmon farming have already been released in previous EIRs. These are:

a) Well boats and salmon farms: EIR release - (https://www.gov.scot/publications/foi-202000084355/)

b) Information relating to Imidacloprid (BMK08/Ectosan), CleanTreat and Benchmark: EIR release - (Information relating to Imidacloprid (BMK08/Ectosan), CleanTreat and Benchmark: EIR release - gov.scot (www.gov.scot))

c) Trial of Benchmark’s Clean Treat system: EIR release – ( Trial of Benchmark’s Clean Treat system: EIR release - gov.scot (www.gov.scot))

d) Benchmark PLC correspondence - trials of CleanTreat system in Scotland: EIR release – (https://www.gov.scot/publications/foi-19-02443/)

Under regulation 6(1)(b) of the EIRs, we do not have to give you information which is already publicly available and easily accessible to you in another form or format.
Some of the information you have requested is available from the links below:

It is understood that while the CleanTreat technology can be used with imidacloprid, this is not always the case. Careful consideration was given to information relating to CleanTreat where this had been dissociated with imidacloprid to check if the information was relevant to the request. Detailed information on the Benchmark purification technology can be found online. Information considered as part of the review on this theme was cross checked with the information available in the public domain. It was confirmed that some of the background information on the technology relevant to this request is available online:

• https://www.bmkanimalhealth.com/products/cleantreat/
• Ectosan® Vet | Benchmark Animal Health (bmkanimalhealth.com)

4. Information on imidacloprid in a terrestrial context

A report on the impact and sustainable use of pesticides in the UK from 2019 was reviewed and this can be found online (Pesticides in the UK 2019 report (amenityforum.co.uk)). The report describes exposure of pesticides (including imidacloprid and thiamethoxam) to pollinators.

A document relating to the UK Expert Committee on Pesticides includes description of regulations on the use of pesticides (including imidacloprid) in the EU were reviewed (see Report on the pesticide residues monitoring programme: Quarter 3 2019 (publishing.service.gov.uk)). A report from the Commission to the European Parliament includes a comment on the potential effect of pesticides on pollinators, which can be found online, see section 5.1.11 EUR-Lex - 52020SC0087 - EN - EUR-Lex (europa.eu).

Word documents relating to plant health were found in the search to include information on imidacloprid in the context of pesticides and the outbreak of pests. These pest specific response plans can be found online: Rhagoletis-pomonella-CP-v2022.pdf (defra.gov.uk) and Rhynchophorus-ferrugineus-CP-v2.pdf (defra.gov.uk).

Information on imidacloprid was found in a document titled “BVA, BSAVA and BVZS policy position on responsible use of parasiticides for cats and dogs”. This includes a section on the impact of parasiticides on non-target invertebrates which comprises discussion on the toxicity of neonicotinoids. This document can be found online, see page 6 bva-bsava-and-bvzs-policy-position-on-responsible-use-of-parasiticides-for-cats-and-dogs.pdf.

4.1 Animal health and welfare (a division of the Scottish Government within the Agriculture and Rural Economy Directorate) policy includes action to help prevent, plan for and deal with disease, including veterinary surveillance, controls on livestock movement, identification and traceability, animal by-products and the control of imports and exports. Imidacloprid is used in flea treatments for pet animals, but the approval of veterinary medicines by Veterinary Medicines Directorate (VMD) is a reserved issue. You may wish to contact the Veterinary Medicines Directorate (How to make a freedom of information (FOI) request: Overview - GOV.UK (www.gov.uk)) who may be able to help you.

4.2 The Pesticide Survey Unit sit under Science and Advice for Scottish Agriculture (SASA), a division of the Scottish Government within the Agriculture and Rural Economy Directorate, and are responsible for collecting and publishing information about the use of pesticides on agricultural and horticultural crops in Scotland. They have advised that Imidacloprid is no longer approved as a plant protection product for use on crops. In December 2013, the European Commission amended the approval conditions for three neonicotinoid insecticides; clothianidin, imidacloprid and thiamethoxam due to concern that there was insufficient information to fully describe their risk to pollinators. In the UK, the main impact of these restrictions was the loss of insecticidal seed treatments for oilseed rape. A full ban on outdoor use of these neonicotinoids were introduced in 2018. SASA publish all their pesticide usage reports online which are available to download from: Pesticide Usage | SASA (Science & Advice for Scottish Agriculture). Imidacloprid has not been encountered in any of their surveys since 2014 when it was predominantly used as a seed treatment on oilseed rape and winter wheat.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.

FOI 202300360843 - Information Released - Annex A-D

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3 page PDF

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FOI 202300360843 - Information Released - Documents 1 - 8

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49 page PDF

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