EPA document trail

A trail of documents showing how incomplete research was eventually declared “scientifically sound.”

2/20/03 Risk assessment, corn

Considering the toxicity profile and reported incidents of other neonicotinoids (e.g., imidacloprid), the proposed seed treatment with clothianidin has the potential for toxic risk to honey bees, as well as other
pollinator insects. As a result of this concern, EFED is asking for additional chronic testing on bee hive activity (e.g., effects to queen, larvae, etc.).

4/10/03 Bee study protocol, clothianidin

The possibility of toxic chronic exposure to nontarget pollinators through the translocation of clothianidin residues in nectar and pollen has prompted EFED to require field testing (141-5) that can help in evaluating this uncertainty. In order to fully evaluate the possibility of this long term toxic effect, a complete worker bee life cycle study must be conducted, as well as an evaluation of exposure and effects to the queen…

3/11/04 Gabe Patrick’s memo on clothianidin protocol

Although it is stated that no flowering crops will be planted in the vicinity, bees can forage as far as 10 krn from the hive. This could pose a risk of cross-contamination in the study if bees start foraging in other fields. Not knowing a lot about the flowering phenology of canola, it is hard for me to suggest an exact number of days or to know how long it would take before the flowers are near tapped, but these are things the researcher should consider.

11/16/07 EPA’s review of the Bayer clothianidin study

This study is scientificallysound and satisfies the guideline requirements for a field toxicity test with honeybees (OPP Gdln. No. 141-5; OPPTS 850.3040).

Doubt is their product

Industry groups are fighting regulation by fomenting scientific uncertainty. DOUBT Is Their Product.

Uncertainty is an inherent problem of science, but manu- factured uncertainty is another matter entirely. Over the past three decades, industry groups have frequently become involved in the investigative process when their interests are threatened. If, for example, studies show that a company is exposing its workers to dangerous levels of a certain chemical, the business typically responds by hiring its own researchers to cast doubt on the studies. Or if a pharmaceutical firm faces questions about the safety of one of its drugs, its executives trumpet company- sponsored trials that show no significant health risks while ignoring or hiding other studies that are much less reassuring. The vilification of threatening research as “junk science” and the corresponding sanctification of industry-commissioned research as “sound science” has become nothing less than stan- dard operating procedure in some parts of corporate America.

Six years old, but what we will face, in fact already are.

Widespread immune deficiency disease in wildlife

This paper, Widespread Immune Deficiency Disease in Wildlife: a hypothesis, came to me from Rosemary Mason, a retired Doctor in Wales who has been active in the efforts to rein in the neonics. It is long, but filled with good information.

The view from Canada

This essay, Honey Bee Die-Off Threatens Global Food Chain, was sent to me by Kim Flottum, who received it from Malcolm Sanford. It is very close to what many have been saying in the U.S., UK and elsewhere.

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Is a pesticide harming all those bees?

The NYTimes covers Tom Theobad and the systemic pesticides on Green: A Blog About Energy and the Environment.

National Pesticide Forum in Denver, Colorado

Tom Theobald is speaking at the National Pesticide Forum hosted by Beyond Pesticides on Friday, April 8th, 2011. Check out the Pesticides and Pollinators panel at 8:00pm. The full details are available here.

Panelist Biographies
Tom Theobald – Beekeeper and owner of the Niwot Honey Farm for 35 years, Mr. Theobald is one of the founders of the Boulder County Beekeepers’ Association and its president for 30 years. Tom recently stepped into the limelight when he leaked an EPA memo disclosing a critically flawed science used to register (legalize) the bee-killing pesticide clothianidin. Tom was the last County Bee Inspector in the state of Colorado, a position created in 1891 and retired in 2000. Listen to Tom and Beyond Pesticides executive director Jay Feldman talk about the leaked EPA document.\

James Frazier, PhD – Professor of entomology at Penn State University, Dr. Frazier is part of the team leading the national research into the disappearance of honeybees, known as colony collapse disorder (CCD). CCD is a phenomenon in which worker bees from a beehive or honeybee colony abruptly disappear. His team is focusing on synergistic and sublethal effects of multiple pesticides on the chemical senses and chemically mediated behaviors of honeybees in relation to honeybee health and CCD. Dr. Frazier is an expert in the field of chemical ecology. His other research focuses on the structure and functioning of insect chemosensory systems and on chemically mediated behavior.

Marygael Meister is a backyard beekeeper and founder of the urban beekeeping group, Denver Bee. In 2008 Ms. Meister took a beekeeping class and set up two hives in her backyard to help her garden thrive. She was initially told by the city that it was legal to keep bees. The information was incorrect, and she received a cease-and-desist order when a neighbor complained about her hives. Despite potential fines and jail time, Ms. Meister organized, founded Denver Bee and changing the city ordinance. Read about Ms. Meister in a December New York Times article on urban beekeeping.

Tom Theobald and Graham White: clothianidin and the urgent need for environmental reform

In this segment of The Organic View Radio Show, host, June Stoyer talks to Tom Theobald and Graham White about the negative impact Clothianidin has and their efforts to raise awareness.

Clothianidin has been widely used as a seed treatment on many of the USA’s key crops (which include canola, soy, sunflowers, wheat and sugar beet crops) for eight growing seasons under a conditional registration granted while EPA waited for Bayer Crop Science, the pesticide’s maker, to conduct a field study assessing the insecticide’s threat to bee colony health. The EPA has moved from granting a conditional registration to full registration of this chemical just in time for the spring planting. Tom Theobald is the Colorado beekeeper that slammed the EPA for granting full registration to the Bayer Corporation for Clothianidin. He has been relentlessly trying to raise awareness about this chemical and has been working towards environmental reform regarding the EPA’s process to grant registration. Graham White is a beekeeper and environmental author who lives in Scotland, near Scotland’s greatest salmon-river, the River Tweed. He began keeping bees about 15 years ago and first noticed severe environmental changes to his bees, to butterflies and other wildlife, around 2002, which he soon linked to the introduction of neonicotinoid pesticides. He is the author and editor of a number of environmental books including: The Nature of Scotland and several collections of John Muir’s writings. He served for 20 years as the Director of the Edinburgh Environment Centre, providing over 200 local schools with outdoor education and environmental programs. His message is that we are in danger of creating an agricultural environmental that is toxic to wildlife of every kind.

Are regulators doing enough to prevent bee die-offs?

Original article
By Brendon Bosworth
New West

The EPA had initially proposed that a label for clothiandin-treated corn seeds would read: “This compound is toxic to honeybees. The persistence of residues and the expression of clothianidin in nectar and pollen suggests the possibility of chronic toxic risk to honeybee larvae and the eventual stability of the hive.” But, along with the conditional registration, it was decided that this label be deferred until after the life-cycle study had been reviewed . . .

Tom Theobald’s comments on the EPA response to the National Honey Bee Advisory Board

It should be understood that these comments are intended for beekeepers and others who have been following this issue, to clarify and challenge some of the evasion and misinformation being offered under the guise of an official “response.” These comments are not intended as a response to the EPA. The EPA is listening only to itself, and further dialogue at this point would appear to be pointless.

EPA:
Clothianidin was originally evaluated for registration through a North American Free Trade Agreement (NAFT A) Joint Review with Canada and was identified as an alternative to the organophosphate insecticides, a class of insecticides that is generally very highly acutely toxic to bees and, unlike clothianidin, also very highly acutely toxic to humans and wildlife. During the clothianidin registration process, hundreds of studies were reviewed and evaluated. When EPA granted the initial registration for clothianidin seed treatment uses in 2003, the Agency determined that the uses met the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) risk benefit standard for registration.

Tom Theobald:
f this is true, then why was clothianidin released to the market under a “conditional” registration in 2003 rather than full registration? EPA’s own documents clearly show that there were serious concerns, serious enough that EPA scientists said the life cycle study should be completed before registration, and the “condition” of conditional registration was the completion of the life cycle study by the end of the first growing season. It was not completed until 4 full growing seasons has passed. Anyone can see that by looking at the EPA memos. Do they think we can’t read? Or just that we can’t think?

“Hundreds of studies…?” Just send us a list of the first 200…

Read the full document here.

Interview – Jeff Anderson, David Hackenberg and Clint Walker of the National Honey Bee Advisory Board

Today (3/3/11) at 2:00 PM Colorado time June Stoyer of The Organic View Radio Show will interview Jeff Anderson, David Hackenberg and Clint Walker, members of the National Honey Bee Advisory Board, which has been meeting with the EPA and USDA for the past 3 years triyng to bring some sense to the pesticide problems beekeepers have been facing. This should be a great interview and I encourage you all to listen. If you can’t listen live, it will be available as a podcast afterward.

Tomorrow June will interview Percy Schmeiser, the Canadian farmer who has been in a protracted legal battle with Monsanto. This is another interview everyone should listen to. June is doing some great work getting these issues out before the public and we should avail ourselves of all her hard work.