Thirty-six toxic pesticides washed into headwaters of SAC chalkstream

Bakkavör washing unknown quantities of thirty-six toxic pesticides, which present real danger to aquatic life, into headwaters of SAC chalkstream

Following on from our recent release about dangerous quantities of toxic neonicotinoid Acetamiprid being washed off salad leaves into the headwaters of a protected chalkstream, a further freedom of Information (FOI) request proves this is just the tip of the iceberg.

Information obtained by Salmon & Trout Conservation (S&TC), confirms thirty-six other chemicals, (Appendix 1) from Bakkavör’s Alresford salad washing activities, which could be causing environmental damage. The list of chemicals, which Bakkavör declare are permitted for use on the produce they wash at the site, highlights thirty-six chemicals of great concern where the Environment Agency believe they “present a real or present danger to the environment”. Current laboratory tests for these chemicals cannot detect the presence in the discharge low enough to ensure they are not causing environmental damage.

The problem is national in scale. Alongside neighbouring Vitacress on the Bourne Rivulet, a tributary of the River Test, there are several hundred similar factories across England which could also be discharging lethal quantities of pesticides.

The Environment Agency has produced, using the best available science on the ecological impact, a minimum reporting value (MRV) for each chemical, at which they believe they can be confident no damage to the surrounding environment, to its fish, bugs, kingfishers, otters and water voles, will occur. However, unfortunately for thirty-six of the pesticides listed current laboratories Limit of Quantification (LOQ), the lowest analyte concentration that can be quantitatively detected with a stated accuracy and precision, is in the worst case 3500 times higher than these “safe” concentrations.

S&TC believes the only safe and responsible solution is for Bakkavör to stop washing salads and discharging its lethal cocktail immediately while a means to measure and remove harmful pesticides is introduced. And the EA needs to demand Bakkavör meets the environmentally safe levels come what may.

Nick Measham, S&TC CEO states,

”Pesticides are, of course, by their very nature designed to kill unwanted animals, unlike industrial chemicals or pharmaceuticals whose toxic impact is an unfortunate side-effect. Is it really acceptable that any pesticides are allowed to be discharged into our natural environment whatever the concentrations? Surely as a responsible business Bakkavör must stop discharging all knowingly toxic pesticides into this river which in so importance to the local community and has international ecological importance, before it’s too late”.

The River Alre, which receives Bakkavör’s toxic discharge, is a tributary to the River Itchen, a Special Area of Conservation- the highest environmental protection a site can get, and a world important chalkstream, as 85% of global chalkstreams are in England. Yet, because of historical discharge permits, once small, but now industrial level salad washing activity is able to pollute this invaluable natural resource.

Janina Gray, Head of Science and Policy at S&TC added,

“Chemical pollution is arguably the biggest single threat to our wildlife and us. In truth, we know very little about most of the chemicals we are pumping into the environment, so governments have put it in the too difficult to deal with box for too long. With wild fish populations like salmon endangered, bugs both in the water and on land showing catastrophic populations collapses and 85% of our rivers considered unhealthy, we cannot ignore this problem any longer. Pesticides are the obvious place to start, and in particular point discharges like Bakkavör. I for one will not be buying any washed bagged salad until I know it isn’t silently killing our rivers with its washed-off pesticides”.

S&TC is calling on Bakkavör to stop their discharge immediately until they can be certain they are not discharging pesticides at toxic levels in the surrounding environment.

NOTES FOR EDITORS

(1) Salmon and Trout Conservation

Salmon & Trout Conservation (S&TC) was established as the Salmon & Trout Association (S&TA) in 1903 to address the damage done to our rivers by the polluting effects of the Industrial Revolution. Since then, S&TC has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC has charitable status in England, Wales and Scotland and its charitable objectives empower it to address all issues affecting fish and the aquatic environment, supported by robust evidence from its scientific network, and to take the widest possible remit in protecting salmonid fish stocks and the aquatic environment upon which they depend.

www.salmon-trout.org

2) Case History

Fears about pesticides and other chemicals in the discharges from this salad washing plant have been long standing and culminated in June 2018 when S&TC issued the EA with a formal notification of environmental damage pursuant to the Environmental Liability Directive. This followed the results of S&TC’s invertebrate sampling at a site immediately downstream of Bakkavör’s outflows which indicated that chemicals were impacting the invertebrate communities.

The resulting EA investigation confirmed S&TC’s findings; that there were pesticides present, which were on the salad leaves imported by Bakkavör and which were being subsequently washed off and into the Upper Itchen. It appears that Bakkavör had not self-notified the EA of the presence of these chemicals. Once made aware of the pesticide threat the EA began a monitoring and sampling regime. This testing revealed the presence of dozens of chemicals, pesticides and herbicides being washed off the fresh produce at Bakkavör

Appendix 1:

Pesticide Minimum Reporting Value (MRV) and Limit of Quantification (LOQ), where pesticides highlighted in red indicate Environment Agency concerns current monitoring cannot prove they are not impacting the environment.

 

Toxic neonicotinoid washed off salad leaves into protected chalkstream

Toxic neonicotinoid washed off salad leaves into protected chalkstream exceeds acceptable concentrations by up to 400%.

NEWS RELEASE 23 June 2020

Data from a recent Freedom of Information request by Salmon & Trout Conservation shows that levels of Acetamiprid, a pesticide discharged by Bakkavör plc into the Upper Itchen catchment[1], have regularly exceeded acceptable concentrations. This toxic pesticide and many more are washed off leaves in preparing bags of salad.

Bakkavör plc supplies leading retailers, including M&S, Sainsbury's and Waitrose, with fresh produce such as watercress, baby leaf and organic salads and herbs.[2]

Acetamiprid regularly exceeded, by a factor of up to four times, the lethal dose (chronic and acute Regulatory Acceptable Concentration (RAC))[3]. Acetamiprid is in the neonicotinoid family, many of which were recently banned for use in Europe due to their acute toxic impact on bees. While Acetamiprid is considered less harmful to pollinators than its banned relatives, research shows that it is significantly more toxic to aquatic insects.[4]

Nick Measham, CEO Salmon & Trout Conservation said,

“Enough is enough. Bakkavör’s Alresford Salads factory has a long history of polluting the Upper Itchen. This latest revelation is the most troubling yet. Quite simply this pesticide pollution has to stop, and now. These chemicals will be killing aquatic insects, destroying the primary food source of wild salmon and trout. Bakkavör must end emissions of these and all other toxins which occur as a by-product of their processes. If they continue to refuse to do so, the EA must take decisive action.”

S&TC fears this is not the only insecticide discharging from the plant at quantities dangerous to aquatic life, and that, nationally, Bakkavör is not alone in this activity.  Until S&TC raised concerns over potential chemical inputs from the factory affecting the river, no-one was aware or monitoring what was actually being discharged. Current discharge permits require the operators to disclose to the EA any toxic substances which may be present in their discharge, and then monitoring procedures are established accordingly. Clearly, in this case, that did not happen. There are fundamental failures in the regulatory approach applied here, which must be addressed by the EA.

Additional Freedom of Information data obtained by S&TC suggests up to five hundred other sites throughout England of a similar nature could be operating under the same or similar inadequate permits with no pesticide monitoring requirements, but with pesticide residues being discharged.

Dr. Janina Gray, Head of Policy and Science, Salmon & Trout Conservation,

“Bakkavör is surely the tip of the iceberg. These issues appear to be widespread and will be causing ongoing environmental damage. The existing permitting regime wholly fails to protect the environment from the damaging effects of a range of toxic chemicals. What is even more worrying is the emerging science suggesting that a “cocktail effect” may increase the toxicity of many different chemicals beyond the sum of their parts. The EA has failed to keep pace with what is actually polluting our rivers.”

S&TC is calling on Bakkavör plc to stop their discharge immediately until they can be certain they are not discharging pesticides above regulatory standards and until they can demonstrate they are not impacting the river.

Bakkavör plc urgently needs to outline: 

  1. what action it is taking to remove Acetamiprid and other pesticides from its discharge;
  2. why it is taking so long to put proper protections in place for the Itchen;
  3. why as a responsible business, it should be discharging any pesticides into the headwaters of a highly protected chalkstream; and
  4. why, given the growing body of scientific evidence showing synergistic impacts of chemical cocktails, it routinely discharges a cocktail of 40 plus chemicals into the Itchen.

S&TC is calling on the Environment Agency to:

  1. accept no more delays and to vary Bakkavör’s discharge permit immediately, to give the EA the ability to regulate all chemical discharges made by Bakkavör;
  2. enforce permit variations at any other similar activities in England to require monitoring at any sites where pesticides are identified and, given the risk of synergistic effects, limit these discharges to well below safe levels.

NOTES FOR EDITORS

(1) Salmon and Trout Conservation

Salmon & Trout Conservation (S&TC) was established as the Salmon & Trout Association (S&TA) in 1903 to address the damage done to our rivers by the polluting effects of the Industrial Revolution. Since then, S&TC has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC has charitable status in England, Wales and Scotland and its charitable objectives empower it to address all issues affecting fish and the aquatic environment, supported by robust evidence from its scientific network, and to take the widest possible remit in protecting salmonid fish stocks and the aquatic environment upon which they depend.

https://www.salmon-trout.org

2) Case History 

Fears about pesticides and other chemicals in the discharges from this salad washing plant have been long standing[5] and culminated in June 2018 when S&TC issued the EA with a formal notification of environmental damage pursuant to the Environmental Liability Directive. This followed the results of S&TC’s invertebrate sampling[6] at a site immediately downstream of Bakkavör’s outflows which indicated that chemicals were impacting the invertebrate communities.

The resulting EA investigation confirmed S&TC’s findings; that there were pesticides present, which were on the salad leaves imported by Bakkavör and which were being subsequently washed off and into the Upper Itchen. It appears that Bakkavör had not self-notified the EA of the presence of these chemicals. Once made aware of the pesticide threat the EA began a monitoring and sampling regime. This testing revealed the presence of dozens of chemicals, pesticides and herbicides being washed off the fresh produce at Bakkavör Alresford Salads.

References

[1] The salad washing plant is situated on the River Aire a tributary of the protected River Itchen, a Special Area of Conservation (SAC)

[2] https://www.bakkavor.com/investors/

[3] The long-term chronic Regulatory Acceptable Concentration (RAC) for Acetamiprid is 0.0235mg/l, and the short- term acute RAC is 0.085mg/l.

[4] https://sitem.herts.ac.uk/aeru/ppdb/en/Reports/11.htm

[5] https://www.salmon-trout.org/2019/06/17/bakkavor-alresford-salads-impacting-upper-itchen/ [6] http://bit.ly/2RhzimT

Appendices (3):

Graph 1: Presence of Acetamiprid in the overnight wash discharge of Bakkavör Alresford Salads. The Lowest Limit of Analytical Determination (LOD) refers to the lowest concentration of the analyte that can be reliably detected and quantified. [It is believed that salad leaves associated with Acetamiprid, and its use, are more commonly associated with Spring seasonal produce, hence the absence of data during other months].

Table 1: Results of the sampling of the water leaving the factory during the overnight wash of salads and other fresh produce. [Only certain laboratories have the ability to test for Acetamiprid at the levels at which it is found to cause harm].

Table 2: Monthly Bakkavor - April 2020 - Sampling Data Summary April 2020. Released as part of Environment Agency FOI: 200605 SSD171346 - Bakkavor Data

 

Bakkavör plc must now end pollution of Upper Itchen

Bakkavör plc must now end pollution of Upper Itchen

“Continued pollution unnecessary and unacceptable.” 

NEWS RELEASE 13 Feb 2020

Sustained pressure from S&TC has resulted in Bakkavör plc finding a solution that should effectively end their pollution of the Upper Itchen, but twenty months after S&TC first complained to the EA we are still waiting for action.

S&TC understands that following our notification under the Environmental Liability Directive to the EA, which raised concerns that pesticides from the Alresford Salads plant represented an imminent threat to aquatic invertebrates, Bakkavör has successfully trialled a technical solution to remove a range of chemicals from their discharges.

S&TC has seen the results of trials using ozone (attached) which appear to have removed pesticides, herbicides and insecticides to levels below the current limits of detection. This process not only appears to remove problem pesticides washed off imported salad leaves but will also remove toxic chemicals that have leached into the groundwater over previous years., If treatment is implemented, this could mean the discharge would return water to the river in a cleaner state than it came out of Bakkavör’s borehole.

Bakkavör deserves credit for developing what appears to be a powerful solution that will deliver real world, meaningful improvements for the ecology of this important chalkstream. But it must be implemented without delay and operate full-time.

Nick Measham, Deputy CEO for Salmon & Trout Conservation said:
“Almost two years on from our initial complaint the river is still suffering. A solution has now been identified. Continued pollution is unnecessary and unacceptable. It is untenable that rapid action will not now be taken to bring an end to this episode. 
 
S&TC wants the process to remove pesticides to be implemented by the end of 2020. If not, we will have to consider all options open to us to bring this pollution to an end”

The success of S&TC in motivating Bakkavör to find a solution is a strong validation of our approach to conserve and restore our rivers. However, there remain long standing structural issues with the Environment Agency’s current discharge permitting regime which raise considerable doubts about its ability to deliver genuine environmental protection. Importantly, there is a severe lack of resources for the EA’s monitoring programme.

S&TC’s invertebrate sampling and analysis clearly indicated a strong signal for chemical damage which subsequently forced the EA to conduct its own detailed investigation. That EA investigation revealed Bakkavör was in fact discharging a cocktail of potentially dangerous pesticides, including the neonicotinoid, acetamiprid. In response to these findings the EA requested Bakkavör find a means of removing pesticides from its discharge and to accept revisions to its discharge permit. Whether any of this would have happened without S&TC forcing the issue must be in doubt.

Dr Janina Gray, Head of Science & Policy for Salmon & Trout Conservation, added:

"The situation at Bakkavör Alresford Salads makes it obvious that the way the EA manages and regulates its permitting process is not protecting the environment. 

The EA must now ensure nationally that any permit with the potential to discharge pesticides into rivers is reviewed. 

There is no excuse to delay and we expect significant progress on this from the EA in 2020.”

While this is a noteworthy local issue, it may also have national implications. Further investigations by S&TC indicate that there could be hundreds of other sites with similar issues across England.

S&TC’s use of aquatic invertebrate analysis as a diagnostic tool, combined with an uncompromising approach to dealing with public authorities, is a tried and tested approach that can rapidly improve wild water habitats across all of the UK. We will continue to press the EA to adopt this process of permit revision for pesticide discharges nationally and pursue polluters to the fullest of our ability.

ENDS

Issued by Corin Smith comms@salmon-trout.org (07463 576892) on behalf of Salmon and Trout Conservation.

Notes to Editors

(1) Salmon and Trout Conservation

Salmon & Trout Conservation (S&TC) was established as the Salmon & Trout Association (S&TA) in 1903 to address the damage done to our rivers by the polluting effects of the Industrial Revolution. Since then, S&TC has worked to protect fisheries, fish stocks and the wider aquatic environment for the public benefit. S&TC has charitable status in England, Wales and Scotland and its charitable objectives empower it to address all issues affecting fish and the aquatic environment, supported by robust evidence from its scientific network, and to take the widest possible remit in protecting salmonid fish stocks and the aquatic environment upon which they depend.

https://www.salmon-trout.org/news

 

(2) Previous coverage

https://www.salmon-trout.org/2019/06/17/bakkavor-alresford-salads-impacting-upper-itchen/

https://www.hampshirechronicle.co.uk/news/17719320.river-pollution-row-returns-as-report-on-bakkavor-released/

Discharges from salad washing – Update

Salad washing on the Upper Itchen: A local problem with national significance…

Nick Measham , Deputy CEO, S&TC writes…….

S&TC’s battle to stop Bakkavör discharging pesticides and chlorinated plant-cleaning chemicals from its salad washing activities is achieving increased environmental protection, and not just for the Upper Itchen. [Previously covered by BBC Countryfile]

As a result of an Environment Agency investigation, in response to S&TC’s Environmental Damage challenge, both Bakkavör and The Watercress Company will be subject to individual pesticide discharge limits and required to carry out monitoring for a wide range of toxins.

The outcome so far is an improvement but much more remains to be done both on the Itchen and nationally to provide protection against pesticides in combination. Our fight to change national policy to require consideration of the impact of a mixture of pesticides continues.

Results so far:

  • On the Upper Itchen, the Environment Agency (EA) is seeking to revise the discharge permits of both Bakkavör and The Watercress Company’s to limit pesticide concentrations. Bakkavör discharges its overnight factory cleaning waste water directly into the river, but the daily water used to wash the salad leaves goes to The Watercress Company cress beds. TWC does not use pesticides in its growing activities and has therefore not been monitored up to now.
  • We understand Bakkavör is already trialling equipment to remove the pesticides from its discharges to enable it to meet the limits the EA imposes. The company has already stopped using chlorinated chemicals in its plant cleaning waste water.
  • It looks like the EA will require Vitacress’ salad washing plant on the Bourne Rivulet, a tributary of the Test, to meet the same pesticide discharge standards as Bakkavör.

What’s next?

  • The immediate next step is to ensure any revised discharge permits protect the river from the salad washing activities. While the EA has accepted the need for pesticide limits and associated monitoring, S&TC will scrutinise proposed permit changes, when they are published, to ensure the pesticide limits deliver the highest standards of protection currently available.
  • These current standards only consider pesticides individually not in the cocktail which is discharging into the Upper Itchen. There is an urgent need for the Government to investigate the impact of chronic, often low-level pesticide impacts in combination. We are extremely concerned about the impact of multiple different pesticides in combination. The EA’s investigation report following the Environmental Damage challenge in respect of the Upper Itchen refers to the risks on page 36:

“this poses a potential risk of exposure to invertebrates downstream of the discharge and being exposed to multiple different pesticide compounds intermittently at low concentrations (which may be above the Probable No Effect Concentration on infrequent occasions). 

 Current UK policy is to look at the effect of individual pesticides, not the effective exposure to a mixture. A change to policy is being considered at a European Union level, but we are a long way (temporally) from this policy being revised.”

This delay in acting on potentially lethal cocktails of pesticides is just plain wrong and, like so much government policy, completely ignores the precautionary principle. S&TC has written to Dr. Thérèse Coffey to ask what Defra intends to do about this on the Itchen, other SAC rivers and, indeed, any river.

Reporting with a purpose

S&TC is a national organisation and we use evidence from local case studies to help instigate policy changes that will benefit UK wild fish populations. But, this is just part of the value - we are making all our Riverfly Census findings available so they can be used to inform local management and drive action.

Each individual river report is based on three years of surveying data. Where possible, we have linked up our findings with other existing literature and data. Using the available information we suggest where local fishing and/or conservation groups can focus their management efforts to achieve the best health outcomes for each of the 12 original Census rivers.

Some of our local reports can be found on the slider below. Alternatively, visit the Riverfly Census page and scroll down to the map.