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?
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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!
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