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photoRegulatory Action

The decline in honeybee populations has received increased attention from researchers and regulators. In 2007, the National Academy of Sciences National Research Council’s (NRC) “Status of Pollinators Committee” issued the findings of a two-year study detailing the serious problems facing the beekeeping industry, which was described as being in crisis mode. Since then Environmental Protection Agency (EPA), U.S. Department of Agriculture (USDA) and other institutions have started collaborating, but environmentalists and beekeepers don't believe they are doing enough.

In 2011, EPA formed a Pollinator Protection workgroup within its Pesticide Program Dialogue Committee (PPDC). Beyond Pesticides participates on this stakeholder group that provides input to EPA on pollinator protection related to the following themes:  1) initial science- based risk management approaches, including appropriate label restrictions and training; 2) development of information on state approaches and authorities; 3) transfer of lessons learned by various stakeholders to improve existing management practices; 4) continuing international communication; and, 5) other issues the agency wishes to bring to the work group’s attention.

USDA Agricultural Research Service (ARS)

The U.S. Department of Agriculture (USDA) is leading the federal government response to Colony Collapse Disorder (CCD), particularly through its CCD Steering Committee which includes participation from government agencie, academia, as well as the EPA. Other activities include workshops and stakeholder meetings. In April 2007, ARS held a Colony Collapse Disorder Research Workshop that brought major bee scientists, industry representatives, extension agents, and others to discuss a research agenda and discern where more information is needed and the highest-priority needs for additional research projects related to CCD.

CCD Steering Committee
In 2007 Federal Colony Collapse Disorder Steering Committee was mandated by Congress to investigate the causes of and find solutions to colony collapse disorder (CCD). This committee is led by Agricultural Research Service and the Cooperative State Research, Education, and Extension Service. Other members include EPA, APHIS, Natural Resources Conservation Service, Purdue University, Pennsylvania State University, Department of Defense, Bee Alert Technology, Inc., Montana as well as Departments of Agriculture of Florida and Pennsylvania; Universities of Arizona State, North Carolina State, Illinois, and Montana. The CCD Steering Committee has since developed an action plan which outlines 1) survey and data collection; 2) analysis of samples; 3) hypothesis-driven research; and, 4) mitigation and preventative action.

National Stakeholders Meeting on Honey Bee Health
The Pennsylvania State University, Center for Pollinator Research, collaborated with the USDA-led CCD Steering Committee to host the National Stakeholders Meeting on Honey Bee Health in October 2012. Stakeholders, research scientists, beekeepers, agrochemical companies, state officials, non-governmental organizations and others including Beyond Pesticides provided comments to the CCD Steering Committee on best management practices and future directions of research aimed at supporting and improving honey bee health.

The National Institute of Food and Agriculture
The National Institute of Food and Agriculture (NIFA) is an agency within the U.S. Department of Agriculture (USDA), created by Congress through the Food, Conservation, and Energy Act of 2008. NIFA replaced the former Cooperative State Research, Education, and Extension Service (CSREES), which had been in existence since 1994. NIFA, which helps fund state and local level research, education, and extension, has spent an average of $1.7 million per year on honey bee and pollinator research with one third to one half of this funding spent on research on honey bee health. NIFA has provided significant intramural and extramural funding for research that is making use of the honey bee genome, including an NRI-funded grant that resulted in the creation of a genome-wide map in late 2006. ARS researchers are using the microarray to perform studies relevant to bee-associated microbes that may be causing CCD.

NIFA and ARS also have facilitated several extension and outreach efforts to inform the public of CCD research findings and updates. These include the maintenance of several Web sites, such as the ARS Web site to answer general questions about CCD, the CCD Coordinated Agricultural Project Web site outlining the objectives and aims of the project, and the Honey Bee Health Community of Practice on eXtension Web site (University of Tennessee).

EPA Office of Pesticide Programs

EPA‘s role in the federal response to CCD is to keep abreast of and help advance research investigating pesticide effects on pollinators. The agency is also an active participant in the CCD Steering Committee.

EPA Pesticide Data
EPA’s conventional approach to protecting pollinators when registering a pesticide has been to require pesticide data such asstudies to determine the toxicity of a compound, using labeling to require measures to reduce risk. EPA requires toxicity studies that look at the acute (short-term) effects of a pesticide on individual bees when they come into contact (dermal) with pesticide residue. The agency also relies on bee-kill incident reports from government, industry, and public sectors to help us understand the effects of pesticides on bees. EPA may also require long-term studies if a pesticide appears to be very toxic to bees.

However, the agency often allow pesticides to be used in the environment without data pertinent to the chemical’s effect on these sensitive species. Even though the agency claims that there is no data demonstrating that an EPA-registered pesticide has caused CCD, the evidence is mounting the EPA-registered pesticides play an important role in CCD, especially neonicotinoid pesticides.

Pesticide Labels
EPA continues relying on pesticide product labels that the agency believes reduce risk by reducing potential exposure. The agency states, label’s use directions can reduce the potential for bee exposures by providing instructions on exactly how, when, and where the product can be applied. However label instructions are often vague and unrealistic. Product labels cannot prevent drift, or reduce residues on pollen, nectar and flowers which expose bees to the toxic chemicals.

Pollinator Protection Strategic Plan
EPA established a multidisciplinary team, the Pollinator Protection Team (PPT), which includes staff from the various scientific and regulatory divisions within EPA’s Office of Pesticide Programs as well as staff from EPA’s regional offices and the Office of General Counsel. This multidisciplinary team is tasked with exploring possible approaches, tools, and resources for reducing the potential risks of pesticides to pollinators and with developing the Pollinator Protection Strategic Plan that will guide its future work and direction.

Reporting Bee-Related Incidents
After learning from beekeepers about pesticide incidents that were never reported to EPA, the agency worked with the National Pesticide Information Center (NPIC), to develop a new Web-based portal for beekeepers to report incidents. Information from these reports helps identify bee kills associated with the use of a specific pesticide or active ingredient. The reports of pesticide incidents can also help identify patterns that indicate a potential unreasonable adverse effect of a pesticide. In addition to reporting incidents through the NPIC portal, beekeepers now have the option of also reporting incidents directly to the Office of Pesticide Programs.

North American Pollinator Protection Campaign
ThIn 2009, EPA hosted the annual NAPPC International Conference. At the conference, EPA and NAPPC signed a Memorandum of Understanding (PDF) that signifies our cooperative relationship and shared objectives. EPA staff serve on various NAPPC task forces, including the Pesticide Task Force, which is developing brochures on the safe use of pesticides to protect pollinators. EPA will work with NAPPC and its many other partners to develop materials in support of continuing education to be used by states in recertifying licensed pesticide applicators.

Pesticide Program Dialogue Committee
The Pesticide Program Dialogue Committee (PPDC) was established in 1995 and under the Federal Advisory Committee Act of 2009 was renewed for another two years. This Committee provides a forum for a diverse group of stakeholders to provide feedback to the pesticide program on various pesticide regulatory, policy and program implementation issues. Topics of discussion at past meetings have included the following: inerts disclosure, registration review, spray drift, non-animal testing, antimicrobial pesticides, endangered species, reduced risk pesticides, labeling, minor uses, ecological standards, fees for service, experimental use permits, environmental marketing claims, outreach to the public, and several implementation issues emanating from the Food Quality Protection Act of 1996. The Committee meets two to three times a year and all meetings are open to the public.

Other EPA Activities

EPA has hosted several and provided presentations at conferences and committee meetings. Most recently, in May 2010, EPA and the French Food Safety Agency made a joint presentation (PDF) to the Society of Environmental Toxicology and Chemistry, Europe (SETAC Europe) regarding uncertainties in risk assessment for insect pollinators. In July 2010, at the International Conference on Pollinator Biology, Health and Policy at the Pennsylvania State University, EPA presented their efforts to protect pollinators.

The agency has also issued annual grants awarded focused on pollinator work. EPA scientists are members of the Colony Loss Network, a global network of scientists, beekeepers, and industry members from 49 countries working to identify the factors causing severe colony losses.

Legislative Action

The 2008 Farm Bill [Section 7204 (h)] authorized funding for research and grants for pollinator protection, for honey bee and CCD research. It also mandates the USDA to submit an annual report describing the progress made in investigating the cause or causes of CCD and finding appropriate strategies to reduce colony loss.

Clothianidin Controversy

In 2008 a massive bee die-off occurred in Germany which was subsequently associated with clothianidin. Germany moved to ban clothianidin and other neonicotinoids pending further investigation. Clothianidin was given conditional registration in the US in 2003, without sufficient data to support its registration. Current data gaps include a lack of field tests for honeybees. A study, submitted in 2007 to EPA in support of this registration criteria, was recently deemed inadequate.

An internal EPA memo, leaked to the beekeeping community from an undisclosed source at the U.S. Environmental Protection Agency (EPA) in December 2010, shines light on a key deficiency in the agency’s efforts to protect honeybees. The memo indicated that registration of clothianidin was unsound considering the study findings, and EPA was quietly re-evaluating its use, even as they planned future expansion. Beyond Pesticides and Pesticide Action Network North America (PANNA) wrote a letter to EPA following this leaked memo urging the agency to remove this pesticide from the market. Read EPA's official response to our letter, which rejects immediate action on removing this chemical which is toxic to bees. See also what the agency initially said to the press, and our chronology of events on clothianidin in response.

  • You can read the paper trail on clothianidin through each EPA memo below:

  • Read the petition filed by beekeepers and environmentalists to stop pesticide use linked to bee deaths. On March 21, 2012, over 1 million urge EPA to suspend use of pesticide harmful to bees, fix broken regulatory system
  • Listen to beekeeper Tom Theobald and Beyond Pesticides executive director Jay Feldman talk about the leaked EPA document.
  • Read EPA's letter rejecting immediate action in response to the 12-08-10 letter from beekeepers and environmentalists, including Beyond Pesticides, requesting clothianidin cancelation.
  • Letter to EPA, 12-08-2010 - Letter requesting removal of chemical by EPA from beekeepers and environmentalists. Also Press Release, Backgrounder, Available for Interviews.
  • EPA Memo, 11-2-2010 - EPA memo declaring core study unacceptable for registration
  • Read about more about clothianidin here.

In 2013, Beyond Pesticides joined with beekeepers and environmental allies in a lawsuit challenging EPA's approval clothianidin and another neonicotinoid, thiamethoxam.. For a primer on the pollinator crisis, see the lawsuit's Press Release. Also, read the 2013 Lawsuit, Appendix A: Clothianidin, and Appendix B: Thiamethoxam.