(Beyond Pesticides, September 18, 2012) Take Action! On September 25, EPA will close its public comment period for the petition requesting the agency to suspend the bee-killing pesticide clothianidin. The U.S Environmental Protection Agency (EPA) has failed to recognize that pollinators face unique hazards from clothianidin, a neonicotinoid pesticide which is linked to disruptions in bee mobility, navigation, and feeding behavior. So far thousands of concerned beekeepers, gardeners, hobbyists and folks like you have told EPA to suspend clothianidin and protect pollinators now!
Without your support, clothianidin‚Äôs effects on honey bees will continue to put beekeepers, rural economies, and our food system at risk. With one in three bites of food reliant on honey bee pollination, it‚Äôs imperative that we act now!
Colony Collapse Disorder (CCD) is the name given to the mysterious decline of honey bee populations around the world beginning in 2006. On average, the U.S. Department of Agriculture (USDA) reports that beekeepers have been losing over 30% of their honey bee colonies each year‚Äďbut some are losing many more times that number. While CCD appears to have multiple interacting causes, including pathogens, a range of evidence points to sublethal pesticide exposures as important contributing factors. Neonicotinoids are a particularly suspect class of insecticides, especially in combination with the dozens of other pesticides found in honey bee hives. Key symptoms of CCD include: 1) inexplicable disappearance of the hive‚Äôs worker bees; 2) presence of the queen bee and absence of invaders; 3) presence of food stores and a capped brood.
Clothianidin, thiamethoxam, and imidicloprid are members of the neonicotinoid family of systemic pesticides, which are taken up by a plant‚Äôs vascular system and expressed through pollen, nectar, and gutation droplets from which bees then forage and drink. Neonicotinoids kill sucking and chewing insects by disrupting their nervous systems.
Beginning in the late 1990s, these systemic insecticides began to take over the seed treatment market. Clothianidin is Bayer‚Äôs successor product to imidacloprid, which recently went off-patent. Both are known to be toxic to insect pollinators, and are lead suspects as causal factors in CCD. Together, the two products accounted for over a billion dollars in sales for Bayer Crop Science in 2009. Imidacloprid is the company‚Äôs best-selling product and among the most widely used insecticides in the U.S. Starting in about 2004, seed companies in the U.S. began to market seeds treated with a 5-X rate of neonicotinoids (1.25mg/seed, compared with the traditional 0.25 mg/seed).
The emergency legal petition, filed in March 2012 by beekeepers and environmental organizations, cites significant acute and chronic bee kills across the United States linked to neonicotinoid pesticides, particularly the insecticide clothianidin. The petition asks the agency to suspend all registrations for pesticides containing clothianidin. It further establishes that EPA failed to follow its own regulations when it granted a conditional, or temporary, registration to clothianidin in 2003 without required data establishing that the pesticide would have no ‚Äúunreasonable adverse effects‚ÄĚ on pollinators.
In July, after the French Agricultural Ministry banned the use of the neonicotinoid pesticide thimethoxam in order to protect pollinators, EPA told pollinators to buzz off. The agency formally refused to recognize that honey bees face an ‚Äúimminent hazard.‚ÄĚ EPA denied the request to ban the use of products containing clothianidin, turning its back on over one million citizen petition signatures worldwide. This denial prompted Kristen Gillibrand (D-NY), Senators Patrick Leahy (D-VT), and Sheldon Whitehouse (D-RI) to write a letter to EPA calling for an expedited review of neonicotinoid pesticides.
In her letter to EPA Administrator Lisa Jackson, Senator Gillibrand wrote, ‚ÄúProtecting honey bees and other pollinators is vital to American agriculture. In fact, one in three bites of food is reliant on honey bee pollination, and threats to pollinators concern the entire food system and could drive up the cost of food in this country. Highlighting the economic importance of pollinators, a recent study by Cornell University found that insect pollination results in a value of more than $15 billion annually.‚ÄĚ
Representative Markey (D-MA) joined in the protection of honey bees in late August, calling on EPA to investigate the link between pesticides and honey bee deaths. ‚ÄúThe proverb ‚ÄėNo bees, no honey, no work, no money‚Äô may become all too true if we don‚Äôt investigate the impact of pesticides on our valuable honeybee population,‚ÄĚ said Rep. Markey. ‚ÄúBees are vital to our nation‚Äôs economy and food security. I urge the EPA to look more closely at the impacts of these commonly used pesticides on the bee population, and I look forward to the agency‚Äôs response.‚ÄĚ
Although EPA denied the emergency petition, it did open a 60-day public comment docket in order to review additional points raised in the legal petition. This is where we need your help. We need to tell EPA to ban clothianidin once and for all.
In addition to the emergency petition, Beyond Pesticides has joined with the Center for Food Safety and the Sierra Club, along with beekeepers from around the country, in filing a 60-Day Notice letter with them EPA, announcing the intent to jointly sue the agency for Endangered Species Act (ESA) violations. The potential lawsuit highlights EPA‚Äôs continuing failure to ensure, through consultation with the U.S. Fish and Wildlife Service, that its numerous product approvals for the neonicotinoid insecticides clothianidin and thiamethoxam are not likely to jeopardize any federally-listed threatened or endangered species.
Despite EPA‚Äôs recognition of the acute and chronic toxicity risks to endangered and threatened birds, mammals and insects from these chemicals nearly a decade ago, the agency has continued to ignore concerns surrounding the effects on these critical species. Over the past 12 years, EPA has approved a total of 86 products containing clothianidin and thiamethoxam, and it permits the use of these insecticides on more than 30 crops, as well as ornamental, turfgrass and structural applications.
The 60-Day Notice cites several violations of the ESA, all of which address EPA actions that have enabled clothianidin and thiamethoxam to be applied over a vast amount of U.S. farmland and in, or near, a wide range of critical habitats and ecosystems. If the ESA violations are not resolved within 60 days, the letter signers may then sue EPA.
Make Your Voice Heard! We only have until September 25th to tell EPA to suspend clothianidin. Submit your comments, identified by Docket ID number EPA-HQ-OPP-2012-0334-0015 at www.regulations.gov, or by clicking on this link. Follow the online instructions for submitting comments (please note that only the fields with asterisks are required).
For more information on how pesticides affect pollinators and what you can do to help, see Beyond Pesticides’ Pollinator Program page.
All unattributed positions and opinions in this piece are those of Beyond Pesticides.