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EPA Thinks Pollinators Should Buzz Off!
Urgent Action Needed to Prevent EPA from Repeating Past Missteps

Note: This Docket is Now Closed
Thank you to all who submitted a public comment. Stay tuned as Beyond Pesticides waits for EPA's response
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EPA has proposed to register a new insecticide, sulfoxaflor, which the agency has classified as “very highly toxic” to honey bees. Despite efforts underway in Europe to protect bee populations, and continued warnings from beekeepers, EPA is poised to allow another chemical toxic to bees into the environment without proper field studies evaluating long-term effects to bee colonies and with label statements that are impractical and unenforceable. With continuing reports of bee deaths, would sulfoxaflor be yet another bee disaster waiting to happen?

Letting EPA know what you think is your right!

To have the most impact, EPA needs to hear directly from you with your comment in the docket! Email communications on this is not as effective and often do not get read or counted.

Please submit your comments directly to the docket by using the link provided. Click the link and tell EPA what you think in the form provided Please note that only fields with an asterisk are required, and if you are not affiliated with an organization, you may put your own name in the Submitter's Representative field (if you are still having problems, click here). You can use the sample comment as a guide, or you can copy/paste the sample comment below into the form in the docket. Once you are done editing your comments, click the submit button and you are done! Remember, personalized comments have a much greater impact.

Sample Comment

I am writing to express concern regarding the proposed conditional registration of the new pesticide active ingredient, sulfoxaflor. This chemical is highly toxic to honey bees and its use will compound the already growing problem of bee decline. There are many aspects of EPA’s risk assessment for sulfoxaflor that I find troubling and which I believe should disqualify this chemical from being granted conditional registration.

Sulfoxaflor is highly toxic to bees according to EPA, and there are still outstanding ecological data regarding honey bees, including field studies for assessing colony heath. Given the global phenomenon of bee population decline and the recent precautions taken in the European Union to protect bee health with the pending suspension of certain pesticides known to elicit adverse effects in bees, it is irresponsible that the agency would allow yet another chemical with a high potential to be hazardous to bee health into the environment, with unknown risks.

With continuing reports of bee deaths, I am concerned that sulfoxaflor may create yet another bee calamity. I urge the agency to protect honeybees and reject the pending registration for sulfoxaflor..

Thank you,
Your_Name

Background

Last month, EPA opened the comment period for the proposed conditional registration of sulfoxaflor, a new active ingredient, whose mode of action is similar to that of neonicotinoid pesticides -it acts on the nicotinic acetylcholine receptor (nAChR) in insects. Even though it has not been classified as a neonicotinoid, it elicits similar neurological responses in honey bees, with many believing that sulfoxaflor is the new generation of neonicotinoid.

 EPA has noted that sulfoxaflor is highly toxic to bees, and other studies reporting inconclusive effects on bee brood development, even though high mortalities were observed. Despite this, the agency believes that observed adverse effects in bees are “relatively short-lived” even though a long- term study on colony health is still outstanding.  According to the agency, sulfoxaflor residues in nectar and pollen are estimated to exceed levels of concern for honey bees, and so EPA is proposing to lower the application rate from that initially requested by the registrant, Dow AgroSciences LLC, as well as reduce minimum spray intervals. However, given sulfoxaflor’s highly neurotoxic nature, and that pertinent data gaps exists (i.e. field studies for bee colony strength and for assessing residues in bee attractive crops), it is irresponsible for EPA to allow sulfoxaflor into the environment.

EPA has routinely allowed chemicals into the environment without a firm understanding of human and ecological effects. In fact, in spite of not being formally registered, sulfoxaflor has been granted for use through emergency use permits (section 18 of the Federal Insecticide, Fungicide and Rodenticide Act) by various states on cotton in 2012. This means that without proper ecological assessments, sulfoxaflor was introduced into the environment posing unknown risks to honey bees for some time now. Similarly, label statements proposed for sulfoxaflor underscore the potential risks to bees, but like most product labels may be unrealistic and unenforceable.

The case of sulfoxaflor is reminiscent of clothianidin,  a neonicotinoid highly toxic to bees, which was conditionally registered in 2003 without the required field studies for assessing risks to honey bees. Clothianidin, and its parent compound, thiamethoxam, have since been linked to bee decline and are now subject to restrictions in Europe. Clothianidin is primarily used as a seed treatment on corn and translocates throughout the plant to pollen and nectar, which exposes bees to residues which leads to disruptions in mobility, navigation, and feeding behavior. Sublethal exposures have been shown to decrease foraging activity, along with olfactory learning performance and decrease hive activity.

Tell EPA to protect honey bees, other pollinators, and our food supply! Tell the agency not to register another bee-killing chemical!

If you are having trouble submitting your comment to the docket

If you are unable to access the docket, you can still let your voice be heard. Send Beyond Pesticides an email at comments@beyondpesticides.org indicating what message you would like to send to EPA. Provide your name and state to us and we will submit your comment to the docket for you. Or, you can use our simple form to send us your comments.