(Beyond Pesticides, February 6, 2013) The U.S. Environmental Protection Agency (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? Take action and tell EPA not to repeat past missteps and protect pollinators from sulfoxaflor by providing a public comment to EPA. (see below for sample comments).
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.
Just last week, the European Commission announced its position against the use of neonicotinoid insecticides, pushing nations within the European Union (EU) to impose a two year suspension on their use. The proposal, put forward at a meeting of the Standing Committee on the Food Chain and Animal Health, would restrict the application of neonicotinoids as granules, seed-treatment or spray, on crops that are attractive to bees, particularly, sunflowers, rapeseed, corn, cotton, and cereal crops. This announcement was issued in reaction to a European Food Safety Authority (EFSA) report that three neonicotinoid insecticides ””imidacloprid, clothianidin, and thiamethoxam, pose an unacceptable hazard to honey bees. The EFSA report concludes that systemic contamination of neonicotinoid-treated crops, neonicotinoid dust exposure, and contaminated nectar and pollen contributes to declines in honey bees and weakens their hives. High risks were also identified from exposure to guttation fluid from corn for thiamethoxam.
Additionally, the human health assessment for sulfoxaflor reveals the occurrence of developmental abnormalities in laboratory organisms, as well as an increased incidence of several types of tumors in both male and female rats and mice, leading EPA to classify sulfoxaflor as “suggestive evidence of carcinogenic potential.” Sulfoxaflor is proposed for use on various agricultural commodities, including numerous vegetables, canola, soybeans, beans, turfgrass and wheat among others for aerial and ground broadcast applications. There are currently no residential uses requested for sulfoxaflor.
New Mexican honey bee inspector, president of the New Mexico Beekeepers Association, and a beekeeper for over 30 years, Les Crowder, will be speaking at Beyond Pesticides’ 31st National Pesticide Forum, addressing organic and natural solutions for problems commonly treated with chemicals, and the role beekeepers can play in protecting biodiversity. Join us in Albuqueque, New Mexico for a discussion on strategies that we all can take to protect pollinators.
Take Action: Tell EPA Not To Repeat Missteps of the Past and Protect Pollinators. Send a Public Comment to EPA!
Given recent action in Europe to protect pollinators from hazardous pesticides, EPA should be doing the same in the U.S. Sulfoxaflor is too toxic to honey bees to be allow widespread use in the environment. Submit your comments to the federal docket (the best way to get your voiced heard) using docket number EPA-HQ-OPP-2010-0889 by February 12, 2013.
Sample Public Comment:
To the U.S. Environmental Protection Agency:
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..