(Beyond Pesticides, February 17, 2011) Beyond Pesticides is urging the U.S. Environmental Protection Agency (EPA), during a public comment period (closing February 23) on its review of the neonicotinoid pesticide, clothianidin, to take swift action to cancel the chemicalâ€™s registration. Groups are joining together with comments to EPA, citing the extensive science that shows clothianidin’s toxic effects on honey bees.
Beyond Pesticides has drafted comments that it will submit to EPA outlining serious concerns regarding clothianidin. The agency is accepting public comments through February 21, 2012. Tell EPA that because this pesticide is toxic to honey bees and wild pollinators, and has not been properly evaluated in field studies as required it should be banned. Submit comments directly to the EPA docket or sign-on to Beyond Pesticidesâ€™ comments.
Clothianidin is in the neonicotinoid family of systemic pesticides, which are taken up by a plantâ€™s vascular system and expressed through pollen, nectar and gutation droplets from which bees forage and drink. Scientists are concerned about the mix and cumulative effects of the multiple pesticides bees are exposed to in these ways. Neonicotinoids are of particular concern because they have cumulative, sublethal effects on insect pollinators that correspond to symptoms of honey bee colony collapse disorder (CCD) â€“namely, neurobehavioral and immune system disruptions.
Clothianidin has been on the market since 2003. With a soil half-life of up to 19 years in heavy soils, and over a year in the lightest of soils, commercial beekeepers are concerned that even an immediate stop-use of clothianidin wonâ€™t save their livelihoods or hives in time.
Beyond Pesticides, in its comments, states
â€śHoney bees are the most economically valuable pollinator worldwide, and many high-value crops, such as almonds and broccoli, are entirely reliant upon pollination services by commercial beekeepers and their honey bees. Globally, 9.5% of the total economic value of agricultural production for human consumption comes from insect pollination â€“in 2005, this amounted to just under $200 billion. However, each year since 2006 commercial beekeepers have reported annual losses of 29-36%. Such losses are unprecedented, and approximately double what is considered normal. Like France, Germany, and other European countries, EPA must make a proactive decision against the neonicotinoid class of chemicals. Clothianidin and thiamethoxam [a neonicotinoid precursor that converts to clothianidin in plants and animals] are not only extremely persistent in the environment, but they are highly toxic to bees and other non-target insects. Clothianidinâ€™s use as a systemic pesticide means that every part of the plant is potentially toxic to the honey bee, and can result in widespread contamination of soil and wild plants. We believe the risks posed by clothianidin and other neonicotinoids have been underestimated by the agency, especially given the outstanding honey bee data that have yet to be adequately reviewed. In light of the agencyâ€™s mandate in Section 3(c)(7)(A) of [the Federal, Insecticide, Fungicide, and Rodenticide Act (FIFRA)] to ensure that pesticides do not pose unreasonable adverse effects on the environment, clothianidin and its parent thiamethoxam should be cancelled.â€ť
Other points outlined in the comments include:
Clothianidinâ€™s Toxicity to Honeybees
Clothianidin, like other neonicotinoids, is an insecticide that is highly toxic to a range of insects, including honey bees and other pollinators. It is particularly dangerous because, in addition to being acutely toxic in high doses, it also results in serious, though sub-lethal, effects when insects are exposed to chronic low doses, as they are through pollen and water droplets laced with the chemical as well as dust that is released into the air when coated seeds are planted. These effects cause significant problems for the health of individual honey bees as well as the overall health of honey bee colonies and they include disruptions in mobility, navigation, feeding behavior, foraging activity, memory and learning, and overall hive activity.
Clothianidinâ€™s Registration Is Unlawful
Clothianidin was initially registered by EPA in 2003 on the condition that the registrant, German chemical manufacturer Bayer, completes and submits a field study demonstrating the chemicalâ€™s effects on pollinators. In addition to any registration of clothianidin being a violation of FIFRAâ€™s prohibition of chemicals that pose â€śunreasonable adverse effects on the environment,â€ť in December 2010 it was revealed that the pollinator study Bayer had submitted had been downgraded by EPA and deemed insufficient to fulfill the field study requirement upon which the chemicalâ€™s registration was contingent. However, EPA took no action to ban or restrict clothianidin in light of this development and to this day is not in possession of an acceptable pollinator field study for clothianidin. Thus, following the agencyâ€™s own logic, there is no current basis for continuing to allow clothianidin to remain registered.
EPA Is Behind In Its Understanding of Pollinator Effects
Judging by the pollinator data requirements that EPA has stated it is seeking for clothianidinâ€™s registration review, the agency is severely lacking in its understanding of how the chemical affects pollinators, and honey bees specifically. Despite allowing the chemical to be used on thousands of acres of American farmland over the past nine years, there is still a great deal EPA does not know about how bees are exposed to clothiandin and what the consequences of exposure actually are for bee health on the individual, colony, and species level.
The comments also note,
â€śThe rapid disappearance of the honey bees, also dubbed â€śColony Collapse Disorderâ€ť or CCD, has been observed in the U.S. since 2006. Even though researchers have indicated that there may be several variables associated with CCD, clothianidin, and other chemicals in its class, cannot be ruled out as a major contributor and this must be factored into the agencyâ€™s assessment. Honey bees intercept, and are contaminated by, particles on crops and suspended in the air, and retain them in their hair and/or accumulate them in their bodies and hives. Mitigation techniques (e.g. product label restrictions) to prevent honeybees from coming into contact with this highly toxic pesticide once it is used in the environment are highly infeasible. The only way to protect important pollinators is to remove these toxic neonicotinoids from the environment.â€ť
TAKE ACTION: EPA is accepting public comments in the clothianidin docket through February 21, 2012. Tell EPA that because this pesticide is toxic to honey bees and wild pollinators, and has not been properly evaluated in field studies as required, it should be banned. Submit comments directly to the EPA docket or sign-on to Beyond Pesticidesâ€™ comments.
For more information on pesticides, honey bees and other pollinators, as well as more you can do, see Beyond Pesticides’ Pollinator Protection web page.