Neonicotinoids, including clothianidin, imidacloprid, and thiamethoxam, are most commonly applied by coating crop seeds with the chemical. When these treated seeds are planted, the chemical becomes part of the plants vascular system and stays in the plant for the duration of its lifetime, expressing itself in the pollen. Previously, it had been thought that bees were only exposed to these chemicals through pollen and water droplets from treated plants, which would occur later in the season once the plants had grown and bloomed. However, the Italian study shows that bees are actually exposed to high levels of clothianidin, imidacloprid, and thiamethoxam during the spring corn planting season. This occurs because, when the seeds are planted using a mechanical seeder, small amounts of the chemical coating can be scraped off of the seeds and expelled through the planter’s exhaust as dust. Bees that are near the area or are flying through then come into direct physical contact with the chemical dust.

The findings of the Italian Research team, led by Professor Andrea Tapparo, confirm that high amounts of neonicotinoids are present in the exhaust of corn seed planters and that bees are exposed to these potentially lethal concentrations of the chemical simply by flying through the area during planting. In analyzing bees that were induced to fly through planter exhaust in a field that was being planted, the team found that there were high concentrations of clothianidin and thiamethoxam in and on the bees themselves. These concentrations were “significantly higher” than known lethal doses of the chemicals for honeybees, according to the researchers. The study included analyses of several different kinds of seed coatings as well as seed planting machines, but the team found that no modifications to seeds or planters resulted in any significant decrease in the emission of chemical dust or the contamination levels of the bees themselves. In conclusion, the authors note that,

“This emission source of particles with acute toxic effects on bees (and on other insects too) is of concern for both apiculture and crop productions based on bee pollination. But it is also a widespread ecological problem that, in view of the worldwide increase in corn production partly promoted by government subsidies to renewable energy sources, and the consequent predictable exacerbation of the problem, should require a deeper analysis of the related agricultural policies.”

This new route of exposure through seed planter dust was previously demonstrated in the work of Dr. Christian Krupke, Ph.D. at Purdue University. In that study, researchers found that, during the spring planting season, there were extremely high levels of both clothianidin and thiamethoxam in planter exhaust material produced during the planting of seed treated corn. The field soil was also found to be contaminated with these neonicotinoids, including unplanted fields. Plants visited by foraging bees, including dandelions growing near these fields, were found to contain neonicotinoids in their plant material as well. According to the Purdue research team, this indicates deposition of neonicotinoids on the flowers, uptake by the root system, or both. During the spring, when neonicotinoid levels are highest, dead bees collected near hive entrances were found to contain clothianidin as well, although whether exposure was oral (consuming pollen) or by contact (soil/planter dust) is unclear. Clothianidin was also detected in pollen collected by bees and stored in the hive.

This growing body of scientific evidence needs to be considered by the U.S. Environmental Protection Agency (EPA) in its evaluations of these chemicals. The agency recently initiated its reregistration review process for clothianidin. EPA has indicated previously that label requirements restricting applicators from spraying the chemical during blooms, when bees might be present, should be enough to ensure the safety of the bees. However, this research, as well as the systemic nature of the pesticides, irrefutably demonstrates that spray restrictions are entirely inadequate in protecting bees and other pollinators from exposure to clothianidin.

Scientists are concerned about the mix and cumulative effects of the multiple pesticides that bees are exposed to in these ways. Neonicotinoids are of particular concern because they have cumulative, sublethal effects on insect pollinators that correspond to symptoms of honey bee colony collapse disorder — namely, neurobehavioral and immune system disruptions.

Clothianidin has been on the market since 2003. With a soil half-life of up to 19 years in heavy soils, and over a year in the lightest of soils, commercial beekeepers are concerned that even an immediate stop-use of clothianidin won’t save their livelihoods or hives in time.

Dr. Krupke, the lead author of the Purdue study showing that bees are subject to multiple routes of exposure to neonicotinoids, will be speaking at the 30th National Pesticide Forum on March 30-31, 2012 at Yale University in New Haven, CT. He will be joined by other speakers including Sandra Steingraber, Ph.D., acclaimed author of several books such as Raising Elijah and Living Downstream; Gary Hirshberg, Chairman and cofounder of Stonyfield Farm; David Hackenberg, the commercial beekeeper who first discovered colony collapse disorder; and many more. To register and find more information on travel and lodging, see our forum page.

For more information on pesticides, honey bees and other pollinators, as well as what you can do, see Beyond Pesticides’ Pollinator Protection page.

Work on updating the health assessment began in 1991 and was partially completed with the February 12 release of the Final Non-Cancer Dioxin Science Assessment. While EPA characterized the findings as showing that “generally, over a person’s lifetime, current exposure to dioxins does not pose a significant health risk,” the Assessment establishes a daily “acceptable” exposure threshold, or reference dose, which the agency says is comparable to levels which people routinely experience. Beyond Pesticides reviewed the underlying chemistry and historical exposure patterns, including diet and human health effects of dioxins, in a recent Daily New blog entry leading up to the Assessment’s release.

EPA’s decision to adopt its recommended reference dose of 0.7 picograms of dioxins per kilogram of body weight per day that it originally proposed in a 2010 draft version is one the Assessment’s significant outcomes. A picogram is one-trillionth of a gram. The reference dose does not contribute to enforceable standards, but is crucial for setting many guidelines, including cleanup of Superfund and other hazardous waste sites, industrial emission controls, drinking water standards and dietary guidelines for fish. The newly-confirmed EPA reference dose is lower than the World Health Organization’s daily limit of roughly 2.3 picograms.

Arnold Schecter, Ph.D., of the University of Texas School of Public Health, an experienced dioxins researcher and author, said EPA’s statement about people in general not being at risk could be misleading. “I am puzzled regarding the statement about the health risk over a lifetime. As phrased it seems correct, for the average person, but we vary in sensitivity and time of exposure and there are some instances of higher exposure. Why not mention these as well?” Dr. Schecter commented. Stephen Lester, Ph.D., Science Director of the Center for Health, Environment & Justice, which has worked on dioxin issues for several decades, said data in the new report show “that the average background exposure of the American public to dioxin in food is very close to or above the EPA new reference dose.”

While EPA states that air emissions of dioxin chemicals have decreased 90% in recent years, the total disposal or other releases of such compounds actually increased 18% from 2009 to 2010. Air releases of dioxins also increased by 10% during that time period. Chemical manufacturers accounted for almost 64% of total disposal or other releases of dioxins in 2010 with electric utilities accounting for an additional 35%. Manufacturing processes for polyvinyl chloride plastics, the bleaching of pulp at paper mills and the incineration of municipal solid waste are significant contributors to the formation and release of dioxin chemicals. Total disposal or other releases of dioxins for 2010 were 54,426 grams per kilogram of body weight per day, including 1,234 grams of air releases. Dioxins are contaminants in numerous pesticides, including the widely herbicide 2,4-D, the wood preservative pentachlorophenol, and the disinfectant triclosan.

EPA stated that it is working as expeditiously as possible to complete the second component of the Science Assessment on the carcinogenicity of dioxin chemicals.

Source: Environmental Health News

Although IPM can be a helpful tool in the transition from a pesticide-intensive to a non-toxic management system, it makes no sense to weaken an already strong standard aimed at protecting the health of children. The effort to adopt such a system through passage of HB 5155 is being led by public works officials and groundskeepers, with support from the lawn chemical industry. They believe highly toxic pesticides are needed to make lawns and athletic fields playable, despite the success of proven organic land management practices that are effective, sustainable and protective of children’s health in Connecticut and across the country. Given the perspective of the legislation’s advocates, it can be presumed that the adoption of the new bill will result in a serious increase in the application of pesticides around schools. Nancy Alderman, president of the public interest group Environment and Human Health, Inc., spoke in her testimony against the bill about the dangers of adopting a poorly defined IPM program: “IPM allows for pesticide uses — and therefore when IPM has been mandated in other states it has proven unenforceable — because it allows pesticides — and once pesticides are allowed one cannot tell how much or how many times they are used. IPM has not proven to be a workable method when mandated for schools — and has proven to be in almost all cases — pesticide use as usual.” Additional testimony from the hearing can be found here.

Schools and day care centers must nurture a healthy environment in which children can grow and learn. Children are especially sensitive to pesticide exposure as they take in more pesticides relative to their body weight than adults and have developing organ systems that are more vulnerable and less able to detoxify toxic chemicals. Even at low levels, exposure to pesticides can cause serious adverse health effects. Numerous studies document that children exposed to pesticides suffer elevated rates of childhood leukemia, soft tissue sarcoma and brain cancer. Studies also link pesticides to childhood asthma, respiratory problems, and learning disabilities and inability to concentrate. For more information, see Beyond Pesticides’ Children and Schools page. To see more scientific research on the effects of pesticides on human health, see our Pesticide-Induced Diseases Database.

While the U.S. Environmental Protection Agency, the U.S. Department of Agriculture, Centers for Disease Control and Prevention, and the National PTA, among others, recommend schools adopt pesticide-reduction programs, without minimum federal standards, such as those contained in the proposed School Environment Protection Act (SEPA), the protection provided children is uneven and inadequate across the country. SEPA provides basic levels of protection for children and school staff from the use of pesticides in public school buildings and on school grounds by requiring schools to implement a strictly defined IPM system and identify allowed least-toxic materials as a last resort for building management and organic practices for school grounds. Contact your Congressional Representative today and ask them to support SEPA.

Aside from the serious concerns associated with pesticide use, it also should be noted that it has been repeatedly demonstrated that organic land management, when properly applied, can result in full, healthy, and weed-free turf. Organic land management is not simply a “hands-off” approach in which one is expected to sit back and do nothing to maintain the area. It requires careful fertility management, monitoring, and examination of weed and pest issues to diagnose problems, determine their source, and alter maintenance practices accordingly. Additionally, it has been shown that this approach can actually lower maintenance costs in the long term. Beyond Pesticides has numerous resources regarding research and guidance on organic lawn care.

TAKE ACTION: There are several possible next steps for HB 5155 as it makes its way through the General Assembly. The most likely course is that it will come to a full vote before the Planning and Development Committee. If you live in Connecticut, click here to send an email to the legislators on this committee and tell them that you do not want pesticides to be used on school grounds when we know that organic methods are both safe and effective.

Several people deeply involved in the state fight to preserve the school pesticide ban in Connecticut, as well as other issues throughout the state, will be speaking at the 30th National Pesticide Forum on March 30-31, 2012 at Yale University in New Haven, CT. These include Nancy Alderman of Environment and Human Health, Inc., Jerry Silbert of the Watershed Partnership, and State Senator Ed Meyer, who sponsored the original school pesticide ban and who is leading the effort to allow local communities to adopt strong pesticide reduction policies, among many others. For details, including registration, travel and lodging information, go to our forum page.

Pollination of insect pollinated crops is correlated with pollinator abundance and diversity. Since organic farming has the potential to mitigate negative effects of agricultural intensification on biodiversity, it may also benefit crop pollination, but direct evidence of this has so far been lacking. Researchers speculate that this effect may be due to an increase in insect pollinator abundance and/or diversity.

The researchers evaluated the effect of organic farming on pollination of strawberry plants focusing on whether (1) pollination success was higher on organic farms compared to conventional farms, and (2) there was a time lag from conversion to organic farming until an effect was manifested.

The results “suggest that organic farming could enhance the pollination service in agricultural landscapes, which is important for developing a sustainable agriculture. The method made it possible to measure the pollination independent of landscape composition, soil-type and other factors that can affect pollination success”, says Dr. Andersson.

Pollination success not only benefits the crops, but the entire ecosystem as well. According to researchers, butterfly and plant species richness has been found to increase rapidly after transition to organic farming. This suggests that pollinator richness may respond rapidly too.

Approximately 90 percent of all flowering plants require pollinators to survive. In agriculture, nearly a third of pollination is accomplished by honeybees. Threats to pollinators, especially commercial honey bees, concern the entire food system and economy. With one in three bites of food reliant on pollination, beekeepers and environmental organizations alike call out the wide-scale problem. The shift to organic practices is essential for our health and the environment.

For more information on pesticides, honey bees and other pollinators, including tips on what you can do, see Beyond Pesticides Protecting Pollinators program page.

Source: Eureka Alert Press Release

Following a lawsuit filed against the U.S. Environmental Protection Agency (EPA) in 2008, which cited EPA’s glaring omission in not considering risks to children, EPA announced in 2010 that it would, instead of stopping exposure to a known hazard immediately, phase-out over a six year period all uses of endosulfan in the U.S. Rather than regulating a stop use, EPA astounded many in the environmental and public health community by negotiating a long phase-out agreement with manufacturers that allows some uses to continue through 2016. Despite the failure of EPA to act quickly to protect public health, the agency could no longer ignore data in its 2002 Reregistration Eligibility Decision (RED), which shows that risks faced by workers are greater than previously acknowledged. In completing revised assessments, EPA concluded that endosulfan’s significant risks to wildlife and agricultural workers outweigh its limited benefits to growers and consumers. EPA also found that there are risks above the agency’s level of concern for aquatic and terrestrial wildlife, as well as birds and mammals that consume aquatic prey that have ingested endosulfan. The crop uses of endosulfan allowed in the U.S. in 2012 through 2016 are found in an EPA document Endosulfan Crop Uses and Last Use Dates.

Endosulfan, a DDT-era pesticide, is one of the most toxic pesticides still in use today. More than 74 countries have already banned endosulfan. However, countries, like India, where this study was conducted have resisted a ban on endosulfan, saying that a ban on the widely used chemical would put the country’s food security at risk and harm the welfare of farmers. However, thousands of Indian villagers, who have become disabled due to the use of the pesticide, pushed for a ban in 2004 and have since joined the global movement to ban endosulfan.

This study, “Pesticide (Endosulfan) Levels in the Bone Marrow of Children with Hematological Malignancies,” published in the journal Indian Pediatrics, involved 26 patients in the age group of one to 15 years with blood related cancer and an equal number of patients suffering from other blood-related disorders, but not cancers. The children were undergoing treatment in hospitals of a medical college in Dakshina Kannada district of Karnataka, India. The study was carried out over an 18-month period from September 2006 to March 2008. All the children who had high endosulfan levels in the bone marrow were from areas, where they were and may still be exposed to the pesticide. Children with blood cancer had elevated levels of endosulfan in the bone marrow compared to those without the disease. Six out of 26 children with blood cancer tested positive for endosulfan in the bone marrow compared to one out of 26 children who did not have blood cancer.

“Greater awareness of the toxic effects and improper use of pesticides needs to be created among the public. Siblings of children with leukemia may need to be screened for pesticide levels to prevent chronic long term exposure in the future,” the authors of the study said.

The endosulfan industry in India is estimated to be worth over $100 million, making it the world’s largest producer, exporter, and user of the product. The three companies that produce the product in India, including one that is partially government-owned, claim that pesticide manufacturers in Europe are driving the push for the ban in an effort to promote their products. However, doctors in India say that over 550 deaths and health problems in over 6,000 people in the region are related to the aerial spraying of the pesticide over cashew farms between 1979 and 2000.

Endosulfan is an organochlorine insecticide that was first registered for use in the U.S. in the 1950s. It is an endocrine disruptor and exposure in male children may delay sexual maturity and interfere with sex hormone synthesis. Endosulfan also appears to interfere with sex hormone synthesis in males aged 10-19 years in a community of cashew plantations in northern Kerala, India. A 2007 study found that children exposed to endosulfan in the first trimester of pregnancy had a significantly greater risk for developing autism spectrum disorders. It also poses risks to school children in agricultural communities where it has been detected at unsafe levels in the air. In addition, endosulfan has been found in food supplies, drinking water, and in the tissues and breast milk of pregnant mothers. Endosulfan, which continues to be used in the U.S. during a tiered phase-out period through 2016, travels long distances and has been found in Sierra Nevada lakes and on Mt. Everest. It can also migrate to the Poles on wind and ocean currents where Arctic communities have documented contamination, making it one of the most abundant organochlorine pesticides found in the Arctic. It has also been detected in the Great Lakes and various mountainous areas, including the National Parks in the western United States, distant from use sites.

Last May, endosulfan was finally added to the Stockholm Convention’s list of banned substances. The decision follows recommendations from the December 2009 Stockholm Convention Persistent Organic Pollutants Review Committee (POPRC), which call for urgent “global action” to address health and environmental impacts of the toxic pesticide. Scientific experts at the POPRC concluded that endosulfan is likely to cause significant adverse human health and environmental effects as a result of the chemical’s medium- and long-range transport on a global scale and subsequent accumulation in nearly all environmental media.

Source: The Daily Mail

According to The Californian, agricultural interests present asked County Supervisors to take no action. However, with dozens of local farm workers in attendance pleading their case, the board passed the resolution on a 4-1 recommending that Gov. Brown take another look at the fumigant.

Methyl iodide is known to cause miscarriages, thyroid dysfunction, and cancer, and is applied to crops like strawberries and peppers. It was approved by California state pesticide regulators in December as an alternative to methyl bromide, an ozone-depleting chemical being phased out under international treaty.

In 2007, EPA fast-tracked the registration of methyl iodide for use as a soil fumigant, despite serious concerns raised by a group of over 50 eminent scientists, including six Nobel Laureates in Chemistry. These scientists sent a letter of concern to EPA explaining, “Because of methyl iodide’s high volatility and water solubility, broad use of this chemical in agriculture will guarantee substantial releases to air, surface waters and groundwater, and will result in exposures for many people. In addition to the potential for increased cancer incidence, EPA’s own evaluation of the chemical also indicates that methyl iodide causes thyroid toxicity, permanent neurological damage, and fetal losses in experimental animals.” The letter concludes, “It is astonishing that the Office of Pesticide Programs (of EPA) is working to legalize broadcast releases of one of the more toxic chemicals used in manufacturing into the environment.”

Several environmental groups sued the State of California last year in an attempt to reverse the state’s approval of the chemical. Environmental advocacy groups and other opponents of methyl iodide use in the state have released documents detailing dissension in the ranks of DPR over the risk assessment of methyl iodide and its subsequent approval.

The ongoing court case helped reveal documents showing DPR manipulated data and that department scientists were worried risk managers minimized health dangers and didn’t take strong enough steps to mitigate the threats. One of the released documents, a memo from one disapproving DPR scientist, chastised the agency for its cut-and-paste approach to calculations determining how big buffer zones should be to protect public health. During a hearing on January 13, a California Superior Court Judge raised concerns about whether CDPR complied with its legal obligation to consider alternative options before approving the use.

Methyl iodide poses the most direct risks to farmworkers and those in the surrounding communities because of the volume that would be applied to fields and its tendency to drift off site through the air. Methyl iodide causes late term miscarriages, contaminates groundwater, and is so reliably carcinogenic that it’s used to create cancer cells in laboratories. It is on California’s official list of known carcinogenic chemicals and has been linked to serious risks in reproductive and neurological health. It is approved to be applied to California’s strawberry fields at rates up to 100 pounds per acre on much of the state’s 38,000 acres in strawberry production, totaling millions of pounds of use. Though methyl iodide will likely be used primarily on strawberries, it is also registered for use on tomatoes, peppers, nurseries, and on soils prior to replanting orchards and vineyards.

Organic certification standards require crop farmers to establish a preventive pest management strategy based on crop rotation, variety selection, biological controls, and sanitation and fertility practices. Synthetic materials that are allowed in organic crop production must satisfy a rigorous review process to insure their necessity, efficacy and safety to humans and the environment throughout their production and utilization. This review process must be updated every five years for the material to remain in use. A journal article from 2010 shows that organic farms produce more flavorful and nutritious strawberries while leaving the soil healthier and more biologically diverse than conventional strawberry farms. For more information on organic versus conventional agricultural practices, see Beyond Pesticides’ guide, Organic Food: Eating with a Conscience as well as our organic program page. In addition to the personal health risks posed by pesticide residues, Beyond Pesticides urges consumers to consider the impacts on the environment, farmworker and farm families’ health when making food choices.

Sources: The Californian, Grist

Beyond Pesticides has drafted comments that it will submit to EPA outlining serious concerns regarding clothianidin. The agency is accepting public comments through February 21, 2012. Tell EPA that because this pesticide is toxic to honey bees and wild pollinators, and has not been properly evaluated in field studies as required it should be banned. Submit comments directly to the EPA docket or sign-on to Beyond Pesticides’ comments.

Clothianidin is in the neonicotinoid family of systemic pesticides, which are taken up by a plant’s vascular system and expressed through pollen, nectar and gutation droplets from which bees forage and drink. Scientists are concerned about the mix and cumulative effects of the multiple pesticides bees are exposed to in these ways. Neonicotinoids are of particular concern because they have cumulative, sublethal effects on insect pollinators that correspond to symptoms of honey bee colony collapse disorder (CCD) —namely, neurobehavioral and immune system disruptions.

Clothianidin has been on the market since 2003. With a soil half-life of up to 19 years in heavy soils, and over a year in the lightest of soils, commercial beekeepers are concerned that even an immediate stop-use of clothianidin won’t save their livelihoods or hives in time.

Beyond Pesticides, in its comments, states

“Honey bees are the most economically valuable pollinator worldwide, and many high-value crops, such as almonds and broccoli, are entirely reliant upon pollination services by commercial beekeepers and their honey bees. Globally, 9.5% of the total economic value of agricultural production for human consumption comes from insect pollination —in 2005, this amounted to just under $200 billion. However, each year since 2006 commercial beekeepers have reported annual losses of 29-36%. Such losses are unprecedented, and approximately double what is considered normal. Like France, Germany, and other European countries, EPA must make a proactive decision against the neonicotinoid class of chemicals. Clothianidin and thiamethoxam [a neonicotinoid precursor that converts to clothianidin in plants and animals] are not only extremely persistent in the environment, but they are highly toxic to bees and other non-target insects. Clothianidin’s use as a systemic pesticide means that every part of the plant is potentially toxic to the honey bee, and can result in widespread contamination of soil and wild plants. We believe the risks posed by clothianidin and other neonicotinoids have been underestimated by the agency, especially given the outstanding honey bee data that have yet to be adequately reviewed. In light of the agency’s mandate in Section 3(c)(7)(A) of [the Federal, Insecticide, Fungicide, and Rodenticide Act (FIFRA)] to ensure that pesticides do not pose unreasonable adverse effects on the environment, clothianidin and its parent thiamethoxam should be cancelled.”

Other points outlined in the comments include:

Clothianidin’s Toxicity to Honeybees

Clothianidin, like other neonicotinoids, is an insecticide that is highly toxic to a range of insects, including honey bees and other pollinators. It is particularly dangerous because, in addition to being acutely toxic in high doses, it also results in serious, though sub-lethal, effects when insects are exposed to chronic low doses, as they are through pollen and water droplets laced with the chemical as well as dust that is released into the air when coated seeds are planted. These effects cause significant problems for the health of individual honey bees as well as the overall health of honey bee colonies and they include disruptions in mobility, navigation, feeding behavior, foraging activity, memory and learning, and overall hive activity.

Clothianidin’s Registration Is Unlawful

Clothianidin was initially registered by EPA in 2003 on the condition that the registrant, German chemical manufacturer Bayer, completes and submits a field study demonstrating the chemical’s effects on pollinators. In addition to any registration of clothianidin being a violation of FIFRA’s prohibition of chemicals that pose “unreasonable adverse effects on the environment,” in December 2010 it was revealed that the pollinator study Bayer had submitted had been downgraded by EPA and deemed insufficient to fulfill the field study requirement upon which the chemical’s registration was contingent. However, EPA took no action to ban or restrict clothianidin in light of this development and to this day is not in possession of an acceptable pollinator field study for clothianidin. Thus, following the agency’s own logic, there is no current basis for continuing to allow clothianidin to remain registered.

EPA Is Behind In Its Understanding of Pollinator Effects

Judging by the pollinator data requirements that EPA has stated it is seeking for clothianidin’s registration review, the agency is severely lacking in its understanding of how the chemical affects pollinators, and honey bees specifically. Despite allowing the chemical to be used on thousands of acres of American farmland over the past nine years, there is still a great deal EPA does not know about how bees are exposed to clothiandin and what the consequences of exposure actually are for bee health on the individual, colony, and species level.

The comments also note,

“The rapid disappearance of the honey bees, also dubbed “Colony Collapse Disorder” or CCD, has been observed in the U.S. since 2006. Even though researchers have indicated that there may be several variables associated with CCD, clothianidin, and other chemicals in its class, cannot be ruled out as a major contributor and this must be factored into the agency’s assessment. Honey bees intercept, and are contaminated by, particles on crops and suspended in the air, and retain them in their hair and/or accumulate them in their bodies and hives. Mitigation techniques (e.g. product label restrictions) to prevent honeybees from coming into contact with this highly toxic pesticide once it is used in the environment are highly infeasible. The only way to protect important pollinators is to remove these toxic neonicotinoids from the environment.”

TAKE ACTION: EPA is accepting public comments in the clothianidin docket through February 21, 2012. Tell EPA that because this pesticide is toxic to honey bees and wild pollinators, and has not been properly evaluated in field studies as required, it should be banned. Submit comments directly to the EPA docket or sign-on to Beyond Pesticides’ comments.

For more information on pesticides, honey bees and other pollinators, as well as more you can do, see Beyond Pesticides’ Pollinator Protection web page.

Originally reported on February 9, the results are derived from GE Bt seed suppliers who are required to report refuge data to EPA. As a condition of registering Bt seed varieties as pesticides, EPA requires that farmers using them also plant an appropriately-sized refuge of non-Bt varieties adjacent to the genetically engineered crop. In theory, western rootworms that develop resistance to Bt through constant exposure to the toxins in the genetically engineered varieties will mate with non-resistant rootworms that are harbored in the refuge. This crossbreeding is intended to reduce the likelihood that the genes that impart resistance will be successfully transferred to the succeeding generations of the pest.

Organic and sustainable agriculture researchers and advocates have long warned that the EPA’s refuge requirements and other preventive measures are inadequate to prevent resistance from rapidly emerging once Bt corn became planted widely. Alternating between Bt and non-Bt varieties and planting varieties that express different Bt toxins are the other primary management tools for delaying the onset of resistance. While slightly more than one million acres of Bt corn were planted in 1996, that number rose to nearly 50 million acres in 2008. Cumulatively, more than 280 million acres of Bt corn and 75 million acres of Bt cotton were planted in the United States between 1996 and 2008.

In 2011, entomologists at Iowa State University published a study verifying the first field-evolved resistance of corn rootworm to a Bt toxin. The researchers documented resistance to the Bt toxin Cry3Bb1, which has been inserted into nearly one third of the corn planted in the United States.

The study found the western rootworm’s ability to adapt was strongest in fields where Bt corn was planted for three consecutive years and suggested that insufficient planting of refuges may have contributed to the resistance. The study concluded that, “Even with resistance management plans in place, sole reliance on Bt crops for management of agriculture pests will likely hasten the evolution of resistance in some cases, thereby diminishing the benefits that these crops provide.”

The data documenting the widespread failure of farmers to plant refuges as required was compiled by the Agricultural Biotechnology Stewardship Technical Committee (ABSTC), which represents Bt seed suppliers including Monsanto, Syngenta AG, Dow Chemical and DuPont. The 41% non-compliance rate was based upon 3,053 farm inspections and represented a nearly threefold increase from the 15% rate which ABSTC reported in 2010. The American Corn Growers Association attributes the higher incidence of non-compliance to increased monitoring of sales records that identified farmers who did not appear to purchase the quantities of non-Bt varieties to plant suitable refuges. The EPA mandated that seed suppliers enhance their refuge enforcement activities as a condition of re-registering Bt corn varieties. Farmers who were found to be deficient with their mandatory resistance management practices will be visited at least twice over the next five years by their seed supplier and may lose access to Bt varieties should they fail a follow-up inspection.

The higher rates of non-compliance with refuge responsibilities now being reported by ABSTC are more consistent with previous findings of the Center for Science in the Public Interest. Using EPA data obtained through the Freedom of Information Act, the Center determined that American farmers maintain refuge compliances rates in excess of 90% between 2003 and 2005. However, the Center determined that non-compliance spiked to 25% in 2008 and affected more than 13 million acres altogether. The Center also notes that as Bt corn varieties take over a greater share of the market (reaching 57% in 2008), the likelihood that coincidental non-Bt refuges on neighboring farms could help delay resistance grows less and less probable.

The Western corn rootworm is a potentially devastating pest that does its greatest damage during its larval stage by feeding upon the plant’s roots. Severe feeding inhibits the plant’s ability to absorb moisture and nutrients and opens a pathway for attack from soil-borne pathogens. Before monoculture production became standard practice for many farms, the western rootworm could be effectively managed by crop rotations, including pasture, hay and legume crop components because the insect starves in fields not planted in corn.

For more on genetically engineered agriculture, read Beyond Pesticides’ article “Ready or Not, Genetically Engineered Crops Explode on Market.”

Source: Bloomberg Business Week

The current federal National Pollutant Discharge Elimination System (NPDES) permit, which recently went into effect after much resistance from the pesticide and agriculture industry and intensive lobbying efforts in Congress, does not authorize the discharge of biological and residual pesticides or their degradation by-products to waters of the U.S. that are impaired by the same pesticide active ingredients or any pesticide in the same chemical family. ”˜Impaired waters’ are polluted waters, i.e. those waters not meeting water quality standards pursuant to section 303(d) of the Clean Water Act (CWA). The NPDES permit is authorized under the CWA to require pesticide applicators to apply for permits before applying pesticides on or near surface waters. This process involves keeping records of pesticides used and monitoring application sites.

Controversy Over the NPDES Permit

In short, the purpose of the NPDES permit is to protect water bodies from chemical pollution that threatens aquatic life, public health, and drinking water quality. The California State Water Resources Control Board (Water Board) is considering the opinions raised by the Vector Control Association of California to amend the permit in California and remove the language of “in the same chemical family.” The group argues that since various water bodies in California are already listed as impaired by pesticides: diazinon, chloropyrifos, and pyrethroids, and because of the interpretation of “in the same chemical family,” the only authorized adulticides (naled, malathion, and pyrethrins) could no longer be used in impaired waters, and as a result the permit is overly restrictive. The amendment would remove the “in the same family” clause and, if accepted, would mean agencies could spray near certain waterways considered overly polluted, or “impaired,” with the pesticides currently used by vector control. The change would affect seven waterways, including some in the Sacramento Delta region that are impaired with organophosphates and pyrethroids, and will potentially further degrade these waterbodies.

Further, the vector control community argues that the changes would help but still leave intact what they see as ”˜duplicate’ monitoring procedures on larvicides. While federal guidelines require a basic check on ”˜adverse affects,’ such as fish kills after pesticide application, California requires more involved monitoring processes like pH, water clarity, and temperature monitoring during the larvicide process. Larvicide treatments are used in water where mosquitoes mature, and represent the majority of abatement work. The state water board says permits call for monitoring to assess compliance. “We don’t think that this requirement will prevent vector control agencies from keeping mosquito populations down,” said a spokesman for the state water board, adding that the EPA’s pesticide registration is not “necessarily as protective of water quality as the Clean Water Act.”

The NPDES permit requirement relating to pesticide use stems from the 2009 court decision in the case of the National Cotton Council et al. v. EPA in which the 6th Circuit Court of Appeals ruled that pesticide discharges into water are pollutants and require CWA permits. Since then, the pesticide industry has lobbied Congress to get the permit revoked, including supporting the introduction of HR 872 —a bill that seeks to reverse the 2009 Sixth Circuit court decision. While the federal NPDES permit provides coverage for discharges in the areas where the U.S. Environmental Protection Agency (EPA) is the permitting authority, which include six states (Alaska, Idaho, Massachusetts, New Hampshire, New Mexico, and Oklahoma), Washington, D.C., most U.S. territories and Indian country lands, states are authorized to develop and issue the NPDES pesticide permits. See previous Daily News Coverage.

Additionally, the California permit, like the federal one, provides immediate NPDES permit coverage for pesticide discharges in response to a declared pest emergency situation. Vector control operators, therefore, have the flexibility to manage mosquito problems in both emergency and non-emergency situations under permitting guidelines. Therefore, mosquito managers making a public health risk argument posed by mosquitoes will not be hampered by any permitting requirements, whether federal or state. Nor would proper record keeping and monitoring be an undue burden to pest control managers.

Adulticides For Mosquito Control Are Ineffective

There is often a heavy reliance on mass spraying of pesticides to kill adult mosquitoes. This method of mosquito management is widely considered by experts to be the least effective and most risky response to this important public health concern. There is no credible evidence that spraying pesticides used to kill adult mosquitoes, also known as adulticides, reduce or prevent mosquito-borne incidents or illnesses. Pesticides like those used in California against mosquitoes have been linked to numerous adverse health effects including asthma and respiratory problems, dermatological reactions, endocrine disruption, chemical sensitivities, and cancer. Adulticides can also be harmful or fatal to non-target wildlife. A program involving regular monitoring and the use of least-toxic methods and treatments as sustainable, long term effect against mosquito populations. For more information on protecting your community from mosquito spraying, visit Beyond Pesticides’ mosquito management tools page.

Water Contamination is Pervasive

Of California’s more than 10,000 waterways, 100 are impaired by organophosphates and pyrethroids. More than 173 million pounds of pesticides were reported applied statewide, an increase of nearly 15 million pounds — or 9.5 percent — from 2009. In 2008, a study found pyrethroid contamination in 100 percent of urban streams sampled in California. Another recent study found extensive pyrethroid contamination in urban creeks, the San Joaquin River, and a 20-mile stretch of the American River. Recent U.S. Geological Survey data have found that California and other U.S. waterways are contaminated with toxic substances.

Take Action: Are you in California? Tell the State Water Board not to weaken permit restrictions as they are necessary to safeguard waterways from contamination. The State Water Board will accept both written and oral comments on the proposed amendment. Written comments should be limited only to the proposed changes to the Permit. Written comments must be received by 12:00 noon on March 12, 2012 and addressed to:

Jeanine Townsend, Clerk to the Board
State Water Resources Control Board
1001 I Street, 24th Floor
Sacramento, CA 95814

Comment letters may be submitted electronically, in pdf text format (if less than 15 megabytes in total size), to the Clerk to the Board via email at [email protected]. Indicate the subject line: “Comment Letter — Vector Control Permit Amendment.”

Registration
Register online. Fees start at $35 ($15 for students) and include all sessions, conference materials, and organic food and drink.

Speaker Highlights
Sandra Steingraber, PhD – An acclaimed ecologist and author, Dr. Steingraber explores the links between human rights and the environment, with a focus on chemical contamination. She takes a personal and scientific look at these issues and offers insights into how we can protect our environment and ourselves. She brings a clear, lyrical voice to the complex evidence of biology. The author of several books, including her latest, Raising Elijah, Dr. Steingraber has been called “a poet with a knife” by Sojourner magazine, and received many honors for her work as a science writer. Her highly acclaimed Living Downstream: An Ecologist’s Personal Investigation of Cancer and the Environment has been adapted for film.

Gary Hirshberg is chairman and co-founder of Stonyfield Farm, the world’s leading organic yogurt producer, and the author of Stirring It Up: How to Make Money and Save the World. Previously, he directed the Rural Education Center, the small organic farming school from which Stonyfield was spawned. Before that, Gary had served as executive director of The New Alchemy Institute, a research and education center dedicated to organic farming, aquaculture and renewable energy. He has also authored books on wind power and organic gardening. Gary is a speaker on sustainability, climate change, the profitability of green and socially responsible business, organic agriculture and sustainable economic development.

David Hackenberg is the beekeeper who first discovered the disappearance of honeybees known as Colony Collapse Disorder (CCD). Mr. Hackenberg believes that pesticides contribute to CCD and that honeybees are a barometer of the environment. He is featured in the film Vanishing of the Bees and various media reports, including this 60 Minutes segment. Mr. Hackenberg founded Hackenberg Apiaries in 1962 as a high school vo-ag project. Today, he and his son operate approximately 3,000 hives of bees in 5 states for pollination and honey. David is a past president of the American Beekeeping Federation, and currently serves as co-chair of the National Honey Bee Advisory Board.

Curt Spalding is head of EPA’s New England Region (Region 1 Administrator) and has extensive experience in the environmental protection field as an advocate, policy analyst and administrator. For almost 20 years, he served as Executive Director of Save the Bay in Rhode Island. Since joining the EPA leadership team in February 2010, Mr. Spalding has been leading a holistic approach to finding environmental solutions in New England. He’s emphasized efforts in environmental justice and green economy.

Julia Brody, PhD, executive director of Silent Spring Institute, is a leader in research on breast cancer and the environment and in community-based research and public engagement in science. Dr. Brody’s current research focuses on connecting breast cancer advocacy and environmental justice in a study of household exposures to endocrine disruptors and air pollutants. Since 1996, she has been the principal investigator of the Cape Cod Breast Cancer and Environment Study, a case-control study that includes testing for endocrine disruptors in homes and historical exposure mapping. Dr. Brody is an adjunct assistant professor at the Brown University School of Medicine.

Christian Krupke, PhD is a professor of entomology at Purdue University. His recent research examines the impacts on honey bees of neonicotinoid pesticides applied to corn. The results demonstrate that bees are exposed to neonicotinoids and several other agricultural pesticides in several ways throughout the foraging period, including exposure through dust, soil corn pollen, and through dandelions growing in contaminated soil. Dr. Krupke is also the chairman of a group of university researchers that sent a letter to EPA stating that biotechnology companies are keeping university scientists from fully researching the effectiveness and environmental impact of genetically engineered crops.

Chip Osborne, founder and President of Osborne Organics, has over 10 years experience in creating safe, sustainable and healthy athletic fields and landscapes, and 35 years experience as a professional horticulturist. As a wholesale and retail nurseryman he has first hand experience with the pesticides routinely used in landscape and horticultural industry. Personal experience led him to believe there must be a safer way to grow plants. His personal investigation, study of conventional and organic soil science practices, and hands-on experimentation led him to become one of the country’s leading experts on growing sustainable, natural turf.

Warren Porter, PhD is a professor of Zoology and Environmental Toxicology at the University of Wisconsin at Madison. Dr. Porter’s research has shown that combinations of commonly used agricultural chemicals in concentrations that mirror levels found in groundwater can significantly influence immune and endocrine systems, as well as neurological health in animals. His recent research links pesticide exposure in utero to impaired learning, changes in brain function and altered thyroid levels. His lab has also shown lawn chemical mixtures at low-levels increase abortion rates in lab animals.

Andrea Kidd Taylor, DrPH is an assistant professor at the Morgan State University School of Public Health and Policy, and an adjunct faculty member at Howard University’s College of Medicine and the George Meany Center National Labor College. She served on the U.S. Chemical Safety and Hazard Investigation Board, the Presidential Advisory Committee on Gulf War Veterans’ Illnesses and the National Advisory Committee on Occupational Safety and Health. Dr. Taylor’s journal article, “Integrated Pest Management Policies in America’s Schools,” demonstrates the need for a federal school pest management policy.

See the full speaker list.

Location
Sessions will be held in the Yale School of Forestry & Environmental Studies’ Kroon Hall. It is a truly sustainable building: a showcase of the latest developments in green building technology. See Forum website for lodging and other local information.

The plaintiffs in this case are suing preemptively to protect themselves from being accused of patent infringement should they ever become contaminated by Monsanto’s genetically engineered seed, something Monsanto has done to others in the past. “We were very pleased that the court granted our request to have oral argument regarding Monsanto’s motion to dismiss our case today,” said Daniel Ravicher, PUBPAT Executive Director and lead lawyer for the plaintiffs. “The judge graciously permitted both parties to raise all the points they wished in a session that lasted over an hour. While Monsanto’s attorney attempted to portray the risk organic farmers face from being contaminated and then accused of patent infringement as hypothetical and abstract, we rebutted those arguments with the concrete proof of the harm being suffered by our clients in their attempts to avoid such accusations.” Hundreds of organic farmers and advocates engaged in a dynamic Citizen’s Rally organized by several groups including Occupy Food Justice that was held outside the court house after the hearing.

Genetic contamination of organic and non-genetically engineered crops by pollen that originates from genetically engineered crops and drifts to neighboring field has been incontrovertibly confirmed by scientific research. It is especially prevalent with the wind-pollinated corn and insect-pollinated canola, whose pollen can travel for two or more miles before fertilizing another plant. Such contamination has proven extremely costly to farmers raising organic and non-genetically engineered crops whose loads are rejected by buyers when trace levels of contamination are detected. Farmers in these circumstances lose any potential price premium for the extra effort and expense taken to preserve their crop’s integrity and they typically have no recourse but to dump the load on generic markets. Under the current interpretation of relevant law, Monsanto bears no legal or financial responsibility for such contamination.

The crux of the Federal District Court case is Monsanto’s claim that it has the right to sue farmers whose crops are contaminated for infringing upon the company’s intellectual property. The intellectual property Monsanto is referring to is the patented genetic material in the drifting pollen that is ultimately expressed in the contaminated organic or non-genetically engineered crop. “I don’t think it’s fair that Monsanto should be able to sue my family for patent infringement because their transgenic seed trespasses onto our farm and contaminates and ruins our organic crop. We have had to abandon raising corn because we are afraid Monsanto wouldn’t control their genetic pollution and then they would come after us for patent infringement. It’s not right,” said organic farmer Bryce Stephens of Jennings, Kansas and OSGATA member

PUBPAT is asking Judge Buchwald to declare that if organic farmers are ever contaminated by Monsanto’s genetically modified seed, they need not fear also being accused of patent infringement. To support this position, PUBPAT argues that Monsanto’s patents on genetically modified seed are invalid because they don’t meet the “usefulness” requirement of patent law, according to Mr. Ravicher. Evidence cited by PUBPAT proves that genetically modified seed has negative economic and health effects, while the promised benefits of genetically modified seed — increased production and decreased herbicide use — are false. Beyond Pesticides regularly updates its website with resources documenting the risks of genetic engineering and information on public advocacy actions and campaigns to restrict or eliminate their use.

Soon after the original filing of the lawsuit, Monsanto issued a statement saying it would not assert its patents against farmers who suffer “trace” amounts of transgenic contamination. In response, and in the hope that the matter could be resolved out of court, PUBPAT attorneys wrote Monsanto’s attorneys asking the company to make its promise legally binding. The lawyers rejected PUBPAT’s request and instead confirmed that the company may indeed make claims of patent infringement against organic farmers who become contaminated by Monsanto’s genetically modified seed. Copies of both letters are available as exhibits at the end of the amended complaint.

Beyond Pesticides is also a plaintiff in another lawsuit involving genetically engineered crops led by attorneys for the Center for Food Safety (CFS), Earthjustice, and farm and environmental groups. The lawsuit filed against the U.S. Department of Agriculture (USDA) argues that the agency’s 2011 unrestricted approval of genetically engineered alfalfa is unlawful.

Source: Organic seed Growers and Trade Association press release

“The data FDA has on GE salmon, which were supplied by Aquabounty, are incomplete, biased, and cannot be relied upon to show that the GE salmon is safe to consume,” said Food & Water Watch Executive Director Wenonah Hauter. “Aquabounty’s own study showed that GE salmon may contain increased levels of IGF-1, a hormone that helps accelerate the growth of the transgenic fish and is linked to breast, colon, prostate, and lung cancer.”

The potential health risks of GE salmon, the groups warn, are no different from a number of food additives that FDA has banned in the past, including those that are cancer causing.

“FDA’s choice to allow the first proposed transgenic animal for food to somehow only be review as a drug is contrary to law, science and common sense,” said George Kimbrell, Senior Attorney for the Center for Food Safety. “Public health and transparency should be championed, not skirted, particularly when contemplating such an unprecedented approval.”

In order to create the transgenic fish, Aquabounty genetically engineered an Atlantic salmon by inserting a Chinook salmon growth-hormone gene, as well as a gene sequence from an ocean pout. The company claims this engineering causes the GE salmon to undergo an increase in growth rate that allows the fish to reach market size in half the normal time.

Aquabounty has submitted an application to FDA for approval of the transgenic salmon under the new animal drug provisions of the Federal Food, Drug and Cosmetic Act. Members of the FDA’s own advisory committee have described the agency’s review of the GE salmon under this process as lacking in rigor.

The consumer groups’ petition asserts that the process used to create the GE salmon substantially alters its composition””including its nutrition value””and demand that the fish and its components be treated as a food additive pursuant to FDA’s guidelines. As a food additive, AquaBounty’s GE salmon would be considered unsafe for consumption unless the company’s data overwhelmingly proved otherwise.

“If FDA actually evaluated GE salmon as a food additive, including allergy-causing potential, they would not likely be able to approve it because of the health risks that have can already be seen in an incomplete set of data.” said Michael Hansen, Senior Scientist with Consumers Union.

The groups assert that a proper review process would require GE salmon to undergo comprehensive toxicological studies, specifically those developed to ensure that foods entering the market are safe to consume and are properly labeled.

The January 31, 2012 cut-off was part of a reassessment process that has stretched out for 20 years, but the agency has promised to finalize its guidelines “as expeditiously as possible,” although it gave no new deadline. In August 2011, EPA announced a plan for moving forward to complete the dioxin Reanalysis, Volume 1, which is to contain an evaluation of all the scientific literature on dioxin dose-response, including information published since the release of a previous draft Reassessment, and post it by the end of January 2012. EPA was then to post Volume 2 of the Reanalysis soon thereafter. These efforts have been met with resistance from the American Chemistry Council, the International Dairy Foods Association, the American Farm Bureau Federation, and others. These groups have argued that EPA is using flawed science and will scare Americans about the food they eat.

Dioxins, also known as polychlorinated dibenzo dioxins (PCDDs), include about 75 chemicals that can disrupt hormonal pathways, cause reproductive and developmental problems and lead to cancers, such as 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), found in the infamous Agent Orange herbicide deployed during the Vietnam War. War veterans exposed to Agent Orange have developed chronic lymphocytic leukemia, Hodgkin’s disease, and non-Hodgkins lymphoma and diabetes. Many children of exposed veterans have been affected by their parents’ exposure to the chemical and show a wide range of symptoms. Most dioxin exposure in the U.S. is attributable to emissions from waste incinerators, copper smelters, and makers of paper pulp, but dioxins are still manufactured and released as contaminants of pentachlorophenol and phenoxy herbicides like 2,4-D. Regulations have curtailed dioxin emissions by 90% since the 1980s, but the pollutants persist in the environment, so they continue to contaminate livestock forage and meat and dairy products. The structure of dioxins closely resembles that of polychlorinated biphenyls (PCBs) and polychlorinated dibenzo furans (PCDFs), which also have similar toxicological and environmental effects.

EPA published its first assessment of dioxins as a guideline for U.S. consumers and policy-makers in 1985. In 1991, the agency launched a reassessment to resolve outstanding issues and incorporate new data. However, the agency’s Scientific Advisory Board warned that a 1994 draft report had a “tendency to overstate the possibility of danger” and did not adequately spell out scientific uncertainties. Soon afterwards industry sued to block the reassessment, arguing the assessment was not based on sound science.

EPA published a draft of its reassessment called, “”Reanalysis of Key Issues Related to Dioxin Toxicity and Response to NAS Comments”(Reanalysis)” in 2010, recommending that people consume less than 0.7 picograms (less than one trillionth of a gram) of dioxins per kilogram of body weight per day. This is lower than the World Health Organization’s daily limit of roughly 2.3 picograms per kilogram; in the U.S., people currently consume an average of less than 0.5—3 picograms per kilogram per day. The EPA’s strict recommendation has been lauded by cancer-awareness groups and environmentalists, but chemical and agricultural industries protested, arguing that although it is not legally binding, the lower limit could alarm consumers unnecessarily.

A 2003 report from a joint panel of the Institute of Medicine of the National Academies and the Food and Nutrition Board recommended the formation of a federal interagency group to develop and implement a public health strategy to reduce human exposure to dioxin. The report cites, as a high-priority risk management intervention, exposure reduction to dioxins and dioxin-like compounds in girls and young women before they become pregnant. Dioxins and dioxin-like compounds are often transmitted from mother to child through breastfeeding. The report states, “[P]readolescent and teenage girls and young women were of concern ”¦ because body burdens of dioxin-like compounds can, when they enter their child-bearing years, become a potential source of exposure for developing infants in utero and while breastfeeding.” Infants exposed to high levels of dioxins and dioxin-like compounds in utero suffer poor psychomotor skills, altered thyroid hormone levels, and reduced neurological optimality. A recent study investigating the long-term immune effects of dioxin found that exposure to dioxin during development or while nursing diminishes the young’s capacity to fight infection later in life. Another found that exposure to dioxin in the womb can affect female reproduction for generations, reducing fertility and increasing the chance for premature delivery.

Dioxin has been found in milk, cheese, beef, pork, fish, chicken, and other animals, as well as soil and sewage sludge. High levels of dioxin still exist in the Tittabawassee and Saginaw rivers and floodplains in Michigan, after being dumped there decades ago by Dow Chemical Co. Clean-up and restoration for these systems are still being debated. Even though dioxin levels in the environment have dropped considerably in recent years from their peak in the late 1970’s, it is important to be vigilant in the foods consumed in order to avoid an exposure hazard, since dioxins are persistent and bioaccumulative. A diet rich in organic foods can help minimize the risk of dioxin exposure.

See the Toxicological Profile for Chlorinated Dibenzo-p-dioxins (CDDs) by Agency for Toxic Substances and Disease Registry (ATSDR) for more detailed information on dioxin, its health and environmental effects, and exposure.

Source: Wall Street Journal, Nature